IR 05000298/1992019

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/92-19

ML20126E171
Person / Time
Site:	Cooper
Issue date:	12/21/1992
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 9212290039
Download: ML20126E171 (3)

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.g NUCLEAR REGULATORY COMMISSION yg, 17.lf .j REGl0N IV o, ,8 611 RY AN PLAZA DHIVE, SUITE 400

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DEC 211992 Docket No. 50-298 License lio. DPR-46 Nebraska Public Power District AITN: Guy R. Horn, Nuclear Power Group Manager P.O. Box 499 Columbus, Nebraska 68602-0499 Gentlemen:

SUBJECT: NRC INSPECTION REPORT 50-298/92-19 (NOTICE OF VIOLATION)

Thank you for your letter of December 1,1992, in response to our letter and Notice of Violation dated November 3, 199 We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violatio We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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in' /, i g, A. Bill Beach, i/ect Division of Re (or r ects cc:

Nebraska Pubiic Power District ATTN: G. D. Watson, General Counsel P.O. Box 499 '

Columbus, Nebraska 68602-0499 Cooper Nuclear Station ATIN: John M. Meacham, Site Manager P.O. Box 98 Brownville, Nebraska 68321 9212290039 921221 n PDR ADOCK 05000298 (/

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Nebraska Public Power District -2-

Nebraska Department of Environmental l Control i ATTN: Randolph Wood, Director  ;

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Lincoln, Nebraska 68509-8922 l l Nemaha County Board of Commissioners

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ATTN: Richard Moody, Chairman I l Nemaha County Courthouse 1824 N Street

Auburn, Nebraska 68305

l Nebraska Department of Health

ATTN: Harold Borchert, Director ,

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301 Centennial Mall, South i

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P.O. Box 95007 lincoln, Nebraska 68509-5007 Kansas Radiation Control Program Director l

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Nebraska Public Power District -3- DEC 21 1992 bcc to DMB (IE01)

bcc distrib, by RIV:

J. L. Milhoan Resident inspector DRP Section Chief (DRP/C)

Lisa Shea, RM/ALF, MS: MNBB 4503 Mis System DRSS-FIPS Section Chief (DRP/TSS)

RIV file J. Lieberman, OE, MS: 7-H-5 DRS G. F. Sanborn, E0 Senior Resident inspector - River Bend _

Senior Resident inspector - Fort Calhoun f

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Nebraska Public Power District -3- _

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bcc distrib. by RIV:

J. L. Milhoan Resident Inspector DRP Section Chief (DRP/C)

Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS Section Chief (DRP/TSS)

RIV File J. Lieberman, OE, MS: 7-H-5 DRS G. F. Sanborn, E0 Senior Resident Inspector - River Bend Senior Resident inspector - Fort Calhoun f.800:a-n L f

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De c ortbo r 1, 1992 IE8pv Document Control Dook l S. fJucionr Regulatory Commionion Washington, DC 2055L Gontlement c

I i Subject: REPLY TO A t10TICE OF VIOLAT10!4 (!4RC I!1S PFCTI O!J REPORT

{ tio. 50-290/92-19) j i

This lottor in writ. ton in rupponno to your lutter dated flovernbur 3, 1992, which l tranumitted the flotico of Violation (NRC Innpoetion Roport. 11 o . 50-290/92-19).

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Thoroin you identiflod ono violation.

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i l Following la the otatercont of violation and our rapponnon in accordanco with 10 l

} CPR 2.201.

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I j G.thtfF3nt of VInlji(.1pn j

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i 10 CFR Part 50, Appendix H, critorian XVI, requiros, in part, that moanuros shall

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be omtabliahod to annuro that conditions advorne to quality are promptly identified and correcte .

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l l Cont rary t o t.hu above, f roin 1914 until Septortbor 1992, the 11conson failed to l

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identify and correct the procenco of temporary start-up otrainorn in the

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condonsat o storago tank ouction line f or the coro spray pumps, which was not in 1 accordance with the core spray ayutom donign.

l Operation of the core opray system with the temporary s t a r t. -u p strainero inutalled in the condensato atoraga tank ouction was not in accordance with coru

spray ayatom design, an indicated on Drawing UR 2045 and, thun, was a condition l adverso to quality. 10 CFR Part 50, Appendix u, Critorion XVI, requiron that the

! licensen identify and correct conditionn adverno to qualit The liconson

operated the core opray nyatom from 1974 until September 1992 and did not l identify and correct thiu condition adverno to quality when notified of a i

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potential generic tesuo in Irformation tiotico 85-96, until prompted by the NRC in 199 This condition in a violation of 10 CFR Part 50, Appondix U (298/9219-03).

