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{{#Wiki_filter:May 8, 2018 Mr. John Dent, Jr. | {{#Wiki_filter:May 8, 2018 Mr. John Dent, Jr. | ||
Vice President-Nuclear and CNO Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville , NE | Vice President-Nuclear and CNO Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville, NE 68321 SUBJECT: COOPER NUCLEAR STATION - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/ | ||
STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000298/2018010 | |||
STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS | |||
- INSPECTION REPORT | |||
==Dear Mr. Dent:== | ==Dear Mr. Dent:== | ||
On March 15, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of this inspection at your Cooper Nuclear Station. On April 16, 2018 , the NRC inspectors discussed the results of this inspection with Mr. J. Kalamaja, General Manager of Plant Operations | On March 15, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of this inspection at your Cooper Nuclear Station. On April 16, 2018, the NRC inspectors discussed the results of this inspection with Mr. J. Kalamaja, General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report. | ||
, and other members of your staff. The results of this inspection are documented in the enclosed report. | |||
The inspection examined activities conducted under your license as they relate to the implementation of | The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel. | ||
NRC inspectors documented one finding of very low safety significance (Green) in this report | NRC inspectors documented one finding of very low safety significance (Green) in this report. | ||
The finding did not involve a violation of NRC requirements. | |||
2 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, | If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear Station. Jr. 2 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding. | ||
Sincerely, | Sincerely, | ||
/RA/ Jason W. Kozal , Chief Project Branch C Division of Reactor Projects Docket: 50-298 License: DPR-46 Enclosure: | /RA/ | ||
Jason W. Kozal, Chief Project Branch C Division of Reactor Projects Docket: 50-298 License: DPR-46 Enclosure: | |||
Inspection Report 05000298/2018010 w/Attachment: | |||
Documents Reviewed | Documents Reviewed | ||
U.S. NUCLEAR REGULATORY COMMISSION | |||
==Inspection Report== | ==Inspection Report== | ||
Docket Number: | Docket Number: 05000298 License Number: DPR-46 Report Number: 05000298/2018010 Enterprise Identifier: I-2018-010-0017 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, Nebraska Inspection Dates: March 12, 2018 to April 16, 2018 Inspectors: M. Stafford, Resident Inspector - Cooper (Team Leader) | ||
R. Alexander, Sr. Project Engineer - Region IV J. Mateychick, Sr. Reactor Inspector - Region IV S. Sheldon, Project Engineer - Region III Approved By: Jason Kozal Chief, Project Branch C Division of Reactor Projects | |||
DPR-46 Report Number: | |||
Enclosure | |||
I- | |||
March 12, 2018 to April 16, 2018 Inspectors: | |||
M. Stafford, Resident Inspector | |||
- Cooper (Team Leader) | |||
R. Alexander, Sr. Project Engineer | |||
- Region IV S. Sheldon | |||
, Project Engineer | |||
- Region III Approved By: | |||
Jason Kozal Chief, Project Branch C Division of Reactor Projects | |||
=SUMMARY= | =SUMMARY= | ||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring | The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a Temporary Instruction 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ | ||
Staffing/Multi-Unit Dose Assessment Plans at Cooper Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below. | |||
List of Findings and Violations Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events Cornerstone Significance Cross-cutting Aspect | List of Findings and Violations Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events Cornerstone Significance Cross-cutting Report Aspect Section Emergency Green H.3 - TI 2515/191 Preparedness FIN 05000298/2018010-01 Change Closed Management The NRC inspection team identified a Green finding related to the licensees failure to maintain the station satellite phones in locations that would provide reasonable assurance the phones would remain available following all beyond design basis external events. | ||
-01 Closed | |||
=INSPECTION SCOPES= | =INSPECTION SCOPES= | ||
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading | Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. | ||
-rm/doc-collections/insp | |||
-manual/inspection | |||
-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, | |||
-Water Reactor Inspection Program - Operations Phase. | |||
==OTHER ACTIVITIES== | ==OTHER ACTIVITIES== | ||
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL TI 2515/191 | - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Agencywide Documents Access and Management System (ADAMS) Accession No. | ||
-Unit Dose Assessment Plans Inspectors | ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS No. ML12053A340) and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS No. | ||
-Design-Basis External Events (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS No. ML12053A340) and multiunit dose assessment information provided per COMSECY 0010, | |||
: (1) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals | ML12339A262). | ||
: (1) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals [including the Final Integrated Plan (ADAMS Accession No. ML17017A166)] and the associated safety evaluation (ADAMS No. ML17226A032) and determined that the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The inspectors verified the licensee satisfactorily: | |||
-Design-Basis External Events. The inspectors verified the licensee satisfactorily | a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b) integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c) protected FLEX equipment from site-specific hazards; d) developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e) trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f) developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations. | ||
: (2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals [including the Final Integrated Plan (ADAMS Accession No. | |||
-specific hazards; d) developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e) trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f) developed the means to ensure the necessary off | |||
-site FLEX equipment would be available from | ML17017A166)] and the associated safety evaluation (ADAMS No. ML17226A032) and determined that the licensee is in compliance with NRC Order NRC Order EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation. | ||
. | |||
: (2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals | The inspectors verified the licensee satisfactorily : | ||
a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b) installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; c) trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d) developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation. | |||
: (3) The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter (ADAMS No. ML12053A340), and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 in response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site. The inspectors verified the following: | |||
: (3) The inspectors reviewed information provided in the | a) the licensee satisfactorily implemented required staffing changes to support an extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS) scenario; b) EP communications equipment and facilities are sufficient for dealing with an ELAP/LUHS scenario; and c) the licensee implemented multi-unit/-source dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach. | ||
-unit dose submittal and in response to the | |||
-Term Task Force Recommendation 9.3 in response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site. The inspectors verified the following: | |||
a) the licensee satisfactorily implemented required staffing changes to support an extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS)scenario; b) EP communications equipment and facilities are sufficient for dealing with an ELAP/LUHS scenario; and c) the licensee implemented multi | |||
-unit/-source dose assessment capabilities (including releases from spent fuel pools) using the | |||
-specific dose assessment software and approach. | |||
The inspectors verified that non | The inspectors verified that non-compliances with requirements and standards identified during the inspection were entered into the licensee's corrective action program as appropriate. | ||
-compliances with requirements and standards identified during the inspection were entered into the licensee's corrective action program as appropriate. | |||
==INSPECTION RESULTS== | ==INSPECTION RESULTS== | ||
Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events Cornerstone Significance Cross-cutting Aspect | Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events Cornerstone Significance Cross-cutting Report Aspect Section Emergency Green H.3 - Change TI 2515/191 Preparedness FIN 05000298/2018010-01 Management Closed The NRC inspection team identified a Green finding related to the licensees failure to maintain the station satellite phones in locations that would provide reasonable assurance the phones would remain available following all beyond design basis external events. | ||
=====Description:===== | =====Description:===== | ||
The Cooper Nuclear Station FLEX Program Document, Revision 1, Section 5.2.27, | The Cooper Nuclear Station FLEX Program Document, Revision 1, Section 5.2.27, Support Functions - Communications, states, in part: NEI 12-01 provides required emergency communications capabilities during an Extended Loss of AC Power (ELAP)Satellite phones are credited for off-site communicationDocking stations and remote antennas have been installed to allow use of the satellite phones from inside buildings. | ||
- Communications, | |||
-01 provides required emergency communications capabilities during an Extended Loss of AC Power (ELAP) | NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, Section 4.5, Equipment Location Requirements, states: to be assumed operable, a piece of on-site communications equipment should be in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external eventEquipment should be stored, or otherwise available, in locations that can be readily accessed when neededThe above guidance applies to equipment at the point of use as well as any supporting infrastructure components. Such components may include portable power sources, and radio system repeaters and antennas. | ||
-site | |||
Initially, when the licensee implemented their plans to resolve issues associated with communications during a beyond design basis external event (BDBEE), they had handheld satellite phones located in the control room and the technical support center (TSC), which required the users to relocate outdoors to acquire a usable signal. These locations are rated to withstand all BDBEE, and would therefore meet the requirements of NEI 12-01. However, in an effort to enhance the communications methods, the licensee pursued plans to provide a means for personnel to be able to communicate with satellite phones from inside buildings. | |||
These enhancements involved providing external antennas, relocating the existing satellite phones to docking stations in a structure attached to the elevated release point (ERP shack)and in a communications room (PBX room), and routing wires to control room and TSC desk phones. These enhancements are mentioned in general in a letter from the licensee to the NRC, NLS2013028, dated 2/21/13, Response to NRC Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Near-Term Task Force Recommendation 9.3. | |||
-Term Task Force Recommendation 9.3. | |||
In moving the physical location of the satellite phones from the control room and TSC | In moving the physical location of the satellite phones from the control room and TSC, the licensee failed to ensure that the new locations were suitable to withstand all BDBEE. The ERP shack is not rated for tornado wind loading, and the phones relocated from the control room may not survive this external event. Additionally, the external antennas located on the elevated release point and the meteorological tower would not be able to withstand the elevated wind speeds during a tornado or other high wind event. | ||
, the licensee failed to ensure that the new locations were suitable to withstand all BDBEE. The ERP shack is not rated for tornado wind loading, and the phones relocated from the control room may not survive this external event. Additionally, the external antennas located on the elevated release point and the meteorological tower would not be able to withstand the elevated wind speeds during a tornado or other high wind event. | |||
The team determined that, by implementing this enhancement to communications systems, the licensee placed | The team determined that, by implementing this enhancement to communications systems, the licensee placed their satellite phone equipment in locations that are vulnerable to BDBEE. | ||
This does not meet the requirements of NEI 12-01 and therefore does not meet the requirements of the FLEX Program Document. | |||
Additionally, the licensee is in the process of procuring three additional satellite phones to | Corrective Action(s): In response to the teams questions, the licensee documented the concerns in the corrective action program. Additionally, the licensee is in the process of procuring three additional satellite phones to stage in the control room, thereby restoring compliance with NEI 12-01. | ||
