IR 05000298/1986026

Insp Rept 50-298/86-26 on 860901-30.Violations Noted:During Performance of Sys Operating Procedure 2.2.33,Valves HPCI-129 & HPCI-130 Found Open But Unsealed & HPCI-26 Found Open

ML20215M716
Person / Time
Site:	Cooper
Issue date:	10/24/1986
From:	Dubois D, Harrell P, Hunter D, Jaudon D, Plettner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215M712	List: IR 05000298/1986026 ML20215M711 ML20215M713
References
50-298-86-26, NUDOCS 8611030193
Download: ML20215M716 (12)

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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/86-26 License: DPR-46 Docket: 50-298

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Licensee: Nebraska Public Power Dittrict (NPPD)

P. O. Box 499 Columbus, NE 68601 Facility Name: Cooper Nuclear Station (CNS)

' Inspection At: Cooper Nuclear Station, Nemaha County, Nebraska Inspection Conducted: September 1-30, 1986 Inspectors: [. /c [/4 !8(a E. A. Plettner, Resident Inspector, (RI) _ Dati /

Chu-A wa V P. H. Harrell, Senior Resident Inspector

'o h+/s Date O lO//6/$6 D. L. DuBois, Senior Resident Inspector, (SRI) Date Approved: >> tjYL lo y J. P.( Jgddon, Chief, Project Section A, Date L Reactdr Project Branch Approved: 4 ') [0 [7<f!84 D. R. Ilunter, Chief, Project Section B, Date Reactor Projects Branch 8611030193 DR 861024 ADOCK 05000298 PDR

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Inspection Summary Inspection Conducted September 1-30, 1986 (Report 50-298/86-26)

Areas Inspected: Routine, unannounced inspection of Notification of Unusual Event, Licensee Event Reports, spent fuel shipment,. operational safety verification, monthly surveillance and maintenance activities, systematic assessment of' licensee performance, and annual emergency preparedness exercis Results: Within the areas inspected, two violations were identified (failure to follo'w procedure, paragraph 5; inadequate review of surveillance test results, paragraph 6).

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DETAILS Persons Contacted Principal Licensee Employees

• R. Horn, Division Manager of Nuclear Operations

• J. M. Mescham, Senior Manager of Technical Support Services

• H. Hitch, Plant Services Manager

• R. Brungardt, Operations Manager

• C. R. Goings, Regulatory Compliance Specialist

• P. Ballinger, Operations Engineering Supervisor

• M. Hamm, Security Supervisor

• G. E. Smith, Acting Quality Assurance Manager The NRC inspectors also interviewed other licensee employees during the course of the inspectio * Denotes those present during exit interview October 8, 1986.

' Notification of an Unusual Event On September 21, 1986, the 8:00 a.m. calculated 4-hour and 24-hour reactor coolant drywell unidentified leakage rates were 2.95 gpm and 2.5 gpm respectively. Both leak rate values had been observed to be increasing steadily over the past several days. At 8:52 a.m., following an automatic pump down of the drywell floor drain sump, the calculated leak rate was 5.66 gpm. The CNS Technical Specification section 3.6.C., " Coolant Leakage," requires that if reactor coolant drywell unidentified leakage I exceeds a 2 gpm increase within the previous 24-hour period and the source

! of leakage can not be identified, the plant will be placed in the Cold Shutdown Condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Also, the CNS Emergency Plan Implementing Procedure 5.7.1, " Emergency Classification," emergency action level (EAL) 4.1, requires the licensee to implement a Notification of I

Unusual Event (NOUE) if the limit of 5 gpm unidentified drywell leakage is exceeded. As a result, the licensee initiated a plant shutdown and a NOUE at 9:25 The drywell was subsequently deinerted and an initial drywell entry was made at 12:38 a.m. on September 22, 1986, while at a reactor power of 18 percent. That entry lead to the discovery of a packing gland leak from the reactor recirculation pump "A" discharge valve RR-M0V-53A. The packing gland was tightened and unidentified leakage was reduced to 1.43 gpm. The plant shutdown was terminated when the source of leakage was identified. The NOUE was terminated at 3:50 a.m. when the leak rate appeared to stabilize at the reduced valu The drywell was inerted and the oxygen level reduced to less than 4 percent by 12:35 p.m. The plant was subsequently returned to normal power operatio _ _ _ _ _ _ _ _

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The SRI observed the following licensee actions associated with the drywell unidentified leakage rate:

