IR 05000298/1987019
| ML20238D651 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/08/1987 |
| From: | Dubois D, Jaudon J, Plettner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20238D638 | List: |
| References | |
| 50-298-87-19, NUDOCS 8709110306 | |
| Download: ML20238D651 (14) | |
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APPENDIX
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.U.'S.
NUCLEAR REGULATORY COMMISSION I
REGION IV.
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NRC' Inspection Report: 50-298/87-19
' License: DPR-46
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. Docket:; 50-2983 9'
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i.icensee: Nebraska Public Power District (NPPD)
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=P. 0.: Box 499
Columbus, NE-68601
Facility 1 Name: Cooper Nuclear Station (CNS)
Inspection At: Cooper Nuc1 car Station, Nemaha County, Nebraska Inspection'. Conducted : July 16-August 31,.1987 cInspectors: 6 IM,,
9///f7 E. A. Plettner, Resident Inspector, (RI)
D#te'
Wsexh Uso/r/
D. L. DuBois, Senior Resident Inspector, (SRI)
Date Approved:
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P./Jaudog, Chief, Project ection A, Date [
Rea& tor P'roject Branch I
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8709110306 870909 PDR ADOCM 05000298 G
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Inspection Summary-
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Inspection Conducted' July'16=through August 31,.1987-(Report 50-298/87-19)
~ Areas Inspected:' Routine, unannounced. inspection ~of licensee action on previous.
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- inspection findings. notification of an unusual' event, 10 CFR Part 21 reports,
' spent ~ fuel shipments, operational safety verification, security,: radiological
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_ protection, monthly-surveillance, and maintenance activities.L
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Results:. :Within thu. areas inspected, no violations ~ or deviations were
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. identified.
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-DETAILS l.'
P'ersons Contacted
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. Principal Licensee Employees
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- G. R. Horn,. Division Manager of Nuclear Operations
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?*J. M.:Meacham, Senior Manager,: Technical Support
- C; R. Goings-Merrill, Regulatory Compliance Specialist
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- R. D. Black, Supervisor, Operations-
- M.iD. Hamm,~ Supervisor, Security-
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- E. ;M.~ Mace, Manager, Engineering
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- G. : Smith,_ Manager, Quality Assurance
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- J.. Sayer, Manager, Radiation
- D. Norvell, Manager, Maintenance
- S. Peterson, Acting Manager, Plant Service
- R. Brungardt, Manager, Operations
- L. Clark, Supervisor, Electrical A. J. Hubl,- Mechanical Engineer I K. J. Done, Supervisor, Mechanical' Engineering The NRC _ inspectors.also interviewed other licensee employees during the course of_the inspection.
-* Denotes those present during.the' exit interview held on August 26, 1987.
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2.
-Licensee Action on Previous Inspection Findings The following violations and unresolved items were reviewed by the NRC inspectors to. verify that the licensee's responses to the items identified in previous _ inspection reports are now in conformance with regulatory-requirements and that corrective measures were completed in a timely manner.
(Closed) Violation (298/8531-01):
Secondary Containment Integrity.
This violation contained two separate elements. The first element involved electrical jumpers which were installed on auxiliary trip units of the reactor building ventilation radiation monitor. -Those jumpers would have prohibited automatic reactor t.uilding isolation and standby gas treatment system initiation upon receipt of a reactor building ventilation monitor high radiation signal. The jumpers were installed during surveillance testing and were not removed after testing was completed. The licensee's-corrective actions were as follows:
Surveillance Procedure (SP) 6.3.7.5, " Reactor Building Ventilation
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Radiation Monitor Calibration and Functional / Functional Test " was revised to include:
(a) clarification of the procedural steps o
requiring installation and removal of electrical jumpers, and (b) independent verification of electrical jumper removal.
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All CNS surveillance procedures were reviewed and independent l
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verification steps were added as needed.
The RI reviewed the above licensee actions and determined that those actions were completed and adequate.
