IR 05000298/1990001

Insp Rept 50-298/90-01 on 900212-16.Violations Noted. Major Areas Inspected:Review of Design Documents,Physical Insp of Instrumentation Displays & Evaluation of Calibr Procedures & Records

ML20012D435
Person / Time
Site:	Cooper
Issue date:	03/08/1990
From:	Paulk C, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20012D434	List: IR 05000298/1990001 ML20012D433
References
50-298-90-01, 50-298-90-1, NUDOCS 9003270321
Download: ML20012D435 (14)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION'

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REGION IV'

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NRC Inspection Report: 50-298/90-01 Operating License: DPR-46-Docket:- 50-298

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Licensee: HebraskaPublicPowerDistrict(NPPD)

P.O. Box 499

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Columbus, Nebraska 68602-0499 Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS-Site Brownville, NE

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Inspection Conducted: _ February 12-16, 1990 Inspectors:

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. C. PahTk, Ifeactor Inspector, FThiit' Systems bate

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Section, Division of Reactor Safety L

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Accompanying-

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Personnel:

A. Udy, NRC Consultant,;EG&G Idaho

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' Di. $[90 Approved:

T. F. 5t'e

, Chief. Plant Sy' stems Section Division of Reactor Safety

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( T h Inspection Summary Inspection Conducted FebruarL12-16, 1990 (Repor,t_ 50-298/90-01)

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Areas Inspected: Routine, announced inspection of the implementation of

> - 0 $8 ~ T(immitments made relative to. Regulatory Guide (RG) 1.97, "Postaccident.

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Monitoring Instrumentation." The inspection included the review of design documents, physical inspection _of instrumentation displays and an' evaluation of

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Ed. Instrument calibration procedures and records. The inspectors also evaluated

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licensee actions in response to previous inspection findings.

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L N-Results:- Within the areas inspected, the inspectors identified two additional

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, examples of a failure to calibrate instruments that was the subject of a E

os o.c previous violation (Violation 298/8919-01). Although corrective actions for this previous violation were not complete, the inspectors' analysis indicated p

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' that these examples (failure to calibrate suppression pool water temperature sensors and drywell air temperature sensors) would not have been identified by the corrective action plan. A third example (standby power instruments) was-identified by-the licensee, but was not specifically scheduled for calibration-during the upcoming refueling outage.

The licensee was responsive when informed of these findings. For example, on the. issue of temperature sensors, the licensee promptly began evaluating the situation and prepared an engineering evaluation to support their position, k' hen a justification for continued operation (JCO) was requested, the licensee had one prepared in a timely manner. -Additionally, the licensee submitted a revision to the JC0 that expanded the JC0 so that both types of temperature sensors (resistancetemperaturedetectors(RTDs)andthermocouples)were addressed. The licensee also prepared design change notices (DCNs) to drcwings in order to. correct deficiencies identified by the inspectors.

- The licensee has implemented a program to comply with the requirements of RG 1.97. This inspection identified a continuing weakness with the licensee's calibration progra _ _ _ _ _...

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t DETAILS-i

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1. -PERSONS CONTACTED

.j-NPPD i

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• T. Arit, Licensing _ Specialist

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• A._Boesch,InstrumentationandControls(I&C) Engineering' Supervisor a

• L. Bray, Regulatory Compliance Specialist

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- *R.: Brungardt, Operations Manager

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• R. Deatz, Senior Quality Assurance (QA) Specialist

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• J. Dutton, Nuclear Training Manager

_ *R. Gardner, Maintenance Manager

• G. Horn, Division Manager of Nuclear Operations

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• H. Jantzen. I&C Supervisor R. Krause, Maintenance Engineer, Electrical

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• L~. Kunc1, Nuclear Power Group Manager

- *E.' Mace,_ Engineering Manager

• J.'Meacham, Senior Manager of Operations

• S. Peterson, Senior Manager of Technical Support Services

• G. Smith, QA Manager

• G. Smith, Licensing Supervisor

• D. Wacha, Lead I&C Engineer

• K. Walden. Nuclear Licensing and Safety Manager NRC Personnel

- *R. Bennett, Senior Resident Inspector, CNS

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• D.- Kelley, Reactor Inspector, Region IV

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• G. Pick, Resident Inspector, CNS

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• A. Singh, Reactor Inspector, Region IV

' *W. Seidle, Chief, Test Programs Section, Region IV

- * Denotes personnel who attended the exit interview conducted on February 16, 1990.

