IR 05000298/1987006
| ML20207S445 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/11/1987 |
| From: | Dubois D, Jaudon J, Plettner E, Skow M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207S432 | List: |
| References | |
| 50-298-87-06, 50-298-87-6, IEB-84-01, IEB-84-1, IEB-86-001, IEB-86-002, IEB-86-003, IEB-86-004, IEB-86-1, IEB-86-2, IEB-86-3, IEB-86-4, IEIN-84-53, IEIN-85-094, IEIN-85-94, IEIN-86-047, IEIN-86-47, NUDOCS 8703190463 | |
| Download: ML20207S445 (24) | |
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>.a APPENDIX B
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U. S. NUCLEAR REGULATORY COMMISSION REGION-IV
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NRC Inspection-Report: -50-298/87-06 License:. DPR-46
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Docket: ~50-298 Licensee: Nebraska Public Power District (NPPD)
P. O. Box 499 Columbus, NE 68601 Facility Name: Cooper Nuclear Station (CNS)
Inspection'At:- Cooper Nuclear Station, Nemaha County, Nebraska
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Inspection Conducted: February 1-28, 1987
Inspectors:. I d. [ d % o 3/5 )g f-s E. A. Plettner, Resident Inspector. (RI)
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%%3Ea 2Mr7 D. L. DuBois, Senior Resident Inspector, (SRI)
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U T7 M. E. Slow. Project Engineer, Project D'a t e '
Section A. Reactor Projects Branch
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Approved:
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J/ P. gaudon', Chief, Project Section A Date L Reactor Projects Branch k[hN
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Inspection Summary Inspection Conducted February 1-28, 1987 (Report 50-298/87-06)
Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings, IE Bulletins / Temporary Instructions, IE Information Notices,10 CFR Part 21 Reports, independent inspection, measuring and test equipment calibration, plant trips-safety systems challenges, operational safety verification, and monthly surveillance and maintenance observations.
Results: Within the areas inspected, one violation was identified (failure to adhere to'a maintenan'ce and test equipment procedure, paragraph 7).
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s DETAILS
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' Persons Contacted
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Principal Licensee Employees
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- G. R. Horn, Division Manager of Nuclear Operations
- J. M. Meachams Senior Manager, Technical Support Services
- J. Sayer, Manager',' Radiological
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- C. R. Goings," Regulatory Compliance Specialist t
- G.. E. Smith, Manager, Quality Assurance
- R. ' Brungardt, Manager, Operations
- D. 'W. Sremer, Supervisor, Operations Support Group
- R. Brown, Specialist, Instrument and Control R. Beilke, Chemistry and Health Physics Supervisor S. Freborg, Lead Mechanical Engineer P. Morris, Coordinator, ALARA
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T. Wilson, Mechanical Engineer
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H. Hitch, Manager, Plant Services The NRC ins sectors 'also interviewed other licensee employees during the course of tie inspect. ion.
- Denotes those present during uit igterview March 4,1987.
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Licensee Action on_,[revious Inspection Finnings The following items cf noccompliance or deviatiwn were raviewed by the NRC,
inspectors to verify what the licensee'p respowia to the items identified in previous inspection Gports are now in conforn.once with regulatory requirements and that corrective measures were coc9 eted in a timely
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(Closed) Unresolved (298/8421-12): Apparent Failure of the Licensee to
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Provide an Adequate Procedure for the Control of-High Radiation Areas (HRAs)
The CNS Technical Specification has been revised,to require that HRAs be barricaded and conspicuously posted as an HRA and entrance controlled by s
Special Work Permit. Parricade examples listed in the Technical Specification includes doors, yellow and ngenta rope, and turnstile. The USAR continues to state that URAs will be locked or cocipletely blockt.J off. Procedure 9.1.2.2 has been revised to state verbatic, the Technical Specification requirement for the control of HRAs.-
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This item is closed.
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'(Closed)-Violation (298/8515-03):
Failure to Have Procedures for
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.' Activities Affecting Quality
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,This item originated with the NRC Performance Appraisal Team (PAT)
Inspection Report 50-298/84-21.
Several of the items noted in the PAT
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steport were closed and incorporated into Violation 298/8515-03.
The discussion which follows will close this violation and identify an open
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Item requiring followup during a future inspection.
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Qualification, training, and independence of quality control
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inspectors.
In NRC Inspection Report 50-298/85-15, it was noted that licensee proposed corrective actions included hiring a QC coordinator
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who would be assigned to the plant QA organization (target date of July 1, 1985). Also, the QC coordinator would develop necessary
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procedures (target date of February 1, 1986) to cover QC inspector qualification, training, and organization.
Subsequently, the licensee hired an individual to perform as QC coordinator.
However, the QC
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coordinator was later terminated from the licensee's staff and procedures were not developed.
The licensee has hired another person to replace the former QC coordinator who will officially assume his
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duties on March 16, 1987.
This portion of Violation 298/8515-03 is closed and incorporated into a new open item pending completion of
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licensee action and additional NRC inspection (298/8706-01).
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Audit program.
Quality Assurance Instruction QAI-5, Revision 21,
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dated July 22, 1986, was reviewed by the NRC inspector.
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Clarifications to this procedure discuss the difference between an audit finding and an audit observation.
The procedure also details how findings are to be dispositioned.
This portion of Violation 298/8515-03 is closed.
Supplier Quality Assurance Program.
This portion of the violation
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described an apparent failure by the licensee to have procedures that
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required corrective action for vendors having identified QA program deficiencies. Quality Assurance Instruction QAI-16, Revision 12, dated December 18, 1986, clarifies the procedural requirements.
The-procedure details supplier evaluation activities and appears adequate.
This portion of Violation 298/8515-03 is closed.