Element two of this violation involved the licensee's failure to properly
. identify drywell snubbers that had visible indications of impaired-operability while in an operational mode other than COLD SHUTDOWN or REFUELING, during'the period of August 20 through October 5,1985. The licensee corrective e.ctions were as follows:
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Maintenance frocedure (MP) 7.2.34." Snubber Inspection," was revised
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to include:
(a) ASME Code,Section XI requirements for inspector and reviewer certification, (b) individual hydraulic and mechanical snubber checklists as Attachments E and F, (c) bracket / clamp Attachment G, and (d) hydraulic and mechanical snubber nomenclature Attachments H,'I, and J.
MP 7.2.52, " Snubber Removal and Installation," was revised to include
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hydraulic and mechanical snubber nomenclature Attachments G and H.
Related inservice inspection procedures were revised to include -
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specific inspection criteria.
A comprehensive training program was developed to include lesson
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plans, training aids, and visual inspection qualification criteria.
A program was developed to train and qualify designated inspectors to
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perform snnber inspections.
I program was developed to revise existing or create new drawings as
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necessary to better define the criteria for each snubber, including the snubber attachments and potential interfaces.
The 11 reviewed the above licensee actions and determined that those actions were completed and acequate.
This item is closed.
(Closed)UnresolvedItem(298/8607-01):
Classification of the Alternate Shutdown System.
This item contained two separate elements. The first element involved alternate shutdown panel instrumentation purchase orders (P0s) that did not identify whether the instruments were classified as essential or not.
In a letter from the NRC Office of Nuclear Reactor Regulation (NRR) to the Chief, Project Section A, NRC Region IV, dated April 22, 1986, the NRC Project Manager for CNS stated, " Assuming the shutdown panels were
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installed to satisfy the requirements in 10 CFR 50.48 only, they need not meet EQ Appendix B and seismic criteria." Therefore, the licensee's classification of the instruments was correct.
The second element concerned ambiguous wording in Engineering Procedure 3.13, " Equipment Classification," which could result in the licensee classifying fire protection equipment as either essential or nonessential. The RI reviewed Engineering Procedure 3.13, " Equipment Classification," Revision 3, dated April 30, 1987, to verify that ambiguous wording was changed to clearly classify fire protection equipment as nonessential.
This item is closed.
(Closed) Violation (298/8613-01):
Failure to Fully Implement the Design
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Change Procedure.
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This item involved Engineering Procedure 3.4, " Station Design Changes,"
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Revision 3, dated December 26, 1985, which implements design change controls.
The licensee's corrective actions included the following:
An on-the-spot change was generated to Design Change (DC) 83-23 to
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properly document the work performed on WI 83-2112.
An on-the-spot change was generated to add a list of procedures to the
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document section of DC 80-84 for the design engineer to consider for possible revision as a result of the design change.
Non-Conformance Report (NCR) 5034 was generated to ensure the final
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review was performed and the signature block filled in as required by the design engineer.
Engineering Procedure 3.4 was revised to clearly state that status
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reports will be submitted for all completed design changes within 10 working days, or prior to plant startup, whichever comes first.
The RI reviewed the above licensee actions and determined that those actions were completed and adequate.
This item is closed.
(0 pen)UnresolvedItem(298/8636-01):
Diesel Sequential Loading.
This item required information on three separate elements dealing with diesel sequential loading.
The licensee provided sufficient information to close the following two elements:
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Motor.' Control Center (MCC) (K) or (S) is not part of the load shedding i
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and loading sequence on the IF'for.MCC (K) or IG for MCC (S) emergency
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switchgear busses.
The~ standby gasftreatment (SGT)' fans start automatica11y'when MCC (K)
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for Train "A" and MCCl(S) for Train "B" are, energized because the high
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drywell pressure ' signal' is present when performing SP 6.3.4.3,-" Diesel
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Sequential Loading." The time delays for the SGT Fans function only
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when the respective fan is. selected inistandby and SGT not related to the sequential loading _ test.
