IR 05000298/1989002
| ML20235T848 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/27/1989 |
| From: | Barnes I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20235T837 | List: |
| References | |
| 50-298-89-02, 50-298-89-2, NUDOCS 8903080497 | |
| Preceding documents: |
|
| Download: ML20235T848 (13) | |
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APPENDIX U.S. NUCLEAR REGULATORY. COMMISSION
REGION IV
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NRC Inspection Report:
50-298/89-02 Operating License:
DPR-46 Docket:
50-298
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Licensee:
Nebraska Public Power District (NPPD)
P.O. Box 499-Columbus, NE 68602-0499 Facility Name:
Cooper Nuclear Station (CNS)
Inspection At:
NPPD Offices, Columbus, NE Inspection Conducted: 1 January 23-27, 1989 Inspectors:
L.-Gilbert, Rcactor Inspector, Materials and Quality Programs Section (M&QPS), Division of Reactor Safety-(DRS)
R. Stewart, Reactor Inspector, M&QPS, DRS A.' Singh, Reactor Inspector, Plant Systems Section (PSS), DRS P. Wagner, Reactor Inspector, PSS, DRS Approved:
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24.7/97 lan Barnes, Chief, Materials and Quality Date Programs Section, Division of Reactor Safety Inspection Summary Inspection Conducted January 23-27, 1989 (Report 50-298/89-02)
Areas Inspected:
Special, announced inspection of the engineering and technical support capabilities and activities for the CNS which were provided by the NPPD offsite staff.
The NRC inspectors ' reviewed the NPPD Nuclear Power Group organization, concentrating mainly on the Nuclear Engineering and Construction Division.
The staffing and expertise of the organization together with the procedural controls and interactions with other organizations was evaluated.
The NRC inspectors also reviewed records of audits of the engineering function which had been conducted by NPPD Quality Assurance (QA)
Division.
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The NRC inspectors, selected ten design change packages for detailed review in order to evaluate the quality and completeness of the engineering activities.
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>The packages were selected from changes implemented on the residual heat removal (RHR) system over the plant life,.to obtain a perspective on past and present activities over a variety of engineering disciplines.
The NRC inspectors also discussed the NPPD Configuration Management Plan.
Results:
The NRC i'nspectors identified one violation (failure to update a
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drawing properly, paragraph 3.d) during the inspection of design change packages.
The NRC inspectors found the other design changes to have been implemented acceptably.
The NRC inspectors found the NPPD engineering organization and procedural controls to be acceptable but noted that both had.
been recently revised.
The~NRC inspectors found that the QA audits of engineering had been of sufficient scope and depth to detect engineering division weakness.
The NRC inspectors also discussed the NPPD Configuration Management Plan with involved NPPD personnel to gain an understanding of the scope and status of this undertaking.
The NRC inspectors qLestioned the schedule for the Plan and were informed that the NPPD schedule was consistent with the schedule at other facilities implementing similar plans.
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DETAILS 1.
Persons Contacted NPPD T. Arlt, Licensing Specialist
~A. Boesch, Instrument and Control Engineering Supervisor K. Dowe, Mechanical Engineering Supervisor W.. Fisher, Electrical Engineering Supervisor A. Heymer, Manager, Configuration Management L. Kohles, Manager, Nuclear Projects and Construction L. Kuncl, Nuclear Power Group Manager S. McClure, Manager, Nuclear Engineering H. G. Parris, Vice President, Production M. Siedlik, Civil / Structural Engineering Supervisor G. Smith, Acting Division Manager, QA G. Trevors, Division Manager, Nuclear Support K. Walden, Licensing Manager R. Wilber, Division Manager, Nuclear Engineering and Construction Other NRC Personnel L. Constable, Chief, Projects Section C The above personnel attended the exit interview conducted on January 27, 1989.
The NRC inspectors also contacted and interviewed other 1.icensee employees during the course of the inspection.
2.
Licensee Action on Previous Inspection Findings (92701)
(Closed) Open Item (298/8212-01):
Training for offsite staff.
An NRC inspector determined, during this earlier inspection, that no formal training plan for offsite personnel had been implemented in response to a NPPD task force recommendation.
