IR 05000298/1985031
| ML20205N432 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/18/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8605020131 | |
| Download: ML20205N432 (1) | |
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APR 181986
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In Reply Refer To:
Docket: 50-298/85-31 Nebraska Public Power District ATTN:
J. M. Pilant, Manager, Technical Staff-Nuclear Power Group P. O. Box 499 Columbus, Nebraska 68601 Gentlemen:
Thank you for your letter of March 14, 1986, in response to our letter dated February 18, 1986, and Notice of Violation dated February 13, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
In your response, we note that you characterize that the snubbers were potential problems and that you state, "... in no case was a snubber clearly verified to be incapable of perfanning its intended function." We agree that the problems noted were generally potential in nature; however, we disagree with the characterization that all snubbers were potential problems only. For example, snubber S/N 10060 was found to be loose and laying on adjacent piping. This is documented in your non-conformance report NCR 4999. Since your statements do not invalidate your corrective action commitments, we accept these comitments as stated above.
"E8E0.b*faned Gy 11. E. Gagliardo J. E. Gagliardo, Chief Reactor Projects Branch cc:
Guy Horn, Division Manager of Nuclear Operations Cooper Nuclear Station P. O. Box 98 Brownville, Nebraska 68321 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bec distrib. by RIV:
RPB DRSP Resident Inspector R. D. Martin, RA Section Chief, RPB/A q
D. Weiss, LFMB (AR-2015)
RIV File RSTS Operator W. M. McNeill, RPB/A i
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GENERAL OFFICE Nebraska Public Power District
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March 14,1986
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MAR 2 01985 u/~
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Mr. James M. Taylor, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C.
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Subject: Notice of Violation and Proposed Imposition of Civil Penalty NRC Inspection Report No. 298/85-31
Dear Mr. Taylor:
This letter is written in response to the NRC letter dated February 13, 1986 transmitting Notice of Violation and Proposed imposition of Civil Penalty as a result of Inspection Report No. 50-298/85-31.
Therein it indicated that four of our activities were in violation of NRC requirements and that two of these violations were being assessed a civil penalty.
Attached are statements of the violations and our responses in accordance with the referenced letter and 10CFR2.201.
Attachment I addresses the violations assessed a $50,000 civil penalty and Attachment 2 addresses the remaining violations.
We have carefully reviewed the February 13, 1986, letter and have concluded that additional clarification is warranted regarding the violations assessed a civil penalty; however, mitigation will not be requested pursuant to 10CFR2.205 and payment of the civil penalty is enclosed, if you have any questions regarding this response, please contact me.
Sincerely, V
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L. G. Kunci Vice-President i
Nuclear Power Group JMP/RB/JMM/DMN/lb:lk14/G(9B)
cc:
egional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 7G011
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Mr. J:m:s M. Tcyler
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P:gs 2
March 14,198G STATE OF NEBRASKA)
)ss PLATTE COUNTY
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L. G. Kuncl, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this information on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge end belief.
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f oi.e L. Gt Kunc1 Subscribed in my presence a: d sworn to before me this /d day of
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7hd7
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NOTARY PUIfLIC mam sunaansasm COLLEWI18.KUTA Br Ouut BIL Aug & W j l
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Attechment 1
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10CFR2.201 Response to Violations Evaluated as Severity Level III Civil Penalty - $50,000 - Assessed Equally Between Violations I. Violations Assessed A Civil Penalty A.
Technical Specification 3.7.C.1 requires that secondary containment integrity be maintained when irradiated fuel is handled inside the reactor building.
Technical Specification 3.7.B.1 requires that both standby gas treatment systems (SGTS) be operable at all times when secondary containment is required.
integrity is defined in the Cooper Technical Specification paragraph 1.V, in part, as att automatic ventitation system isolation valves
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operable or secured in the isolated position.
Technicat Specification 3.7.B.3 attous one SGTS to be inoperable for up to seven days only if the other SGTS is operable.
Technical
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Specification Section 6.3 requires that detailed written procedures be used to conduct surveillance activities.
Surveillance Procedure
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f.3.7.5, paragraph VIII. A.14 requires that electrical jumpers be
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nmoved at the completion of testing.
