IR 05000298/1990019
| ML20044A845 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/06/1990 |
| From: | Barnes I, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20044A844 | List: |
| References | |
| 50-298-90-19, NUDOCS 9007160126 | |
| Download: ML20044A845 (9) | |
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. . , ' " . APPENDIX.
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, JP Mr ' U.S. NUCLEAR REGULATORY COMMISSION !L. REGION IV' q..
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. u .I D .,, cNRC inspection Report: 4501298/90-19 Op'erating License: DPR-46 T
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Docket:.50-298; .+ ' ~ , N>: Licensee!' Netiraska PtElic; Power Districv(NPPD) ' &. ' $ Columbus, NE --68602-0499-- ~ P.0' Box =499' .g , . E < . a. x' . . Facility,Namei Cooper Nuclear; Station (CNS).
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- CNS, Brownville, Nebraska m
. , - , , ' Inspection At:' s < ', ,1nspection Conducted:- May"7-11, 23-25, and June 4-8, 1990 ' W .c - ' ., , j , Inspector: [ 8s 1 7 -1-i o - ' , A' p W. M. McNeill, Reactor Inspector, Materials Date s C, and Quality Programs Section, Division of-Reactor' Safety: ~ ~ og a , , , J v 7: V,"'T 8= v 7 -[- 7 o - ' Approved:: '. ' ~ - I. Barnes,n Chief.. Materials and Quality .Date-x ' Programs Secti.on,' Division of-Reactor-Safety 3.
> - s ..v c < y 'INspectionSummary: ' ' i ' , . > . ... a . . 7-11. 23-25',: and-June'4-8,1990-(Report 50-298/90-19) . Inspection Conducted May -
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. Areas 1 Inspected:.~ Routine, unannounced-inspection of action on a previously- <, is identified inspection' finding, self-assessment capability.and annual. qualityj . ' r s z , assurance program review, ' , - w7 y - Results;c The documentation of-Safety Review and Au'dit Board (SRAB); meetings e , was<fo'indjtc1besmore detailed than previously noted and resolution of concerns- ' . , '4 appeared to be more' effective thaniin the past. As a result of-the recent reconstitution;of'the SRAB. committee, implementation details for the new e ,
. charter have,not yet been fully established. The use of subcommittees should ' strengthen SRAB. activities, but the subcommittees were noted at this' time to be , y..~ still.-in the process of developing their specific functions. One noncited fg violation was identifiedLregarding the.. failure of SRAB to review and approve a special test procedure (i.e., STP 87-003).
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' 1:e " E -_ h e Station Operations Review Committee (SORC) meetings appeared to be better p ' Th6'. ' >,"
- documented than in the'past, in that the reasons for withdrawal of items from~
f ' - the agenda _were' identified and the handling of Open' Items appeared to be more .
- formal._ Improvements were noted with: respect to the ' adequacy of' root cause.
. t analysis and corrective actirns,' as a result of-the creation of a subcommittee _' .for oversight of this area. One:noncited violation was' identified in regard.to , , ',
- the failure to identify "on the spot changes" in test report summaries.
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"- The Technical Staff has been expanded and is planned to more fully function as =an independent safety review group.
Improvements were noted since the.last._, .
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- inspection in-terms of-documentation of activities.and fo.110wup of recommendations.
' ' ', The' established Quality Assurance _ program was found 'to be in conformance with ' ' commitments to the NRC.
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' DETAILS ^4 '1.
PERSONS LONTACTEDi ' , n-1.1 - rtPPD ' ,
- P.1 Ballinger, Operations Engineering Supervisor
- L.. E.: Bray,-Regulatory Compliance Specialist.
'*S' L. Bray, Operations Quality Assurance.(QA) Supervisor
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- . ' R; Drungardt, Operations Manager y '" B. L. Crow,; Lead: Mechanical Engineer M. A.-Dean,! Lead Operations Engineer S.W.Dierberger,InstrumentandControl(I&C) Foreman _.