As discussed in paragraph 3.b., below, a training plan has now been implemented; therefore, this item is closed.
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Engineering and Technical Support The NRC inspectors evaluated the effectiveness of the NPPD r.orporate engineering program in the areas of adequacy of staffing levels and experience, training, interfaces with other organizations, design changes, i
I and QA audits.
The evaluation consisted of documentation reviews and personnel interviews to verify that the license requirements included in
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the Technical Specifications (TS) and Codes and Standards were being implemented and that the commitments contained in the Updated Safety Analysis Report (USAR) and other correspondence were being followed.
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Organization and Staffing (40703)
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L The licensee-sutimitted 'a change to.the USAR 'concerning the organization-structure by letter dated ' January 13, 1989.
The'NRCf
' inspectors questioned the status:of'the revised organization, including.the new Nuclear Power Group (NPG),fand were informed,that
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the.new organization had recently.been implemented', Further' review
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disclosed that the license? amendment-requeststo revise..the Organization Charts in Section 6.0 of the-TS had'not,las yet, been submitted forLNRC review and approval.
The licensee. amendment-
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request is presently being processed within.the lice'nsee's organization.
This change will be submitted to the NRC'in the near future.
The NRC inspectors evaluated the new organization'to ascertain
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whether the offsite technical support staff, functions.were performed.'
by qualified personnel in accordance with licensee approved.
administrative. controls.
The NPG, under the Vice-President, Production, has~ direct
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support to the CNS site. -.The Nuclear Engineering and Construction Division (NED) has direct responsibility'to provide offsite technical support to CNS.
The NED is. comprised of six major disciplines.in the areas of-Electrical,' Mechanical, Civil / Structural, Projects. & Construction,
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Configuration' Management:and Nuclear Fuels: Department. 'The NED provides technical support for station operation and maintenance.
These activities are under the direction'of the Division Manager'who reports directly to the Vice= President of Nuclear Power Group, Production. 'It is the' responsibility of this group to ensure'and
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verify the safe, reliable,'and efficient operation of the station and the adequacy and accuracy of records kept concerning the technical aspects of operation.
The engineering work requests for modification to the plant or.' equipment are evaluated by this group.
The NED. consists of 67 individuals with specialized experience.
Members of the engineering staff are required to have as a minimum a Bachelor's' degree in engineering or in an appropriate field.
The average total experience of the NED staff is 12.45 years with approximately 4 years with CNS.
The NRC inspector nottd that the
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majerity of the engineering staff are registered professional engineers.
Review of personnel records and interviews with various members of'
the offsite technical staff did not identify any questions or inconsistencies concerning individual qualifications.
Each department and group maintained administrative procedures which
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described the responsibilities, lines of communication, and interfaces with site personnel and organizations.
The engineering work requests can be generated by anybody at CNS
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and are reviewed by the applicable system engineer and department.
manager.at the site before submittal to the NED. 'The assigned design engineer has the total responsibility from the beginning to the completion of the task.
If the assigned task involves more' than c
-$150,000s then the appropriate engineering services are contracted.
Design packages are prepared on the bases of.a 12 month refueling'
cycle.
The nonoutage work packages are prepared at least 90 days before they are required.
The outage packages are prepared at least-60 days before an outage.
Consultants are used to prepare the packages; these consultants are hired in time to allow them to meet the scheduled outage dates.
The licensee also stated that some consultants are used year-after year.
The licensee does not have a qual.ified fire protection engineer on the staff but is considering such an addition.
A contractor, Engineering Project Management.(EPM),
is the licensee's permanent consultant for the fire protection issues.
The turnover rate in the NED has been minimal.
The turnover rate was 2.4 percent in 1987 and 6.1 percent in 1988.
It was noted that the turnover rate included an individual who left the engineering division for promotion wi Din the licensee's organization.
No violations or deviations were identified in the area of organization and staffing.
b.
Training (40703)
The NRC inspector reviewed the licensee's training program for.the offsite technical staff in the NED. 'The licensee implemented a new-
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training plan on July 8, 1988, which the NRC-inspectors found to be acceptable.
