IR 05000298/1989028

Insp Rept 50-298/89-28 on 890731-0804.Violations Noted.Major Areas Inspected:Implementation of ATWS Requirements & Licensee Actions on Findings of Previous Insps

ML20246E144
Person / Time
Site:	Cooper
Issue date:	08/18/1989
From:	Boardman J, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246E133	List: IR 05000298/1989028 ML20246E129 ML20246E141
References
50-298-89-28, GL-85-06, GL-85-6, NUDOCS 8908290020
Download: ML20246E144 (8)

Text

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, W APPENDIX B 4 kf,'$1 ,

U;S.' NUCLEAR REGULATORY COMMISSION" jQ i REGION IV'

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"' ] iRC Inspection Report:' 50-298/89-28 -

. Operating: License: 'DPR-46,

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-}t Docket:/50-298

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Licensee:uNebraskaPublicPowerDistrict(NPPD)

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Columbus, NE 68601 ,

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LFacility_Name: 'CooperNuclearStation(CNS) ,

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. Inspection At:: CNS,..Brownsville,. Nebraska

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Inspection Conducted: July 31 through August 4, 1989

. Inspector:

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64 4 ' I /8/89 J. R. Boardman,Jeactor Inspector, Plant . Date

< Systems Section Division of Reactor Safety

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Approved: -

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. f7 T. F_5tetka, Chief. Plant Systems Section Date '

<' Division-of Reactor Safety Inspection Summary Inspection Conducted July 31 through August 4,-1989 (Report 50-298/89-28)-

Areas Inspected: Routine', announced inspection of the implementation' of the anticipated transient without scram'(ATWS) requirements and licensee actions on previous inspections finding )

Results: Within the areas inspected, two apparent violations were identifie ,

.The apparent violations' involved the area of design control. The licensee accomplished a' design change that increased the maximum alternate rod insertion time without adequete evaluation and-failed to comply with procedural requirements for on-the-spot-changes (paragraph 3). Except for the identified apparent violations, the licensee's actions were in compliance with , .

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the ATWS requirements contained in 10 CFR Part 50.62 and were determined.to be satisfactory. The licensee's actions on sone previous inspection findings were reviewed and.found to be satisfactory as noted in the report

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DETAILS Sr 3 . Persons Contacted

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• G. Horn Division' Manager of Nuclear Operations 7 *J. Meacham, Senior Manager of Operations E *E. Mace, Engineering Manager s - *R. Brumgardt. Operations Manager

• H. Hitch, Plant Service Manager-

• G. Smith, Quality Assurance Manager

• J. Flaherty, Plant Engir;tering Supervisor

, *G._ Smith, Licensing Supervisor B. Fischer, Electrical Supervisor

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'*M. H111strom, Assistant Mechanical Supervisor S.: Thompson, Electrical Engineer

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A. Weise, Mechanical Engineer

• G. Stenger, Engineering Technician

• L. Bray, Regulatory Compliance Specialist M. Dean, Engineer-R. Gibson, Quality Assurance

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• M. Boyce, Licensing

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• T. Stetka, Chief, Plant Systems Section

• R..Bennett,: Senior Resident. Inspector

• G. Pick',. Resident Inspector

• A. Singh, Reactor Inspector-

• M. Murphy, Reactor Inspector

• C.^ Johnson, Reactor Inspector

• Denotes attendance at the exit meeting held on August 4. 198 The inspector also contacted and interviewed other NPPD' personnel during the performance of this inspectio . Licensee Actions on Previously Identified Items (92701)

2.1 (0 pen) Unresolved Item (298/8710-12): This item dealt with the adequacy

.of postmaintenance testing (PMT). The licensee's review of the PMT program had been completed. ~ A summary memorandum was in preparation, and procedure changes, as required, were targeted for initiation by August 11, 1989. : This item is considered open pendir.g the issuance of revised - '

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prccedures for PM i f

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-?- l 2.2 (0 pen)InspectorFollowupItem(2S0/8914-01): This item dealt with ,

weaknesses in the licensee's control of vendor technical information (VTI). !