-01. Corrective Action Reference(s): | |||
-CNS-2018- | Corrective Action Reference(s): CR-CNS-2018-01499 | ||
=====Performance Assessment:===== | =====Performance Assessment:===== | ||
Performance Deficiency: | Performance Deficiency: That the station failed to maintain the satellite phones in locations that provide reasonable assurance the phones will remain available following all beyond design basis external events is a performance deficiency. Specifically, by moving the satellite phones from locations where the phones were protected from beyond design basis external events to locations where the phones were not protected was contrary to NEI 12-01, Revision 0, Section 4.5. The ERP shack is not rated for tornado wind loading and therefore the phones relocated from the control room may not survive this external event. Additionally, the antennas may not survive high wind speeds. | ||
-01, Revision 0, Section 4.5. The ERP shack is not rated for tornado wind loading and therefore the phones relocated from the control room may not survive this external event. | |||
Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the facilities and equipment attribute of the Emergency Preparedness Cornerstone and its objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, by moving the satellite phones to locations that are not rated for all beyond design basis external events, the licensee would not be able to contact any offsite organizations. | |||
Significance: The team assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix O, Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation (Orders EA-12-049 and EA-12-051), dated October 7, 2016. The team determined that the performance deficiency did not | |||
: (1) impact the spent fuel pool instrumentation order (EA-12-051); | |||
Significance: | |||
: (1) impact the spent fuel pool instrumentation order (EA 051); | |||
: (2) did not involve a failure of FLEX equipment for 72 hours or more that would result in a complete loss of one or more of the FLEX functions; | : (2) did not involve a failure of FLEX equipment for 72 hours or more that would result in a complete loss of one or more of the FLEX functions; | ||
: (3) did not involve deficient procedures or training that would result in a complete loss of one or more of the FLEX functions; | : (3) did not involve deficient procedures or training that would result in a complete loss of one or more of the FLEX functions; | ||
: (4) did not have a product of the exposure time and external even initiating event frequency greater than 1E | : (4) did not have a product of the exposure time and external even initiating event frequency greater than 1E-6; and | ||
-6; and | : (5) did not involve significant programmatic issues which reduced the effectiveness of the Mitigating Strategies. Therefore, the finding was determined to be of very low safety significance (Green). | ||
: (5) did not involve significant programmatic issues which reduced the effectiveness of the Mitigating Strategies. Therefore, the finding was determined to be of very low safety significance (Green) | |||
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated with change management, in that the licensee failed to fully evaluate implementing the enhancement to move the satellite phones from the control room and TSC to the ERP shack an the PBX room [H.3]. | |||
On April 16, 2018, the lead inspector presented the final inspection results in an exit meeting to Mr. J. Kalamaja, General Manager of Plant Operations | =====Enforcement:===== | ||
, and other members of the site staff. | Inspectors did not identify a violation of regulatory requirements associated with this finding. | ||
==EXIT MEETINGS AND DEBRIEFS== | |||
The inspectors verified no proprietary information was retained or documented in this report. | |||
* On March 15, 2018, the inspection team presented the on-site inspection results in a management debrief to Mr. J. Kalamaja, General Manager of Plant Operations, and other members of the site staff. | |||
* On April 16, 2018, the lead inspector presented the final inspection results in an exit meeting to Mr. J. Kalamaja, General Manager of Plant Operations, and other members of the site staff. | |||
=DOCUMENTS REVIEWED= | =DOCUMENTS REVIEWED= | ||
Other Activities | Other Activities - TI 2515/191 | ||
- TI 2515/191 | |||
Procedures/Instructions | Procedures/Instructions | ||
Number Title Revision 0-CNS-OU-108 Shutdown Safety Management Program | Number Title Revision | ||
0.50.5 Outage Shutdown Safety | 0-CNS-OU-108 Shutdown Safety Management Program 4 | ||
2.4FPC Fuel Pool Cooling Trouble | 0.50.5 Outage Shutdown Safety 37 | ||
5.1FLOOD Emergency Operations Procedure: Flood | 2.4FPC Fuel Pool Cooling Trouble 34 | ||
7.0.11 Maintenance Procedure: Flood Control Barriers | 5.1FLOOD Emergency Operations Procedure: Flood 22 | ||
14.41.1.1 FPC-LIT-1 Testing 4 EOF08 Position Instruction Manual: Logistics Coordinator | 7.0.11 Maintenance Procedure: Flood Control Barriers 30 | ||
FSG 5.10FLEX | 14.41.1.1 FPC-LIT-1 Testing 4 | ||
FLEX Support Guidelines (FSGs) | EOF08 Position Instruction Manual: Logistics Coordinator 30 | ||
FSG 5.10FLEX.01 | FSG 5.10FLEX FLEX Support Guidelines (FSGs) 2 | ||
FSG 5.10FLEX.01 125 VDC Div 1 FLEX Operations 1 | |||
FSG 5.10FLEX.02 | FSG 5.10FLEX.02 125 VDC Div 2 FLEX Operations 1 | ||
FSG 5.10FLEX.03 250 VDC Div 1 FLEX Operations 1 | |||
FSG 5.10FLEX.03 | FSG 5.10FLEX.04 250 VDC Div 2 FLEX Operations 1 | ||
250 VDC Div 1 FLEX Operations | FSG 5.10FLEX.05 Reliable Hardened Containment Vent Battery 1 | ||
FSG 5.10FLEX.04 | Charger Tie-in | ||
250 VDC Div | FSG 5.10FLEX.06 Fuel Pool Level Instrument Electrical Tie-In 1 | ||
FLEX Operations | FSG 5.10FLEX.07 4160 F Bus Tie-in with Off-Site Generator 2 | ||
FSG 5.10FLEX.05 | FSG 5.10FLEX.08 4160 G Bus Tie-in with Off-Site Generator 2 | ||
Reliable Hardened Containment Vent Battery Charger Tie | FSG 5.10FLEX.09 Hotwell to ECST FLEX Operations 1 | ||
-in | FSG 5.10FLEX.10 ECST Makeup from North Well 2 | ||
Fuel Pool Level Instrument Electrical Tie | FSG 5.10FLEX.11 Spent Fuel Pool Supply FLEX Operations 2 | ||
-In 1 FSG 5.10FLEX.07 | FSG 5.10FLEX.12 Reactor Building Reliable Air FLEX Operations 1 | ||
4160 | FSG 5.10FLEX.13 REC SW FLEX Supply 1 | ||
-in with Off | FSG 5.10FLEX.14 RHR Div 1 Shutdown Cooling FLEX Operations 1 | ||
-Site Generator | FSG 5.10FLEX.15 RHR Div 2 Shutdown Cooling FLEX Operations 1 | ||
FSG 5.10FLEX.08 | FSG 5.10FLEX.16 Residual Heat Removal Service Water (RHRSW) 2 | ||
4160 | Div 1 FLEX Operations | ||
-Site Generator | FSG 5.10FLEX.17 Residual Heat Removal Service Water (RHRSW) 2 | ||
FSG 5.10FLEX.09 | Div 2 FLEX Operations | ||
Hotwell to ECST FLEX Operations | FSG 5.10FLEX.18 Alternate Reactor Building Ventilation FLEX 1 | ||
FSG 5.10FLEX.10 | Operations | ||
ECST Makeup from North Well | FSG 5.10FLEX.19 Alternate Ventilation FLEX Operations 1 | ||
FSG 5.10FLEX.11 | FSG 5.10FLEX.20 Debris Removal in Support of FLEX Operations 1 | ||
Spent Fuel Pool Supply FLEX Operations | FSG 5.10FLEX.21 Shutdown Injection FLEX Operations 1 | ||
FSG 5.10FLEX.12 | FSG 5.10FLEX.22 Communications and Lighting Equipment FLEX 1 | ||
Reactor Building Reliable Air FLEX Operations | Power | ||
FSG 5.10FLEX.13 | FSG 5.10FLEX.23 Reactor Equipment Cooling FLEX Operations 1 | ||
REC SW FLEX Supply | FSG 5.10FLEX.24 Control Building Temporary Heating FLEX 1 | ||
FSG 5.10FLEX.14 | Operations | ||
RHR Div 1 Shutdown Cooling FLEX Operations | FSG 5.10FLEX.25 Alternate RPV Injection thru RHR SW Riser or RHR- 1 | ||
FSG 5.10FLEX.15 | B B.5.B Connection | ||
RHR Div 2 Shutdown Cooling FLEX Operations | FSG 5.10FLEX.26 RHR Suppression Pool Cooling Div 1 FLEX 1 | ||
FSG 5.10FLEX.16 | Operations | ||
Residual Heat Removal Service Water (RHRSW) Div 1 FLEX Operations | FSG 5.10FLEX.27 RHR Suppression Pool Cooling Div 2 FLEX 1 | ||
FSG 5.10FLEX.17 | Operations | ||
Residual Heat Removal Service Water (RHRSW) Div 2 FLEX Operations | FSG 5.10FLEX.28 Vital Instrumentation FLEX Operations 1 | ||
FSG 5.10FLEX.18 | FSG 5.10FLEX.29 Alternate Reactor Vessel Injection from Missouri 1 | ||
Alternate Reactor Building Ventilation FLEX Operations | River | ||
FSG 5.10FLEX.19 | FSG 5.10FLEX.30 Hardened Containment Vent System FLEX 5 | ||
Alternate Ventilation FLEX Operations | Operations | ||
FSG 5.10FLEX.20 | FSG 5.10FLEX.31 FLEX Equipment Refueling Operations 1 | ||
Debris Removal in Support of | 5.3SBO Station Blackout 43 | ||
FLEX Operations | 5.7.17 CNS Dose Assessment 49 | ||
FSG 5.10FLEX.21 | 5.7.17.1 Dose Assessment (Manual) 3 | ||
Shutdown Injection FLEX Operations | 6.FPC.701 FPC Level Transmitter Functional Test 0 | ||
FSG 5.10FLEX.22 | OI 25 Operations Routine Duties 70 | ||
Communications and Lighting Equipment FLEX Power | Security Access Control Devices 50 | ||
Reactor Equipment Cooling FLEX Operations | Procedure 2.8 | ||
FSG 5.10FLEX.24 | Site Services Station Security 59 | ||
Control Building Temporary Heating FLEX Operations | Procedure 1.1 | ||
FSG 5.10FLEX.25 | FLEX Final Integrated Plan 1 | ||
Alternate RPV Injection thru RHR SW Riser or RHR | FLEX Program Document 1 | ||
FSG 5.10FLEX.26 | |||
RHR Suppression Pool Cooling Div 1 FLEX Operations | |||
FSG 5.10FLEX.27 | |||
RHR Suppression Pool Cooling Div | |||
FSG 5.10FLEX.28 | |||
Vital Instrumentation FLEX Operations | |||
FSG 5.10FLEX.29 | |||
Alternate Reactor Vessel Injection from Missouri River | |||
Hardened Containment Vent System FLEX Operations | |||
FSG 5.10FLEX.31 | |||
FLEX Equipment Refueling Operations | |||
5.3SBO Station Blackout | |||
5.7.17 CNS Dose Assessment | |||
5.7.17.1 Dose Assessment (Manual) | |||
6.FPC.701 FPC Level Transmitter Functional Test | |||
OI 25 Operations Routine Duties | |||
Security Procedure 2.8 | |||
Site Services Procedure 1.1 | |||
FLEX Final Integrated Plan | |||
FLEX Program Document | |||
Preventative Maintenance Activities | Preventative Maintenance Activities | ||
Number Title Revision 5067082 SAMG Diesel Generator Testing | Number Title Revision | ||
9/27/2016 5155721 Perform Vendor FLEX Maintenance Activities (1 year | 5067082 SAMG Diesel Generator Testing 9/27/2016 | ||
5/23/2017 5164463 Perform Vendor FLEX Equipment Maintenance (6 | 5155721 Perform Vendor FLEX Maintenance Activities (1 year 5/23/2017 | ||
5194852 Spent Fuel Pool Primary LI Signal PCRS | Operational Inspections) | ||
5164463 Perform Vendor FLEX Equipment Maintenance (6 11/06/2017 | |||
Drawings Number Title Revision 453010422 Emergency Condensate Storage Tanks | month) | ||
AB/02 R110827 Cooper Nuclear Strategy Topography Survey | 5194852 Spent Fuel Pool Primary LI Signal PCRS 12/29/2017 | ||
8/23/2012 | Drawings | ||
Number Title Revision EC 6036621 | Number Title Revision | ||
Install Remote Satellite Units | 453010422 Emergency Condensate Storage Tanks AB/02 | ||
EE 01-057 Class I Restrained Seismic Design Basis of Class IIS Piping | R110827 Cooper Nuclear Strategy Topography Survey 8/23/2012 | ||
ER 2016-002 FLEX Portable Equipment Deployment Path Liquefaction Evaluation | Other Documents/Reports | ||
Number Title Revision INT0350113 | Number Title Revision | ||
FLEX Modifications | EC 6036621 Install Remote Satellite Units 0 | ||
INT0350114 | EE 01-057 Class I Restrained Seismic Design Basis of Class IIS 0 | ||
FLEX Strategy | Piping | ||
INT0350116 | EE 01-147 Summary of Main Steam Isolation Valve (MSIV) 2 | ||
FLEX Strategy Walkdown | Leakage Pathway to the Condenser Seismic | ||
Lesson Plan IAC202-00-00 | Qualification | ||
LO#2018-0092 2018 CNS TI | ER 2016-002 FLEX Portable Equipment Deployment Path 0 | ||
-2515/191 Mitigating Strategies (SFP/EP) Inspection Assessment | Liquefaction Evaluation | ||
MEC 500-01-01 MEC OSC Emergency Response Overview | Number Title Revision | ||
ML17226A032 | INT0350113 FLEX Modifications 1 | ||
Cooper Nuclear Station Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders | INT0350114 FLEX Strategy 1 | ||
EA-12-049 and EA | INT0350116 FLEX Strategy Walkdown 0 | ||
-12-051 (CAC Nos. MF0971 and MF0972) | Lesson Plan Level Measurement & Devices 8 | ||
FLEX Equipment Maintenance Plans for FLEX Air Compressors; 175 kW, 60 kW, and 6 kW Diesel Generators; and FLEX Godwin Pumps | IAC202-00-00 | ||
LO#2018-0092 2018 CNS TI-2515/191 Mitigating Strategies (SFP/EP) | |||
NEDC 09-102 Internal Flooding | Inspection Assessment | ||
- HELB, MELB, and Feedwater Line Break | MEC 500-01-01 MEC OSC Emergency Response Overview 2 | ||
NEDC 14-027 Review of ERIN Calculation C122140001 | ML17226A032 Cooper Nuclear Station Safety Evaluation Regarding 9/20/2017 | ||
-11622, | Implementation of Mitigating Strategies and Reliable | ||
NEI 12-01 Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities | Spent Fuel Pool Instrumentation Related to Orders | ||
NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) Implementation Guidelines | EA-12-049 and EA-12-051 (CAC Nos. MF0971 and | ||
NLS2013028 | MF0972) | ||
Response to NRC Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Near | MP FLEX Equipment Maintenance Plans for FLEX Air {Not Dated} | ||
-Term Task Force Recommendation 9.3 | 800000050260 Compressors; 175 kW, 60 kW, and 6 kW Diesel | ||
Generators; and FLEX Godwin Pumps | |||
9/15/2015 PM Notification | NEDC 09-102 Internal Flooding - HELB, MELB, and Feedwater Line 2 | ||
Break | |||
10/25/2017 | NEDC 14-001 Storage Facility Structural Calculation 1 | ||
Purchase Order | NEDC 14-027 Review of ERIN Calculation C122140001-11622, 0 | ||