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Verification of Certificates of Conformance.
This portion of the
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violation described an apparent failure by the licensee to have
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' procedures requiring verification of the validity of vendor Certificates of Conformance for identical replacement parts.
QAI-16 clarifies the procedural requirement such that Certificates of Conformance are not considered as the only basis for supplier approval.
In addition, the Approved Suppliers List identifies
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current supplier limitations and in some cases requires that
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Certificates of Conformance include a summary of any design changes that were made to equipment or parts since the original equipment or
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parts were installed in the plant.
This portion of
Violation 298/8515-03 is closed.
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. Receipt Inspection. This portion of the violation de' scribed an-
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f apparent failure by the licensee to have procedurer! rsquiring
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a performance of an additional receipt inspection for. items not examined or bspected at the source.
The ljcensee has hired a
- receipt inspector and clarified Plant-Services Procedure -1.5, Revision 5, dated August 7, 1986, to provide details for receipt h spection.
This portion of Violation 298/8515-03 is closed.
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Storage of Hazardous Materials.
This portion of the violation described an apparent. failure by the licensee to have procedures requiring proper storage for hazardous ~ material.
Plant Services Procedure 1.7, Revision 3, dated September 25, 1986, discusses storage methods for. hazardous material such as chemicals, paints, and solvents in close proximity to important nuclear plant items.
In-addition, the licensee stated that a design change is in process to construct a new building on site to store this type of material..
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Based on the procedure revision and the licensee's decisicn to build a new storage building, this portion of Violation 298/851E-03 is
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closed.
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Control of Vendor Technical Information. This portion of the
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violation de' scribed an apparent failure by the, licensee to have procedures for establishing control of vendor technical information.
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Procedures' have been established by the licensee to regularly obtain
,a verification from vendors that their technical manuals are up to date.
Procedures exist to process _ technical-manual changes'from-R various sources.
Procedures reviewed by the NRC inspector included
. ),j v 3.11, Revision.0, dated August. 20,-1985; 0.24, Revision 1, dated
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This portion of Violation 298/8515-03
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Calibration of Mechanical Measuring and Test Equipment.
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described an apparent failure by the' licensee to have procedures for
,u controlling calibration of mechanical measuring and test T'
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equipment (M&TE), Maintenance Procedure 7.1.1, Revision 3, dated September 25, 1986, implements the' licensee's~M&TE program.
The licensee appears to have fully. implemented the procedure.
This area was also the subject of a more' detailed routine inspection that is documented in paragraph 7 of this report. This portion of y,
Violation 298/8515-03 is closed.
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d.S Control of Shop Guides. This item described the licensee's
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i,Al utilization of written instructions and guidelines called " shop guides" to accomplish safety-related activities.
The shop guides had
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'not received the same level of review, approval, or control as other
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CNS maintenance related procedures.
The NRC inspector found that the licensee has reviewed the shop guides and selected approximately 70
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of the shop guides for inclusion into controlled procedures.
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date, approximately 39 of the shop guides have been converted to approved maintenance procedures.
Based on the licensee having implemented a program to upgrade the shop guides, having developed
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and approved a significant number of new maintenance procedures, and aggressively processing those remaining shop guides, this portion of Violation 298/8515-03 is closed.
Design Verification.
This portion of the violation described an
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apparent failure by the licensee to provide an adequate station design change procedure.
The NRC inspector reviewed Procedure 3.4, Revision 4, dated July 2, 1986, and verified that the procedure revision included requirements to check a design change for its affect on the CNS Technical Specification, Updated Safety Analysis Report-(USAR), Training Manual, operational procedures, and to determine the need for interim revised drawings.
This portion of Violation 298/8515-03 is closed.
Evaluation and Documentation of-Temporary Lead Shielding.
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described an apparent failure by the licensee to provide procedures for the conduct and documentation of safety evaluations involving temporary lead shielding installed on systems or components discussed in the USAR.
Procedure 3.14, Revision 1, dated November 17, 1985, appears to implement a program to perform and document safety evaluations involving temporary lead shielding to be installed on systems or components discussed in the USAR.
The NRC inspector also
. reviewed licensee records to verify implementation of the procedure.
This portion of Violation 298/8515-03 is closed.
In summary, all portions of Violation 298/8515-03 are considered closed.
The item dealing with quality control inspectors, qualification training, and independence from other licensee activities is considered an open item as noted above.
(Closed) Violation (298/8521-01):
Nebraska Public Power District Procedures for Preparation and Completion Closure of CNS Design Changes This item concerned a failure by the licensee to have procedures covering all activities relating to design changes.
The licensee has included in Engineering Procedure 3.4, Revision 4, dated July 2, 1986, certain clarifications in response t., the violation.
Those changes included revision to the design input checklist to address additional specific line items such as bolt preload torque and code material verification. Another revision included a clarification to address procedural adequacy regarding verification of conforming materials used and as-built conditions versus design specifications.
The licensee has committed to and appears to be progressing in a review of all completed safety-related design changes to verify preload torque calculation.
The licensee has also committed to replace the nonconforming spiral-wound, metal-asbestos gaskets in the torus drain connection associated with Design Change 78-016 during an outage when the torus is drained.
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(Closed) Violation (298/8524-01):
Inadequate Operating Procedures This item involved CNS Procedure 2.1.1, " Cold Startup Procedure,"
Revision 39, dated July 11, 1985. The procedure required licensee personnel to verify that reactor water chemistry was adequate for startup,
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but did not include criteria for making the determination. The licensee's response to this violation was.to include Technical Specification limits for water chemistry on the chemical analysis report Data Sheet 8.4.0.0.7.
This docurant is used by licensed personnel to verify. that reactor water chemistry is adequate for startup as required in Procedure 2.1.1.