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A revision of Cooper Nuclear Station (CNS) Engineering Procedure enhancing the control of VTI, by providing VTI review guidance, was in review. This item is considered open pending the issuance of the revision of CNS Engineering Procedure .3 (0 pen)InspectorFollowupItem(298/8914-02): .This item dealt with i proceduralizing the annual replacement of the emergency diesel generators' lubricating oil filter gaskets when the filters are cleane A revision to the licensee's Procedure 7.2.53.1 incorporating gasket replacement parameters had been completed and was in review. This item is considered open pending the issuance of the revision of licensee's Procedure 7.2.5 .4 (0 pen) Inspector Followup Item (298/8919-02): This item dealt with the inspector's concern relating to potential problems of long-term deterioration of the Buna-N rubber insulation on General Electric Company (GE) Type SJO cables. The licensee's engineering organization had completed their review of this problem. The engineering review was undergoing management review. ~1his item is considered open pending the licensee's issuance of a formal policy on GE Type SJO cable . Corrpliance With Anticipated Transients Without Scram Rule (ATWS) (25020) l The purpose.of this inspection was to verify that the licensee has implemented the requirements of 10 CFR 50.62 (ATWS rule), and the quality assurance program as stated in Generic Letter (GL) 85-06, " Quality Assurance Guidance for ATWS-Equipment That Is Not Safety-Related." This inspection included verification that the design and specifications conformed to the licensee's commitments as endorsed in the NRC Safety EvaluationReport(SER). In accordance with the SER, CNS is committed to install an alternate rod injection (ARI) system, an upgraded standby liquidcontrol(SLC) system,andequipmenttoautomaticallyactuatea reactor coolant recirculation pump trip (RPT) for both recirculation pumps, under conditions indicative of an ATW The inspector verified the licensee's implementation of the design and specifications approved by the NRC in SERs dated September 23 and December 23, 1987. Verification was accomplished by document reviews and installation walkdown. Document reviews included the completed station design change documentation packages and ATWS equipment procurement data, as well as quality assurance, design control, maintenance, and surveillance procedures applicable to ATWS systems. The documents reviewed included those contained in the enclosed Attachmen Durirg the inspector's dccument review, the following findings were identified:

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+ ~-4- Lack'of Desian Control Station-Design Change (DC) 86-034B installed the'ATWS changes for the

.ARI and RPT4 systems. This DC was based upon the NRC approved SER, dated September 23. 1987. The SER approved a maximum ARI control rod insertion time of 25 seconds. On-the-spot-change-(OSC)27.tostation 4 DC 86-034B increased the maximum ARI rod insertion time from the H approved maximum of 25 seconds to a maximum of 34.5 seconds. Also approved in the SER was an ARI lockin feature. The lockin was a i 30-35 second time-delay to prevent manual action prior to completion

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of automatic ARI action. OSC 27 did not consider the affect of '

extending the ARI rod insertion time on defeating the lockin

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feature. Therefore it would, in theory, be possible to reset to rod insertion before the time allocated for it had run out. This was considered to be potentially safety significant, although the significance was relatively small, because reset could not have occurred until after all rods would have been expected to be inserted full Nothing'in the applicable CNS Engineering Procedure 3.4, " Station Design Changes," prevented such an OSC. Failure to have procedures for the cffective control of OSC to DCs is an apparent violation of 10 CFR 50, Appendix B, Criterion V, which requires that activities such as design changes be controlled by procedure Violation (298/8928-01): Failure to have adequate procedures to control DC Lack of Compliance with Licensee Design Control Procedures During the review of station DC 86-034A for the installation of changes to the SLC system to meet the ATWS rule, the inspector identified the following two examples of an apparent violation of CNS Engineering Procedure 3.4 " Station Design Changes " Revision This procedure revision controlled OSCs at the time that the station DCs were made to comply with the ATWS rul *

The licensee failed to issue an OSC for the addition of a i torque value for tightening bolts in Section VII.B.6.k of the DC .'

• The licensee failed to issue an OSC for the deletion of completed ,

test data for a postmodification SLC pump performance test in Section IX.E.10 of the D ,

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Failure to follow the requirements of CNS Engineering Procedure 3.4 ' I for the issuance of OSCs is an apparent violation of 10 CFR 50, Appendix B, Criterion V, and the licensee's quality assurance program descriptio l I

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This finding is considered to have minimal) safety significance, ' ,l and the identified errors appeared to be isolated examples l within a generally effective program. In addition, the licensee took prompt corrective action in initiating OSCs for these examples ;

y when identified. The-licensee also comitted to the retraining of 1

'l the individual involved. Therefore,'in accordance with.10 CFR -

. ' Part 2. Appendix C, of the NRC Enforcement Policy, dated October 13, 1988, this; apparent violation will not be cite ,

Except:for the apparent violations identified above', the licensee's actions in compliance with the ATWS requirements contained in 10 CFR 50.62 were found to be satisfactor . Exit Interview .