'The inspectors also contacted and interviewed other licensee personnel during the course of the inspection.

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FOLLOWUP ON PREVIOUS INSPECTION FINDINGS (92702)

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(0 pen) Violation (298/8919-01): Failure to Calibrate Instrumentation. During

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a previous-inspection, NPPD was found to have an inadequate program to ensure the proper calibration of instruments that were utilized for not specifically identified in the Technical Specifications (plant control but TSs).

Since some of the: instruments-reviewed during this'RG 1.97 inspection are not specifically

^11sted in the-TSs, the inspectors reviewed the corrective action program being implemented at CNS to correct'the inadequacies identified by this violation.

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- As stated in the licensee's July 5,1989, response to the violation,' CNS"

procedure 0.38, "CNS Calibration Program," was developed to integrate the

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various programmatic elements of the CNS calibration program. The inspectors

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reviewed._the procedure and concluded that, if the procedure is properly implemented, the program would'be acceptable.

Procedure 0.38 identifies the types of instruments to be included in the calibration program.

Included was process monitoring instrumentation which is comprised"...ofasensor(RTD, thermocouple,pressureordifferential pressure. transmitter, current or potential transformer, etc.)..."

Although the licensee has expended much effort in identifying those instruments not addressed at the time of the-violation, an adequate effort was not taken to ensure that instruments already identified were being properly' calibrated. For

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example, the suppression pool water temperature instruments and the drywell air temperature instruments were not identified.

During a telephone conference conducted on February 26, 1990, the licensee was informed-that these recent findings would be considered as additional examples of this violation. As stated previously, while Procedure 0.38.specifically addresses RTDs and thermocouples, the inspectors determined.that the corrective actions for this violation would not have identified instruments such as these because the licensee considered them to be already covered by the existing-procedures. The licensee has agreed to submit a supplemental response to this' violation to address what actions would be taken to ensure that all instruments in the existing program are being calibrated properly-(additional details' relating to the inspector's concerns with calibration of RTDs is.

discussedinparagraph3.2.1.1).

The licensee committed to providing the requested response within 30 days of the date of this report. This item will remain open pending receipt, evaluation, and inspection of the actions provided in the supplemental j

I response.

-3, 2POSTACCIDENT MONITORING INSTRUMENTATION (25587)

3.1-Background

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By letter dated December 17,1982(GenericLetter82-33),theNRCprovidedall

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reactor licensees and applicants with the " Requirements for Emergency Response Capability."

Included in these requirements was the application of Regulatory

Guide (RG)'1.97,_" Instrumentation for Light Water Cooled Nuclear Power Plants j

to Assess Plant and Environs Conditions During and Following an Accident." The provisions for the instrumentation described in RG 1.97 were endorsed by the NRC to ensure that nuclear power plant operators would have sufficient and reliable information available for preventing and/or mitigating the

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consequences of a reactor accident. During this inspection, the inspectors evaluated the acceptability of the installed instrumentation at the CNS. The inspection was conducted in accordance with the NRC Inspection and Enforcement Manual's Temporary Instruction 2515/87.

The inspectors reviewed the licensee submittals and the NRC staff evaluation of those submittals

" Safety Evaluation Related to Conformance to Regulatory

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Guide 1.97," transmitted tc the licensee by letter dated April 22, 1987. The inspectors also reviewed the CNS Updated Safety Analysis Report (USAR),

-Section VII, " Control and Instrumentation," and t u CNS TSs related to instrumentation systems. The inspectors reviewed a revision to the CNS RG 1.97 submittal which had been sent to the NRC by NPPD letter dated August 21, 1989.

This latest revision reflected the instrumentation actually being utilized to.

. fulfill the CNS RG 1.97 commitments.