The RI verified that appropriate changes were made to the chemical analysis report Data Sheet 8.4.0.0.7.
This item is closed.
(Closed) Violation (298/8524-03):
Failure to Meet an NRC Reportability Requirement This item involved the licensee's failure to submit a licensee event report involving movement of irradiated fuel which was not properly supported and grappled. This condition was not covered by a plant procedure. Corrective action taken by CNS was to revise Nuclear
Performance Procedure (NPP) 10.25, " Refueling," to include a step which required a visual confirmation that the grapple was properly engaged prior
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to raising a fuel assembly. :The RI reviewed NPP 10.25, Revision 5, dated January 2,1986, and verified that the appropriate change was made. The licensee' issued Licensee Event Report No.85-021' on January 2,1986, as required by 10'CFR Part 50.73.
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This item is closed.
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' (Closed) Violation (298/8524-04):
Failure to Perform Surveillance Testing l
According to Procedures
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This item involved a licensee person who did _not perfonn testing in accordance with the requirements of CNS Surveillance Procedure (SP) 6.1.3,
"APRM System Excluding 15% Trip Function Test," Revision 12. The corrective step taken by the licensee included counseling the person who j
failed to follow the procedure.
In addition, the operations supervisor conducted weekly shift crew meetings from January 21 through February 21,
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l 1986, covering the topic of " Failure to Follow Procedures." The RI j
conducted a personal interview with the individual involved and confirmed that he received the necessary briefing. Also, the RI verified by his
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review of weekly shift crew meeting attendance sheets that all station operating personnel were present for the briefings.
This item is closed.
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(Closed) Violation (298/8524-05):
Inadequate Evaluation of Surveillance
. Test Results This item involved three licensed persons who reviewed SP 6.2.4.1, " Daily Surveillance (Technical Specifications)," Revision 49, without identifying the presence of an incorrect data entry.
The corrective actions taken by the licensee included counselling the individual who recorded the incorrect data on SP 6.2.4.1, and conducted weekly shift crew meetings informing all station operating personnel of the occurrence, the need to correctly record data values, to verify correctness, and perform adequate review of test results.
The RI verified by his review of weekly shift crew meeting attendance sheets from December 3,1985, through February 13, 1986, that all station operating personnel were present for the briefings.
This item is closed.
(Closed) Violation (298/8626-02):
Failure to Follow Procedure This item described High Pressure Coolant Injection System Valves which were properly positioned but did not have lead seals attached as required by Operating Procedure 2.0.2, " Operations Logs and Reports, Section H, Sealed Valve Log."
Corrective actions taken by the licensee were verification that required lead seals would be installed prior to startup from the refueling outage and the operations supervisor would conduct weekly shift crew meetings.
The RI verified that required lead seals were in place and by his review of weekly shift crew meeting attendance sheets from September 30 through October 15, 1986, verified that all station operating personnel were present for the briefings.
This item is closed.
(Closed) Violation (298/8626-03):
Inadequate Review of Surveillance Test Results This item described the incorrect transfer of data by a station operator from Station Procedure 2.2.11, " Station Operators Tour," to SP 6.2.4.1P,
" Daily Surveillance Logs (Technical Specification)." The incorrect entries were reviewed and accepted by a station operator, control room supervisor, and shift supervisor.
Licensee corrective actions included counselling affected operations personnel by the operations supervisor; SP 6.2.4.1P, Revision 55, dated October 30, 1986, was approved and implemented which required the control room supervisors or shift supervisors to review log entries involving transfer of data from Station Procedure 2.2.11 for correctness.
The RI verified completion of the preceding actions and determined those actions to be adequate.
This item is closed.
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IE Bulletins / Temporary Instructions The following IE Bulletins and Temporary Instructions'(tis) were reviewed by the NRC Inspectors for applicability to Cooper Nuclear Station and to determine if the licensee had performed required actions:
(Closed) IE Bulletin No. 86-01 " Minimum Flow Logic Problems That Could Disable Residual Heat Removal (RHR) Pumps," dated May 23, 1986 The bulletin described the circumstances whereby the single failure of a flow sensor instrument in either of the two RHR loops could
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The bulletin required that the licensee should: (1) promptly determine whether or not the' facility has this single failure vulnerability; (2) if the problem exists immediately instruct all operating shifts of the problem and measures to recognize and mitigate the problem; (3) within seven days of receipt of this bulletin, (a) provide a written report to the NRC which identified whether or not this problem exists at the facility, and (b) and if the problem exists, identify the short-term modifications to the plant operating procedures or hardware that have been or are being implemented to assure safe plant operations; and (4) if the problem
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exists provide a written report within 30 days of receipt of this
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bulletin informing the NRC of the schedule for long-term resolution y
of the problems that are. identified as a result of the bulletin.
l CNS promptly reviewed electrical circuitry to determine if the single I
failure vulnerability existed at CNS.
The results of the review revealed that CNS does not have the single failure vulnerability described in the bulletin. The circuitry was field verified and i
functionally tested to ensure that the loss of either RHR loop flow l
sensor would not affect the operation of the minimum flow bypass valve in the opposite loop.
CNS responded to the NRC within seven days of receipt of the bulletin in a letter dated May 30, 1986, reference No. CNSS867438.
The letter contained a short brief that described why the problem did not exist at CNS. In fulfilling requirements 1 and 3 of the required actions, CNS was not required to respond to Action Items 2 and 4.
This item is closed.
(Closed) Temporary Instruction (TI) 2515/82:
Inspection Requirements for IE Bulletin 86-01, " Minimum Flow Logic Problems That Could Disable RHR Pumps," dated December 15, 1986.