. Management meetings including the Station Operations Review Committee (50RC) meetin . Continual monitoring of the leak rat . Evaluation of leak detection system information; planning for, and the initiation of, drywell entry teams; implementation of repair activities; and the performance of surveillance testing required as a result of the pcwer reduction and repair activite . Drywell deinerting and reinerting operation . Implementation of the CNS Emergency plan, Technical Specification, and procedural requirement The SRI interviewed shift personnel and the CNS Emergency Planning Coordinator concerning that event. Also, he performed a review of the following licensee logs, procedures, and reports:

. Control Room logs for complete and timely entry of significant information pertaining to the even . 5.7.1, "CNS Emergency Plan Implementation," Revision 6, dated August 21, 1986

. 5.7.2, " Notification of Unusual Event," Revision 4, dated April 24, 1985

. 5.7.6, " Notification," Revision 7, dated April 17, 1986

. Chronology of events

. Licensee followup report to the NRC in a letter from Mr. G. Horn (NPPD) to Mr. R. Martin (NRC-RIV) dated September 22, 1986 (CNSS864329).

While performing the notifications of agencies delineated in Procedure 5.7.6, the licensee failed to contact the Missouri State Emergency Management Agency (SEMA) within 15 minutes as require The licensee identified this failure in Nonconformance Report (NCR)

Number 006121, dated September 21, 198 However, licensee personnel continued in their attempt to contact SEMA and eventually succeeded at 10:06 a.m. with assistance from the Missouri Army National Guard Headquarters. The licensee determined that the cause of failure to contact SEMA using the primary communications telephone number was the installation of a new PBX system that was in progress at SEMA headquarters during that weekend.

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! .The SRI reviewed licensee and affected states records concerning the ,

communications problems associated with the attempts to notify SEMA. The following are observations the NRC inspector called to the licensee's

- attention during the exit interview on October 8, 1986. These observations are neither violations nor unresolved items. These items l

were recommended for licensee consideration for program improvement, but

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they have no specific regulatory requirement. The licensee stated that these items would be reviewed:

. Upgrade the CNS Emergency Telephone Directory to the status of a l

Controlled Document. Insure that backup telephone numbers for SEMA are included.

. Recommend to the Nebraska State Patrol and the Nebraska Civil Defense L Agency that their emergency notification lists include notification

of outside agencies in the event a Notfication of Unusual Event is

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declared.

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. Recommend that all affected state agencies include a notification call-back verification provision in their emergency notification procedure The reviews and discussions were conducted to ensure that licensee

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personnel performed all actions required by the CNS emergency procedures, Technical Specification, and Emergency Pla No violations or deviations were identified in this are , Licensee Event Reports Followup The following Licensee Event Reports (LERs) were closed on the basis of the SRI's inoffice reviews, reviews of licensee documentation, and discussions with licensee personnel:

LER 86-010, " Release of Radioactive Material to Unrestricted Area" LER 86-011, " Turbine Stop Valve Closure" LER 86-012, " Loss of Emergency Transformer supply" LER 86-013, " Breach of Primary Containment Integrity" Spent Fuel Shipment The NRC inspectors inspected the licensee's activities associated with one shipment of spent fuel from CNS. Included in that inspection were observations and reviews of applicable procedures, documentation, surveys, inspections, and shipping document preparation.

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The NRC--inspectors verified by review of licensee documentation, through discussions with responsible personnel, and by independent inspection that the licensee completed the following:

. Receiving inspection of railcars and shipping casks

. Shipping documents

. Advance notification of and approval by affected state and federal-agencies

. Proper placarding of the transport vehicles

. Appropriate labeling of the spent fuel shipping casks

. Establishment of provisions for response by escorts and local law enforcement agencies

. . Training of escort personnel

. Testing of communications systems

. Continual manning of the licensee's communications center (Movement Control)

. Testing of fuel and cask handling cranes, hoists, and tools

. Proper loading and sealing of the spent fuel shipping casks

. Surveillance of area radiation monitors, ventilation systems, and spent fuel pool water level and chemistry

. Update of fuel location and accountability records

. Applicable quality assurance audits and inspections

. U.S. Department of Energy and U.S. NRC, " Nuclear Material Transaction Report," 00E/NRC Form 741

. Bill of Lading

. CNS Health Physics Procedure 9.5.3.7, " Cask IF-300 Shipment,"

Revision 3, dated December 26, 1985

. CNS Nuclear Performance Procedure 10.27, " Cask IF-300 Handling and Shipping," Revision 6, dated July 17, 1986

. CNS HP-138, " Contamination Survey - Sample Count Data Sheets"

. CNS HP-141, " Contamination Survey - Railroad Car for IF-300 Irradiated Fuel Shipping Cask"