The inspectors selected for detailed review, the instruments utilized for all five of.the Type A variables; these were all designed as Category 1 instruments. An additional sample of three Category 1 and five Category 2 instruments were also selected. The sampled instruments are listed in Table 1.

The design and qualification criteria for Categories 1, 2, and 3 instrumentation is-provided in Regulatory Position 1.3 of RG 1.97 Revision 2, dated December 1980. A brief comparison of these criteria is included in

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Table 2.

Category 3 instruments provide backup. type information and were not included in this inspection effort. The inspectors compared the attributes of the selected instruments to the provisions contained in Revision 2 of RG 1.97 to-verify conformance with the recommendations for range, power supply,

.environu ntal qualification, seismic qualification, and redundancy. During this comparison, the inspectors also determined whether there were any open questions that required a more detailed review (e.g., verify proper instrument range when the readout was specified as only 0-100 percent span) to determine acceptability.

The requirements for an acceptable postaccident, neutron flux monitoring system have been the subject of numerous NRC and BWR Owner's Group meetings and correspondence exchanges.

By letter dated January 29, 1990, the NRC informed

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the BWR Owner's Group that their latest proposed position was unacceptable.

The BWR Owner's Group was further directed to fulfill the provisions of RG 1.97, and develop a schedule for the installation of a Category 1 neutron flux moritoring system. Therefore, the inspectors did not evaluate the neutron flux monitoring system during this inspection. The instrumentation related to meteorological and radiological parameters that are included in RG 1.97 are inspected.in accordance with separate guidance contained in Temporary Instructions 2500/18 and 2515/65, respectively, and were also not included in this inspection.

During-this onsite inspection, the inspectors reviewed piping and instrumentation diagrams to verify that all of the selected )arameters were being detected by direct sensing. The inspectors reviewed tie listing of equipment required to be environmentally qualified to verify that the appropriate RG 1.97 instruments were included. The inspectors also verified that all of the selected instruments were included in the licensee's quality assurance program by reviewing the "Q" list.

The inspectors had noted that some of the instruments listed in the licensee's RG 1.97 submittals were specifically listed in the CNS TS. During the onsite inspection effort, the subject of operability and surveillance requirements for

.these instruments was discussed with licensee personnel. The inspectors

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concluded that implementation of the calibration program discussed in paragraph 2

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of this report should address those instruments not included in the TSs.

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The inspectors reviewed the various schematic, loop, and connection wiring diagrams to identify the power supply, electrical separation, and isolation i

devices utilized for each of the selected instruments. The diagrams were

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reviewed to ensure that redundant instruments were energized from separate

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sources, that system interconnections were properly isolated from each other,

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and that the systems contained the necessary components.

The inspectors verified that the required indications and monitors were availableinthecontrolroomandthetechnicalsupportcenter(TSC). The

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inspectors also verified the installation of the remitred strip chart

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recorders in the control room for the Category 1 parseters.

3.2 Inspection findings

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3.2.1 Review of Design Documentation The inspectors reviewed various design documents and drawings for the selected instruments to ensure that the RG 1.97 guidance, as committed to by NPPD, had been implemented. A listing of the pertinent drawings and procedures that were i

reviewed are contained in Attachments 1 and 2.

The inspectors had the following observations during.the review of the design documents.

3.2.1.1 Suppression Pool Water Temperature

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During the review of Surveillance Procedure 6.2.2.8.5, "PCSI Suppression

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Chamber Air and Water Temperature Calibration Test," the inspectors noted that the procedure did not require the temperature sensor, a resistance temperature detecticn (RTD), be subjected to a known temperature value to verify that the output was within the design accuracy. The inspectors were informed by a licensee representative that RTDs were only subjected to known temperatures l

prior to installation and were not periodically checked thereafter.

When this observation was discussed with a licensca representative, the repretentative stated that temperature loops were calibrated by applying resistance values to the loop electronics downstream of the sensor. This

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method of " calibration" was being performed at a frequency of 6 months as

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required by TS. While the electronics were being calibrated at the prescribed frequency, it did not appear that the temperature loop was being calibrated as def.ined by the TS. The TS requires an instrument calibration to "...

encompass the entire instrument including sensor, alarm /or trip functions and shall include the functional test."