The TI requires, (1) the NRC Regional or resident inspector to determine that licensee had submitted their initial responses in seven days of receipt of IE Bulletin 86-01, and (2) if the licensee had the logic problem, the NRC Regional or resident inspector was to monitor licensee corrective actions and licensee commitments for instructing and training operations personnel.
The RI performed a review during the week of February 9-13, 1987, and verified the licensee response to IE
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The RI's review of appropriate electrical prints verified that CNS does not have the single failure vulnerability described in IE Bulletin 86-01.
No response to action. item 2 is required.
This item is closed.
i (Closed)LIEBulletinNo.86-02:
Static "0" Ring Differential Pressure Switches, dated July 18, 1986 The bulletin describes the circumstances whereby SOR Series 102 or 103 differential pressure switches failed to perform their intended function in electrical equipment important to safety.
IE Bulletin-86-02 required the licensee to submit a report within 7 days describing the extent to which SOR Model 102 or 103 differential pressure switches are installed in equipment important to safety as defined in 10 CFR 50.49(D). The report was to include the model number of the switch, the system in which it is installed, the
application of the switch, and the function of the switch.
There were five other actions required of the licensee if they had SOR Model 102 or'103 differential pressure switches installed in a system that is subject to. Technical Specification limiting conditions for operation.
CNS responded to the NRC in a letter dated July 25, 1986, reference No. NLS8600238.
In their written response, the licensee identified that SOR Model 102 or 103 Differential Pressure Switches were not installed at CNS.
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This item is closed.
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(Closed) IE Bulletin No. 86-03:
Potential Failure of Multiple ECCS
. Pumps'Due to Single Failure of Air-0perated Valve in Minimum Flow Recirculation Line, dated October 8, 1986 This bulletin describes design deficiencies involving minimum flow recirculation paths for ECCS pumps.
IE Bulletin 86-03 requires that:
(1) the licensee promptly determine whether or not the facility has a single failure vulnerability in the minimum flow recirculation line of any ECCS pump that could cause a failure of more than one ECCS (
train; (2) if the problem exists, (a) to promptly instruct all operating shifts of the problem and measures to recognize and mitigate the problem, and (b) to promptly develop and implement corrective action which will bring the facility quickly into compliance with General Design Criterion 35, 10 CFR 50 Appendix A; (3) within 30 days from issuance of the bulletin, (a) provide a
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written report to the NRC which identifies whether or not the problem exists at the facility, and (b) if the problem exists, include in the report the justification for continued operation and identify the short-term modifications to plant operating procedures or hardware that have been or are being implemented to ensure safe plant operations; and (4) if the problem exists, provide a written report within 90 days of receipt of the bulletin informing NRC of the
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schedule for long-term resolution of this or any other significant problems that were identified.as a result'of the bulletin. Note:
Actions required of the licensee in response to IE Bulletin 86-01 are not required to be repeated in this bulletin.
CNS insnediately conducted an evaluation of the applicable mechanical and electrical documents and concluded that no single failure vulnerability in the minimum flow recirculation line for the Core Spray (CS) System existed. Control of the minimum flow valve in either CS Loop is totally independent of the opposite CS Loop and the RHR system. Therefore, failure of a single device cannot impact upon the operation of the minimum flow valve in more that one CS Loop or cause failure of more than one ECCS train. The licensee responded to the NRC in a letter dated October 31, 1986. The letter contained the infomation stated above.
In fulfilling requirements 1 and 3 of the required actions, CNS was not required to respond to Action Items 2 and 4.
This item is closed.
(Closed)IEBulletinNo.86-04: Defective Teletherapy Timer That May Not Teminate Treatment Dose The bulletin describes the malfunction of a Sedeco Model RP-112I teletherapy timer used in Colbalt-60 teletherapy units manufact Jred by Picker /AMS. This bulletin is not applicable to CNS because +. hey are not licensed to use a Cobalt-60 teletherapy unit.
This item is closed.
l (Closed) I.E. Temporary Instruction (TI) 2500/12, " Inspection of the Actions Taken by the Licensees and Applicants of BWR Facilities with Mark I and Mark II Containments in Response to GE SIL No. 402."
On February 3,1984, the NRC issued IE Bulletin (IEB) 84-01, " Cracks in Boiling Water Reactor Mark I Containment Vent Headers." At the time IEB 84-01 was issued, the cause of the vent header cracks was not known and was under investigation. The CNS has a Mark I containment and therefore promptly responded to IEB 84-01 as required. Subsequently, the vent header cracks were confirmed to be the result of brittle fracture caused by the injection of cold nitrogen into the torus during inerting. On February 14, 1984, the General Electric (GE) Company issued Service Information Letter.(SIL) 402 that included five recommended actions to be taken by affected licensees to confirm that equipment damage had not occurred and to ensure that damage would not occur in the future.
The licensee responded to SIL 402 in a letter from Mr. J. M. Pilant (NPPD) to Mr. D. B. Vassallo (NRC) dated September 12, 1984. The SRI reviewed the licensee's responses and corrective actions to IEB 84-01 and SIL 402 during the period October 1 through November 30, 1984, and documented those reviews in NRC Inspection Report 50-298/84-2 r s
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On February 7. -1985, the. NRC issued Temporary Instruction (TI) 2500/12 to _ provide specific guidance to NRC inspectors for performing inspection _of actions taken by the licensee's in response to SIL 402.
It was noted in TI 2500/12 that the CNS response to SIL 402 did not contain sufficient detail to ensure that SIL recommendations were adequately implemented.- The SRI performed a reinspection of CNS actions in this area during the present inspection period in order to-provide additional details of the-licensee's actions specifically-related to'the TI 2500/12 items listed below:
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Evaluate Inerting System Design
The requirement was to evaluate the design of the nitrogen inerting system.