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~ The third element. involved the lack of a-timing requirement on-the monthly surveillance and will remain unresolved pending a review by NRR.
'3.
Notification 'of an Unusual Event (NOVE)
On ' August' 8,1987, at 2:38 a.m. (CDT) ~ a reactor building to torus vacuum
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breaker failed in the open position because of a loss of instrument. air.
The loss of instrument air.~was attributed to a failure of an air filter gasket located in the instrument air supply line to that valve. No other valves supplied by. the instrument airLsystem were affected. Approximately 2 minutes after the vacuum breaker opened, the reactor operators noted a
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decreasing suppression chamber pressure which was indicative of a primary
containment leak to the reactor building. The licensee's investigation '
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found that a checkvalve located in series with the open vacuum breaker was leaking. An operator manually agitated the 21-inch checkvalve until the checkvalve seated. The'CNS Technical Specification (TS) Section 3.7.A,
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" Pressure Suppression Chamber Reactor Building Vacuum Breakers," did not specifically address the abnormal conditions stated above. Therefore, the licensee referred to the TS definition of " limiting conditions for operations (LCO)" in Section 1.J. which states, "In the event an LC0 cannot be satisfied because of circumstances in excess of those addressed in the specification, the facility shall be placed in hot shutdown within
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30, unless corrective I
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measures are completed to permit operation under the LC0 for the specified time interval as measured from initial discovery." Also, the CNS Emergency Plan Implementing Procedures, Section 5.7.1, " Emergency Classification," in Attachment B, Section 6.1.1, requires the licensee to implement a NOUE when j
any TS LCO results in a reactor shutdown. The licensee commenced a normal j
shutdown and subsequently declared a NOUE at 3:20 a.m.
An emergency work
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request-(EWR) was generated to perform the required repairs to restore instrument air to the valve. Repairs were satisfactorily completed, and the NOUE was terminated at 5:50 a.m.
The licensee resumed normal power operation and returned reactor power to 100 percent later that day.
4.
Part 21 Reporting of Defects and Noncompliance
l The following-10 CFR Part 21 report was reviewed by the RI for applicability j
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(Closed) 10 CFR Part 21 Report 8703250444; NRC Region IV No. P21-87-45,
" Potential Design Defect in Bingham /Willamette RHR Pumps Flow Capacity."
This Part 21 report identified a change in the minimum flow rate for i
the RHR pumps. This item was first documented in NRC Inspection
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Report 50-298/87-06, paragraph 6 and closed in NRC Inspection
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Report 50-298/87-09, paragraph 2.
This item is closed.
5.
Spent Fuel Shipment The NRC inspectors inspected the licensee's activities associated with two shipments of spent fuel from CNS.
Included in those inspections were observations and reviews of applicable procedures, documentation, surveys, inspections, and shipping document preparation.
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
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Shipping documents
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Advance notification of and approval by affected state and federal
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agencies-Proper placarding of the transport vehicles
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Appropriate labeling of the spent fuel shipping casks
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Establishment of provisions for response by escorts and local law
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enforcement agencies Training of escort personnel
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Testing of communications systems
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Continual manning of the licensee's communications center (Movement
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Control)
Testing of fuel and cask handling cranes, hoists, and tools
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Proper loading and sealing of the spent fuel shipping casks
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Surveillance of area radiation monitors, ventilation systems, and
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spent fuel pool water level and chemistry Update of fuel locaticn and accountability records
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Applicable quality assurance audits and inspections
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U.S. Dep'artment of Energy and U.S. NRC, " Nuclear Material Transaction
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Report, DOE /NRC Fonn 741 Bill of Lading
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CNS Health Physics' Procedure 9.5.3.7, " Cask IF-300 Shipment,"
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Revision 3, dated December 26, 1985 CNS Nuclear Performance Procedure 10.27, " Cask IF-300 Handling and
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Shipping," Revision 8, dated June 18, 1987 CNS HP-138, " Contamination Survey - Sample Count Data Sheets"
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CNS HP-141, " Contamination Survey - Railroad Car for IF-300 Irradiated
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Fuel Shipping Cask" CNS HP-142, " Contamination Survey of IF-300 Shipping Casks"
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CNS HP-143, " Radiation Survey of IF-300 Shipping Cask"
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CNS HP-608, " Spent Fuel Shipment Checkoff Sheet and Certificate of
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Compliance of Number 9001 Conditions for Shipping Spent Fuel" CNS HP-14a, " Radioactive Material Shipment Record"
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The following independent radiation and contamination surveys were performed by the SRI on August 18, 1987, and verified to be satisfactory:
Contact radiation surveys of the shipping casks
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Radiation surveys at a distance of 2 meters from the cask transport
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vehicles Contamination surveys of the shipping casks surfaces
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Contamination surveys of the cask transport vehicles
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The spent fuel shipments left the CNS on July 21 and August 18, 1987.