The licensee representative stated that this definition was interpreted to mean that only instruments which could be adjusted would be calibrated. Since the RTDs had no adjustments, it was the licensee's position that they did not need to be calibrated.

Conversely to this position, the CNS procedure that controls

the plant calibration program, Procedure 0.38, specifically identifies RTDs and thermocouples as process monitoring instrumentation sensors that require

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-7-i calibration. This indicattd that while the licensee was aware of the necessity

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to calibrate the-temperature sensors, a decision had been made to not perform

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the requisite calibrations, j

Following identification of this discrepancy to the licensee, an engineering evaluation, dated February 15, 1990, was provided to the inspectors. This

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evaluationprovidedthebasisforajustificationforcontinuedoperation(JCO)

that was prepared the following day. The engineering evaluation addressed the i

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i operability of the RTDs based on manufacturer information. The subsequent JC0

included material used by another licensee as justification to amend their TS.

The amendment that was granted changed the definition of calibration with respect to RTDs and thermocouples. This change permitted an operability check i

of the sensors and adjustment, as necessary, of the remaining adjustable devices in the loop.

Since the devices in question are required for postaccident monitoring and are

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required to be environmentally qualified in accordance with 10 CFR 50.49, the

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verification of operability should be more vigorous than for an instrument used t

for normal plant operations. For a postaccident monitoring device to be operable, it must be functioning within its designed accuracy prior to being

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exposed to the harsh environment of a design basis accident.

In order to

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ensure the RTDs are operable, not only must it be demonstrated that they respond to temperature inputs, but that the response is within the design accuracy. The periodicity of this verification may be longer than the 6 months

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presently in TS; however, no determination has been made with respect to the periodicity.

This lack of calibration finding will be considered as a part of previous violation 298/8919-01 (discussed in paragraph 2). The corrective actions for that violation will be amended to reflect actions necessary to correct this issue as discussed in a telephone conference conducted on February 26, 1990, between the NRC and the licensee. This will be addressed in a future inspection as a part of the followup activities for violation 298/8919-01.

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3.2.1.2 Drywell Air Temperature Regulatory Guide 1.97 recommends that all instrumentation used for the regulatory guide be part of the licensee's calibration program. The licensee's calibration program includes the electronics for the variable drywell air

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l temperature. Three of the drywell air temperature RTDs were checked in 1988 as part of the integrated leak rate test. However, the RTDs installed in the drywell to sense the air temperature are not a procedural part of the l

licensee's calibration program. These omissions from the calibration program l

are considered as additional examples of violation 298/8919-01. The corrective l

actions for that violation will also be amended to address this issue.

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Subsequent review will be accomplished as a part of the followup activities for violation 298/8919-01.

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-8-3.2.1.3 Standby power In the August 21, 1989, submittal to the NRC, the licensee identified which instruments were to be used to determine the status of standby power af ter an

- accident. The list of instruments included diesel generator indicators for volts, amperes, watts, and frequency as well as volts and ampere indications for both the AC and DC emergency busses.

During this inspection, an effort was made to determine the status of calibration

'of these instruments. The licensee, however, did not have any procedures to perform the calibrations and had not calibrated any standby power instruments since 1988 during modifications to " Vertical Board C" in the control room.

The, diesel generator instruments are the same instruments identified in violation 298/8919-01. The corrective actions for this violation are not scheduled to be completed until the end of the upcoming refueling outage. The calibration of these instruments, therefore, will be followed as part of the corrective actions for violation ?98/8919-01.

3.2.2 Review of Installed Instrument Displays The inspectors performed a walkdown of selected plant parameters in order to verify that the installed meters and recorders had the same range as described

in the submittal. During this walkdown, the inspectors noted that the two redundant ox Rec ~ der PC-R-02-1

.(DivisionI)ygenconcentrationrecordershaddifferentranges..had a range of 0 to 10 percent a had a range of 0 to 30 percent. The Division 11 recorder had an expanded range so that the containment oxygen content could be verified as acceptable for reentry after a containment deinerting operation. Both recorders met the O to 10 percent range recomended by Regulatory Guide 1.97. While the licensee's most recent submittal (August 21,1989) implied that the range was 0 to 30 percent, it did

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not specifically state what the range of either recorder was.