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. CNS HP-142, " Contamination Survey of IF-300 Shipping Casks"  ;

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. CNS HP-143, " Radiation Survey of IF-300 Shipping Cask"

. CNS HP-608, " Spent Fuel Shipment Checkoff Sheet and Certificate of Compliance of Number 9001 Conditions for Shipping Spent Fuel" l

. CNS HP-14a, " Radioactive Material Shipment Record" The following independent radiation and contamination surveys were performed by the RI and verified to be satisfactory:

. Contact radiation surveys of the shipping casks l . Radiation surveys at a distance of two meters from the cask transport

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vehicles

. Contamination surveys of the shipping casks surfaces

. Contamination surveys of the cask transport vehicles

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The spent fuel shipment left the CNS on September 17, 1986. The shipment consisted of 2 spent fuel shipping casks; one contained 18 spent fuel bundles, and the other was empty and being returned for repai The shipment was transported to the G.E. Morris Operation Complex, Morris, Illinoi The spent fuel casks identification numbers were:

. IF-301 (Empty)

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IF-304 (18 bundles)

The observations, reviews, and independent measurements were conducted to verify that spent fuel handling and shipment operations were in conformance with the requirements established in the CNS Operating License and Technical Specificatio No violations or deviations were identified in this are . Operational Safety Verification The NRC inspectors observed control room operations, instrumentation, controls, reviewed plant logs and records, conducted discussions with control room personnel, and performed system walk-downs to verify that:

. Minimum shift manning requirements were me . Technical Specification requirements were observe . Plant operations were conducted using approved procedure . Plant logs and records were complete, accurate, and indicative of actual system conditions and configuration .

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. System pumps, valves, control switches, and power supply breakers-were properl y al igne . Licensee systems lineup procedures / checklists, plant drawings, and as-built configurations were in agreemen . Instrumentation was accurately displaying process variables and protection system status to be within permissible operational limits '

for operatio . When plant equipment was found to be inoperable or when equipment was removed from service for maintenance, it was properly identified and redundant equipment was verified to be operable. Also, the NR inspectors verified that applicable limiting conditions for operation were identified and maintaine . Equipment safety clearance records were complete and indicated that affected components were removed from and returned to service in a correct and approved manne . Maintenance work requests were initiated for equipment discovered to require repair or routine preventive upkeep, appropriate priority was assigned, and work commenced in a timely manne . Plant equipment conditions such as cleanliness, leakage, lubrication, and cooling water were controlled and adequately maintaine . Areas of the plant were clean, unobstructed, and free of fire hazard Fire suppression systems and emergency equipment were maintained in a condition of readines . Security measures and radiological controls were adequat The SRI observed the licensee's performance of the following operating procedures during the period September 21-24,' 1986:

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. 2.1.2, " Hot Startup Procedure," Revision 25, dated April 24, 1986

. 2.1.4, " Normal Shutdown From Power," Revision 23, dated April 29,

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The NRC inspectors performed a lineup verification of the following systems:

. High Pressure Coolant Injection (HPCI) . Core Spray "A" and "B"

l In preparation for performing the system walkdown of the HPCI system, the RI conducted a review of and comparison between the following licensee

! HPCI system valve checklist and applicable as-built drawings:

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. System Operating Procedure (S0P) 2.2.33 "High Pressure Coolant Injection System," Revision 27, dated October 3,1985; Appendix A,

" Valve Checklist."

. As-Built drawing - Burns & Roe 2041 for HPCI system

. As-Built Drawing - Burns & Roe 2044 for HPCI system

. As-Built drawing NPPD 1550-406 for HPCI system

. As-Built drawing NPPD I.D.-15 for HPCI system

. As-Built drawing GE 115D6011 for HPCI system

The above review identified that S0P 2.2.33 Appendix A, listed 72 instrument related valves that were not numbered or labled on applicable as-built drawings I.D.-15,1550-406, or 11506011. This deficiency is similar to the violation that was documented in NRC Inspection Report 50-298/86-14, paragraph 5. This item will be tracked as an open item pending review of licensee corrective action (298/8626-01).

During the perfonnance of S0P 2.2.33, Appendix A " Valve Checklist," the RI noted the following:

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HPCI-129 and 130 valves found open and unsealed; normal position is open and sealed

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HPCI-26 valve found open; normal position is closed (the HPCI system remainedoperable)

CNS Procedure 0.4 " Preparation Review and Approval of Procedures,"

Revision 7, dated July 2,1986, states that approved written station procedures shall be adhered to by all station personnel. Conduct of Operations Procedure 2.0.2, " Operations Logs and Reports," Revision 6, dated September 11, 1986,Section II.H. requires that specified valves be sealed in position. Procedure 2.2.33, Appendix "A," " Valve Checklist,"

lists the required position of valves in the HPCI System. The licensee's failure to seal valves and to place valves in position as required by procedures is an apparent violation (298/8626-02).