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l Contrary to the above, on November 14, 1986, secondary containment integrity was not maintained as required uhen irradiated fuel was
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moved in the reactor building in that the automatic start capability (
of both trains of the SGTS was inoperable and the automatic isolation feature of the reactor building ventitation system uas l
The violation occurred because electrical jumpers used
during surveillance testing vere not removed after testing was completed.
Admission or Denial of the Alleged Violation
l Admission, with the following clarification.
Surveillance
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procedures require that electrical jumpers be removed at the completion of testing.
Contrary to this, on November 13, 1985, i
electrical jumpers were not removed as required and remained installed for five days.
These electrical jumpers, which were a
installed on the auxiliary trip units 'of the reactor building ventilation radiation monitors, would have prohibited automatic reactor building isolation and standby gas treatment initiation upon a reactor building ventilation monitor high radiation signal.
Admittedly, this condition constitutes a violation of'CNS Technical Specificacions; however, it should be recognized that
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instrumentation and control room annunciators which would identify a j
reactor building high radiation condition remained operable during
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the period the electrical jumpers were installed.
In addition, the SBGT system during this time period was operable as were all automatic ventilation system isolation valves. The SBGT system was inhibited from an automatic start only from the reactor building ventilation monitor high radiation initiation signal.
All other SBGT system initiation signals were functional, as well as the manual start capability. The automatic ventilation isolation valves a
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building ventilation monitor high radiation signal.
All other sutomatic ventilation isolation valve closure initiation signals were functional, as well as the manual ventilation isolation valve closure.
While the CNS Technical Specifications were violated during the period the electrical jumpers were installed, both trains
voald have met the requirements of these sections if manually initiated.
Reason for the Violation The violation is primarily attributable to personnel error by the i
I&C Technician involved.
The technician signed Surveillance Procedure 6.3.7.5, Rev. 7. Step VIII.A.14 prior to completion of the
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action required by the step. Then as a result of a distraction, he failed to remove the installed electrical jumpers.
The violation is also attributable to procedural deficiency.
Specifically, steps in Surveillance Procedure 6.3.7.5 which require the installation and removal of the electrical jumpers were unclear.
In addition, the procedure lacked a requiretaent for independent verification that. the electrical jumpers were removed. This would j
have ensured that the reactor buil, ding ventilation radiation monitors were returned back to an operable status following testing.
Corrective Steps Which Have Been Taken and the Results Achieved
J The involved I&C Technician was immediately removed from surveillance testing and maintenance on plant critical systems.
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addition, all temporary modifications (electrical jumpering, fuse removal, etc.) conducted by the technician between October 5, 1985,
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(the date when CNS shut down for a turbine vibration problem) and the date of the event were verified to be correctly implemented and
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The I&C Technician was counseled by the Operations Manager and the I&C Supervisor.
Further disciplinary action
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l involved suspension without pay for a period of two days and his demotion to the next lower position.
Surveillance Procedure 6.3.7.5,
" Reactor Building Ventilation
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Radiation Monitor Calibration And Functional / Functional Test", was i
reviewed and revised. The revision included:
(a) clarification of the procedural steps requiring installation and removal of electrical jumpers, and (b) independent verification of electrical
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jumper removal.
A review of all CNS surveillance procedures has been completed in order to identify procedures requiring independent verification steps. Approximately 70 procedures were identified and
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70% of these have been revised to date.
The I&C Department personnel have been counseled by the Operations Manager and the I&C Supervisor about the importance of completing all the action required by a procedural step prior to signing the step as completed.
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Corrective Steps Wich Will Be Taken to Avoid Furth. Violation The remaining procedures identified in the afo: emertioned. review will be revised in order to provide independent verification steps.
j These enhancements to the surveillance testing program should preclude further violations in this regard.
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Date W en Full Compliance Will Be Achieved
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Full compliance was achieved on November 18, 1985, when the
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installed jumpers sere found and subsequently removed. The on-going revision of proceoures to minimize the potential for future problema j
of this type will be completed by May 31, 1986.
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Technical Specification Section 6.3 requires thr.c detailed written procedures be used to conduct surveillance acts'oities. Surveillance
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i Procedure 4.6.H.2 requires that inspection sFait verify that there
are no visible indications of damage or impaired operability for
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.:ated snubbers.