All new engineering staff members. are required to spend a minimum of 6 months at the site before coming into the NED.
All staff engineers are required to attend sixty hours of~ video taped-seminars on the respective systems of the CNS.. The staff members are also encouraged to: attend the seminars.such as EPRI and INP0 meetings.
No violations or deviations were identified in the area of training, c.
Interfaces with Internal and External Organizations (37700 and 40703)
The NRC inspectors performed an inspection of the licensee's interfacing policies and procedures related to internal and external
. coordination in the" design and engineering activities of the CNS.
The NED is the primary design engineering department within the district's NPG, located at the NPPD facilities in Columbus, Nebraska.
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Two additional engineering organizations', operations; engineering'and plant engineering, may provide design engineering,- but have operational support and maintenance support as their. primary activities.'
Both plant" engineering-and operations engineering are in the
. Technical: Department of.the Nuclear Operations Division'(N0D) located
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at the CNS site.- -Both NED and N0D ultimately; report to the Manager,
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NPG, a'nd all three engineering organizations share.the common task ofJ providing. engineering support to CNS..
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[f The NRCj nspectors reviewed the principal CNS engineering procedures
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'which prescribe the engineering policies and activities. -These-proceduras included CNS Engineering Procedure 3.1, '" Engineering
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Interfaces," and CNS Engineering Procedure l3.4, " Station Design y
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During the' review',' the NRC inspectors examined ~ additional, associated l
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l administrative directives and procedures (delineated in Attachment 1).
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and verified that engineering interfacing responsibilities.and j
activities included the following:
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Timelyidentification,"evaluationandresolutkonofproblemsand:
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concerns, w
l Interfacing work assignments'between corporate and site-l
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engineering staffs.
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Engineering organization involvement in evaluation and
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resolution of LERs, 10 CFR Part 21 reports, NRC reporting requirements, and NRC Bulletins.
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l Evaluation and resolution of< issues generated within thei
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engineering organizations and issues generated by-other
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organizations; e.g., plant staff, QA/QC.
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Engineering reviews and activities associated with plant G
information with regard to equipment / component history and-trending.
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During the inspection, the NRC inspectors interviewed several NED staff engineers to ascertain their familiarity with the plant site, frequency and purpose of plant visits, and opportunities for
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system walk-downs.
The NRC inspectors had no significant concerns i
resulting from those interviews.
l During the inspection, the NRC inspectors met with the cognizant NED licensing representative for the purpose of determining engineering interfacing activities associated with external organizations.
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licensee representative provided the NRC inspectors with a-copy of j
the "BWR Owners Group Activities and Participation Commitment Summary," which reflects those committees in which NPPD participates (4 f
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~ as a member.- In' addition, the'NRC inspectors discussed NPPD :
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interfacing. activities with other. external.organizationsLand' owner-
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Design Changes and Modifications (37700 and 37701)
- The NRC inspectors evaluated the results'of the. engineering / technical support efforts through the review of completed engineering tasks.
The NRC inspectors reviewed the CNS procedures appli'able to the NED c
o and found them to be of acceptable detail and content..The reviewed
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procedures are listed in Attachment 1.
The NRC inspectors noted,.
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however,;that the 3.4 series procedures:had'all been' revised (and new procedures added) in December 1988.
The NRC inspectors were informed
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.e that most of.the. requirements which appears in the new, more task specific' procedures, had been included as' parts of larger
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procedures.
The NRC. inspectors then selected a number of' design changes for detailed review from a listing of those which~had been_ implemented on-
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the RHR system. The NRC inspectors chose a system approach in order to obtain'a variety ofetypes of design changes (DCs). 1The RHR system was' selected because of its'importance to safety in both normal and-accident operating conditions. -The inspectors reviewed the DCn
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packages to verify that procedural and regulatory requirements had s
been. fulfilled. The types of. items the NRC. inspectors ve'rified included evaluations-for 10 CFR 50.59 determinations, proper NRC reporting requirement considerations, fire protection and
.equipmentLqualification considerations, and calculation-
- checks.-In addition,'the NRC inspectors verified acceptable-levels of' review and approval of the DC, including any changes to the
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original DC, and that closure of the DC included required.
procedure / drawing revisions and personnel training.