MAAP Analysis to Support Cooper FLEX Strategy | |||
NEI 12-01 Guideline for Assessing Beyond Design Basis 0 | |||
Accident Response Staffing and Communications | |||
Capabilities | |||
NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) 2 | |||
Implementation Guidelines | |||
NLS2013028 Response to NRC Technical Issues for Resolution 2/21/13 | |||
Regarding Licensee Communication Submittals | |||
Associated with Near-Term Task Force | |||
Recommendation 9.3 | |||
NSRC-005 SAFER Response Plan for Cooper Nuclear Station 9/15/2015 | |||
PM Notification Maintenance Plan 800000050260 Revision 10/25/2017 | |||
11417703 | |||
Purchase Order Preventive Maintenance Program 3/06/17 | |||
4500200470 | 4500200470 | ||
Technical Beyond Design Basis Components 11/06/16 | |||
Requirements | |||
Manual Section | |||
-01 Phase 2 Staffing | 3.12 | ||
4/21/2016 | Cooper Nuclear Station NEI 12-01 Phase 2 Staffing 4/21/2016 | ||
NANTeL Generic Basic FLEX, ERO0010102/ILT | Assessment | ||
FLEX Validation Document | |||
NANTeL Generic Basic FLEX, ERO0010102/ILT- | |||
Corrective Action Program | 251/NAN-56252 | ||
Documents (CR-CNS-) 2016-02845 2016-02869 2017-01463 2017-02565 2017-02568 2017-02799 2017-02801 2017-03089 2017-03777 2017-05033 2017-05285 2017-06372 2018-01166 2018-01243 2018-01442* 2018-01443* 2018-01450* 2018-01451* 2018-01457* 2018-01458* 2018-01463* 2018-01469* 2018-01475* 2018-01494* 2018-01496* 2018-01499* 2018-01500* 2018-01509* 2018-01511* 2018-02294* | NANTeL Generic Advanced FLEX, ERO0010103/ILT- | ||
253/NAN-56254 | |||
Corrective Action Program Documents (CR-CNS-) | |||
2016-02845 2016-02869 2017-01463 2017-02565 | |||
2017-02568 2017-02799 2017-02801 2017-03089 | |||
2017-03777 2017-05033 2017-05285 2017-06372 | |||
2018-01166 2018-01243 2018-01442* 2018-01443* | |||
2018-01450* 2018-01451* 2018-01457* 2018-01458* | |||
2018-01463* 2018-01469* 2018-01475* 2018-01494* | |||
2018-01496* 2018-01499* 2018-01500* 2018-01509* | |||
2018-01511* 2018-02294* | |||
* - Initiated as a result of this inspection | |||
ML18128A074 | |||
SUNSI Review | SUNSI Review Non-Sensitive Publicly Available Keyword: | ||
By: | By: MHS2/rdr Sensitive Non-Publicly Available NRC-002 | ||
Non-Publicly Available | OFFICE RI:DRP/C/CNS SPE:DRP/A SRI:DRS/EB2 RIII:DRP/PE BC:DRP/C | ||
NAME MStafford RAlexander JMateychick SSheldon JKozal | |||
SPE:DRP/A SRI:DRS/EB2 | SIGNATURE /RA-E/ /RA/ /RA/ /RA-E/ /RA/ | ||
RIII:DRP/PE | DATE 4/19/18 4/19/18 4/20/18 4/19/18 5/8/18 | ||
BC:DRP/C | |||
JMateychick | May 8, 2018 | ||
SSheldon JKozal | Mr. John Dent, Jr. | ||
May 8, 2018 | Vice President-Nuclear and CNO | ||
Vice President | |||
-Nuclear and CNO | |||
Nebraska Public Power District | Nebraska Public Power District | ||
Cooper Nuclear Station | Cooper Nuclear Station | ||
2676 648A Avenue | 2676 648A Avenue | ||
P.O. Box 98 | |||
Brownville, NE 68321 | |||
STAFFING/MULTI | SUBJECT: COOPER NUCLEAR STATION - INSPECTION OF THE IMPLEMENTATION OF | ||
-UNIT DOSE ASSESSMENT PLANS | MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION | ||
- INSPECTION REPORT | ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/ | ||
STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION | |||
Station. On April 16, 2018 , the NRC inspectors discussed the results of this inspection with Mr. | REPORT 05000298/2018010 | ||
: [[contact::J. Kalamaja]], General Manager of Plant Operations | Dear Mr. Dent: | ||
, and other members of your staff. The results of this inspection are documented in the enclosed report. | On March 15, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite | ||
The inspection examined activities conducted under your license as they relate to the implementation of | portion of this inspection at your Cooper Nuclear Station. On April 16, 2018, the NRC | ||
inspectors discussed the results of this inspection with Mr. | |||
-12-049 and EA-12-051) and Emergency Preparedness Communication , Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the | : [[contact::J. Kalamaja]], General Manager of | ||
NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding did not involve a violation of NRC requirements. | Plant Operations, and other members of your staff. The results of this inspection are | ||
If you disagree with a cross | documented in the enclosed report. | ||
-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 | The inspection examined activities conducted under your license as they relate to the | ||
days of the date of this inspection report, with the basis for your disagreement, to the | implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 | ||
and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose | |||
-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the | Assessment Plans, your compliance with the Commissions rules and regulations, and with the | ||
Cooper Nuclear Station. | conditions of your operating license. Within these areas, the inspection involved examination of | ||
J. Dent Jr. | selected procedures and records, observation of activities, and interviews with station | ||
personnel. | |||
NRC inspectors documented one finding of very low safety significance (Green) in this report. | |||
The finding did not involve a violation of NRC requirements. | |||
If you disagree with a cross-cutting aspect assignment or a finding not associated with a | |||
regulatory requirement in this report, you should provide a response within 30 days of the date | |||
of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory | |||
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the | |||
Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear | |||
Station. | |||
J. Dent Jr. 2 | |||
This letter, its enclosure, and your response (if any) will be made available for public inspection | This letter, its enclosure, and your response (if any) will be made available for public inspection | ||
and copying at http://www.nrc.gov/reading | and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document | ||
-rm/adams.html | Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for | ||
and at the NRC Public Document Room in accordance with 10 | Withholding. | ||
CFR 2.390, | Sincerely, | ||
/RA/ | |||
: [[contact::W. Kozal ]], Chief Project Branch | Jason | ||
: [[contact::W. Kozal]], Chief | |||
Docket: | Project Branch C | ||
-298 License: | Division of Reactor Projects | ||
Docket: 50-298 | |||
License: DPR-46 | |||
Enclosure: | |||
Inspection Report 05000298/2018010 | |||
w/Attachment: | |||
Documents Reviewed | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
Inspection Report | Inspection Report | ||
Docket Number: 05000298 | |||
License Number: DPR-46 | |||
Report Number: 05000298/2018010 | |||
Enterprise Identifier: I-2018-010-0017 | |||
Licensee: Nebraska Public Power District | |||
Facility: Cooper Nuclear Station | |||
Location: Brownville, Nebraska | |||
Inspection Dates: March 12, 2018 to April 16, 2018 | |||
Inspectors: | |||
: [[contact::M. Stafford]], Resident Inspector - Cooper (Team Leader) | |||
: [[contact::R. Alexander]], Sr. Project Engineer - Region IV | |||
: [[contact::J. Mateychick]], Sr. Reactor Inspector - Region IV | |||
: [[contact::S. Sheldon]], Project Engineer - Region III | |||
Approved By: Jason Kozal | |||
Chief, Project Branch C | |||
Division of Reactor Projects | |||
SUMMARY | |||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance | |||
by conducting a Temporary Instruction 2515/191, Implementation of Mitigation Strategies and | |||
Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ | |||
Staffing/Multi-Unit Dose Assessment Plans at Cooper Nuclear Station in accordance with the | |||
Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for | |||
overseeing the safe operation of commercial nuclear power reactors. Refer to | |||
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self- | |||
revealed findings, violations, and additional items are summarized in the table below. | |||
2515/191 , | |||
-Unit Dose Assessment Plans | |||
Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the | |||
overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html | |||
for more information. NRC and self | |||
List of Findings and Violations | List of Findings and Violations | ||
Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events | Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They | ||
Cornerstone | Will Remain Available Following All Beyond Design Basis External Events | ||
Significance | Cornerstone Significance Cross-cutting Report | ||
Cross-cutting Aspect | Aspect Section | ||
Emergency Green H.3 - TI 2515/191 | |||
-01 Closed | Preparedness FIN 05000298/2018010-01 Change | ||
Closed Management | |||
The NRC inspection team identified a Green finding related to the | The NRC inspection team identified a Green finding related to the licensees failure to maintain | ||
the station satellite phones in locations that would provide reasonable assurance the phones | |||
would remain available following all beyond design basis external events. | |||
INSPECTION SCOPES | INSPECTION SCOPES | ||
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading | Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in | ||
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with | |||
-manual/inspection | their attached revision histories are located on the public website at http://www.nrc.gov/reading- | ||
-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, | rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared | ||
-Water Reactor Inspection Program - Operations Phase. | complete when the IP requirements most appropriate to the inspection activity were met | ||
OTHER ACTIVITIES | consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection | ||
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL | Program - Operations Phase. The inspectors reviewed selected procedures and records, | ||
TI 2515/191 | observed activities, and interviewed personnel to assess licensee performance and compliance | ||
with Commission rules and regulations, license conditions, site procedures, and standards. | |||
-Unit Dose Assessment Plans | OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL | ||
Inspectors | TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool | ||
-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond | Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose | ||
-Design-Basis External Events | Assessment Plans | ||
(Agencywide Documents Access and Management System | Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses | ||
with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events | |||
-13-0010, | (Agencywide Documents Access and Management System (ADAMS) Accession No. | ||
ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel | |||
verified that the licensee satisfactorily implemented appropriate elements of the | Pool Instrumentation (ADAMS No. ML12054A679) are in place and are being implemented by | ||
Diverse and Flexible Coping Strategies | the licensee. Additionally, the inspection verified implementation of staffing and | ||
communications information provided in response to the March 12, 2012, request for | |||
information letter (ADAMS No. ML12053A340) and multiunit dose assessment information | |||
provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency | |||
-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond | Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS No. | ||
-Design-Basis External Events. The inspectors verified the licensee satisfactorily | ML12339A262). | ||
(1) Based on samples selected for review, the inspectors verified that the licensee | |||
satisfactorily implemented appropriate elements of the Diverse and Flexible Coping | |||
b) integrated their | Strategies (FLEX) as described in the plant specific submittals [including the Final | ||
FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; | Integrated Plan (ADAMS Accession No. ML17017A166)] and the associated safety | ||
c) protected FLEX equipment from site | evaluation (ADAMS No. ML17226A032) and determined that the licensee is in | ||
-specific hazards; | compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to | ||
d) developed and implemented adequate testing and maintenance of FLEX | Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The | ||
inspectors verified the licensee satisfactorily: | |||
a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX | |||
strategies for postulated external events; | |||
b) integrated their FSGs into their existing plant procedures such that entry into and | |||
departure from the FSGs were clear when using existing plant procedures; | |||
c) protected FLEX equipment from site-specific hazards; | |||
d) developed and implemented adequate testing and maintenance of FLEX equipment | |||
to ensure their availability and capability; | |||
e) trained their staff to assure personnel proficiency in the mitigation of | e) trained their staff to assure personnel proficiency in the mitigation of | ||
beyond-design basis events; and | beyond-design basis events; and | ||
f) developed the means to ensure the necessary off | f) developed the means to ensure the necessary off-site FLEX equipment would be | ||
-site FLEX equipment would be available from | available from off-site locations. | ||
(2) Based on samples selected for review, the inspectors verified that the licensee | |||
satisfactorily implemented appropriate elements of the FLEX strategy as described in the | |||
verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific | plant specific submittals [including the Final Integrated Plan (ADAMS Accession No. | ||