Technical Specifintion 3.6.H requires that during att modes of operation except for cold shutdown or
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refueling, att safety-related snubbers be og erable.
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Contrary to the above, surveittance inspections perfomed during i
July 198S by the licensee did not identify tuo dryvell snubbers that
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had visible indications of impaired operability.
As a result, from l
August 20 to October S, 1985, Cooper Nuclear Station was in operational modes other than cold shutdown or refueling with these i
snubbers inoperable. Also from August 20 to October S, 1985, about 23 additional safety-related snubbers were inoperable white the facility was in operational modes other than cold shutdown or
refueling.
t Admission or Denial of the Alleged Violation
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Admission, with the following clarification.
As written, the violation indicates that CNS operated for a period of time with L
inoperable snubbers-installed. However, as can be determined from j
the detailed description contained in Appendix A to NRC Inspection-
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Report 50-298/85-31, all of the snubber problems noted by the NRC Inspector, as well as those found by CNS inspectors. were
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" potential" problems which may have rendered the affected snubbers I
In each case, the problems noted 'had to do with
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attachments of questionable adequacy and potential interferences.
l Wile a rigorous engineering analysis would likely have shown that
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many of the snubbers were capable of acceptable performance, the District chose to take a most conservative course of action.
Each snubber was conservatively considered to be inoperable and its i
apparent problem corrected: h wever, it is important to note that in
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no case was a snubber clearly verified to be incapable of performing
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its intended function. Upon careful examination of the snubbers, it
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is the District's engineering judgement that had a seismic event i
occurred, each snubber would, in all probability, have performed l
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adequately.
On the other hand, our review of this matter will lead
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to the elimination of some weaknesses in the CNS Snubber Inspection
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Reason for the Violation
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This violation is the result of two general problems with the CNS
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Snubber Inspection Program. These are discussed in detail below:
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Inadequate Procedural Guidance i
A review of the history of the Snubber Inspection Program revealed that, in the past, the CNS Engineering Department had
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conducted the required in situ inspections, with a contractor providing operability tests on removed snubbers. The involved i
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CNS personnel were trained on the details of the in situ
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inspections and a general procedure was provided to document i
the inspection results.
Potential interferences and questionable snubber attachments were resolved by the CNS Snubber Engineer based on engineering judgement as thay were identified by the inspectors. Due to the location of several
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of the snubbers (inside the Drywell) and the number of
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qualified Engineering personnel who could perform the
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inspections, individual personnel radiation exposure became a l
problem.
Therefore, the in situ inspection portion of the i
i Snubber Inspection Program was transferred to the CNS j
Maintenance Department. However, the aforementioned procedure j
was not revised in sufficient detail to enable these personnel
to adequately conduct the inspections.
Consequently, those
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inspections failed to identify questionable snubber attachments j
and potential interferences and, therefore, these apparent j
problems were not resolved.
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Insufficient Trainina of Snubber Inspector's
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As described in Item 1. above, the in situ snubber inspections i
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were transferred to the CNS Maintenance Department to lower
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individual radiation exposures. The resulting increase in the
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i number of personnel involved in the snubber inspection program
required extensive training in order to properly conduct the
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i snubber inspections.
The referenced training provided these l
individuals was insufficient. This, coupled with the deficient
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l procedure, led to the failure to identify questionable snubber j
attachments and potential interference problems.
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t Corrective Steps Which Have Been Taken and the Results Achieved i
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Prior to plant startup from tha October-November 1985 Outage, all
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snubbers that were apparercly inoperable were identified and ' the i
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problems were corrected.
This immediate corrective measure was i
accomplished by engineerits personnel experienced in the specific l
types of problems which itere being encountered.
The Architect i
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Engineer, Burns and Roe, was consulta.d to verify a clear j
understanding o" the inspection requirements. The inspection of all safety related snubbers was then conducted and all votential operability problems corrected.
Corrective Steps Which Will Be Taken to Avoid Further Violation The following longer range steps are being taken to avoid further violations:
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CNS Maintenance Procedure 7.2.34, " Snubber Inspection", 7.2.52,
" Snubber Removal And Installati,n", and related Inservice Inspection procedures are being revised to include specific inspection criteria.
