IR 05000298/1988021
| ML20151S117 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/05/1988 |
| From: | Barnes I, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151S111 | List: |
| References | |
| 50-298-88-21, NUDOCS 8808150077 | |
| Download: ML20151S117 (9) | |
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APPENDIX'
U.S. NUCLEAR REGULATORY COMMISSION REGION IV'
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NRC Inspection Report: - 50-298/88-21 Operating License: DPR-46 Docket:
50-298 Licensee: Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68601 Facility Name:
Cooper Nuclear Station (CNS)
Inspection At:
CNS, Brownville, Nebraska Inspection Conducted: June 20-24 and July 11-15 1988
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Inspector:
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R. C. Stewar:t,Wdt3F Inspector, Materials Date and Quality Programs Section, Division of Reactor Safety Accompanying Personnel:-
Robert S. Hartley, EG&G Idaho, Inc., NRC Contractor
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Approved:
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% Barnes, Chief, Materials and Quali g Date l-
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Inspection Summary Inspection-Conducted June 20-24 and July 11-15, 1988 (Report 50-298/88-21)
Areas Inspected:
Routine, unannounced inspection of actions on previous inspection findings and the licensee's implementation of the inservice testing (IST) program for pumps and valves.
Subject activities. reviewed in the IST area included program overview / organization, test procedures and results, test witness, IST trending, quality assurance audits, training qualifications, and IST maintenance activitiss, Results: Within the areas inspected, no violations or deviations were identified, e
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DETAILS 1.
Persons Contacted
- G. R.' Horn, Division Manager, Nuclear 0perations
- J. R. Flaherty, Plant Engineering Supervisor
- P. L. Ballinger, (Acting) Engineering Manager
- J. L. Peaslee, Surveillance Coordinator
+*R. A. Schultz, Inservice Inspection (ISI)/ Inservice Testing (IST) Engineer
+*G. R. Smith, Licensing Supervisor
- G. F. Smith, Quality Assurance (QA)pecialist
- L. E. Bray, Regulatory Compliance S Manager The NRC inspector also interviewed other licensee employees during the inspection.
- Denotes those attending the exit interview on June 24, 1988.
+ Denotes those attending the exit interview on July 15, 1988.
(Attendance limited because of plant outage)
2.
Action on Previous NRC Inspection Findings (92702)
(Closec) Violation (298/8804-01):
Failure to perform receipt inspection of and assure identity of diesel generator cooling fan blades.
During this inspection, the NRC inspector examined the four diesel generator cooling fan blades stored in the warehouse.
Ghost images of the stamping
"6061-T6" were visible under natural lighting on all four blades.
In addition, the NRC inspector verified that a letter dated May 26, 1988, advised all station personnel of the receipt inspmtion requirements contained in Plant Services Procedure 1.5.
As a result of the verification of material identity markings being present on the fan blades, Item 1 of Violation A (Inspection Report 50-298/88-04) is no longer considered to be'a violation.
Item 2 of this violation is considered closed.
(Closed) Violation (298/8804-02):
Failure to have procedures required by 10 CFR Part 21.
During this inspection, the NRC inspector reviewed the Nuclear Power Group Directive, "10 CFR 21 - Reporting of defects and Noncompliance," dated May 26, 1988, and Attachment A, "Checklist for 10 CFR 21 Reports to NRC."
The NRC inspector had no further questions regarding this matter.
This item is considered close (
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3.
IST Program - Pumps and Valves (73756)
The objectives of this inspection were to evaluate the implementation of the CNS IST program for safety-related pumps and valves, and to assess the adequacy of the testing performed with respect to licensee commitments and requirements of Section XI of the ASME Code, a.
IST Program Overview The NRC inspector ascertained from review of the IST Program Plan review that the CNS IST program is subject to the requirements of 10 CFR 50.55a(g) and the ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWP and IWV, 1980 Edition through the Winter of 1981 Addenda. 'The current CNS IST Program Plan is currently being implemented under Revision 4 and covers the second 10-year testing interval from July 1, 1984, through July 1, 1994. The plan is presently under transition to Revision 5, which was originally submitted on July 30, 1986, to the NRC for review, and is in the process of amendment in response to the IST Program Safety Evaluation Report (SER)issuedJanuary 13, 1988, by NRC. This amendment involves significant revision of existing surveillance test procedures and the incorporation of additional components into the IST program.