submittals | ML17017A166)] and the associated safety evaluation (ADAMS No. ML17226A032) and | ||
determined that the licensee is in compliance with NRC Order NRC Order EA-12-051, | |||
Accession No. ML17017A166)] and the associated safety evaluation (ADAMS No. ML17226A032) and determined that the licensee is in compliance with NRC Order | Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation. | ||
NRC Order EA | The inspectors verified the licensee satisfactorily : | ||
-12-051 , Order Modifying Licenses With Regard to Reliable Spent Fuel | a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power | ||
Pool Instrumentation. The inspectors verified the licensee satisfactorily | supplies to provide physical and electrical separation as described in the plant | ||
specific submittals and safety evaluation; | |||
b) installed the SFP instrumentation display in the location, environmental conditions | |||
c) trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and | and accessibility as described in the plant specific submittals; | ||
d) developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation. | c) trained their staff to assure personnel proficiency with the maintenance, testing, and | ||
use of the SFP instrumentation; and | |||
reviewed information provided in the | d) developed and issued procedures for maintenance, testing and use of the reliable | ||
-unit dose submittal and in response to the | SFP instrumentation. | ||
-Term Task Force Recommendation 9.3 in response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site. The inspectors verified the following: | (3) The inspectors reviewed information provided in the licensees multi-unit dose submittal | ||
a) the licensee satisfactorily implemented required | and in response to the NRCs March 12, 2012, request for information letter (ADAMS | ||
staffing changes to support an extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS) | No. ML12053A340), and verified that the licensee satisfactorily implemented | ||
scenario; b) EP communications equipment and facilities are | enhancements pertaining to Near-Term Task Force Recommendation 9.3 in response to | ||
sufficient for dealing with an ELAP/LUHS scenario; and | a large scale natural emergency event that results in an extended loss of all ac power to | ||
c) the licensee implemented multi | all site units and impedes access to the site. The inspectors verified the following: | ||
-unit/-source dose assessment capabilities (including releases from spent fuel pools) using the | a) the licensee satisfactorily implemented required staffing changes to support an | ||
-specific dose assessment software and approach. | extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS) scenario; | ||
The inspectors verified that non | b) EP communications equipment and facilities are sufficient for dealing with an | ||
-compliances with requirements and standards identified during the inspection were entered into the licensee's corrective action program as appropriate. | ELAP/LUHS scenario; and | ||
c) the licensee implemented multi-unit/-source dose assessment capabilities (including | |||
releases from spent fuel pools) using the licensees site-specific dose assessment | |||
software and approach. | |||
The inspectors verified that non-compliances with requirements and standards identified during | |||
the inspection were entered into the licensee's corrective action program as appropriate. | |||
INSPECTION RESULTS | INSPECTION RESULTS | ||
Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events | Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They | ||
Cornerstone | Will Remain Available Following All Beyond Design Basis External Events | ||
Significance | Cornerstone Significance Cross-cutting Report | ||
Cross-cutting Aspect | Aspect Section | ||
Green | Emergency Green H.3 - Change TI 2515/191 | ||
Preparedness FIN 05000298/2018010-01 Management | |||
TI 2515/191 | Closed | ||
The NRC inspection team identified a Green finding related to the | The NRC inspection team identified a Green finding related to the licensees failure to | ||
assurance the phones would remain available following all beyond design basis external events. | maintain the station satellite phones in locations that would provide reasonable assurance the | ||
Description: | phones would remain available following all beyond design basis external events. | ||
- Communications, | Description: The Cooper Nuclear Station FLEX Program Document, Revision 1, Section | ||
-01 provides required emergency communications capabilities during an Extended Loss of AC Power (ELAP) | 5.2.27, Support Functions - Communications, states, in part: NEI 12-01 provides required | ||
-site | emergency communications capabilities during an Extended Loss of AC Power | ||
NEI 12-01, | (ELAP)Satellite phones are credited for off-site communicationDocking stations and | ||
Revision 0, Section 4.5, | remote antennas have been installed to allow use of the satellite phones from inside | ||
-site communications equipment should be in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external | buildings. | ||
Initially, when the licensee implemented their plans to resolve | NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and | ||
issues associated with communications during a beyond design basis external event (BDBEE), they had handheld satellite phones located in the control room and the technical support center (TSC), which required the users to relocate outdoors to acquire a usable signal. These locations are rated to withstand all BDBEE, and would therefore meet the requirements of NEI 12 | Communications Capabilities, Revision 0, Section 4.5, Equipment Location Requirements, | ||
-01. However, in an effort to enhance the communications methods, the licensee pursued plans to provide a means for personnel to | states: to be assumed operable, a piece of on-site communications equipment should be in a | ||
be able to communicate with satellite phones from inside buildings. These enhancements involved providing external antennas, relocating the existing satellite phones to docking stations in a structure attached to the elevated release point (ERP shack) | location, and maintained in a manner, that maximizes survivability following a beyond design | ||
and in a communications room (PBX room), and routing wires to control room and TSC desk phones. These enhancements are mentioned in general in a letter from the licensee to the NRC, NLS2013028, dated 2/21/13, | basis external eventEquipment should be stored, or otherwise available, in locations that | ||
NRC Technical Issues for Resolution | can be readily accessed when neededThe above guidance applies to equipment at the | ||
Regarding Licensee Communication Submittals Associated with Near | point of use as well as any supporting infrastructure components. Such components may | ||
-Term Task Force Recommendation 9.3. | include portable power sources, and radio system repeaters and antennas. | ||
In moving the physical location of the satellite phones from the control room and TSC | Initially, when the licensee implemented their plans to resolve issues associated with | ||
, the licensee failed to ensure that the new locations were suitable to withstand all | communications during a beyond design basis external event (BDBEE), they had handheld | ||
satellite phones located in the control room and the technical support center (TSC), which | |||
required the users to relocate outdoors to acquire a usable signal. These locations are rated | |||
The team determined that, by implementing this enhancement to communications systems, the licensee placed | to withstand all BDBEE, and would therefore meet the requirements of NEI 12-01. However, | ||
in an effort to enhance the communications methods, the licensee pursued plans to provide a | |||
-01 and therefore does not meet the requirements of the FLEX Program Document. | means for personnel to be able to communicate with satellite phones from inside buildings. | ||
Corrective Action(s): | These enhancements involved providing external antennas, relocating the existing satellite | ||
Additionally, the licensee is in the process of procuring three additional satellite phones to | phones to docking stations in a structure attached to the elevated release point (ERP shack) | ||
and in a communications room (PBX room), and routing wires to control room and TSC desk | |||
-01. Corrective Action Reference(s): | phones. These enhancements are mentioned in general in a letter from the licensee to the | ||
-CNS-2018- | NRC, NLS2013028, dated 2/21/13, Response to NRC Technical Issues for Resolution | ||
Performance Deficiency: | Regarding Licensee Communication Submittals Associated with Near-Term Task Force | ||
-01, Revision 0, Section 4.5. The ERP shack is not rated for tornado wind loading and therefore the phones relocated from the control room may not survive this external event. | Recommendation 9.3. | ||
Additionally, the antennas may not survive high wind speeds. | In moving the physical location of the satellite phones from the control room and TSC, the | ||
Screening: | licensee failed to ensure that the new locations were suitable to withstand all BDBEE. The | ||
ERP shack is not rated for tornado wind loading, and the phones relocated from the control | |||
room may not survive this external event. Additionally, the external antennas located on the | |||
elevated release point and the meteorological tower would not be able to withstand the | |||
elevated wind speeds during a tornado or other high wind event. | |||
The team determined that, by implementing this enhancement to communications systems, | |||
the licensee placed their satellite phone equipment in locations that are vulnerable to BDBEE. | |||
This does not meet the requirements of NEI 12-01 and therefore does not meet the | |||
requirements of the FLEX Program Document. | |||
Corrective Action(s): In response to the teams questions, the licensee documented the | |||
concerns in the corrective action program. Additionally, the licensee is in the process of | |||
procuring three additional satellite phones to stage in the control room, thereby restoring | |||
compliance with NEI 12-01. | |||
Corrective Action Reference(s): CR-CNS-2018-01499 | |||
Performance Assessment: | |||
Performance Deficiency: That the station failed to maintain the satellite phones in locations | |||
that provide reasonable assurance the phones will remain available following all beyond | |||
design basis external events is a performance deficiency. Specifically, by moving the satellite | |||
phones from locations where the phones were protected from beyond design basis external | |||
events to locations where the phones were not protected was contrary to NEI 12-01, | |||
Revision 0, Section 4.5. The ERP shack is not rated for tornado wind loading and therefore | |||
the phones relocated from the control room may not survive this external event. Additionally, | |||
the antennas may not survive high wind speeds. | |||
Screening: The inspectors determined the performance deficiency was more than minor | |||
because it adversely affected the facilities and equipment attribute of the Emergency | |||
Preparedness Cornerstone and its objective to ensure that the licensee is capable of | |||
implementing adequate measures to protect the health and safety of the public in the event of | |||
a radiological emergency. Specifically, by moving the satellite phones to locations that are | |||
not rated for all beyond design basis external events, the licensee would not be able to | |||
contact any offsite organizations. | contact any offsite organizations. | ||
Significance: | Significance: The team assessed the significance of the finding using Inspection Manual | ||
-12-049 and EA | Chapter (IMC) 0609, Appendix O, Significance Determination Process for Mitigating | ||
-12-051), | Strategies and Spent Fuel Pool Instrumentation (Orders EA-12-049 and EA-12-051), dated | ||
team determined that the performance deficiency did not (1) impact the spent fuel pool instrumentation order (EA | October 7, 2016. The team determined that the performance deficiency did not (1) impact the | ||
-12-051); (2) did not involve a failure of FLEX equipment for 72 hours or more that would result in a complete loss of one or more of the FLEX functions; (3) did not involve deficient procedures or training that would result in a complete loss of one or more of the FLEX functions; (4) did not have a product of the exposure time and external even initiating event frequency greater than 1E | spent fuel pool instrumentation order (EA-12-051); (2) did not involve a failure of FLEX | ||
-6; and (5) did not involve significant programmatic issues which reduced the effectiveness of the Mitigating Strategies. Therefore, the finding was determined to be of very low safety significance (Green). Cross-cutting Aspect: | equipment for 72 hours or more that would result in a complete loss of one or more of the | ||
FLEX functions; (3) did not involve deficient procedures or training that would result in a | |||
: | complete loss of one or more of the FLEX functions; (4) did not have a product of the | ||
exposure time and external even initiating event frequency greater than 1E-6; and (5) did not | |||
EXIT | involve significant programmatic issues which reduced the effectiveness of the Mitigating | ||
Strategies. Therefore, the finding was determined to be of very low safety significance | |||