The following DCs to the;RHR system were selected from the licensee ~
provided list of changes to the RHR, service water, core spray, and
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high pressure coolant injection. systems.
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DC 76-079 Addition-of Flow Restricting Orifices to the RHR-Pump Discharge Liries -
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DC 76 aa5 Addition of Pressurization Valves DC 77-017
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Addition of Loss of. Voltage Sensing Relays for RHR/LPCI Motor Operated Valves (MOVs).
DC 77-053
. Addition of Test Jacks to the Motor Control FCenters (MCCs) for RHR Suction Valves
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'DC 77-055 Addition of Reset Push' Buttons for' Testing RHR-Valves DC 77-089 Addition of Leak Test Connection for RHR Containment Penetration Valves
.DC 86-111 Modification of RHR Pumps' Impeller Wear. Ring DC 86-125 Removal of RHR Pump Minimum Flow Line Orifice DC 86-148 Upgrade of Power Supply Cable and Fuses for RHR, MOVs DC 88-024 Modification of RHR Piping-Supports With the exception of DC 76-079, which was the most technically.
involved modification reviewed, the NRC inspectors found the above
'DCs to be acceptable. "In a number of cases the NRC inspector requested clarifying information.
This information was usually in the form of supplemental evaluations.
Some problems with drawing revision following completion of modifications were observed and are discussed below.
DC 76-79.
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The addition of orifices to the RHR pump discharge lines, which was
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- implemented by DC 76-79, was recommended by General Electric
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Company (GE) in their letter to NPPD, RHL-76-156 dated August 2, 1976.
The recommendation was made to provide additional flow resistance in each RHR pump discharge line which would,.in turn,
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provide runout protection for the pump during the low pressure
coolant injection (LPCI) mode of operation.
The GE letter went on to recommend that when these pumps are used in the containment spray mode that:
" Hydraulic calculations should be performed to evaluate possible flow limits due to the added resi;,tance.and to evaluate the necessity of removal of some spray nozzles if the pressure drop available at the nozzles is insufficient to permit proper droplet formation.
Although unlikely, the shutdown cooling mode may be affected.
This mode should be evaluated via testing or hydraulic
calculation to verify that the present shutdown rated flow is not
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reduced by the added orifices."
The NRC inspector requested the results of the GE recommended i
hydraulic calculations and was shown a copy of a Burns and Roe evaluation.
That evaluation, however, concluded that the containment spray flow rate would be 3.8 percent lower than the previously assumed flow rate.
The NRC inspector then requested the evaluation of the acceptability of the lower flow rate.
The NRC inspector was informed on February 1, 1989, that the analyses which had been performed concluded that containment spray flow was not required to mitigate unacceptable containment responses to an accident.
The NRC
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! inspector verified that USAR Section 6.3'.3.3 included'a Case D study which concluded acceptableLresults for no containment spray.
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i The NRC inspector had also questioned how the addition of!the;
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. orifices to the RHR pumps' discharge" lines had been' reported to the'
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NRC and was provided a copy of the NRC Safety Evaluation approving the' proposed change and a-copyLof the NPPD Annual Operating'_ Report forl1976 (letter to NRC dated _ March 1,.1977) which documented the1 completion-of the modification.
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monitored..Ik w rector was provided a copy ~of Surveillance.
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Procedure 6.34 : which required monthly; fullsflow (>7700 gpm) tests
of the RHR pumps..This test would provide assurance of-ac.ceptable minimum flow rates but.not acceptable maximum flow rates.
The NRC'
inspector was unable.to determine how maximum flow rates 'or. orifice condition was being' monitored.
The NRC' inspector was subsequently
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informed that;the licensee would develop a surveillance test to ensure proper' orifice performance.
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In order' to evaluate the RHR system configuration following the installation of the flow restricting orifices, the NRC inspector;
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reviewed the' Piping;and Instrument ~ Drawing (P&ID) contained in the USAR..The NRC inspector noted, however, that'this modification, and the modification implemented by.DC 76-085 had not been incorporated.