R. ' A. Dieterich,' Safety? Review and Audit Board (SRAB) Administrator - M K. M."Doswell, Outage Coordinator- , J.'F. Dunn, Records Specialist' hJ.R.Flaherty, Acting' Plant:EngineeringManager -
.J. N. Grace 'SRAB Member . '*R..L. Gardner, Maintenance Manager iR. L. Gibson,iQA;Superv.isor H. J.~ Green,.SRAB MemberJ < H;-T._ Hitch, Plant Services Manager . m - ' .
- G. R.f Horn, Nuclear Operations Division Manager
. - z4 ~*H; A.:Jantsen;-I&C' Supervisor . < R.c A1 Jansky, Outage and Modifications Manager ' , ' C. M.;Kuta,:SRABDSecretary
- J. M.'Meacham,1 Senior. Manager of Operations
' ~ < . C..R.- Moeller.-Technical Staff Supervisor , J.,R. Myers,. Senior Technical Staff Engineer _ . , '
- S. M. PetersonrSenior Manager'of Technical. Support Services
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- D. L.' Reeves,' Senior Techn. cal. Staff. Engineer 1
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- J. V. Sayeri_ Radiological Manager-lL 4' i 1J.:T. Scheuerman, Lead-Safety Review Group (SRG)' Engineer
-, > . G. E. Smith, QA Manager __ , b, ' i ' *GR R. Smith;tNuclear Licensing L' Safety Supervisor ' <
'*V. WJ Stairs, Assistant Operations Manager , ' i !G. A. Trevors, Nuclear. Support Division Manager '
- M. E. Unruh," Acting-Maintenance Manager
. ,' p rKL C'.LWalden Nuclear Licensing and Safety Manager ER. E; Wilbur,1 Nuclear Engineering and Construction Divinion Manager ... T-
- V. U Wolstenholm, QA' Division Manager 1.2 NRC
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- W. R; Bennett, Senior Resident Inspector
. - ' G.~ A. Pick, Resident Inspector <
- Denotes those persons that. attended the. exit meeting on June 8,_.1990, id
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I h 'The NRC inspector'also contected other personnel including, administrative and m 1 clerical personnel.. , 2., ACTION ON A PREVIOUSLY IDENTIFIED INSPECTION FINDlHG.'(92702) -! ' c , ' '(Closed) Violation 298/8905-01: Failure to maintain training records of a SRAB - , ' member.
, .A review of-the training records-of the previous SRAB. membership by the
e ' inspector found; documentation'of the required training..The inspector-i additionally verified that the training requirements for SRAB had been
E documented in a Training Program Description, TPD-510, Revision 0, which was i administered by the training department.
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3.
LICENSEE SELF-ASSESSMENT CAPABILITY ~(40500) l \\ The: objective of.this inspection was to evaluate the effectiveness'of the .l 'n-licensee's self-assessinent program.
In this regard, the inspector reviewed _the ~activitiesoftheSRAB,StationOperationsReviewCommittee(SORC),andthe ' Technical Staff with respect to' assessment of the effectiveness of these groups-( .in-identification of concerns'and following such to resolution.- - '
- 3.1 SRM
.The activities of the SRAB were governad by, " Safety; Review and Audit-Board
- Charter," Revision ~0, dated April:24, 1990. _In addition, SRAB:had three
< implementing procedures which recently had been approved. 'The SRAB was found.
d to meet regularly once a month. - The SRAB membership was found:to be the . _ ' -QA Division Manager, Nuclear Engineering and Construction Division Manager, Nuclear Operation Division Manager, l'uclear Support Division Manager.1 Nuclear z ,3 ' Licensing and Safety Manager.SRAB Administrator, and _two outside: voting members.
j - . 'A standard format for meetings' addressed such agenda items as: ' l Approval-of previous meeting minutes
- LicenseeAmendments'andTechnicalSpecifications~(TSs) Changes
m - l' ' Operating Reports ' , . Safety-Evaluation-Subcommittee Reports
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_' Quality _ Program, Audit Findings and Trends i . ~' ; Quality Audit Subcommittee: Reports = 1 ;
- Industry Experience Subcommittee Reports
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_' 'Open Action item List Status' " - t . Licensee = Event Reports (LERs) and Notices of Violation.