Licensee representatives stated that the Regulatory Guide 1.97 report will be revised to eliminate a few known typographical errors. This revision will document the correct range of the oxygen concentration recorders. The revised report will be submitted to the NRC for information. The inspectors found this comitment satisfactory, and consider this issue closed.

3.2.3 Review of Calibration Documentation The inspectors found that the licensee was able to document the calibration of the parameters selected with the exception of the suppression pool temperature, drywell temperature, and standby power instruments. These items are discussed in detail in the preceding paragraphs.

3.2.4 Review of Instrument Drawings The inspectors reviewed the applicable drawings for selected parameters and found that Drawing 944E162, Revision 2. " Elementary Diagram Postaccident Monitor," had component identification codes (CICs) that were inconsistent with

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l the CICs on other drawings and documentation. The inspectors informed licensee

personnel of this finding. The licensee took immediate action to correct the i

drawing, by preparing a drawing change notice (DCN) for each-sheet. The inspectors reviewed DCN Nos.90-617 and 90-618 and found that the DCNs would correct the deficiency. Based on this corrective action, the inspectors consider this issue closed, i:

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EXIT INTERVIEW (30703)

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An exit interview was conducted on February 16, 1990, with the licensee-representatives identified in paragraph 1.

During this interview, the inspectors reviewed the scope and findings of the inspection as detailed in this report. Although-some proprietary documents were reviewed by the inspectors, no proprietary documents were removed.from the facility, and no

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proprietary information is contained in this report.

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- e TABLE 1 POSTACCIDENT MONITORING INSTRUMENTATION INSPECTED CATEGORY 1 INSTRUMENTS Reactor Vessel Level

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Reactor. Coolant System Pressure Drywell Pressure ContainmentAreaRadiationMonitor(WideRange)

Containment Hydrogen Concentration Containment' Oxygen Concentration

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Suppression Pool Level.

Suppression Pool Temperature CATEGORY 2 INSTRUMENTS Status of Standby power Drywell Temperature

. High Pressure Coolant Injection Flow Residual Heat Removal (RHR) Flow RHR Heat Exchanger Outlet Temperature TABLE 2 COMPARISON OF REQUIREMENTS C,ATEGORY 1 CATEGORY 2 Environmental Qualification Yes As' Appropriate Seismic Qualification Yes As Appropriate Single Failure Yes.

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Power Supply Emergency Standby Reliable

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Indication immediate Demand Recording Yes As Required

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QA Requirements 10 CFR 50, App. B As Appropriate

Testability Yes Yes

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LIST OF DRAWINGS REVIEWED Drawing Number Rev.

Drawing Title-1550-054A=

N01 Primary Containment Cooling and N2 Inerting System YBD-H+G s

I 1550-D55 NO3 Primary Containment Cooling and N2 Inerting

'l System VBD-H

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l 1550-D93A N00-CNS Torus Temperature Loop Flow Diagram, Div. I 1550-D93B N00'

CNS Torus Temperature Loop Flow Diagram, Div. 2 f

1550-D111 N00

. Drywell Pressure PC-PT-512A Loop Diagram

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1550-D112 N01 Drywell Pressure PC-PT-512B Loop Diagram

'1556-203 N09 Vertical Board 'H' Electrical Point to Point

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'2022 N41 Flow Diagram Primary Containment Cooling and Nitrogen Inerting System 2026 N30 Reactor Vessel Instrumentation 2.040 N31 Flow Diagram RHR System 2045 N25 Flow Diagram Core Spray System

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3010 Sh. 7 N13

- Load Study critical Control Panel CCP1A, Sh. 7 3010 Sh. 8 N10 Load Study Critical Control Panel CCPIB, Sh. 8 3012 Sh. 3 N08 Main Three Line Diagram, Sh. 3 3012 Sh. 5 N04 Main Three Line Diagram, Sh. 5