Investigate the potential for introducing cold (less than 40'F) nitrogen and the orientation of the nitrogen port. relative to the vent header, downcomers, or other equipment in the wetwell and drywell which may be in the path of the -
injected nitrogen. Assure that the temperature monitoring devices, the low temperature shutoff valve, and overall system design are adequate to prevent the injection of cold nitrogen into the containment.
The CNS nitrogen system consists of a vendor owned and maintained bulk liquid nitrogen unit that is located outside and adjacent to the reactor building. The bulk nitrogen unit consists of an 8000 gallon liquid nitrogen storage tank and a vaporizor that transforms the nitrogen from a liquid to a gas.
The bulk unit is connected to the licensee's plant nitrogen gas distribution system..The nitrogen system is used to inert the primary containment (drywell and torus), and provide a constant source of nitrogen gas to other plant equipment.
Controls available to and used by operations personnel during inerting activities include manual valve control of nitrogen gas flow (6000-7000 cfm) and header pressure regelator control (1.25 psig). Also, the vaporizor outlet gas temperature is automaticclly controlled at 130 F by thermostatically controlled vaporizer water heaters. Available indicators include liquid nitrogen storage tank level and pressure, nitrogen gas header pressure, gas flow rate, and torus air space temperature.
Protective devices include numerous system pressure relief valves and a temperature trip device that will isolate the liquid nitrogen supply to the vaporizer when the outlet gas t
temperature decreases to less than -40*F.
Several annunciators are associated with this system including Nitrogen Makeup Tank Low Level and Drywell Makeup Nitrogen Flow High.
Nitrogen gas distribution system pipe size is initially 2 inches -
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OD and expands to 20 inches OD prior to penetrating the torus and drywell. The torus nitrogen supply pipe vertically enters t
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the top of the torus at penetration X-205 and extends 13 inches inside the torus where nitrogen is then discharged through the nitrogen injection port.
Equipment located in the discharge path of the nitrogen port includes the torus spray ring header (1 foot from the port) and the containment vent header (9 foot from the port.) The nitrogen piping also connects to the drywell air purge supply pipe which enters the drywell at penetration X-25.
- Evaluate Inerting System Operation The requirement was to review the operating experience of the inerting system to assure that the vaporizer, the low temperature shutoff valve and the temperature indicators have functioned properly.
Evaluate the plant calibration,.
maintenance and operating procedures for the inerting system.
Assure that cold nitrogen injection would be detected and prevented.
The licensee stated that there have not been any operational or maintenance problems associated with the nitrogen gas distribution system.
A review of data from the last two annual
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inspections indicated that one of five 72 KW heaters was defective and a pressure regulator was not working properly in the liquid nitrogen system.
During each annual inspection the bulk nitrogen outlet gas low temperature trip device is replaced.
Also, calibration checks are performed on the vaporizer water heater temperature control thermostat, the header pressure regulator, and the storage tank level indicator.
System safety relief valves are replaced every 5 years.
The nitrogen liquid and gas systems are operated according to CNS System Operating Procedure 2.2.60, " Primary Containment Cooling and Nitrogen Inerting System," and preventive maintenance is performed in accordance with Preventive Maintenance (PM)
No. 04439, " Inspection, Calibration, and Scheduled Replacement of Components in the Nitrogen Storage and Vaporization System."
Inspect Nitrogen Injection Line
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The requirement was to conduct an ultrasonic test (UT) as soon as convenient of all accessible welds in the nitrogen injection line from the last isolation valve to the wetwell and drywell penetrations and to UT the containment penetrations and the containment shell within 6 inches of the penetration. UT was recommended because cracks would be most likely to initiate on the inside of the pipe or on the side of the metal in contact with cold nitrogen.
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The GE Company performed no'ndestructive examinations of 35
. components for the licensee during the period April 2-10, 1984.
The following is a list of the examined components and.the type of. examination:
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Torus nitrogen injection.line piping welds located between
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the torus and-the upstream-isolation valves (UT and PT)
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Torus nitrogen injection line instrument piping welds up to the sensing line isolation valves (PT)
Drywell nitrogen injection line piping welds located
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between the drywell and the upstream isolation valve (UT)
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ACAD System to drywell air purge supply line welds located between the drywell and upstream ACAD isolation valve (PT)
Torus shell at penetration X-205 (UT)
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Torus penetration pipe to torus (UT)
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Torus penetration pipe inside of torus (VT)
Drywell shell penetration assembly X-25 (UT)
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The above nondestructive examination results are documented in the " Nondestructive Examination Service Report," which was prepared for NPPD by General Electric Company's Apparatus and Engineering Services Department, dated April 1984.
Inspect Containment The requirement was, during the next planned outage, to perform a visual inspection of.the vent header, downcomers and other equipment'in the-containment which might be expected to be affected by the injection of cold nitrogen.
The vent header i
should be inspected on the outside and the inside..Also inspect
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the containment shell or steel liner for at least 6 inches around the nitrogen penetration.
The SRI held discussions with members of the licensee's engineering staff concerning this item. The CNS engineers stated that visual examinations were performed in the torus and drywell as required.
However, they were unable to describe the-specifics of those inspections and could not locate relavent documentation.
The licensee was continuing the information and documentation search at the conclusion of this inspection period.
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The following are observations that were presented by the SRI to the licensee during the exit interview on March 4, 1987. These observations are neither violations nor unresolved items and were reconinended for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee indicated that these items would be considered:
Piping, instrument,and electrical drawings sho"ld be developed
for the bulk liquid nitrogen package unit.
In acdition, component identification labels should be developed and attached to the components.
A detailed NPPD surveillance procedure should be developed to
document the periodic inspections that are presently performed and documented by Union Carbide Corporation.