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The inspection scope and findings were summarized in an exit meeting held on August 4,1989, with the licensee personnel indicated in paragraph 1 above. The licensee did not identify, as proprietary, any of the materials provided to, .or reviewed by, the inspector during the inspectio +

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1 s . " ATTACHMENT ,

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NRC INSPECTION REPORT 50-298/89-28 ,

' Correspondence Peviewed ,

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• - -NPPD letter to NRC cated October 14, 1985; Subject:' Response to i

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Generic Letter 85-06,~" Quality Assurance Guidance for ATWS Equipment" i

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That-Is Not Safety-Related"

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< , . NPPD letter to NRC dated August' 4,1986; . Subject: :10 CFR 50.62  !

Implementation Schedule '

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NRC letter to NPPD dated September 10, 1986, Docket 50-298; , .j

Subject: 10 CFR 50.62 Implementation Schedule 1 j

NRC letter to NPPD dated January 8.1987, Docket 50-298; Subject .

ATWSRule'.(10CFR50.62) l

' *1 ,NPPD letter to'NRC dated April ~8.1987 File Number NLS8700187; Subject: ~ ATWS (10 CFR 50.62) Information, Cooper Nuclear Station,'NRC Docket 50-298, DPR-4 * NPPD letter to NRC dated May, 7,1987; Subject: ATWS (10 CFR 50.62)

Additional Information, Cooper Nuclear Station, NRC Docket!No. 50-298, l DPR-46, j

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• NRCJletter to NPPD dated September 23, 1987; Subject: Safety Evaluation Report on Cooper Nuclear Station Compliance with ATWS- j Rule ~10 CFR 50.62 Relating to ARI and RPT Systems, and Request for Additional . Infonnation Regarding SLCS (TAC NO. 59084) .j

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'* NPPD letter to NRC dated November. 18, 1987, File Number NLS00601; j Subject: ATWS '(10 CFR 50.62)' Additional Information, Cooper Nuclear j Station. NRC Docket 50-298, DPR-46 j

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'*' .NRCLletter to NRC dated December 23, 1987 Docket 50-298; Subject:

Safety Evaluation - Standby Liquid Control System - ATWS 10 CFR 50.62~

Rule, Cooper Nuclear Station Surveillance Procedures Reviewed i

Surveillance p ,

Procedure N Revision N Title E 6.2. RI/ATWS/RPT and PCIS Reactor i Low-Low Water Level Calibration and Functional Test

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, 6.2. ARI'andATWS/RPTLogickest;

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with Reactor Shut.Down;

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I 6.2. > 17 ; 'ARI Logic Test with Reactor in Run

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'6.2. ARI.and ATWS/RPT Reactor

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, Test

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6.3. SLC Test Mode' Surveillance

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'; , Operation 1 6.3.8.2!. 31 SLC Pump Operability Test-6.3. SLC Valve Functional Test

t6.3. SLC manual Initiation Test:

Tank to' Reactor Vessel-

' Administrative, Engineering and Operations Procedures Reviewed? .,

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.v 1 Reciuisitioning

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/L Control and: Retention of

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Records 1.10 3 Document Control 1.11 3 Equipment Spare Parts

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Inventory (ESPI)' Program

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3.3' 8 Station Safety Evaluations -

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3.4' 6&9 . Station Design Changes

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2.2.74' 19 Standby. Liquid Control System

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, 2.3.2.27 17 Alternate Rod Insertion Initiated 2.4.2. Trip of Reactor Recirculation Pumps T

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Work Item Tracking --

Corrective. Maintenance:

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k<'- ' .4 . . Drawings Reviewed-

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R- . Drawing ~ Revision N Title:

" F1ow Diagram Control Rod 2039i N26 fg , ,

, Drive Hydraulic System ,

,  ; 945E617; 'O' 'CRD System ARI Modification 945E63 .

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ARI/ATWS Recirculation Pump

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, Trip 7 730E197BB, 5 .Veriable Speed Recirc. Pump;

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Flow Diagram Standby Liquid

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ARI' Piping Isometric

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-CNS-CRD-16- N00 ARI Pipirg Isometric

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