I onto the P&ID; USAR. Figure IV-8-2, Revision No.'l dated September 21, 1978.
The NRC inspector was informed that a similar. problem had been recently discovered.by licensee personnel on a separate system.
The problems apparently'resulted from the existence of two sets of P&IDsg
' one developed by Burns and Roe, the other by GE.
The plant operators
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use the Burns & Roe P& ids.
Licensee engineering personnel showed the.
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inspector that the Burns and Roe.P&ID (Drawing No. 2040, Revision N18-dated July 10,1985) had been revised to include the modifications and informed:the NRC inspector that the Burns and Roe P& ids were utilized by both engineering and operations personnel.
The existence of drawings in the USAR which had not been revised to include the effects of changes made in the facility is an apparent violation of 10 CFR Part 50.71(e).
Since the licensee had initiated corrective actions and since'the violation was of minor safety significance, no Notice of Violation is being issued in accordance with Section V.A. of the NRC's Enforcement Policy.
The NRC inspector noted a similar occurrence during the review of the Configuration Management Plan which is discussed in paragraph 4, r
below.
Neither of the P& ids involved in that, problem, however, were included in the USAR.
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Quality Ass'urance Audits (37702)
The NRC inspectors performed an inspection of the licensee's QA audits.' conducted during 1987 and 1988 that were applicable to design activities.
The licensee schedules an annual audit of design' control which was verified by reviewing ~the 1988 and 1989 audit schedules.
The annual. audit performed by-the licensee exceeds the 24 month auditing requirement.specified in Section'6.0 of the TS. Two audit reports were celected for review to verify that annual audits were performed, aucitors were qualified, audit findings were reported to senior management, corrective actions were implemented in a timely fashion, and trend analyses were performed on audit findings.
The two audit reports selected are listed below:
. Audit'#87-01;lDesignControl,.datedMarch30,1987 Audit #88-02;< Design Control, dated 0ctober 21, 1988 The auditi were performed in accordance with the general guidelines.
of QA Instruction QAl-5 and the1 requirements of QA Plan QAP-1700 for conducting audits of DC.
The qualifications of two auditors and two lead auditors who participated in the audits selected above were-reviewed.
The qualifications of the audit personnel were consistent with the requirements specified in the NPPD QA Division Training and Qualification Programi 'The scope of the audits were generally programmatic in nature; however, the audits also incorporated QA -
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surveillance, that had been performed since the previous audit, which included technical assessments of performance.
The audit findings were reported to senior management staff at the plant and the corporate office.
Negative audit findings were assigned to specific management personnel for resolution with a. response _due date for corrective action.
The resolution of audit findings for the-above audits were reviewed and the dispositions were considered thorough.
The corrective actions for the audit findings were considered to be implemented in a timely fashion.
The audit and surveillance findings'were trended in the audit reports and the quarterly trend analysis.
No violations or deviations were identified.
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ConfigurationManagementPlan(407031 The NRC inspectors discussed the Configuration Management Plan for the.CNS with involved licensee personnel to gain an understanding of the scope and schedule for this undertaking.
The NRC inspectors were informed that the concept of design criteria collation was approved by NPPD in mid-1986.
An early review was performed on the core spray system (approximately 500 manhours of effort) in early 1987 and an independent review of the high pressure coolant injection system is planned for early 1989 (approximately 1250 manhours).
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l The present. NPPD plan;is~ divided.into four parts which work together and -
utilize information-from each other.
The four parts include: As-Built'
Drawing Walkdowns, Data Base Management,', Design Cri_teria. Development' and Probabilistic. Risk Analysis (PRA).. The NRC inspectors wereLinformed that the as-built' effort had been completed on 79 drawings-and.had been scheduled to be completed for; the remaining drawings (approximately; p
2700 drawings) included in the program by mid-1993.
The. licensee was-i" utilizing; original design criteria documentation in PRAs' to establish
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component'and system priorities within the plan._' The NRC inspectors were informed that' difficulties-were being encountered because NPPD lacks a
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considerable amount of the original design documentation. ~The NRC inspectors were'also informed /that the implementation of the plan was L
being controlled by existing facility procedures.but that new interfacing,
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' computer software QA and.PRA procedures would be developed.