- t Review of Action Items from Current Meeting
, , y - Other Business and Special Presentations j The inspector reviewed the meeting minutes of 1990 in detail and attended o meeting-150. Observations by the inspector were as follows: Since the last inspection, the activities of SRAB have been " reconstituted" with a new charter. The most significant changes to SRAB as a result of-this
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- , . " reconstitution" were the addition of outside voting members and subcomittees.
. Because of the recent changes, a=significant portion of the observed activities .was devoted to planning mechanics of implementation of the new charter.- The-inspector! observed a discussion-in the SRAB meeting on whether' SRAB should review and approve Updated Safety Analysis Report (USAR) revisions or have _-information copies. _There was no debate on SORC's need to review and-approve . in the USAR revisions.
It was resolved that SRAB-would only have.information-copies of revisions.
, The' meeting minutes of-the " reconstituted" group appeared to be better-
documented than in-the past. 'A listing of items with the simple notation of-reviewed and approved was not found as was the case in the past. Discussions ' _ of subjects'were found to'be of sufficient depth and scope to indicate a l thorough review of the subject.
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- f The development of the subcomittees appeared to be progressing satisfactorily. 'Their effectiveness could not, however, be fully evaluated because of the limited-time that has elapsed since their formation. The inspector did note-a difference in-philosophy on the role of subcomittees in a meeting discussion between SRAB members. The difference pertained to whether subcomittees would screen-review items for SRAB or were delegated to act for.
SRAB and disposition items.
Five Action Items were identified in the 1990 minutes 'of which only two were- '* in an open status, with the oldest being only 2 months old.
It was-noted, however, that the-implementing procedures did not contain specific guidance with respect'to the~ criteria to be used for initiation, tracking, and closecut-of Action Items by the full SRAB comittee and its subcomittees.
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- 'As:noted11n" paragraph 2, SRAB training was: reviewed...The inspector noted-
- that training and : qualification-requirements for alternates ~and subcomittee memaership has not yet been established.' The' addition of root cause and corrective action training could bs an improvement in SRAB and SORC training.
requirements.
-It has not yet been established whether SRAB. members will be required to
participate in audits on occasion, or if the members will have to' tour the site' t on a regular basis.
Design' Changes--(DCs)pector of-a sample of 25 Special Test Procedures (STPs) and-0* Review by the ins which were identified in the 1989 Annual Operating Report found that STP 87-003-(which was performed in-April and May 1989 on the maximum % ccontrolirod drive system flow) was not documented in SRAB minutes as having .b_eensreviewed and approved. The remaining STPs and DCs in the 1989 annual ' report were checked.as a result of this observation and-found to have been reviewed and approved. /The licensee subsequently. identified STP 87-003 in a nonconformancereport(NCR),90-093. Corrective actions and preventive actions were' established and implemented during the inspection. A Hotice of Violation , .,
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m-6- ! , , ' is not being-issued because the criteria of Section V.A. of the NRC's- 'I Enforcement Policy have been met.
! I Summary-
The documentation of SRAB meetings was found to be more detailed than
a l previously noted and resolution of. concerns appeared to be more effective'than in the past..As a result of the recent reconstitution of'the GRAB committee, , implementation details for the new charter have not yet been fully established.. ' . The use' of subcommittees.should strengthen SRAB activities, but the ' subcommittees were noted at this time 4 to be still in the process of developing ' y - their. specific functions. 'One noncited violation was-identified regarding the- '! " , , failure of,SRAB to review and approve STP 87-003, ' ' 3.2 SORC ' The activities of. the'SORC were governed by CNS Procedure 0.3, " Station
Operations Review Committee," Revision.9, dated June 29, 1989. The.SORC met l , , -weekly in' regular meetings and held special meeting as required by circumstances.=:During outages, regular meetings were held.sometimes more often ' a than weekly. At regular meetings, typically 20 to 60. agenda items were
addressed and at special meetings typically one or two agenda items were i < " = addressed.. As of' this inspection, 68! meetings have,been held this year. The j > meeting attendance was;found>to'be six to nine members, averaging about eight.
s h The.SORC membership was found'to be the Huclear Operations Division Manager, Senior Manager. of-Operations," Senior _ Manager Technical Support, Operations-Manager, Radiological Manager, Maintenance Manager, Outage and Modification.