The inspectors verified no proprietary information was retained or documented in this report | (Green). | ||
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated | |||
-site inspection results in a management debrief to Mr. | with change management, in that the licensee failed to fully evaluate implementing the | ||
: [[contact::J. Kalamaja ]], General Manager of Plant Operations | enhancement to move the satellite phones from the control room and TSC to the ERP shack | ||
, and other members of the site staff. | an the PBX room [H.3]. | ||
On April 16, 2018, the lead inspector presented the final inspection results in | Enforcement: Inspectors did not identify a violation of regulatory requirements associated | ||
an exit meeting to Mr. | with this finding. | ||
: [[contact::J. Kalamaja]], General Manager of Plant Operations | EXIT MEETINGS AND DEBRIEFS | ||
, and other members of the site staff. | The inspectors verified no proprietary information was retained or documented in this report. | ||
* On March 15, 2018, the inspection team presented the on-site inspection results in a | |||
management debrief to Mr. | |||
: [[contact::J. Kalamaja]], General Manager of Plant Operations, and other | |||
members of the site staff. | |||
* On April 16, 2018, the lead inspector presented the final inspection results in an exit meeting | |||
to Mr. | |||
: [[contact::J. Kalamaja]], General Manager of Plant Operations, and other members of the site | |||
staff. | |||
DOCUMENTS REVIEWED | DOCUMENTS REVIEWED | ||
Other Activities | Other Activities - TI 2515/191 | ||
- TI 2515/191 | |||
Procedures/Instructions | Procedures/Instructions | ||
Number Title Revision 0-CNS-OU-108 Shutdown Safety Management Program | Number Title Revision | ||
0.50.5 Outage Shutdown Safety | 0-CNS-OU-108 Shutdown Safety Management Program 4 | ||
2.4FPC Fuel Pool Cooling Trouble | 0.50.5 Outage Shutdown Safety 37 | ||
5.1FLOOD Emergency Operations Procedure: Flood | 2.4FPC Fuel Pool Cooling Trouble 34 | ||
7.0.11 Maintenance Procedure: Flood Control Barriers | 5.1FLOOD Emergency Operations Procedure: Flood 22 | ||
14.41.1.1 FPC-LIT-1 Testing 4 EOF08 Position Instruction Manual: Logistics Coordinator | 7.0.11 Maintenance Procedure: Flood Control Barriers 30 | ||
FSG 5.10FLEX | 14.41.1.1 FPC-LIT-1 Testing 4 | ||
FLEX Support Guidelines (FSGs) | EOF08 Position Instruction Manual: Logistics Coordinator 30 | ||
FSG 5.10FLEX.01 | FSG 5.10FLEX FLEX Support Guidelines (FSGs) 2 | ||
FSG 5.10FLEX.01 125 VDC Div 1 FLEX Operations 1 | |||
FSG 5.10FLEX.02 | FSG 5.10FLEX.02 125 VDC Div 2 FLEX Operations 1 | ||
FSG 5.10FLEX.03 250 VDC Div 1 FLEX Operations 1 | |||
FSG 5.10FLEX.03 | FSG 5.10FLEX.04 250 VDC Div 2 FLEX Operations 1 | ||
250 VDC Div 1 FLEX Operations | FSG 5.10FLEX.05 Reliable Hardened Containment Vent Battery 1 | ||
FSG 5.10FLEX.04 | Charger Tie-in | ||
250 VDC Div | FSG 5.10FLEX.06 Fuel Pool Level Instrument Electrical Tie-In 1 | ||
FLEX Operations | FSG 5.10FLEX.07 4160 F Bus Tie-in with Off-Site Generator 2 | ||
FSG 5.10FLEX.05 | FSG 5.10FLEX.08 4160 G Bus Tie-in with Off-Site Generator 2 | ||
Reliable Hardened Containment Vent Battery Charger Tie | FSG 5.10FLEX.09 Hotwell to ECST FLEX Operations 1 | ||
-in | FSG 5.10FLEX.10 ECST Makeup from North Well 2 | ||
Fuel Pool Level Instrument Electrical Tie | FSG 5.10FLEX.11 Spent Fuel Pool Supply FLEX Operations 2 | ||
-In 1 FSG 5.10FLEX.07 | FSG 5.10FLEX.12 Reactor Building Reliable Air FLEX Operations 1 | ||
4160 | FSG 5.10FLEX.13 REC SW FLEX Supply 1 | ||
-in with Off | FSG 5.10FLEX.14 RHR Div 1 Shutdown Cooling FLEX Operations 1 | ||
-Site Generator | FSG 5.10FLEX.15 RHR Div 2 Shutdown Cooling FLEX Operations 1 | ||
FSG 5.10FLEX.08 | FSG 5.10FLEX.16 Residual Heat Removal Service Water (RHRSW) 2 | ||
4160 | Div 1 FLEX Operations | ||
-Site Generator | FSG 5.10FLEX.17 Residual Heat Removal Service Water (RHRSW) 2 | ||
FSG 5.10FLEX.09 | Div 2 FLEX Operations | ||
Hotwell to ECST FLEX Operations | FSG 5.10FLEX.18 Alternate Reactor Building Ventilation FLEX 1 | ||
FSG 5.10FLEX.10 | Operations | ||
ECST Makeup from North Well | FSG 5.10FLEX.19 Alternate Ventilation FLEX Operations 1 | ||
FSG 5.10FLEX.11 | FSG 5.10FLEX.20 Debris Removal in Support of FLEX Operations 1 | ||
Spent Fuel Pool Supply FLEX Operations | FSG 5.10FLEX.21 Shutdown Injection FLEX Operations 1 | ||
FSG 5.10FLEX.12 | FSG 5.10FLEX.22 Communications and Lighting Equipment FLEX 1 | ||
Reactor Building Reliable Air FLEX Operations | Power | ||
FSG 5.10FLEX.13 | FSG 5.10FLEX.23 Reactor Equipment Cooling FLEX Operations 1 | ||
REC SW FLEX Supply | FSG 5.10FLEX.24 Control Building Temporary Heating FLEX 1 | ||
FSG 5.10FLEX.14 | Operations | ||
RHR Div 1 Shutdown Cooling FLEX Operations | FSG 5.10FLEX.25 Alternate RPV Injection thru RHR SW Riser or RHR- 1 | ||
FSG 5.10FLEX.15 | B B.5.B Connection | ||
RHR Div 2 Shutdown Cooling FLEX Operations | FSG 5.10FLEX.26 RHR Suppression Pool Cooling Div 1 FLEX 1 | ||
FSG 5.10FLEX.16 | Operations | ||
Residual Heat Removal Service Water (RHRSW) Div 1 FLEX Operations | FSG 5.10FLEX.27 RHR Suppression Pool Cooling Div 2 FLEX 1 | ||
FSG 5.10FLEX.17 | Operations | ||
Residual Heat Removal Service Water (RHRSW) Div 2 FLEX Operations | FSG 5.10FLEX.28 Vital Instrumentation FLEX Operations 1 | ||
FSG 5.10FLEX.18 | FSG 5.10FLEX.29 Alternate Reactor Vessel Injection from Missouri 1 | ||
Alternate Reactor Building Ventilation FLEX Operations | River | ||
FSG 5.10FLEX.19 | FSG 5.10FLEX.30 Hardened Containment Vent System FLEX 5 | ||
Alternate Ventilation FLEX Operations | Operations | ||
FSG 5.10FLEX.20 | FSG 5.10FLEX.31 FLEX Equipment Refueling Operations 1 | ||
Debris Removal in Support of | 5.3SBO Station Blackout 43 | ||
FLEX Operations | 5.7.17 CNS Dose Assessment 49 | ||
FSG 5.10FLEX.21 | 5.7.17.1 Dose Assessment (Manual) 3 | ||
Shutdown Injection FLEX Operations | 6.FPC.701 FPC Level Transmitter Functional Test 0 | ||
FSG 5.10FLEX.22 | OI 25 Operations Routine Duties 70 | ||
Communications and Lighting Equipment FLEX Power | Security Access Control Devices 50 | ||
Reactor Equipment Cooling FLEX Operations | Procedure 2.8 | ||
FSG 5.10FLEX.24 | Site Services Station Security 59 | ||
Control Building Temporary Heating FLEX Operations | Procedure 1.1 | ||
FSG 5.10FLEX.25 | FLEX Final Integrated Plan 1 | ||
Alternate RPV Injection thru RHR SW Riser or RHR | FLEX Program Document 1 | ||
FSG 5.10FLEX.26 | |||
RHR Suppression Pool Cooling Div 1 FLEX Operations | |||
FSG 5.10FLEX.27 | |||
RHR Suppression Pool Cooling Div | |||
FSG 5.10FLEX.28 | |||
Vital Instrumentation FLEX Operations | |||
FSG 5.10FLEX.29 | |||
Alternate Reactor Vessel Injection from Missouri River | |||
Hardened Containment Vent System FLEX Operations | |||
FSG 5.10FLEX.31 | |||
FLEX Equipment Refueling Operations | |||
5.3SBO Station Blackout | |||
5.7.17 CNS Dose Assessment | |||
5.7.17.1 Dose Assessment (Manual) | |||
6.FPC.701 FPC Level Transmitter Functional Test | |||
OI 25 Operations Routine Duties | |||
Security Procedure 2.8 | |||
Site Services Procedure 1.1 | |||
FLEX Final Integrated Plan | |||
FLEX Program Document | |||
Preventative Maintenance Activities | Preventative Maintenance Activities | ||
Number Title Revision 5067082 SAMG Diesel Generator Testing | Number Title Revision | ||
9/27/2016 5155721 Perform Vendor FLEX Maintenance Activities (1 year | 5067082 SAMG Diesel Generator Testing 9/27/2016 | ||
5/23/2017 5164463 Perform Vendor FLEX Equipment Maintenance (6 | 5155721 Perform Vendor FLEX Maintenance Activities (1 year 5/23/2017 | ||
5194852 Spent Fuel Pool Primary LI Signal PCRS | Operational Inspections) | ||
5164463 Perform Vendor FLEX Equipment Maintenance (6 11/06/2017 | |||
Drawings Number Title Revision 453010422 Emergency Condensate Storage Tanks | month) | ||
AB/02 R110827 Cooper Nuclear Strategy Topography Survey | 5194852 Spent Fuel Pool Primary LI Signal PCRS 12/29/2017 | ||
8/23/2012 | Drawings | ||
Number Title Revision EC 6036621 | Number Title Revision | ||
Install Remote Satellite Units | 453010422 Emergency Condensate Storage Tanks AB/02 | ||
EE 01-057 Class I Restrained Seismic Design Basis of Class IIS Piping | R110827 Cooper Nuclear Strategy Topography Survey 8/23/2012 | ||
ER 2016-002 FLEX Portable Equipment Deployment Path Liquefaction Evaluation | Other Documents/Reports | ||
Number Title Revision INT0350113 | Number Title Revision | ||
FLEX Modifications | EC 6036621 Install Remote Satellite Units 0 | ||
INT0350114 | EE 01-057 Class I Restrained Seismic Design Basis of Class IIS 0 | ||
FLEX Strategy | Piping | ||
INT0350116 | EE 01-147 Summary of Main Steam Isolation Valve (MSIV) 2 | ||
FLEX Strategy Walkdown | Leakage Pathway to the Condenser Seismic | ||
Lesson Plan IAC202-00-00 | Qualification | ||
LO#2018-0092 2018 CNS TI | ER 2016-002 FLEX Portable Equipment Deployment Path 0 | ||
-2515/191 Mitigating Strategies (SFP/EP) Inspection Assessment | Liquefaction Evaluation | ||
MEC 500-01-01 MEC OSC Emergency Response Overview | Number Title Revision | ||
ML17226A032 | INT0350113 FLEX Modifications 1 | ||
Cooper Nuclear Station Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders | INT0350114 FLEX Strategy 1 | ||
EA-12-049 and EA | INT0350116 FLEX Strategy Walkdown 0 | ||
-12-051 (CAC Nos. MF0971 and MF0972) | Lesson Plan Level Measurement & Devices 8 | ||
FLEX Equipment Maintenance Plans for FLEX Air Compressors; 175 kW, 60 kW, and 6 kW Diesel Generators; and FLEX Godwin Pumps | IAC202-00-00 | ||
LO#2018-0092 2018 CNS TI-2515/191 Mitigating Strategies (SFP/EP) | |||
NEDC 09-102 Internal Flooding | Inspection Assessment | ||
- HELB, MELB, and Feedwater Line Break | MEC 500-01-01 MEC OSC Emergency Response Overview 2 | ||
NEDC 14-027 Review of ERIN Calculation C122140001 | ML17226A032 Cooper Nuclear Station Safety Evaluation Regarding 9/20/2017 | ||
-11622, | Implementation of Mitigating Strategies and Reliable | ||
NEI 12-01 Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities | Spent Fuel Pool Instrumentation Related to Orders | ||
NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) Implementation Guidelines | EA-12-049 and EA-12-051 (CAC Nos. MF0971 and | ||
NLS2013028 | MF0972) | ||
Response to NRC Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Near | MP FLEX Equipment Maintenance Plans for FLEX Air {Not Dated} | ||
-Term Task Force Recommendation 9.3 | 800000050260 Compressors; 175 kW, 60 kW, and 6 kW Diesel | ||
Generators; and FLEX Godwin Pumps | |||
9/15/2015 PM Notification | NEDC 09-102 Internal Flooding - HELB, MELB, and Feedwater Line 2 | ||
Break | |||
10/25/2017 | NEDC 14-001 Storage Facility Structural Calculation 1 | ||
Purchase Order | NEDC 14-027 Review of ERIN Calculation C122140001-11622, 0 | ||
MAAP Analysis to Support Cooper FLEX Strategy | |||
NEI 12-01 Guideline for Assessing Beyond Design Basis 0 | |||
Accident Response Staffing and Communications | |||
Capabilities | |||
NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) 2 | |||
Implementation Guidelines | |||
NLS2013028 Response to NRC Technical Issues for Resolution 2/21/13 | |||
Regarding Licensee Communication Submittals | |||
Associated with Near-Term Task Force | |||
Recommendation 9.3 | |||
NSRC-005 SAFER Response Plan for Cooper Nuclear Station 9/15/2015 | |||
PM Notification Maintenance Plan 800000050260 Revision 10/25/2017 | |||
11417703 | |||
Purchase Order Preventive Maintenance Program 3/06/17 | |||
4500200470 | 4500200470 | ||
Technical Beyond Design Basis Components 11/06/16 | |||
Requirements | |||
Manual Section | |||
-01 Phase 2 Staffing | 3.12 | ||
4/21/2016 | Cooper Nuclear Station NEI 12-01 Phase 2 Staffing 4/21/2016 | ||
NANTeL Generic Basic FLEX, ERO0010102/ILT | Assessment | ||
FLEX Validation Document | |||
NANTeL Generic Basic FLEX, ERO0010102/ILT- | |||
Corrective Action Program | 251/NAN-56252 | ||
Documents (CR-CNS-) 2016-02845 2016-02869 2017-01463 2017-02565 2017-02568 2017-02799 2017-02801 2017-03089 2017-03777 2017-05033 2017-05285 2017-06372 2018-01166 2018-01243 2018-01442* 2018-01443* 2018-01450* 2018-01451* 2018-01457* 2018-01458* 2018-01463* 2018-01469* 2018-01475* 2018-01494* 2018-01496* 2018-01499* 2018-01500* 2018-01509* 2018-01511* 2018-02294* | NANTeL Generic Advanced FLEX, ERO0010103/ILT- | ||
253/NAN-56254 | |||
Corrective Action Program Documents (CR-CNS-) | |||
2016-02845 2016-02869 2017-01463 2017-02565 | |||
2017-02568 2017-02799 2017-02801 2017-03089 | |||
2017-03777 2017-05033 2017-05285 2017-06372 | |||
2018-01166 2018-01243 2018-01442* 2018-01443* | |||
2018-01450* 2018-01451* 2018-01457* 2018-01458* | |||
2018-01463* 2018-01469* 2018-01475* 2018-01494* | |||
2018-01496* 2018-01499* 2018-01500* 2018-01509* | |||
2018-01511* 2018-02294* | |||
* - Initiated as a result of this inspection | |||
ML18128A074 | |||
SUNSI Review | SUNSI Review Non-Sensitive Publicly Available Keyword: | ||
By: | By: MHS2/rdr Sensitive Non-Publicly Available NRC-002 | ||
Non-Publicly Available | OFFICE RI:DRP/C/CNS SPE:DRP/A SRI:DRS/EB2 RIII:DRP/PE BC:DRP/C | ||
NAME MStafford RAlexander JMateychick SSheldon JKozal | |||
SPE:DRP/A SRI:DRS/EB2 | SIGNATURE /RA-E/ /RA/ /RA/ /RA-E/ /RA/ | ||
RIII:DRP/PE | DATE 4/19/18 4/19/18 4/20/18 4/19/18 5/8/18 | ||
BC:DRP/C | |||
JMateychick | |||
SSheldon JKozal | |||
}} | }} | ||
Revision as of 04:56, 21 October 2019
| ML18128A074 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/08/2018 |
| From: | Jason Kozal NRC/RGN-IV/DRP/RPB-C |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Kozal J | |
| References | |
| IR 2018010 | |
| Download: ML18128A074 (14) | |
Text
May 8, 2018 Mr. John Dent, Jr.