The NRC inspector discussed with licensee representatives an apparent lack of timeliness in updating test procedures to be consistent with SER approvals / denials. Licensee personnel committed to the NRC inspector to submit the following documents to the NRC staff by July 31, 1988:
A schedule for surveillance test procedure revisions.
Revised relief requests for those denied in the SER and details
of other significant changes to Revision 5 of the CNS IST Program Plan.
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Submittal of these documents is considered an unresolved item (298/8821-01).
b.
Program Organization / Responsibilities During the NRC inspector's review of the IST Program Plan relative to personnel organization and assignments, he observed that the plan incorporates CNS Engineering Procedures 3.9, "Inservice Testing of l
Pumps General Procedure," and 3.10. "Inservice Testing of Valves i
l General Procedure."
The procedures define the rules and requirements for inservice l
testing to assess operational readiness of certain Class 1, 2, and 3
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pumps and valves and include plans and schedules, containing
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references to detailed examination and testing procedures.
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The above procedures appeared to be both adequately detailed and to demonstrate conformance to the requirements of A3ME Section XI; however, under Section A.1.b. of each procedure reference is made to:
"All personnel assigned to interpret, evaluate, and review inservice test results shall be considered qualified when having
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working knowledge of ASME Section XI, Subsection IWP, and applicable standards, specifications, and station surveillance testing procedures. Qualifications of personnel shall be documented per the Plant Engineering Department system assignments and responsibilities listing, as maintained by the Plant Engineering Supervisor, and the station Q.C. qualification listing."
The NRC inspector's subsequent review of the Plant Engineering Department system assignments and responsibilities listing (as referenced above) revealed minimal clarification as to the scope of duties and responsibilities of assigned IST personnel.
In discussing this matter with the cognizant licensee representatives, the NRC inspector was informed that revisions to the IST procedures will incorporate clarification as to specific duties and assignments of engineering personnel assigned to the IST program. This item is considered open pending NRC review of the revised procedure (298/8821-02).
c.
IST Maint_enance Activities
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During this inspection, the NRC inspector made a random selection of maintenance work items related to IST Category C valves (Code Section IWV-3500, Safety Valve, Relief Valve and Check Valve Tests)
that require disassembly and inspection on a surveillance frequency prescribed by the licensee's IST approved program.
Maintenance work items selected for review and associated valves and documents were as follows:
Work Item 86-3495:
Check Valves 3W-CV-35CV, -36CV, -37CV, and
-38CV; and Implementing Surveillance Procedure 6.3.10.16, "Check Valves in Cooling System of Diesel Generators Integrity Verification."
Work Items 88-0239 and 88-0531: Main Steam Relief Valves MS-RV-708, -70C, -718 and -71C; and Implementing Surveillance Procedures 7.2.22, "Main Steam Relief / Safety Valve Removal, Disassembly, Inspection, Rework, Reassembly, and Installation,"
and 7.2.3, "Main Steam Safety Valve Periodic Testing, Inspecticn, Removal, and Installation," Wyle Laboratories Certification Test Reports 47505-1 dated May 20, 1985; 47505-2 dated May 23, 1985; 49152-0 dated April 11, 1988; 49152-5 dated April 11, 1988; and 49152-7 dated April 18, 198.
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Work Item 88-0958: Steam Supply to RHR Hx.B, Relief Valve, RHR-RV-19RV; and Implementing Procedure.7.2.35, "Safety and Relief Valve Testing."
During the above records review, the NRC inspector made a comparative review of the requirements of IWV-3500 ASME Section XI Code and implementing surveillance procedures,. relative to the work item documented records.
It was observed by the NRC inspector that implementing procedures were adequately detailed through the initial work requests, removal, disassembly, inspection, and reinstallation and tests, including nondestructive examination Quality Control (QC)
hold points and independent QC verification.
The NRC inspector also observed that all main steam relief / safety valves are removed and shipped to Wyle Laboratories on an alternating 3-year cycle for refurbishment and testing.
In reviewing the Wyle
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certification test reports, it was observed by the NRC inspector that disassembly and refurbishment was conducted by the valve manufacturer's representatives with Wyle assistance and recertified in accordance with Wyle Laboratories Test Procedure 1018.
No violations or deviations were identified.
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d.
QA Audits During this inspection, the NRC inspector reviewed ISI/IST Audit Report No. 86-22, conducted during October 6, 1986 through March 4, 1987. The QA audit was performed in accordance with CNS QA Procedure QAP-1500 and encompassed both the ISI and IST activities.