Each shipment consisted of 2 spent fuel shipping casks, and each cask contained 18 spent fuel bundles. The shipments were transported to the G.E. Morris Operation Complex, Morris, Illinois.
The spent fuel casks identification numbers were:
IF-301 and 304 shipped on July 21, 1987
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IF-302 and 304 shipped on August 18, 1987
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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 Specification.
i No violations or deviations were identified in this area.
6.
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 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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Plant logs and records were complete, accurate, and indicative of
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actual system conditions and configurations.
System pumps, valves, control switches, and power supply breakers were
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properly aligned.
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 was within permissible 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.
Equipment safety clearance records were complete and ind:cated that
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affected components were removed from and returned to service in a 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.
The conditions of the plant and equipment such as cleanliness,
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leakage, lubrication, and cooling water were controlled and adequately maintaine _.
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l Areas of the plant were clean, unobstructed, and free.of fire hazards.
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Fire suppression systems and emergency equipment were maintained in a condition of readiness.
Security measures and radiological controls were adequate.
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The NRC inspectors performed a lineup verification of the following systems:
Automatic Depressurization
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Service Water Booster
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Vital Instrument Power (VIP)
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In preparation for performing the system walkdown of the VIP, the RI conducted a review of and comparison between the following licensee VIP system checklist and applicable as-built drawings:
System Operating Procedure (SOP) 2.2.22, " Vital Instrument Power
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System," Revision 17, dated July 16, 1987, Appendix B, " Breaker and Fuse Index" As-Built Drawing Burns & Roe 3010 for VIP System
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The review identified labeling deficiencies between S0P 2.2.22 Appendix B Breakers and Fuse Index, Revision 16. Burns and Roe Drawing 3010, and the labels on the breaker box. The deficiency exists because several design changes were implemented. When notified, the licensee initiated prompt action to correct the deficiency in labeling between the breaker box and
' SOP 2.2.22, Appendix B.
Drawing change notices were issued as part of the design changes to update Burns and Roe Drawing 3010. Because this deficiency appeared to fall within the scope of ongoing licensee corrective action resulting from a violation cited in NRC Inspection Report 50-298/86-14, it is not made a violation herein, but will be tracked as an open item.
(298/8719-01)
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 Specification.
'l No violations or deviations were identified in this area.
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7.
Security The NRC inspectors verified that the physical security plan was being implemented by their observations of the following:
Minimum manning requirements for the security organization were met.
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Personnel within the protected area (PA) displayed their
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identification badges.
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Vehicles were properly authorized, searched, and escorted or
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B controlled within the PA.
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Persons and packages were properly checked before entry into'the PA was permitted.
Effectiveness of, the _ security program was maintained when security
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equipment failure or impairment required compensatory measures to be
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The'PA barrier was maintained and the isolation zone kept free of-
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Vital area barriers were maintained and not compromised by breaches or
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weaknesses.