Vice President-Nuclear and CNO Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville, NE 68321 SUBJECT: COOPER NUCLEAR STATION - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/
STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000298/2018010
Dear Mr. Dent:
On March 15, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of this inspection at your Cooper Nuclear Station. On April 16, 2018, the NRC inspectors discussed the results of this inspection with Mr. J. Kalamaja, General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
The finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear Station. Jr. 2 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jason W. Kozal, Chief Project Branch C Division of Reactor Projects Docket: 50-298 License: DPR-46 Enclosure:
Inspection Report 05000298/2018010 w/Attachment:
Documents Reviewed
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000298 License Number: DPR-46 Report Number: 05000298/2018010 Enterprise Identifier: I-2018-010-0017 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, Nebraska Inspection Dates: March 12, 2018 to April 16, 2018 Inspectors: M. Stafford, Resident Inspector - Cooper (Team Leader)
R. Alexander, Sr. Project Engineer - Region IV J. Mateychick, Sr. Reactor Inspector - Region IV S. Sheldon, Project Engineer - Region III Approved By: Jason Kozal Chief, Project Branch C Division of Reactor Projects
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a Temporary Instruction 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/
Staffing/Multi-Unit Dose Assessment Plans at Cooper Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events Cornerstone Significance Cross-cutting Report Aspect Section Emergency Green H.3 - TI 2515/191 Preparedness FIN 05000298/2018010-01 Change Closed Management The NRC inspection team identified a Green finding related to the licensees failure to maintain the station satellite phones in locations that would provide reasonable assurance the phones would remain available following all beyond design basis external events.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Agencywide Documents Access and Management System (ADAMS) Accession No.
ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS No. ML12053A340) and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS No.
- (1) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals [including the Final Integrated Plan (ADAMS Accession No. ML17017A166)] and the associated safety evaluation (ADAMS No. ML17226A032) and determined that the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The inspectors verified the licensee satisfactorily:
a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b) integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c) protected FLEX equipment from site-specific hazards; d) developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e) trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f) developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.
- (2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals [including the Final Integrated Plan (ADAMS Accession No.
ML17017A166)] and the associated safety evaluation (ADAMS No. ML17226A032) and determined that the licensee is in compliance with NRC Order NRC Order EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.
The inspectors verified the licensee satisfactorily :
a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b) installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; c) trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d) developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation.
- (3) The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter (ADAMS No. ML12053A340), and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 in response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site. The inspectors verified the following:
a) the licensee satisfactorily implemented required staffing changes to support an extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS) scenario; b) EP communications equipment and facilities are sufficient for dealing with an ELAP/LUHS scenario; and c) the licensee implemented multi-unit/-source dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.
The inspectors verified that non-compliances with requirements and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.
INSPECTION RESULTS
Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External Events Cornerstone Significance Cross-cutting Report Aspect Section Emergency Green H.3 - Change TI 2515/191 Preparedness FIN 05000298/2018010-01 Management Closed The NRC inspection team identified a Green finding related to the licensees failure to maintain the station satellite phones in locations that would provide reasonable assurance the phones would remain available following all beyond design basis external events.
Description:
The Cooper Nuclear Station FLEX Program Document, Revision 1, Section 5.2.27, Support Functions - Communications, states, in part: NEI 12-01 provides required emergency communications capabilities during an Extended Loss of AC Power (ELAP)Satellite phones are credited for off-site communicationDocking stations and remote antennas have been installed to allow use of the satellite phones from inside buildings.
NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, Section 4.5, Equipment Location Requirements, states: to be assumed operable, a piece of on-site communications equipment should be in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external eventEquipment should be stored, or otherwise available, in locations that can be readily accessed when neededThe above guidance applies to equipment at the point of use as well as any supporting infrastructure components. Such components may include portable power sources, and radio system repeaters and antennas.
Initially, when the licensee implemented their plans to resolve issues associated with communications during a beyond design basis external event (BDBEE), they had handheld satellite phones located in the control room and the technical support center (TSC), which required the users to relocate outdoors to acquire a usable signal. These locations are rated to withstand all BDBEE, and would therefore meet the requirements of NEI 12-01. However, in an effort to enhance the communications methods, the licensee pursued plans to provide a means for personnel to be able to communicate with satellite phones from inside buildings.
These enhancements involved providing external antennas, relocating the existing satellite phones to docking stations in a structure attached to the elevated release point (ERP shack)and in a communications room (PBX room), and routing wires to control room and TSC desk phones. These enhancements are mentioned in general in a letter from the licensee to the NRC, NLS2013028, dated 2/21/13, Response to NRC Technical Issues for Resolution Regarding Licensee Communication Submittals Associated with Near-Term Task Force Recommendation 9.3.
In moving the physical location of the satellite phones from the control room and TSC, the licensee failed to ensure that the new locations were suitable to withstand all BDBEE. The ERP shack is not rated for tornado wind loading, and the phones relocated from the control room may not survive this external event. Additionally, the external antennas located on the elevated release point and the meteorological tower would not be able to withstand the elevated wind speeds during a tornado or other high wind event.
The team determined that, by implementing this enhancement to communications systems, the licensee placed their satellite phone equipment in locations that are vulnerable to BDBEE.
This does not meet the requirements of NEI 12-01 and therefore does not meet the requirements of the FLEX Program Document.
Corrective Action(s): In response to the teams questions, the licensee documented the concerns in the corrective action program. Additionally, the licensee is in the process of procuring three additional satellite phones to stage in the control room, thereby restoring compliance with NEI 12-01.
Corrective Action Reference(s): CR-CNS-2018-01499
Performance Assessment:
Performance Deficiency: That the station failed to maintain the satellite phones in locations that provide reasonable assurance the phones will remain available following all beyond design basis external events is a performance deficiency. Specifically, by moving the satellite phones from locations where the phones were protected from beyond design basis external events to locations where the phones were not protected was contrary to NEI 12-01, Revision 0, Section 4.5. The ERP shack is not rated for tornado wind loading and therefore the phones relocated from the control room may not survive this external event. Additionally, the antennas may not survive high wind speeds.
Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the facilities and equipment attribute of the Emergency Preparedness Cornerstone and its objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, by moving the satellite phones to locations that are not rated for all beyond design basis external events, the licensee would not be able to contact any offsite organizations.
Significance: The team assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix O, Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation (Orders EA-12-049 and EA-12-051), dated October 7, 2016. The team determined that the performance deficiency did not
- (1) impact the spent fuel pool instrumentation order (EA-12-051);
- (2) did not involve a failure of FLEX equipment for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more that would result in a complete loss of one or more of the FLEX functions;
- (3) did not involve deficient procedures or training that would result in a complete loss of one or more of the FLEX functions;
- (4) did not have a product of the exposure time and external even initiating event frequency greater than 1E-6; and
- (5) did not involve significant programmatic issues which reduced the effectiveness of the Mitigating Strategies. Therefore, the finding was determined to be of very low safety significance (Green).
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated with change management, in that the licensee failed to fully evaluate implementing the enhancement to move the satellite phones from the control room and TSC to the ERP shack an the PBX room [H.3].
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 15, 2018, the inspection team presented the on-site inspection results in a management debrief to Mr. J. Kalamaja, General Manager of Plant Operations, and other members of the site staff.
- On April 16, 2018, the lead inspector presented the final inspection results in an exit meeting to Mr. J. Kalamaja, General Manager of Plant Operations, and other members of the site staff.
