IR 05000298/1989019
| ML20043A188 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/07/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9005180175 | |
| Preceding documents: |
|
| Download: ML20043A188 (2) | |
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y In Reply Refer To-I Docket: 50-298/89-19
-i Nebraska Public Power District ATTH: George A. Trevors Division Manager - Nuclear Support P.O. Box 499 Columbus, Nebraska 68602-0499
Gentlenien:
Thank you for your letter, dated April 4,1990, in response to our
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letter, dated March 14, 1990. We have no further questions at this time and
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will review your corrective action during a future inspection.
Sincerely,
Original Signed By:
Samuel J. Collins
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i Samuel J. Collins, Director Division of Reactor Projects
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Nebraska Public Power District ATTH:
G. D. Watson, General Counsel P.O. Box 499
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Columbus, Nebraska 68601
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Cooper Nuclear Station
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ATTN: Guy R. Horn, Division
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11anager of Nuclear Operations P.O. Box 98 Brownville, Nebraska 68321
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Nebraska Department of Environmental Control ATTH: Dennis Grams, Director i
P.O.. Box 98922 Lincoln, Nebraska-68509-8922 j
i Nemaha County Board of commissioners l
ATTN: Larry. Bohlken, Chairman
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Nemaha County Courthouse 1824 N Street
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Auburn, Nebraska 68305
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Kansas: Radiation-Control Program Directoi-U.S. Nuclear Regulatory Connission
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ATTN: Senior Resident Inspector-P.O. Box 218
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ATTN: Regional Administrator, Region IV-611 Ryan Plaza Drive, Suite-1000
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April 4,:1990
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uc U. S. Nuclear Regulatory Commission Attention: Document Control Desk i
Washingtont DC 20555'
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Subject: ' Supplement to NPPD Response to Inspection Report-50-298/89-19-
References:
(1)~ Letter, S. J. Collins to Nebraska Public Power District, j
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transmitting-Inspection Report No. 50-298/90-01, dated =
March 14,'1990-(2) Letter, G. A. Trevors to'USNRC, Subjects-NPPD Response.to-
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Inspection Report 50-298/89-19, dated July 5, 1989 i
Gentlemen:
As discussed in Reference (1), this letter provides information: to supplement that which was previously transmitted to _ you in Reference (2) regarding _ the i
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Cooper Nuclear Station (CNS) Calibration Program. -Reference (1) identified-additional examples of a f ailure to calibrate instruments, and our. response -is provided below.
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Reason for the Additional Examples-In implementing the corrective action plan for' Notice of Violation'
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298/8919-01, a station procedure, CNS Procedure 0.38, "CNS Calibration Program", was developed and is currently being implemented. -This' procedure describes the types of instruments installed at CNS and establishes the criteria for the instruments which must be included in the calibration program.
In implementing the program stipulated by Procedure 0.38, a.
consultant was retained to assisc in identifying 1 instruments to be included
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and in collecting the various calibration requirement data. This effort was in process at the time of the inspection, which is the subject of Reference (1).
It should be noted that the additional examples contained in Reference (1)-
(suppression pool water temperature sensors and drywell air temperature sensors) are resistance temperature detectors (RTDs).and thermocuples (TCs)
which had already.been identified during the data collection effort. However, as allowed for in Procedure 0.38, these sensors were evaluated as not a
requiring calibration, since they were deemed)to be non-calibratable-(non-adjustable) devices.. This approach is in keeping with commitments made l
in the Corrective Steps Which Will Be Taken To Avoid Further Violations l'
section of Reference (2) in that "... the procedural requirements will then be used as a basis for reviewing installed instrumentation-used to monitor safety WO'I0 QGCf !?$W $ f Powertui Pride in Nebraska
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-N.S.' NuclGOr R gulctory Commission
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April 4, 1990
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,Page 2 related equipment and ensuring that each instrument is either included in the Surveillance Test Program or Preventive Maintenance Program, or that documented justification is provided as_to why it is not."
Theretore, prior to the inspection reported in Reference (1), the aforementioned sensors had been addressed by the new calibration program, but were evaluated at that time as not requiring calibration.
Regarding the third example given in Reference (1) (standby power instruments), the instruments are non-safety related (Regulatory Guide 1.97, Category 2 instruments) and a decision had been made to calibrate them during the current refueling outage. However, documentation reflecting this decision I
was not yet available at the time of the inspection.
They have since been included within the scope of approximately 100 electric system panel meters, which are presently being calibrated.
Corrective Steps Which Have Been Taken And The Results Achieved As noted in Reference (1), a Justification for Continued Operation (JCO) was developed immediately following identification of the concern with the RTDs and TCs. The JC0 concluded that instrument operability was assured until further action could be taken.
l We have also reviewed, and are in the process of revising, Procedure 0.38 to clarify and broaden its scope of application. Among other changes, this revision will specify the evaluation of non-calibratable devices (i.e., RTDs.
TCs, potential transformers, and current transformers) and clearly require that instruments associated with Regulatory Guide 1.97 and Emergency Operating Procedures be included with the Calibration Program. Even though the procedure change administrative process has not yet been completed for this i
revision of Procedure 0.38, the elements discussed above are currently being
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implemented.
Corrective Steps Which Will Be Taken To Avoid Further Violations As identified in the JC0 noted above, the following actions are planned:
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The District will submit a request for a Technical Specification change to clarify the definition of instrument calibration. This request will be submitted by May 1, 1990.
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The District will calibrate check the RTDs and TCs in question during the current refueling outage. This calibration check will verify the expected RTD and TC response to a known temperature.
This testing will be complete prior to startup from the 1990 Refueling Outage.
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The District will review the CNS Technical Specifications and instruments identified as essential for similar calibration issues. This review, and any required action resulting from this review, will be completed prior to startup from the 1990 Refueling Outage.
In addition, Procedure 0.38 vill be revised to clarify and broaden its scope of application, as discussed above.
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U.S. NuclOct R:gulctory Commission
April 4, 1990
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.Paghb Date When Full Co.spliance Will Be Achieved Compliance regarding actual instrument calibrations or calibration checks will be achieved prior to startup from the current outage (presently scheduled for April 27, 1990). As noted above, a Technical Specification change to clarify calibrations of RTDs and TCs will be submitted by May 1, 1990.
The revision to Procedure 0.38 will be approved by June 1, 1990.
We trust that this supplemental information is responsive to your concerns.
Should you have any questions concerning this matter, please contact me or G. R. Horn at the site.
Sincerely
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.A Trevors Division Manager I
Nuclear Support
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GAT:JMM:js/sg Pd S. Nuclear Regulatory Commission cc:
Regional Office - Region IV NRC Resident inspector Cooper Nuclear Station
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