The safety relief valves should be tested periodically to ensure
proper calibration. They are currently replaced every 5 years.
A permanently piped makeup water supply should be installed for maintaining an adequate and readily available source of water to the vaporizer.
Functional tests'should be performed on the nitrogen shutoff
valve, which is controlled by the low temperature trip switch.
All documentation resulting from the annual preventive maintenance inspections performed by Union Carbide Corporation should be obtained and placed into the CNS historical files.
Install a nitrogen gas header temperature indicator.
- Historical CNS documents should be located and/or developed that describe, (1) the orientation of the nitrogen injection port in the drywell relative to equipment that is located in the impingement path, and (2) the visual examinations that were performed in the torus and drywell.
l This item is closed.
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j 4.
IE Information Notices
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The following Information Notices were reviewed by the NRC inspectors for (
applicability at CNS and to determine if the licensee had performed l
required actions:
(Closed)IEInformationNotice84-53,"InformationConcerningtheUse of Loctite-242 and Other Anaerobic Adhesive Sealants," dated July 5, 1984. This item was referenced in 10 CFR Part 21 Report 8404260414 which was closed in paragraph 5 below.
This item is closed.
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'(Closed) IE Information Notice 85-94, Potential -for Loss of Minimum Flowpaths Leading to ECCS Pump Damage During a LOCA," dated December 13, 1985.- This item was referenced in IE Bulletin 86-01 which was closed in paragraph 3 above.
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This item is closed.
(Closed) IE Information Notice 86-47, " Erratic Behavior of Static
"0" Ring Differential Pressure Switches," dated June 10, 1986..This information notice was referenced in IE Bulletin 86-02 which was closed in paragraph 3 above.
This item is~ closed.
5.
Part 21 - Reporting of Defects and Noncompliance The following 10 CFR Part 21' Reports were reviewed by the RI for applicability to Cooper Nuclear Station and to detennine if the licensee had performed the required actions.
(Closed)10CFR21 Report 8404260414. " Loctite 242 Causes Scram-Solenoid Pilot Valves to Fail to Vent" This-Part 21 Report identifies a deficiency of a thread locking material (Loctite-242) which escaped from the solenoid core plunger of the scram pilot solenoid valves resulting in bonding of the plunger to the solenoid base subassembly thus preventing a scram from
- occurring. The cause of the deficiency was a design error _ in selecting the appropriate thread locking device. The deficiency was also identified in IE Information Notice 84-53, "Information Concerning the Use of Loctite-242 and Other Anaerobic Adhesive Sealants," dated July 5, 1984. CNS performed an engineering evaluation of the problem.- The engineering review revealed that CNS does not use Loctite-242 or any other thread locking material in its scram pilot solenoid valves. CNS uses a torque wrench to assure nut tightness as required in their preventive maintenance program.
This item is closed.
(Closed)10CFR21 Report 8603060210, " Noble Gas Radiation Monitor."
This.Part 21 Report identifies a deficiency of a radiation monitoring system.
The system was identified as a Kaman radiation monitor model KMG-HRH with detector enhancement model KDGM-HR. Part No. 952397-003. The cause of the deficiency was a fabrication error in the software operating the radiation monitoring system.
Kaman i
Corporation provided CNS with the appropriate software to correct the problem. CNS performed satisfactory calibration tests on the monitors after the correct software was installed.
This item is closed.
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?The'RI1 performed additional' inspections'~in this area to verify.that the'
- licensee had procedures or controls established to ensure that. defects and
~ noncompliances'would be reported to appropriate organizations as-required by 10 CFR Part 21.
The RI-reviewed the following documents:
-Quality' Assurance, Program 2000
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Administrative Procedure 0.5.1, "Nonconformance'and Corrective
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Action," Revision 0,; dated February 20, 1987.
Administrative ' Procedure 14, " Requisitioning," Revision 5, dated '
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October 30, 1986; CNSTeShnicalSpecification
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The review determined that measures were established to meet the requirements of 10:CFR Part 21.
~No violations or deviations were identified in this area.
6.
Independent Inspection-RHR Pump Minimum Flow Problem-A concern has been raised regarding the. adequacy of RHR pump minimum flow capability at CNS.
The original flow capacity of _each minimum flow.line was-325 gpm which was the minimum recommended flow required to prevent the
. pumps from overheating. The pump manufacturer now suggests that in order to prevent undesirable hydraulic noises or vibrations when_ operating for
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. extended durations of up to two hours, the minimum flow should be
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significantly higher than the present value.
As a' result, the licensee implemented Design _ Change 86-125, " Removal of RHR Minimum Flow Lines-Orfices," The removal of the flow orfices_from each minimum flow line increased the minimum flow, as determined by calculations for one pump and-two pumps, to 1862 gpm and-1450 gpm.respectively.
No performance tests or calculations were done to prove that sufficient cooling water would be--
injected into the core during a design basis accident with the minimum flow valve stuck in the open position.
This lack of information is a concern.
Thus, the office of Nuclear Reactor Regulation (NRR) will perform an independent review to ensure that no unresolved safety question-exists..This will remain an unresolved item pending. completion of NRRs review.
(298/8706-02)
7.
Measuring and Test Equipment Calibration l
The purpose of the inspection was to verify that the licensee had a program to control measuring'and test equipment (M&TE) calibrations.
The program is required to conform with Criterion XII of Appendix B to 10 CFR
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Part 50, Industrial Standards, and the CNS Operating License and Technical
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Specification.
The RI verified the following:
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'18 Test equipment was properly stored, identified by a unique number,
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calibration status is formally maintained, and recalibration is performed within an' established schedule.
Identification of calibration standards used were traceable to
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nationally recognized standards.
Appropriate actions were taken when M&TE or reference standards were
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found out of calibration, lost, or stolen.