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A comprehensive training program which will include lesson plans, training aids, and visual inspection qualification is being developed.
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A program is being developed to assure that designated inspectors will be trained and qualified prior to conducting any related inspections.
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A program is being developed to assure that supporting drawings will be reviewed and updated as necessary to better define the criteria for each snubber, including the snubber, attachments, and potential interfarences.
Date When Full Compliance Will Be Achieved r
Full compliance was achieved prior to plant startup from the
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October-November, 1985, outage.
The longer range steps described above are intended to minimize the possibility of recurrence of the
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type of problem and potential noncompliance, Will be completed by October 1, 1986, the date of the next scheduled Refueling Outage.
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Attcchment 2
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10CFR2.201 Response to Violations Not Assessed A Civil Penalty
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Violations Not Assessed A Civil Penalty A.
Technical Specification, Section 6.3 requires that there be procedures smplemented for fire protection.
Cooper Nuclear Station Administrative Procedures, "CNS Five Protection Plan," A.P.-0. 23, Revision 0, dated August 8, 1986, (paragwph V. A. 2.a.b) states, " good housekeeping practices are l
essential for fire safety.
rage, paper, and other foreign
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materiate must not be attooed to accumulate.... "
Contrary to the above, poor housekeeping practices and the accumulation of materials adverse to fire safety were found on November 20-21, 198S, in certain areas of the reactor building as
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evidenced by the folioving examples:
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Several targe boxes of refuse and other trash vere found in the
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j doorways and access areas of the RHR heat exchanger "B" room and the RPCI room (in the acuthuest quad).
This material vould i
have limited access of personnet and fire equipment.
Admission or Denial of the Alleged Violation Admission.
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Reason for the Violation I
The material involved in the violation consisted of expended and
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used protective clo thir.g.
The method used to ecliect this
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protective clothing is to deposit it in containers located near the
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exit to step-off pads of contaminated areas.
In some instances, these containers are located near doorways to contaminated areas and have the potential to limit access if initial placement is not
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performed with care or through inadvertent management thereafter.
Corrective Steps Which Have Been Taken and the Results Achieved i
i A survey was made and similar potential problems were corrected.
i Also, the personnel involved in maintaining these areas have been
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instructed to periodically monitor the location of containers and to remove or relocate those containers which could impede personnel and equipment access to these areas.
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Corrective Steps Which Will Be Taken to Avoid Further Violation l
An extensive housekeeping effort has been underway since plant
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startup from the previous extended outage to replace the IGSCC
related piping.
A11' excess material has been removed and properly stored or disposed of.
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Date When Full Compliance Will Be Achieved We achieved full compliance after the corrective actions described above were completed.
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A fire hose in the southwest quad at 882' elevation was covered with personnel clothing.
Admission or Denial of the Alleged Violation Admission.
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Reason for the Violation A CNS employee had disrobed to put on protective clothing to work in a nearby contaminated area and had inadvertently placed his personal clothing on the referenced hose station.
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Corrective Steps Which Have Been Taken and the Results Achieved The referenced clothing was immediately removed and all similar areas checked for compliance.
The individuals who were working in this area of the plant have been instructed not to place personal clothing on plant equipment that could reduce plant effectiveness.
Corrective Steps Which Will Be Taken to Avoid Further Violation This topic will be reemphasized with station personnel at the next Safety Meeting.
This will ensure that personnel are aware of the requirements and the importance of comp 1ving with the Fire Protection Plan.
I Date When Full Compliance Will Be Achieved
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Full compliance was achieved on November 21, 1985.
The planned discussions with station personnel will be completed by May 1, 1986.
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The electric motor associated with radiation vaste effTuent monitor (TB-486) at elevation 903' on the south wall of the reactor building was found to have a plastic pail on the top of
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Admission or Denial of the Alleged Violation Admission.
Reason for the Violation
Since cleanup and decontamination efforts had been underway near the
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vicinity of the motor, it is postulated that a worker inadvertently left the bucket stop the motor.
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Corrective Steps Which Have Been Taken and the Results Achieved i
The pail was removed.