It was observed by the NRC inspector that the audit was principally oriented toward safety systems testing overview and did not include the IST administrative program aspects. This observation was discussed with the cognizant QA representative. The QA audit did not identify any significant discrepancies.
No violations or deviations were identified.
e.
Test Procedures / Data Review Review of IST Procedures and Test Results During the inspection, the NRC inspector made a random selection of completed IST surveillance test procedures. These were reviewed to
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ensure that they contained reference values and other pertinent attributes prescribed by guidelines of the ASME Code,Section XI, Articles IWP/IWV-3000.
In some cases, these procedures did not fully comply with the Code requirements due to pending relief requests or increased testing as specified in the SER (i.e., measurement of pump vibration in units of velocity).
Further revisions to the surveillance test procedures are anticipated or nearing completio,
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The NRC inspector also reviewed test procedure changes nearing final approval by the Station Operations Review Committee.
Procedures selected included the following:
Test Procedure 6.3.1.4, "Normally Open Containment Isolation
Power Operated Valve Operation and Closure Timing Test,"
Revision 12. Test results were reviewed for all tests performed in 1987
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Test Procedure 6.3.6.2, "RCIC Motor Operated Valve Operational Test." Reviews were of tests performed in 1987 and a valve
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position indication verification test perfnrmed January 29, 1988.
Test Procedure 6.2.5.1, "Suppression Chamber Reactor Building Vacuum Breaker Functional Test," Revisions 17 and 18.
Reviews were made of tests performed from January through May 1998..
Test Procedure 6.3.4.1, "CS Test Mode Surveillance Operation,"
Revision 23. Tests performed in 1988 were reviewed.
Test Procedure 6.3.18.3, "SW Surveillance Operation,"
Revision 20. Tests performed in 1983 were reviewed. During a test performed May 20, 1988, one pump fell into the high alert range for differential pressure and the appropriate corrective action was verified to have been taken.
Test Procedure 6.3.16.2, "REC Motor Operated Valve Operational Test." These tests did not require the performance of power operated valve stroke timing, however, this procedure is being revised as required by the SER.
Test Procedure 6.3.3.1, "HPCI Test Mode Surveillance Operation,"
Revision 29 (approved July 14, 1988, not yet performed).
No violations or deviations were identified.
f.
Test Witness On July 13, 1987, the NRC inspector witnessed plant operations and engineering personnel performing an IST functional test on a HPCI pump using Test Procedure 6.3.3.1, "HPCI Test Mode Surveillance Operation," Revision 28.
This test was coordinated by a senior reactor operator, located in the control room, in control of each step of the test procedure.
The NRC inspector verified that both the permanently installed and all portable instrumentation used for IST data (other non-IST data was taken during the conduct of this test) were within current calibration
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due dates.
The test acceptance criteria was clearly defined and included in the prccedure.
Valve stroke timing was performed during
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i conduct of this test in accordance with the ASME Code requirements, y'-
It should be noted that the procedure has since been revised to
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conform with statements in the SER to set driver speed and pump flow, and to place limits on the dependent variable (differential pressure)
in accordance w:th the Code requirements.
Further, the licensee's request for relief from the Code requirements concerning measurement of pump vibration is being revised and resubmitted to NRC for approval and may result in further change to this test procedura.
No violations or deviations were identified, g.
IST Trending During this inspectica, the NRC inspector reviewed the licensee's IST component trending program status. A random sampling of valve stroke time trending data showed that the appropriate corrective actions were being performed for out-of-specification stroke time readings.
A limited review was also performed on the pump trending data.
No violations or deviations were identified.
h.
Training / Qualifications During this inspection, the NRC inspector selected for review the training / qualification records of three technical staff members who have been assigned specific duties in the IST program.
In addition, the NRC. inspector reviewed the licensee's training schedules and curriculum required for technical staff personnel.
No violations or deviations were identified.
4.
Summary of Findings This inspection verified that the licensee has administrative controls and procedures to implement the IST program.
Procedural guidance is provided to aid the operators in verifying equipment operability and limitations.
Recorded performance data, reviews, and evaluations appeared to be in accordance with ASME Code and IST Program Plan requirements. A weakness in timely updtting of test procedures to be consistent with current program relief requests and NRC approvals / denials, was discussed at length with the licensee representatives (paragraphs 3.a and 3.e above).
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Unresolved Items
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. Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph 3.a.
6.
Exit Interviews The NRC inspector met with the licensee personnel' denoted in paragraph 1 on June 24 and July 15, 1988,.respectively.
The NRC inspector summarized the purpose, scope, and findings of the inspection, i
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