The licensee was notified of the errors and initiated prompt corrective actions. The open valve was closed and missing seals were replace The tours, reviews, and observations were conducted to verify that facility operations were performed in accordance with the requirements established in the CNS Operating License and Technical Specificatio One violation and one open item were identified in this are _ - - . --_ - _ , _ __ _ . - _ _ - _ _ _ - _ _ _ . - . _ .. _ - ..- _ _ _ . _

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10 Monthly Surveillance Observations The NRC inspectors observed Technical Specification required surveillance tests. Those observations verified that:

. Tests were accomplished by qualified personnel in accordance with approved procedure . Procedures conformed to Technical Specification requirement . Tests prerequisites were completed including conformance with applicable limiting conditions for operation, required administrative approval, and availability of calibrated test equipmen . Test data was reviewed for completeness, accuracy, and conformance with established criteria and Technical Specification requirement .

Deficiencies were corrected in a timely manne . The system was returned to servic The SRI reviewed the following completed surveillance tests that were-performed September 21-23, 1986:

. 6.3.1.1, " Primary Containment Local Leakage Tests," Attachment C, Revision 19, dated July 10, 1986, for the primary containment personnel airlocks onl .

6.3.10.7, " Primary Containment Isolation Valve Closure Timing,"

Attachment A, Revision 12, dated August 8, 1985, for RR-MOV-53A only.

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During his review of Surveillance Procedure 6.2.4.1P, " Daily Surveillance -

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Log (Technical Specifications)," Revision 54, dated July 10, 1986, being performed by licensee personnel on September 19, 1986, the SRI noted an incorrect data entry. Specifically, Attachment "A," page 12 of 15. "CS

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= Header Differential Pressure Instrumentation Check," had the.following

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. DPIS14-43A(Rack 25-1): -28 '

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. DPIS14-43B (Rack 25-1): 7 -

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j The acceptance criteria was stated below those entries as approx 15ately-3.5 psid during normal operations and approximately +3.0 psid in case of a line break. The operator, control room supervisor, and the shift

supervisor had all acknowledged their review and acceptance of the entered data by signing the appropriate signature blanks located below the log l

entries. After detennining the correct values, which were within the acceptable range, the SRI notified the shift supervisor of the data entry

errors. The entered data was inmediately corrected.

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Appendix B, Criterion XI, of 10 CFR Part 50, and the licensee's qual.ity assurance program, require that test results be documented and evaluated l to assure that test requirements have been satisfied. The licensee's failure to adequatel apparent violation 298/8626-03).

(y document, review, and evaluate test results is an The reviews and observations were conducted to verify that facility surveillance operations were performed in accordance with the requirements established in the CNS Operating License and Technical Specificatio One violation was identified in this are . Monthly Maintenance Observation The NRC inspectors observed preventive and corrective maintenance activities. These observations verified that:

. Limiting conditions for operation were me . Redundant equipment was operabl . Equipment was adequately isolated and safety tagge . Appropriate administrative approvals were obtained prior to commencement of work activitie . Work was performed by qualified personnel in accordance with approved procedure . Radiological controls, cleanliness practices, and appropriate fire prevention precautions were implemented and maintaine . Quality control checks and postmaintenance surveillance testing were performed as require . Equipment was properly returned to servic These reviews and observations were conducted to verify that facility maintenance operations were performed in accordance with the requirements established in the CNS Operating License and Technical Specificatio No violations or deviations were identified in this are . Annual Emergency Preparedness Exercise _

The CNS annual emergency exercise occurred on September 24, 1986. The NRC inspectors acted as NRC participants in the Control Room and Technical Support Center areas. Their specific consnents were provided to the NRC exercise team leader and included in NRC Inspection Report 50-298/86-2 Also, the SRI reviewed the minutes of the CNS Safety Operations Review Consnittee (SORC) meeting conducted September 25, 1986, to verify that an

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adequate review and evaluation of the exercise was performed by plant ,

managemen The SRI from Fort Calhoun Station also participated in this exercis No violations or deviations were identified by the NRC resident inspectors in this are . Exit Meetings Exit meetings were conducted at the conclusion of each portion of the inspection. The NRC inspectors summarized the scope and findings of each inspection segment at those meeting l'

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