Manager, Engineering Manager, Plant Services Manager, I&C Supervisor, Operations - Engineering' Supervisor,. Technical Staff Supervisor, and QA Manager. TheiTSs'. , _ - have beenFchanged to identify member by functional areas, rather than titles of-J positions. The meeting addressed such agenda-items as: s m. , 1' Approva1>of new and revised procedures > ' Approval of TSs-changes-
. < - ', Design / Changes - v - *. Temporary Modifications Ehd ntering Specification Ch nges
' Set Po br Cnanges ~ LERs ' Open items ~ The inspector reviewed the meeting minutes numbered S90-001 through -060 in-detail and attended SORC Meetings 590-065 and -068.
The training and ' , qualification records of members were reviewed and observations of the
~ inspector were as-follows: The meeting minutes have improved in regard to information content in that ' items removed from the agenda during meetings now have the reasons documented for their' deletion from the agenda, v ' ,! l A -- -- -
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. [ Discussions of subjects in SORC meetings were found to be of sufficient ' > depth and scope to indicate a thorough review of the subject.
g }' Since the last inspection 50RC has been enhanced by use of a subcommittee on
NCRs. The subcommittee was made up of representatives from such disciplines as operations, engineering, QA, maintenance and I&C, and was chartered with the , review of NCRs for assessment of the adequacy of the identified root cause and ' corrective actions. This subconmittee appeared from review of meeting minutes to be very effective in review of NCRs;. however, the group has yet to establish a data base for use in trend analysis, e Since the first of the year seven Open items have been identified by' SORC,
-with two currently remaining open. One Open item from last year remains open.. The handling of Open items appeared to be more formal than in the past.
.The same sample of 25 STPs and DCs identified previously in aaragraph 3.1
were verified to have been reviewed and approved by $0RC.
In the review of STPs, the inspector noted that a minor p-ocedure violation had occurred, y Several Completion Reports for STPs such as 88-016, 88-?83, and 87-003,did not identify *0n the Spot Changes" (OSCs) revisions in the Test Summary Section of the report as required by Procedure 3.5, Sec'. ion 8.5.1.4.
This was subsequently identified by the licensee in NCR 90-090. Corrective actions and preventive actions were established and implemented during the inspection. A Notice of Violation is not being issued because the criteria of Section V.A. of the NRC's Enforcement Policy have been met.
It was noted by the inspector that Procedure 3.5, "Special Test
Procedures /Special Procedures," Revision 6, dated November 30, 1989, permitted revision of an STP by an OSC, without the change being subject to SORC review.
DCs were revised also with OSCs; however, such OSCs were required to be reviewed by.a SORC member. The licensee agreed to change its procedure to require a 50RC member review of OSCs to STPs. This change was part of the corrective actions in NCR 90-090.
Summary . The 30RC meetings appeared to be better documented than in the past, in that the reasons for withdrawal of items were identified and the handling of Open items appeared to be more formal.
Improvements were noted with respect to the . adequacy of root cause analysis and corrective actions, as a result of the creation of a subcomittee for oversight of this area. One noncited violation was. identified in regard to the failure to identify OSCs in test report summaries.. .w 3.3 Technical Staff . The Technical Staff is the CNS equivalent for an independent safety engineering group. The Technical Staff currently consists of six engineers and a specialist, with four of the engineers assigned to the newly formed Safety l . Review Group (SRG). The activities of the SRG have not yet been established in a policy.and implementing procedures. The remainder of the Technical Staff activities were.found to be governed by Procedures 0.10.1, " Operating , ]f,
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' I' I Experience Review," Revision 4, dated June 8, 1589; 0.10.2, " Operating Plant- ! Experience Report," Revision 0, dated January 15, 1987, and 0.10.3, " Operating - ' Experience Review Effectiveness Review," Revision ?, dated June 8, 1989.