The RI performed an inspection of the calibration records for two calibration cycles of M&TE. The equipment included pressure gauges, digital volt meters, temperature indicators, sound level calibrators, resistant temperature detectors, flow indicators, a dead weight tester, and a dynamometer. The inspection revealed that the " reviewed by" or signature blank and associated "date" blank had not been completed on the following:
Instrument and Control (I&C) Procedure 7.5.4.2, Attachment "A," Item
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Number 32 completed on September 25, 1986.
I&C Procedure 7.5.4.2, Attachment "B," pages 26 and 32, completed on
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September 25, 1986.
I&C Procedure 7.5.4.2, Attachment "B," pages 34 and 39, completed on
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December 19, 1986.
These examples are similar to the violation documented in NRC Inspection Report 50-298/8636, paragraph 6.
These three items will be tracked as an open iten pending review of the licensee's corrective action to the previous violation.
(298/8706-03)
The inspection also revealed that calibration data was not recorded in the appropriate blanks as follows:
I&C Procedure 7.5.4.2, Attachment "B," page 11 for the zero
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calibration point in the as-found and as-left blank performed on l
December 16, 1986.
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I&C Procedure 7.5.4.2, Attachment "B," page 31 for the zero
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calibration point in the as-left blank performed December 16, 1986.
Appendix B Criterion V of 10 CFR Part 50 and the licensee's approved Quality Assurance program require that activities affecting quality be accomplished in accordance with the drawings and procedural instructions.
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.
Instrument and Control Procedure 7.5.4.2, " Pressure Test Gauge Calibration," Revision 19, dated May 1, 1986, requires that calibration data be recorded in the i
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appropriate as-found or as-left data blank.
The failure to record
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calibration data in the as-found and as-left-blanks as noted above is an apparent violation.
(298/8706-04)
The RI performed a followup inspection to document the validity of the test gauges-listed below:
The test gauge identified on page 11 had not been.used for any work
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item requiring a calibrated pressure test gauge.
The gauge was recalibrated on February 23, 1987, and the as-found data was within the tolerances allowed for each calibration test point.
No further action was required.
The test gauge identified on page 32 had been used for three work
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items requiring a calibrated pressure test gauge on December 26 and 28, 1986, and February 4, 1987.
The gauge was recalibrated on February 23, 1987, and the-as-found data was within the tolerances allowed for each calibration test point.
Because the as-found data met the' required tolerances the tests performed with the gauge on the above dates were considered valid.
No further action was required.
One violation was identified in this area.
8.
Plant Trips-Safety Systems Challenges The NRC inspectors held discussions with operations personnel and reviewed control room records including log entries, recorder traces, and computer printouts associated with an unscheduled reactor scram that occurred on February 18, 1987, at 1:50 p.m.:
The reactor was in Run Mode at 50 percent power and steady-state conditions prior to the event.. Operations personnel were performing applicable steps of System Operating Procedure (50P) 2.2.28, "Feedwater System," Revision 39, dated July 17, 1986, in preparation for placing a second reactor feedwater pump (RFP) into service.
Reactor water level was being maintained with "B" RFP controlling in automatic.
The station operator was directed to perform prestartup trip tests on the "A" RFP from the local control panel but he incorrectly selected and tripped "B" RFP which resulted in a loss of feedwater to the reactor vessel.
Operators unsuccessfully attempted to place "A" RFP into service and a low water level scram (+12.5 inches) occurred before feedwater flow could be
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restored.
Primary Containment Isolation Groups 2, 3, and 6 actuated at the low water level setpoint.
The Standby Gas Treatment System automatically started on the Group 6 Isolation.
The High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) Systems pumps automatically started at -37 inches and restored water level to normal.
Both reactor recirculation pumps also tripped at the low water level setpoint (-37 inches).
Diesel generators started when station power transferred from the normal to startup transformer but were not required to assume electrical loads.
No other safety systems were required to
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. operate. I Following the scram,= water level was maintained using RCIC and
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"B"/RFP.
The reactor was: restarted at.6:05 a.m. February 19,1987, and
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the Main Turbine generator was loaded at,4:04'p.m. on-February 19, 1987.
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No' violations or deviations were identified in-this' area.
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Operational = Safety Verification
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The NRC inspectors observed control. room operations, instrumentation,
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controls,. reviewed plant logs and records, conducted discussions with control room personnel, and performed system walk-downs to verify.that:
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Minimum shift manning requirements were met ~.
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Technical Specification requirements were observed.
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Plant operations'were conducted using approved procedures.
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P_lant: logs and records.were-complete, accurate,' and i_ndicative of-
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actual system conditions and configurations.
System pumps, valves, control switches, and power supply breakers
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were properly aligned.
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Licensee systems lineup procedures / checklists, plant drawings,. and
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as-built configurations were in agreement.
Instrumentation was accurately displaying process variables and
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protection system status to be within permissible operational limits for operation.
When plant equipment was found to be inoperable ~or when equipment was
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removed from service for maintenance, it was properly identified and redundant equipment was verified to be operable.
Also, the NRC inspectors verified that applicable-limiting conditions for operation were identified'and maintained.-
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Equipment safety clearance records were complete and indicated that affected components were removed from and returned to service in a
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i correct and approved manner.
Maintenance work requests were initiated for' equipment discovered to
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require repair or routine preventive upkeep, appropriate priority was assigned, and work commenced in a timely manner.
Plant equipment conditions such as cleanliness, leakage, lubrication,
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and cooling water were controlled and adequately maintained.
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f Areas of the plant were clean, unobstructed, and free of fire j
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hazards.
Fire suppression systems and emergency equipment were
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. maintained in a condition of readiness.