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Thin is a Suverity Lovel IV violation (290/9219-03) (Supplomont I).

REASD1LE0lLX10LATlG11 l On August 21, 1992, it was discovorud that the ternporary plant otart-up ntrainore located in the Coro Spray (CS) pumps A and B altornato (chutdown or emergency)

ouction supply lines from the condannato Storago Tank (CST) woro potentially otill inotalle Radiography parformod on August 22, 1992, voriflod that the otrainora woro still in placo. An operability ovaluation of the CS System was

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. Document Centrol Desk Page 2 December 1, 1992 performed which concluded that both CS loopo were still operable with the strainers installed and the core spray system in its normal lineup to take suction from the toru Nonconformance Report (NCR)92-104 was generated on August 24, 1992, to evaluate the root cause of this occurrenc In December 1985, the NRC issued IE Inf ormation Notice 85-96 entitled, " Temporary Strainers Lef t Installed in Pump Suction Piping". The purpose of the Information Notice was to alert licensees about a potentially significant problem pertaining to temporary construction strainers left installed in the suction piping of safety-related pump As a result of IE Information Notice 85-96, system engineers were instructed to confirm that pump suction strainers shown on system P&Ius were either removed or continued to be part of the permanent plant desig This instruction did not result in detection of strainers in the CS System alternate suction supply line apparently because they were not shown on plant P& ids. Had a detailed system walkdown been conducted, the temporary strainers would most likely have been detected. As such, one root cause of this violation is a programmatic weakness in that corrective action taken to address IE Information Notice 85-96 was less than adequat Review of pre-operational test documentation indicated that the strainers were designed to be removed during pre-operational testin However, the test procedure f or the cd System did not contain specific steps for strainer remova Had the procedure used specific sign-off steps to document temporary strainer removal, these strainers probably would not have remained in plac Consequently, another root cause of this violation is a procedural deficiency with the CS System pre-operational test procedur .

,qO,RRECTIVE STEPS TAKEN AND RFSULTS ACHIEVED Immediate corrective action consisted of a walkdown to ensure similar strainers are not located in the main and alternato pump suction lines for other safety systems including the Reactor Core Isolation Cooling (RCIC), High Pressure Coolant Injection (HPCI), Residual Heat Removal (RHR), Service Water (SW), and Reactor Equipment Cooling (REC) systems. As a result of the walkdown, there are no externally visible indications that temporary strainers are present in the SW, REC, RHR, or HPCI suction piping. Additionally, the CS Strainers were removed in September 199 When walking down the RCIC system, an unlabeled spacer plate was discovered in the flange on the inlet to the spool piece used to install the original startup straine A specific completed sign-off in the preoperational uest procedure (unlike the CS System pre-operational test) indicates that the strainer had been removed prior to startup testin As such, it is concluded that adequate evidence exists to indicate that a strainer is not installed in the RCIC suction piping and that the unlabeled plate was left installed as a spacer. However, during the 1993 Outage, this conclusion will be physically verified by removal and inspection of the spool picco or by radiograp COPPECTIVE STEPS WHICH WILL BE TAl'EN TO AVOID FURTHER VIOLATIONS There is no preventive action associated with the original inadequate preoperational test procedure since it will not be used again and the affected strainers have been remove .

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Document control Desk s Page 3 December 3, 1992 Proventivo action to address programmatic concerns has boon implementi in the form of various program upgrades sinco occurronce of this oversight in 198 Specifically, extennive system engineering training and correctiva action program upgrados have been implemente 'this event will also bo incorporated into induotry event training for system engineora. The District beliovos that those upgradas will prevent similar events from recurrin DAIE WHER FULL COMPLIANCE WILL DE ACHIEVED Full complianco with the requirements of the subject violation will be completed upon inspection of the RCIC spool picco which will occur prior to startup from the Spring, 1993 Refueling Outag This in-houso event will bo incorporated into industry event training for system ungineers by May 199 Should you have any questions concerning this matter, please contact my of fic Sine [rol ,

Om G. R Horn Nu 1 ar Power Group Manager GRil/DSDicml-53D cc: g,RdhionalAdmini.tator USNRC - Region IV NRC Resident Inspecsor Cooper Nuclear Statior.