DOCUMENTS REVIEWED
Other Activities - TI 2515/191
Procedures/Instructions
Number Title Revision
0-CNS-OU-108 Shutdown Safety Management Program 4
0.50.5 Outage Shutdown Safety 37
2.4FPC Fuel Pool Cooling Trouble 34
5.1FLOOD Emergency Operations Procedure: Flood 22
7.0.11 Maintenance Procedure: Flood Control Barriers 30
14.41.1.1 FPC-LIT-1 Testing 4
EOF08 Position Instruction Manual: Logistics Coordinator 30
FSG 5.10FLEX FLEX Support Guidelines (FSGs) 2
FSG 5.10FLEX.01 125 VDC Div 1 FLEX Operations 1
FSG 5.10FLEX.02 125 VDC Div 2 FLEX Operations 1
FSG 5.10FLEX.03 250 VDC Div 1 FLEX Operations 1
FSG 5.10FLEX.04 250 VDC Div 2 FLEX Operations 1
FSG 5.10FLEX.05 Reliable Hardened Containment Vent Battery 1
Charger Tie-in
FSG 5.10FLEX.06 Fuel Pool Level Instrument Electrical Tie-In 1
FSG 5.10FLEX.07 4160 F Bus Tie-in with Off-Site Generator 2
FSG 5.10FLEX.08 4160 G Bus Tie-in with Off-Site Generator 2
FSG 5.10FLEX.09 Hotwell to ECST FLEX Operations 1
FSG 5.10FLEX.10 ECST Makeup from North Well 2
FSG 5.10FLEX.11 Spent Fuel Pool Supply FLEX Operations 2
FSG 5.10FLEX.12 Reactor Building Reliable Air FLEX Operations 1
FSG 5.10FLEX.13 REC SW FLEX Supply 1
FSG 5.10FLEX.14 RHR Div 1 Shutdown Cooling FLEX Operations 1
FSG 5.10FLEX.15 RHR Div 2 Shutdown Cooling FLEX Operations 1
FSG 5.10FLEX.16 Residual Heat Removal Service Water (RHRSW) 2
Div 1 FLEX Operations
FSG 5.10FLEX.17 Residual Heat Removal Service Water (RHRSW) 2
Div 2 FLEX Operations
FSG 5.10FLEX.18 Alternate Reactor Building Ventilation FLEX 1
Operations
FSG 5.10FLEX.19 Alternate Ventilation FLEX Operations 1
FSG 5.10FLEX.20 Debris Removal in Support of FLEX Operations 1
FSG 5.10FLEX.21 Shutdown Injection FLEX Operations 1
FSG 5.10FLEX.22 Communications and Lighting Equipment FLEX 1
Power
FSG 5.10FLEX.23 Reactor Equipment Cooling FLEX Operations 1
FSG 5.10FLEX.24 Control Building Temporary Heating FLEX 1
Operations
FSG 5.10FLEX.25 Alternate RPV Injection thru RHR SW Riser or RHR- 1
B B.5.B Connection
FSG 5.10FLEX.26 RHR Suppression Pool Cooling Div 1 FLEX 1
Operations
FSG 5.10FLEX.27 RHR Suppression Pool Cooling Div 2 FLEX 1
Operations
FSG 5.10FLEX.28 Vital Instrumentation FLEX Operations 1
FSG 5.10FLEX.29 Alternate Reactor Vessel Injection from Missouri 1
River
FSG 5.10FLEX.30 Hardened Containment Vent System FLEX 5
Operations
FSG 5.10FLEX.31 FLEX Equipment Refueling Operations 1
5.3SBO Station Blackout 43
5.7.17 CNS Dose Assessment 49
5.7.17.1 Dose Assessment (Manual) 3
6.FPC.701 FPC Level Transmitter Functional Test 0
OI 25 Operations Routine Duties 70
Security Access Control Devices 50
Procedure 2.8
Site Services Station Security 59
Procedure 1.1
FLEX Final Integrated Plan 1
FLEX Program Document 1
Preventative Maintenance Activities
Number Title Revision
5067082 SAMG Diesel Generator Testing 9/27/2016
5155721 Perform Vendor FLEX Maintenance Activities (1 year 5/23/2017
Operational Inspections)
5164463 Perform Vendor FLEX Equipment Maintenance (6 11/06/2017
month)
5194852 Spent Fuel Pool Primary LI Signal PCRS 12/29/2017
Drawings
Number Title Revision
453010422 Emergency Condensate Storage Tanks AB/02
R110827 Cooper Nuclear Strategy Topography Survey 8/23/2012
Other Documents/Reports
Number Title Revision
EC 6036621 Install Remote Satellite Units 0
EE 01-057 Class I Restrained Seismic Design Basis of Class IIS 0
Piping
EE 01-147 Summary of Main Steam Isolation Valve (MSIV) 2
Leakage Pathway to the Condenser Seismic
Qualification
ER 2016-002 FLEX Portable Equipment Deployment Path 0
Liquefaction Evaluation
Number Title Revision
INT0350113 FLEX Modifications 1
INT0350114 FLEX Strategy 1
INT0350116 FLEX Strategy Walkdown 0
Lesson Plan Level Measurement & Devices 8
IAC202-00-00
LO#2018-0092 2018 CNS TI-2515/191 Mitigating Strategies (SFP/EP)
Inspection Assessment
MEC 500-01-01 MEC OSC Emergency Response Overview 2
ML17226A032 Cooper Nuclear Station Safety Evaluation Regarding 9/20/2017
Implementation of Mitigating Strategies and Reliable
Spent Fuel Pool Instrumentation Related to Orders
EA-12-049 and EA-12-051 (CAC Nos. MF0971 and
MF0972)
MP FLEX Equipment Maintenance Plans for FLEX Air {Not Dated}
800000050260 Compressors; 175 kW, 60 kW, and 6 kW Diesel
Generators; and FLEX Godwin Pumps
NEDC 09-102 Internal Flooding - HELB, MELB, and Feedwater Line 2
Break
NEDC 14-001 Storage Facility Structural Calculation 1
NEDC 14-027 Review of ERIN Calculation C122140001-11622, 0
MAAP Analysis to Support Cooper FLEX Strategy
NEI 12-01 Guideline for Assessing Beyond Design Basis 0
Accident Response Staffing and Communications
Capabilities
NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) 2
Implementation Guidelines
NLS2013028 Response to NRC Technical Issues for Resolution 2/21/13
Regarding Licensee Communication Submittals
Associated with Near-Term Task Force
Recommendation 9.3
NSRC-005 SAFER Response Plan for Cooper Nuclear Station 9/15/2015
PM Notification Maintenance Plan 800000050260 Revision 10/25/2017
11417703
Purchase Order Preventive Maintenance Program 3/06/17
4500200470
Technical Beyond Design Basis Components 11/06/16
Requirements
Manual Section
3.12
Cooper Nuclear Station NEI 12-01 Phase 2 Staffing 4/21/2016
Assessment
FLEX Validation Document
NANTeL Generic Basic FLEX, ERO0010102/ILT-
251/NAN-56252
NANTeL Generic Advanced FLEX, ERO0010103/ILT-
253/NAN-56254
Corrective Action Program Documents (CR-CNS-)
2016-02845 2016-02869 2017-01463 2017-02565
2017-02568 2017-02799 2017-02801 2017-03089
2017-03777 2017-05033 2017-05285 2017-06372
2018-01166 2018-01243 2018-01442* 2018-01443*
2018-01450* 2018-01451* 2018-01457* 2018-01458*
2018-01463* 2018-01469* 2018-01475* 2018-01494*
2018-01496* 2018-01499* 2018-01500* 2018-01509*
2018-01511* 2018-02294*
- - Initiated as a result of this inspection
SUNSI Review Non-Sensitive Publicly Available Keyword:
By: MHS2/rdr Sensitive Non-Publicly Available NRC-002
OFFICE RI:DRP/C/CNS SPE:DRP/A SRI:DRS/EB2 RIII:DRP/PE BC:DRP/C
NAME MStafford RAlexander JMateychick SSheldon JKozal
SIGNATURE /RA-E/ /RA/ /RA/ /RA-E/ /RA/
DATE 4/19/18 4/19/18 4/20/18 4/19/18 5/8/18
May 8, 2018
Mr. John Dent, Jr.
Vice President-Nuclear and CNO
Nebraska Public Power District
Cooper Nuclear Station
2676 648A Avenue
P.O. Box 98
Brownville, NE 68321
SUBJECT: COOPER NUCLEAR STATION - INSPECTION OF THE IMPLEMENTATION OF
MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION
ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/
STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION
REPORT 05000298/2018010
Dear Mr. Dent:
On March 15, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite
portion of this inspection at your Cooper Nuclear Station. On April 16, 2018, the NRC
inspectors discussed the results of this inspection with Mr.
- J. Kalamaja, General Manager of
Plant Operations, and other members of your staff. The results of this inspection are
documented in the enclosed report.
The inspection examined activities conducted under your license as they relate to the
implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049
and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose
Assessment Plans, your compliance with the Commissions rules and regulations, and with the
conditions of your operating license. Within these areas, the inspection involved examination of
selected procedures and records, observation of activities, and interviews with station
personnel.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
The finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement in this report, you should provide a response within 30 days of the date
of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator, Region IV; and the NRC resident inspector at the Cooper Nuclear
Station.
J. Dent Jr. 2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Jason
- W. Kozal, Chief
Project Branch C
Division of Reactor Projects
Docket: 50-298
License: DPR-46
Enclosure:
Inspection Report 05000298/2018010
w/Attachment:
Documents Reviewed
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000298
License Number: DPR-46
Report Number: 05000298/2018010
Enterprise Identifier: I-2018-010-0017
Licensee: Nebraska Public Power District
Facility: Cooper Nuclear Station
Location: Brownville, Nebraska
Inspection Dates: March 12, 2018 to April 16, 2018
Inspectors:
- M. Stafford, Resident Inspector - Cooper (Team Leader)
- R. Alexander, Sr. Project Engineer - Region IV
- J. Mateychick, Sr. Reactor Inspector - Region IV
- S. Sheldon, Project Engineer - Region III
Approved By: Jason Kozal
Chief, Project Branch C
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance
by conducting a Temporary Instruction 2515/191, Implementation of Mitigation Strategies and
Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/
Staffing/Multi-Unit Dose Assessment Plans at Cooper Nuclear Station in accordance with the
Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-
revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations
Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They
Will Remain Available Following All Beyond Design Basis External Events
Cornerstone Significance Cross-cutting Report
Aspect Section
Emergency Green H.3 - TI 2515/191
Preparedness FIN 05000298/2018010-01 Change
Closed Management
The NRC inspection team identified a Green finding related to the licensees failure to maintain
the station satellite phones in locations that would provide reasonable assurance the phones
would remain available following all beyond design basis external events.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool
Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose
Assessment Plans
Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses
with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
(Agencywide Documents Access and Management System (ADAMS) Accession No.
ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel
Pool Instrumentation (ADAMS No. ML12054A679) are in place and are being implemented by
the licensee. Additionally, the inspection verified implementation of staffing and
communications information provided in response to the March 12, 2012, request for
information letter (ADAMS No. ML12053A340) and multiunit dose assessment information
provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency
Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS No.
(1) Based on samples selected for review, the inspectors verified that the licensee
satisfactorily implemented appropriate elements of the Diverse and Flexible Coping
Strategies (FLEX) as described in the plant specific submittals [including the Final
Integrated Plan (ADAMS Accession No. ML17017A166)] and the associated safety
evaluation (ADAMS No. ML17226A032) and determined that the licensee is in
compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to
Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The
inspectors verified the licensee satisfactorily:
a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX
strategies for postulated external events;
b) integrated their FSGs into their existing plant procedures such that entry into and
departure from the FSGs were clear when using existing plant procedures;
c) protected FLEX equipment from site-specific hazards;
d) developed and implemented adequate testing and maintenance of FLEX equipment
to ensure their availability and capability;
e) trained their staff to assure personnel proficiency in the mitigation of
beyond-design basis events; and
f) developed the means to ensure the necessary off-site FLEX equipment would be
available from off-site locations.
(2) Based on samples selected for review, the inspectors verified that the licensee
satisfactorily implemented appropriate elements of the FLEX strategy as described in the
plant specific submittals [including the Final Integrated Plan (ADAMS Accession No.
ML17017A166)] and the associated safety evaluation (ADAMS No. ML17226A032) and
determined that the licensee is in compliance with NRC Order NRC Order EA-12-051,
Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.
The inspectors verified the licensee satisfactorily :
a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power
supplies to provide physical and electrical separation as described in the plant
specific submittals and safety evaluation;
b) installed the SFP instrumentation display in the location, environmental conditions
and accessibility as described in the plant specific submittals;
c) trained their staff to assure personnel proficiency with the maintenance, testing, and
use of the SFP instrumentation; and
d) developed and issued procedures for maintenance, testing and use of the reliable
SFP instrumentation.
(3) The inspectors reviewed information provided in the licensees multi-unit dose submittal
and in response to the NRCs March 12, 2012, request for information letter (ADAMS
No. ML12053A340), and verified that the licensee satisfactorily implemented
enhancements pertaining to Near-Term Task Force Recommendation 9.3 in response to
a large scale natural emergency event that results in an extended loss of all ac power to
all site units and impedes access to the site. The inspectors verified the following:
a) the licensee satisfactorily implemented required staffing changes to support an
extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS) scenario;
b) EP communications equipment and facilities are sufficient for dealing with an
ELAP/LUHS scenario; and
c) the licensee implemented multi-unit/-source dose assessment capabilities (including
releases from spent fuel pools) using the licensees site-specific dose assessment
software and approach.
The inspectors verified that non-compliances with requirements and standards identified during
the inspection were entered into the licensee's corrective action program as appropriate.
INSPECTION RESULTS
Failure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They
Will Remain Available Following All Beyond Design Basis External Events
Cornerstone Significance Cross-cutting Report
Aspect Section
Emergency Green H.3 - Change TI 2515/191
Preparedness FIN 05000298/2018010-01 Management
Closed
The NRC inspection team identified a Green finding related to the licensees failure to
maintain the station satellite phones in locations that would provide reasonable assurance the
phones would remain available following all beyond design basis external events.
Description: The Cooper Nuclear Station FLEX Program Document, Revision 1, Section
5.2.27, Support Functions - Communications, states, in part: NEI 12-01 provides required
emergency communications capabilities during an Extended Loss of AC Power
(ELAP)Satellite phones are credited for off-site communicationDocking stations and
remote antennas have been installed to allow use of the satellite phones from inside
buildings.
NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and
Communications Capabilities, Revision 0, Section 4.5, Equipment Location Requirements,
states: to be assumed operable, a piece of on-site communications equipment should be in a
location, and maintained in a manner, that maximizes survivability following a beyond design
basis external eventEquipment should be stored, or otherwise available, in locations that
can be readily accessed when neededThe above guidance applies to equipment at the
point of use as well as any supporting infrastructure components. Such components may
include portable power sources, and radio system repeaters and antennas.
Initially, when the licensee implemented their plans to resolve issues associated with
communications during a beyond design basis external event (BDBEE), they had handheld
satellite phones located in the control room and the technical support center (TSC), which
required the users to relocate outdoors to acquire a usable signal. These locations are rated
to withstand all BDBEE, and would therefore meet the requirements of NEI 12-01. However,
in an effort to enhance the communications methods, the licensee pursued plans to provide a
means for personnel to be able to communicate with satellite phones from inside buildings.
These enhancements involved providing external antennas, relocating the existing satellite
phones to docking stations in a structure attached to the elevated release point (ERP shack)
and in a communications room (PBX room), and routing wires to control room and TSC desk
phones. These enhancements are mentioned in general in a letter from the licensee to the
NRC, NLS2013028, dated 2/21/13, Response to NRC Technical Issues for Resolution
Regarding Licensee Communication Submittals Associated with Near-Term Task Force
Recommendation 9.3.
In moving the physical location of the satellite phones from the control room and TSC, the
licensee failed to ensure that the new locations were suitable to withstand all BDBEE. The
ERP shack is not rated for tornado wind loading, and the phones relocated from the control
room may not survive this external event. Additionally, the external antennas located on the
elevated release point and the meteorological tower would not be able to withstand the
elevated wind speeds during a tornado or other high wind event.
The team determined that, by implementing this enhancement to communications systems,
the licensee placed their satellite phone equipment in locations that are vulnerable to BDBEE.
This does not meet the requirements of NEI 12-01 and therefore does not meet the
requirements of the FLEX Program Document.
Corrective Action(s): In response to the teams questions, the licensee documented the
concerns in the corrective action program. Additionally, the licensee is in the process of
procuring three additional satellite phones to stage in the control room, thereby restoring
compliance with NEI 12-01.
Corrective Action Reference(s): CR-CNS-2018-01499
Performance Assessment:
Performance Deficiency: That the station failed to maintain the satellite phones in locations
that provide reasonable assurance the phones will remain available following all beyond
design basis external events is a performance deficiency. Specifically, by moving the satellite
phones from locations where the phones were protected from beyond design basis external
events to locations where the phones were not protected was contrary to NEI 12-01,
Revision 0, Section 4.5. The ERP shack is not rated for tornado wind loading and therefore
the phones relocated from the control room may not survive this external event. Additionally,
the antennas may not survive high wind speeds.
Screening: The inspectors determined the performance deficiency was more than minor
because it adversely affected the facilities and equipment attribute of the Emergency
Preparedness Cornerstone and its objective to ensure that the licensee is capable of
implementing adequate measures to protect the health and safety of the public in the event of
a radiological emergency. Specifically, by moving the satellite phones to locations that are
not rated for all beyond design basis external events, the licensee would not be able to
contact any offsite organizations.
Significance: The team assessed the significance of the finding using Inspection Manual
Chapter (IMC) 0609, Appendix O, Significance Determination Process for Mitigating
Strategies and Spent Fuel Pool Instrumentation (Orders EA-12-049 and EA-12-051), dated
October 7, 2016. The team determined that the performance deficiency did not (1) impact the
spent fuel pool instrumentation order (EA-12-051); (2) did not involve a failure of FLEX
equipment for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more that would result in a complete loss of one or more of the
FLEX functions; (3) did not involve deficient procedures or training that would result in a
complete loss of one or more of the FLEX functions; (4) did not have a product of the
exposure time and external even initiating event frequency greater than 1E-6; and (5) did not
involve significant programmatic issues which reduced the effectiveness of the Mitigating
Strategies. Therefore, the finding was determined to be of very low safety significance
(Green).
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated
with change management, in that the licensee failed to fully evaluate implementing the
enhancement to move the satellite phones from the control room and TSC to the ERP shack
an the PBX room [H.3].
Enforcement: Inspectors did not identify a violation of regulatory requirements associated
with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 15, 2018, the inspection team presented the on-site inspection results in a
management debrief to Mr.
- J. Kalamaja, General Manager of Plant Operations, and other
members of the site staff.
- On April 16, 2018, the lead inspector presented the final inspection results in an exit meeting
to Mr.
- J. Kalamaja, General Manager of Plant Operations, and other members of the site
staff.
DOCUMENTS REVIEWED
Other Activities - TI 2515/191
Procedures/Instructions
Number Title Revision
0-CNS-OU-108 Shutdown Safety Management Program 4
0.50.5 Outage Shutdown Safety 37
2.4FPC Fuel Pool Cooling Trouble 34
5.1FLOOD Emergency Operations Procedure: Flood 22
7.0.11 Maintenance Procedure: Flood Control Barriers 30
14.41.1.1 FPC-LIT-1 Testing 4
EOF08 Position Instruction Manual: Logistics Coordinator 30
FSG 5.10FLEX FLEX Support Guidelines (FSGs) 2
FSG 5.10FLEX.01 125 VDC Div 1 FLEX Operations 1
FSG 5.10FLEX.02 125 VDC Div 2 FLEX Operations 1
FSG 5.10FLEX.03 250 VDC Div 1 FLEX Operations 1
FSG 5.10FLEX.04 250 VDC Div 2 FLEX Operations 1
FSG 5.10FLEX.05 Reliable Hardened Containment Vent Battery 1
Charger Tie-in
FSG 5.10FLEX.06 Fuel Pool Level Instrument Electrical Tie-In 1
FSG 5.10FLEX.07 4160 F Bus Tie-in with Off-Site Generator 2
FSG 5.10FLEX.08 4160 G Bus Tie-in with Off-Site Generator 2
FSG 5.10FLEX.09 Hotwell to ECST FLEX Operations 1
FSG 5.10FLEX.10 ECST Makeup from North Well 2
FSG 5.10FLEX.11 Spent Fuel Pool Supply FLEX Operations 2
FSG 5.10FLEX.12 Reactor Building Reliable Air FLEX Operations 1
FSG 5.10FLEX.13 REC SW FLEX Supply 1
FSG 5.10FLEX.14 RHR Div 1 Shutdown Cooling FLEX Operations 1
FSG 5.10FLEX.15 RHR Div 2 Shutdown Cooling FLEX Operations 1
FSG 5.10FLEX.16 Residual Heat Removal Service Water (RHRSW) 2
Div 1 FLEX Operations
FSG 5.10FLEX.17 Residual Heat Removal Service Water (RHRSW) 2
Div 2 FLEX Operations
FSG 5.10FLEX.18 Alternate Reactor Building Ventilation FLEX 1
Operations
FSG 5.10FLEX.19 Alternate Ventilation FLEX Operations 1
FSG 5.10FLEX.20 Debris Removal in Support of FLEX Operations 1
FSG 5.10FLEX.21 Shutdown Injection FLEX Operations 1
FSG 5.10FLEX.22 Communications and Lighting Equipment FLEX 1
Power
FSG 5.10FLEX.23 Reactor Equipment Cooling FLEX Operations 1
FSG 5.10FLEX.24 Control Building Temporary Heating FLEX 1
Operations
FSG 5.10FLEX.25 Alternate RPV Injection thru RHR SW Riser or RHR- 1
B B.5.B Connection
FSG 5.10FLEX.26 RHR Suppression Pool Cooling Div 1 FLEX 1
Operations
FSG 5.10FLEX.27 RHR Suppression Pool Cooling Div 2 FLEX 1
Operations
FSG 5.10FLEX.28 Vital Instrumentation FLEX Operations 1
FSG 5.10FLEX.29 Alternate Reactor Vessel Injection from Missouri 1
River
FSG 5.10FLEX.30 Hardened Containment Vent System FLEX 5
Operations
FSG 5.10FLEX.31 FLEX Equipment Refueling Operations 1
5.3SBO Station Blackout 43
5.7.17 CNS Dose Assessment 49
5.7.17.1 Dose Assessment (Manual) 3
6.FPC.701 FPC Level Transmitter Functional Test 0
OI 25 Operations Routine Duties 70
Security Access Control Devices 50
Procedure 2.8
Site Services Station Security 59
Procedure 1.1
FLEX Final Integrated Plan 1
FLEX Program Document 1
Preventative Maintenance Activities
Number Title Revision
5067082 SAMG Diesel Generator Testing 9/27/2016
5155721 Perform Vendor FLEX Maintenance Activities (1 year 5/23/2017
Operational Inspections)
5164463 Perform Vendor FLEX Equipment Maintenance (6 11/06/2017
month)
5194852 Spent Fuel Pool Primary LI Signal PCRS 12/29/2017
Drawings
Number Title Revision
453010422 Emergency Condensate Storage Tanks AB/02
R110827 Cooper Nuclear Strategy Topography Survey 8/23/2012
Other Documents/Reports
Number Title Revision
EC 6036621 Install Remote Satellite Units 0
EE 01-057 Class I Restrained Seismic Design Basis of Class IIS 0
Piping
EE 01-147 Summary of Main Steam Isolation Valve (MSIV) 2
Leakage Pathway to the Condenser Seismic
Qualification
ER 2016-002 FLEX Portable Equipment Deployment Path 0
Liquefaction Evaluation
Number Title Revision
INT0350113 FLEX Modifications 1
INT0350114 FLEX Strategy 1
INT0350116 FLEX Strategy Walkdown 0
Lesson Plan Level Measurement & Devices 8
IAC202-00-00
LO#2018-0092 2018 CNS TI-2515/191 Mitigating Strategies (SFP/EP)
Inspection Assessment
MEC 500-01-01 MEC OSC Emergency Response Overview 2
ML17226A032 Cooper Nuclear Station Safety Evaluation Regarding 9/20/2017
Implementation of Mitigating Strategies and Reliable
Spent Fuel Pool Instrumentation Related to Orders
EA-12-049 and EA-12-051 (CAC Nos. MF0971 and
MF0972)
MP FLEX Equipment Maintenance Plans for FLEX Air {Not Dated}
800000050260 Compressors; 175 kW, 60 kW, and 6 kW Diesel
Generators; and FLEX Godwin Pumps
NEDC 09-102 Internal Flooding - HELB, MELB, and Feedwater Line 2
Break
NEDC 14-001 Storage Facility Structural Calculation 1
NEDC 14-027 Review of ERIN Calculation C122140001-11622, 0
MAAP Analysis to Support Cooper FLEX Strategy
NEI 12-01 Guideline for Assessing Beyond Design Basis 0
Accident Response Staffing and Communications
Capabilities
NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) 2
Implementation Guidelines
NLS2013028 Response to NRC Technical Issues for Resolution 2/21/13
Regarding Licensee Communication Submittals
Associated with Near-Term Task Force
Recommendation 9.3
NSRC-005 SAFER Response Plan for Cooper Nuclear Station 9/15/2015
PM Notification Maintenance Plan 800000050260 Revision 10/25/2017
11417703
Purchase Order Preventive Maintenance Program 3/06/17
4500200470
Technical Beyond Design Basis Components 11/06/16
Requirements
Manual Section
3.12
Cooper Nuclear Station NEI 12-01 Phase 2 Staffing 4/21/2016
Assessment
FLEX Validation Document
NANTeL Generic Basic FLEX, ERO0010102/ILT-
251/NAN-56252
NANTeL Generic Advanced FLEX, ERO0010103/ILT-
253/NAN-56254
Corrective Action Program Documents (CR-CNS-)
2016-02845 2016-02869 2017-01463 2017-02565
2017-02568 2017-02799 2017-02801 2017-03089
2017-03777 2017-05033 2017-05285 2017-06372
2018-01166 2018-01243 2018-01442* 2018-01443*
2018-01450* 2018-01451* 2018-01457* 2018-01458*
2018-01463* 2018-01469* 2018-01475* 2018-01494*
2018-01496* 2018-01499* 2018-01500* 2018-01509*
2018-01511* 2018-02294*
- - Initiated as a result of this inspection
SUNSI Review Non-Sensitive Publicly Available Keyword:
By: MHS2/rdr Sensitive Non-Publicly Available NRC-002
OFFICE RI:DRP/C/CNS SPE:DRP/A SRI:DRS/EB2 RIII:DRP/PE BC:DRP/C
NAME MStafford RAlexander JMateychick SSheldon JKozal
SIGNATURE /RA-E/ /RA/ /RA/ /RA-E/ /RA/
DATE 4/19/18 4/19/18 4/20/18 4/19/18 5/8/18