A survey was made through the plant and
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similar problems were corrected.
Cleanup and decoatsmination crews were reminded that CNS standard practice requires them to remove
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cleaning gear from areas when assigned tasks have been completed.
To reduce further the potential.for the inadvertent placement of
cleaning gear on plant equipment, all cleaning gear is now required
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to be returned to the tool crib and is checked out to perform
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specific tasks.
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j Corrective Steps Which Will Be Taken to Avoid Further Violation l-First line supervisors, by procedure, will now monitor work areas to ensure good housekeeping is being maintained.
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Date When Full Compliance Will Be Achieved I
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We achieved full compliance on November 21, 1985.
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In the 4160 voit switch' gear room a number of aerosol cans of
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switch gear equipment with electric heaters.
Admission or Denial of the Alleged Violation i
Admission.
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1 Reason for the Violation j
The aerosol cans noted in the violation are used during maintenance i
activities and had been inadvertently lef t near the switch gear
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equipment.
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Corrective Steps Which Have Been Taken and the Results Achieved i
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d Cabinets designed for the storage of flammable materials have been
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purchased and placed in areas where flammables are utilized for
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maintenance activities.
Flammables are now being stored in these i
cabinets when not in use.
i Corrective Steps Which Will Be Taken to Avoid Further Violation
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j Appropriate personnel have been instructed to utilize the newly
installed safety cabinets and to comply with written procedures for p
the control of flammable liquids.
Work areas are to be monitored t
for compliance by Maintenance supervision.
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t We achieved full compliance upon removal of the aerosol cans
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Failure To Properly Log And Sign Off Surveillance Discrepancies
Technical Specifications, Section 6.3 requires that detailed uritten procedures be used to conduct surveitiance test activities.
The Cooper Nuclear Station Surveillance Procedures, " Fire Protection
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System Monthly Inspection",
S.P.-6.4.5.1, Revision 38, dated November 7,1985, and " Fire Protection System Annual Inspection",
S.P.-6.4.6.2, Revicion 30, dated November 7,1985, both require in paragraph V.B.1 that "all discrepancies shall be recorded in the Shift Supervisor's tog".
In Attachment A of each procedure a checklist and report form provides space for the shift supervisor to sign off if a nonconformance report of work item is initiated.
Contrary to the above, discrepancies identifiad in the conduct of certain monthly and annual fire prevention inspections were not recorded in the Shift Supervisor's tog.
Additionally, the Shift Supervisor had not signed off on Attachment A to the subject procedures when corrective actions for nonconformance vork items were initiated as illustrated by the following examples:
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Annual inspections dated February 13 and May 15, 1985, and monthly inspections dated August 4 and September 28, 1985,
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identified discrepancies, yet they were not recorded in the shift supervisor's log.
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During monthly inspections dated August 4, September 2, September 28, and October 29, 1986, nonconformance work items were initiated but did not have the shift supervisor's (Attachment A) sign off on the subject procedures.
Admission or Denial of the Alleged Violation NPPD admits the alleged violation.
Reason for the Violation This violation resulted from a failure to follow CNS procedure.
Corrective Steps Which Have Been Taken and the Results Achieved The discrepancies resulting from the annual fire inspection dated February 13 and monthly inspections dated August 4 and September 29, 1985, hcve been recorded in the Shift Supervisor's log.
The discrepancies resulting from the annual fire inspection dated May
15, 1985 were previously recorded in the Shift Supervisor's los on
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May 17, 1985.
The scathly fire inspections dated August 4 September 2, September 28, and October 29, 1985, will be signed to indicate that work items were initiated.
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Corrective Steps Which Will Be Taken to Avoid Further Violation A letter will be sent to all Shift Supervisors and Control Room Supervisors stressing the need to record all discrepancies noted during the performance of surveillance procedures as required by the Administrative Limits section of surveillance procedures.
This letter will also state the need to complete the required sign-off in surveillance procedures if a work item or nonconformance report is initiated.
In addition, the Surveillance Coordinator will be
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instructed to verify the appropriate signatures have been received
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on completed surveillance procedures.
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Date When Full Compliance Will Be Achieved We are presently in full compliance and the actions described above will be completed by March 31, 1986, i
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