, The Technical Staff activities included review of:
- NCRs and LERs
. } ' NRC Bulletins. Information Notices and Generic Letters . " Vendor information-such as 10 CFR Part 21 reports, service advisory letters,
and service information letters
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Institute of Nuclear power Operations Significant Operatit.3 Experience
Reports, Significant' Event Reports and Significant Event notifications
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The Technical Staff was additionally required by its procedures to perform an annual overview or audit:of'the operating experience review process. The
inspector reviewed the most recent annual effectivened review.
> Observations 1by the inspector regarding Technical Staff activities were as , follows: ' ' . With the~ exception of SRG, Technical Staff procedures now fully describe all j
Technical Staff activities. For example, the use of a check list, identified i in the past inspection as not included in procedures, has been included in the i applicable procedure. The 1989 effectiveness review was found to have .! E recommendations for atich follow up was performed.
It was noted, however, by the inspector that it ras difficult to determine the status of the "~ '3 recommendationc as either open or closed.
, Review of five LERs issued during 1990 indicated, with one exception, that C the Technical Staff was performing satisfactory reviews. The exception pertained to LER 90-04, for which some applicable foot cause and corrective' l action information had not been identified in'the text of the LER.
It appeared , . that the engineered safety feature actuation was caused in part by a time delay, t relay malfunction for which corrective actions of cleaning and resetting were t taken.
' l .The SRG presently was devoted to the procedure upgrade program.
" Requirements for SRG. review of new and revised procedures, DCs and asscciated OSCs. STPs and associated OSCs, Set Point Changes and Teuporary Modificatior% had been included in several administrative procedures.
It has not been . currently established whether SRG will conduct tours of plant activities as , l part of their assigned duties.- t i l; Sumary . Improvements were noted since the last inspection in terms of.ttocumentation of . activities and followup of recommendations. The Technical Staff has been i expanded and is planned to more fully function as an independent safety' review
group.
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QA PROGRAM ANNUAL. REVIEW (35701) i The objectives of this inspection were to ensure tnat the licensee is l implementing a QA program that is in conformance with the TS, USAR, regulatory requirements and licensee commitments.
4.1 Program The inspector reviewed the TS, P.evision 6 of the QA program description, the QA [ Program for Operation Manual which included QA Instructions and QA Plans, and , Volume 12 (Quality Control Procedures) of the Operations Manual.
' Observations by the inspector were as follows: Sincethe1Astinspection(SeeInspectionP,eport 50-298/88-04) there have been .f
a number of personnel changes and additions to the plant organization and the QA organization. The basic structure of the QA organization has remained'the same since last inspected, with a QA manager at the General Office with two QA supervisors and five engineers; and a QA manager at the site with two QA . supervisors and eight engineers and specialists. The cualifications-for the new personnel.were reviewed by the inspector and were found to be satisfactory.
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The QA program as described in the above documents appeared to be consistent - with the commitments in the QA program description.
4.2 Implementation l In addition to the current inspection of the self-assessment program, the implementation of the QA program has been previously inspected in the areas of ! the document control program (See Inspection Report 50-298/8930); and the receipt, storage and handling of equipment and materials program (See Inspection
Report 50-298/90-06).
i No violations or deviations were identified in this area of the inspection.
5.
EXIT MEETING An exit meeting was held on June 8, 1990, with those individuals denoted in paragraph 1 of this report. At this meeting, the scope of the inspection and the findings were summarized. The licensee did not identify as proprietary any of the information provided to, or reviewed by the inspector, t , ',, / p ~ .. ! .f , I - t .{ }}