NPPD had
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established mid-1994 as the completion schedule for.the plan.
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The NRC _ inspectors reviewed some of the findings from the as-built activities. - The consultants performing the walkdowns report identified problems to NPPD by. letter along with a recommended corrective action.
One of the walkdown findings was similar-to the violation described in paragraph 3.d.
When the emergency diesel generator ' air header system was reviewed, the consultants' discovered differences between the Burns and Roe-P&ID (Drawing 2077) and the vendor P&ID'(Drawing KSV-36-7).
This problem-was discussed in the consultants report, APA Problem'No. 5346, with the recommendation that the vendor drawing be corrected. ~The NRC1 inspectors'
found the problem reporting and the_ resolution activities to be acceptable.
The-NRC inspectors quostioned the' completion schedules, especially'for the;
'as-built program, and were informed that NPPD' considered the time frame to'
be comparable to other such industry efforts.
The NRC inspectors noted that NPPD would.be in the Region IV office during the week of February 6,_
1989, to discuss the plan with~NRC management.
No violations or deviations were identified.
5.
Exit Interview (30703)
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An exit interview was conducted on January 27, 1989, with licensee representatives (identified'in paragraph 1).
During this interview, the
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NRC inspectors reviewed the scope and findings of the inspection.
Other meetings between the NRC. inspectors and licensee management were held i
periodically during the inspection to discuss identified concerns.
The licensee did'not identify as proprietary any information provided to, or reviewed by, the NRC inspectors'.
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ATTACHMENT LIST OF DOCUMENTS REVIEWED CNS Procedure 0.5.3, Revision 0,r" Licensee Event Reports"
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CNS Procedure 0.10.1, Revision 3, " Operating Experience Review" CNS Procedure 1.10,~ Revision 2, " Document' Control" CNS_ Engineering' Procedure'3.1, Revision 2, " Engineering' Interfaces"
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CNS Engineering' Procedure 3.2, Revision 2, " Systems Engineers and Engineering'
Specialists"
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CNS Engineering Procedure 3.3, Revision 8, " Station Safety Evaluations" CNS Engineering' Procedure 3.4, Revision 8, " Station Modifications" CNS Engineering Procedure 3.4.1, Revision 0, " Engineering Work Request and'
Authorization"
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CNS Engineering Procedure 3.4.2, Revision 1, " Basis of Design Document" CNS Engineering Procedure 3.4.3, Revision 0, " Design Change" CNS Engineering Procedure 3.4.4, Revision 3, " Temporary Design' Change"
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CNS Engineering Procedure 3.4.5, Revision 0, " Equipment Specification Change" CNS Engineering Procedure 3.4.6, Revision 0, " Design Review' Checklists"
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CNS Engineering Procedure 3.4.7, Revision 0, " Design Calculations"
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CNS Engineering Procedure 3.4.8, Revision 0, " Design Verification"
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CNS Engineering Procedure 3.4.9, Revision 0, " Implementation and Acceptance Testing Activities" CNS Engineering Procedure 3.4.10, Revision 0, " Revisions, Amendments, and On-The Spot Changes"
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CNS Engineering Procedure 3.4.11, Revision 0, " Status Reports" CNS Engineering Procedure 3.4.12, Revision 0, "DC/ ESC Completion Reports" CNS Engineering Procedure 3.11, Revision 1, " Vendor Contract for Verification f'
and Manuals" CNS Engineering Procedure 3.20, Revision 0, "10 CFR 21 - Reporting of Defects and Noncompliance" CNS Surveillance Procedure 6.3.5.5, Revision 15, "RHR Pump Operability Test" l
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QA Instruc' tion.QAI-5, Revision 27,'" General Guidelines
. Quality Assurance-
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.QA' Procedure QAP-1700, Revision 6, " Design Changes'(Major & Minor)"
l NPPD Quality Assurance " Division Training and. Qualification Program,"
Revision 3-i.
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' Quarterly _NCR Trend-Analysis - Fourth Quarter, 1988, dated January. 10, 1989
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