111uminatthnofithePAwas~ adequate.
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Security monitors at the secondary and central, alarm stations were
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performing their. intended functions.
l No violations or deviations were identified.
8.
Radiological Protection
'The NRC. inspectors verified that selected activities'of the licensee's radiological protection program were implemented in conformance with facility policies, procedures, and regulatory requirements. The activities listed below were observed and/or reviewed:
Health physics (HP) supervisory personnel conducted plant tours to
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check on activities in progress.
Radiation work permits contained the appropriate information to ensure
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work was performed in a safe and controlled manner.
Personnel in radiation controlled areas (RCA) were wearing the
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required personnel monitoring equipment and protective clothing.
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Radiation and/or contaminated areas'were properly posted and
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i controlled based on the activity. levels within the area.
l Adequate frisking was performed by personnel prior to exiting an RCA.
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No violations or deviations were identified, c
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Monthly Surveillance Observations The NRC inspectors observed Technical Specification-required surveillance -
tests. Those' observations verified that:
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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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Test 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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Test 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 was returned to service.
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The RI observed the licensee's performance of the following surveillance test on the indicated date:
August 8, 1986:
SP 6.4.1.2, " Withdrawn Control Rod Operability,"
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Revision 16, dated December 18, 1986 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 Specification.
No violations or deviations were identified in this area.
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Monthly Maintenance Observation The NRC inspectors observed preventive and corrective maintenance activities.
These observations verified that:
Limiting conditions for operation were met.
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Redundant equipment was operable.
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Equipment was adequately isolated and safety tagged.
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Appropriate administrative approvals were obtained prior to
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commencement of work activities.
Work was performed by qualified personnel in accordance with approved
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procedures.
Radiological controls, cleanliness practices, and appropriate fire
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prevention precautions were implemented and maintaine. _ _ _ _ _
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Quality control checks and post-maintenance surveillance testing were
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performed as required.
Equipment was properly returned to service.
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The RI observed the licensee's performance of the following maintenanc0 test on the indicated date:
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July 31, 1987: Maintenance Work Item 87-246, " Sludge Pond PH Recorder'}
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During a daily routine review of the shift supervisor's log, the RI n6Eed:
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that two iodine monitor detectors had failed on August 10, 1987. One-detector monitors drywell (DW) atmosphere and the other detector monifars air intake to the control room (CR). The DW detector has a Technical Specification (TS) LC0 of 30 days when inoperable. The CR detector has a
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TS LC0 of 7 days when inoperable. Both LC0's were in effect. Personal interviews were conducted by the RI with the onshift supervisor and the I&C technician who performed the work to determine the cause of both detectors failing. The interviews revealed that the normal trouble
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i shooting technique employed by the I&C technician was to substitute a known spare working detector into the troubled system to determine if the problem was the detector or in the electronics to support the detector.
In this instance, no spare working detector was available. An alternative method used in the past when no spare detectors were available was to substitute a detector from a working system and use it in the troubled system. This alternate method was discussed with the shift supervisor by the I&C technician.
It was resolved that since this practice had been allowed in the past that it would be allowed in this instance.
In the past, the CR detector had been used as a substitute for the DW detector without any problems. The substitution proved that the DW detector was indeed faulty.
Upon reinserting the CR detector into the CR monitor system, the detector suddenly ceased to function. High voltage was present at the time of the connection which was a standard practice during removal and reinstallation in the past. Subsequent repairs to each detector were made and both systems were returned to operation on August 12, 1987. Although, no TS
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limits were exceeded, the NRC inspector concluded that it was poor practice to remove an operating system from service to perform troubleshooting on another system. Licensee representatives indicated agreement with the conclusion.
No violations or deviations were identified in this area.
i 11. Exit Interviews Exit interviews were conducted at the conclusion of each portion of the inspection. The NRC inspectors sumarized the scope and findings of each inspection segment at those meetings and at a summary exit interview on August 26, 1987.
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