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Security measures and radiological controls were adequate.
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The NRC-inspectors reviewed and observed performance of the following procedures on February 19, 1987:
OP 2.1.2, " Hot Startup Procedure," Revision 26, dated September 4,
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1986 S0P 2.2.6, " Condensate System," Revision 24, dated December 18, 1986
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S0P 2.2.14, "22KV Electrical System," Revision 23, dated May 15, 1986
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50P 2.2.28, "Feedwater System," Revision 40, dated February 12, 1987
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i S0P 2.2.60, " Primary Containment Cooling and Nitrogen Inerting
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System," Revision 32, dated February 12, 1987 50P 2.2.77, " Turbine Generator," Revision 27, dated December 28, 1986
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NPP 10.13, " Control Rod Sequence and Movement Control," Revision 15,
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-dated October 30, 1986 The NRC inspectors performed lineup verifications of valves in the following systems:
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No. 1 Diesel Generator Starting Air (DGSA)
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Plant Air System for No. 1 Diesel Generator Service Air / Instrument
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Air (PS)
Primary and Secondary Containment Isolation (PC)
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"A" Core Spray (CS)
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In preparation for performing the system walkdown of the DGSA and PS systems for No. 1 diesel generator, the RI conducted a review of and comparison between the following licensee's DGSA and PS systems valve i
checklists and applicable as-built drawings:
Systems Operating Procedure (S0P) 2.2.20, " Standby AC Power System
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(Diesel Generator)," Revision 23, dated January 1, 1987; Appendix A,
" Valve Checklist 3" f
As-Built drawing Burns & Roe 2077; for DGSA system
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As-Built drawing Cooper Bessemer KSV-48-5; for DGSA system
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l As-Built drawing Cooper Bessemer KSV-36-7; for DGSA system
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l Appendix A, " Valve Checklist'l and 2"
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.As-Built drawing Burns &~ Roe 2010; Sheets 1 and 3 for DGIA/SA System-
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The~ review identified the following:
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50Pl2.2.-20 Appendix ~"A" listed 39 valves that were not numbered or
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! labeled on' applicable as-built Drawing KSV-48-5.
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Orawing KSV-36-7 had two valves not numbered or labeled and not
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listed on 50P 2.2.20 Appendix "A".
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Drawing KSV-36-7 had two labeled pressure switches that were not
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listed on S0P 2.2.20 Appendix "C".
'One. valve exists in the system that was not documented on either
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Drawing KSV-36-7 or 50P 2.2.20 Appendix "A".
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50P 2.2'.59 Appendix A listed one valve that was not numbered or
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labeled.on applicable as-built Drawing 2010, Sheet 3 of 3.
These deficiencies are similar to the violation that was documented in NRC Inspection Report 50-298/86-14, paragraph 5, and similar to Open Items 298/8626-01, and 298/8636-04, identified in NRC Inspection Reports 50-298/86-26, and 50-298/86-36, respectively.
These three items
' will be tracked as an open item pending review of licensee's corrective action.
(298/8706-05)
.The tours, reviews, and observations were conducted to verify that
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facility operations were performed in accordance with the requirements established in the CNS Operating License and Technical-Specification.
No violations or deviations were identified in this area.
- 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
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approved procedures.
Procedures conformed to Technical Specification requirements.
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Tests prerequisites were completed including conformance with
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applicable limiting conditions for operation, required administrative approval, and availability of calibrated test equipment.
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-Tes't data was reviewed for_ completeness, accuracy, and conformance
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with-established criteria and Technical Specification requirements.
Deficiencies were corrected in a timely manner.
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The system wa's' returned to service.
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The RI observed.the licensee's performance of the following surveillance tests on the indicated dates:
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February 3, 1987:
Surveillance Procedure (SP) 6.1.5, "RTS High.
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Reactor Pressure Calibration and Functional / Functional Test,"
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Revision 15, dated July 17, 1986
.The reviews and observations were conducted to verify that facility surveillance operations were performed in accordance with the requirements l.
established in the CNS Operating License and Technical Specification.
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F No violations or deviations were identified in'this _ area.
11.
Monthly Maintenance Observation.
l The NRC inspectors observed preventive'and corrective maintenance activities. The'se observations verified-that:
Limiting conditions for operation were met.-
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l Redundant equipment.was operable.
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Equipment was adequately isolated and sa'fety tagged.
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Appropriate administrative approvals were obtained prior to
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l commencement of work activities.
Work was performed by qualified personnel in accordance with approved-
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procedures.
p Radiological controls, cleanliness practices, and appropriate fire
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prevention precautions were implemented and maintained.
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I Quality' control _ checks and postmaintenance surveillance testing were
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performed as required.
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Equipment was properly returned to service.
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The RI observed the licensee's performance of the following maintenance
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test on the indicated date.
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i February 10, 1987:
Design Change (DC)86-088, "NPS Modification for.
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Shredder-Compactor" I
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[ February 10, 1987: 'EquipmentSpecificationChange;($5C)87-67,
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" Replacement:of Micro-Wave Head Units" February 10, 1987:
Instal'lation of = Lagging On Emergency _ Condensate
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Storage Tank (ECST)
February. 10, 1987: Maintenance on Circulation Water Traveling
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Screen C2
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-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 Specification.
No violations"or deviations were identified in this' area.
12.
Unresolved Items-An unresolved item is one about'which additional information is required in order to determine if the item is acceptable, a violation or a deviation. The following unresolved items were identified during this inspection:
Item Paragraph Subject 298/8706-02
50.59 Review of RHR Minimum Flow 13.
Exit Interviews Exit. interviews were conducted at the conclusion of each portion of the inspection.
The.NRC inspectors summarized the sccpe.and findings of each inspection segment at' those meetings.--
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