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3012.Sh. 6 N05 Main Three Line Diagram, Sh. 6 3024 Sh. 8~

N12 4160V Switchgear Elementary Diagram, Sh. 8

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3058 N20 DC One Line Diagram 3430 NO3 CAD System Connection Wiring Diagram Vertical

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Board 'PI'

791E261 Sh. 10 N06 Elementary Diagram RHR System 791E261 Sh. 12A N02 Elementary Diagram RHR System 791E271 Sh. 2 N10 Elementary Diagram HPCI System

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2-791E271 Sh. 6 NIO Elementary Diagram HPCI System 944E162 NO2 Elementary Diagram Postaccident Monitor 911-25501-W1 N01 ACAD System Panels Wiring Diagram VBD-P1 911-25501-W2 N01 ACAD System Panels Wiring Diagram YBD-P2 CNS-EE-82 NO2 Reactor Yessel Level NBI-LT-91B, -150 to

+225 Inches Loop Diagram CNS-EE-91 N01 Reactor Vessel Level NBI-LT-59B, +10 to

+225 Inches Loop Diagram CNS-EE-190 N00 Reactor Vessel Level NBI-LT-59A, +10 to

+225 Inches Loop Diagram CNS-EE-191

Reactor Vessel Level NBI-LT-590, +10 to

+225 Inches Loop Diagram CNS-EE-192 N00 Reactor Vessel Level NBI-LT-91A, -150 to

+225 Inches Loop Diagram CNS-EE-193 N00 Reactor Vessel Level NB1-LT-910, -150 to

+225 Inches Loop Diagram CNS-EE-194

Reactor Vessel Level NBI-LT-92, +160 to

+340 Inches Loop Diagram CNS-EE-195

H202 Analyzer (Div.1) One Line Diagram GE-117C3303 Sh. 4

Containment Pressure and Level Instrument Rack 1-A GE-117C3303 Sh. 5

Containment Pressure and Level Instrument Rack 1-B GE-117C3303 Sh. 6 NO3 Containment Level Rack #137 Northeast Quad El 895 Feet GE-117C3303 Sh. 7 NO3 Containment Level Rack #138 Northeast Quad EL 895 Feet l

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ATTACHMENT 2 LIST OF PROCEDURES REVIEWED i

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Surveillance i

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6.2.1.9 Extended Range Reactor Vessel Water Level

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Calibration and Functional Test L

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6.2.2.3.15-

HPCI Pump Discharge Flow Indication Calibration j

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6.2.2.3.15A

HPCI Pump Discharge Flow Indication Calibration

and Instrument Check at AS0-HPCI Panel

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6.2.2.5.1

RHR System Loop B Flow Indication Calibration 6.2.2.5.1A

RHR System Loop B Flow Indication Calibration

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and Instrument Check at ASD-RHR Panel

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6.2.2.5.5 RHR Reactor Vessel Shroud Level Indication'

Calibration and Functional Test

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6.2.2.8.1 PCSI Reactor Vessel Water Level Calibration Test 6.2.2.8.3 PCSI Drywell Pressure Instrumentation Calibration Test 6.2.2.8.4 PCSI Drywell Temperature Calibration Test

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6.2.2.8.5

PCSI Suppression Chamber Air and Water Temperature Calibration Test s

6.2.2.8.11 Posteccident Monitoring Reactor Pressure Instrumentation Calibration Test

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6.2.2.8.12 Fostaccident Monitoring Drywell Pressure

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Instrumentation Calibration Test i

6.2.2.8.13 Postaccident Monitoring Torus Level Calibration, Test 6'.3.1.13 Division I H2/02 Analyzer Calibration and

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functional Test L

6.3.1.14 Division II H2/02 Analyzer Calibration and l

Functional Test

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Control Procedure Number Rev.

Procedure Title

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14.8.1

Containment High Range Monitors A/R/H

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Determination i

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Procedure-Number Rev.

Procedure Title

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High Range Containment Monitor Victoreen

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Model 875 Source Calibration Check

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CNS Procedure

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Procedure Title

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CNS Calibration Program l

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