IR 05000298/1993005
| ML20012G492 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/23/1993 |
| From: | Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20012G490 | List: |
| References | |
| 50-298-93-05, 50-298-93-5, NUDOCS 9303050003 | |
| Download: ML20012G492 (10) | |
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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-298/93-05 Operating License:
DPR-46 Licensee: Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 Facility Name:
Cooper Nuclear Station (CNS)
Inspection At:
CNS, Brownville, Nebraska Inspection Conducted:
February 1-5, 1993 Ir.spector: Howard F. Bundy, Reactor Inspector, Plant Support Section Division of Reactor Safety Amarjit Singh, Reactor Inspector, Plant Support Section Division of Reactor Safety 2[py J
Approved:
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C W M ablF, Chief, Plant Support Section Date /
Division of Reactor Safety Inspection Summary
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Areas Inspected:
Routine, announced inspection of the licensee's fire protection / prevention program and licensee actions on previous inspection findings.
Results:
The inspection verified that the licensee's fire protection / prevention
program is effective and has been properly maintained (Section 1.8).
There appeared to be a weakness in documenting surveillance procedures
(Section 1.2).
The licensee failed to assign fire watch personnel at certain inoperable
fire barriers (Section 1.4).
9303050003 930226 PDR ADOCK 05000298 G
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-2-Egy,ary of Insoection Findinas:
Violation 298/9305-01 was opened (Section 1.4)
Inspection Followup Item 9120-01 was closed (Section 2).
- Attachments:
Attachment 1 - Persons Contacted and Exit Meeting
Attachment 2 - Documents Reviewed
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DETAILS
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1 FIRE FROTECTION/ PREVENTION PROGRAM (64704)
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i The purpose of this inspection was to determine if the licensee had established and was implementing a program for fire protection and prevention in conformance with regulatory requirements, Technical Specifications, and industry guides and standards.
1.1 Administrative Controls
The inspectors reviewed the licensee's programs and procedures used to control
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combustible material and to reduce fire hazards. The inspectors observed that i
the licensee had technically adequate procedures to implement the fire
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protection program and that the licensee provided good control of combustible materials to reduce fire hazards. Administrative controls had been established to handle inoperable fire detection, suppression, support equipment and fire doors.
Interviews with personnel indicated that the
licensee had established a strong program for personnel fire fighting
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qualifications, training, and staff responsibilities, and established controls
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for welding, cutting, guiding, and other ignition sources. Maintenance i
evolutions, which significantly increased fire risk, were properly controlled.
1.2 Surveillances
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i In this area the inspectors reviewed the records for surveillances conducted
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since the last inspection to verify that:
The fire detection and suppression systems currently meet the Technical
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Specifications (TS) operability testing requirements, and i
Operability for these systems has been satisfactorily demonstrated at
the required frequencies.
The inspectors reviewed the surveillance procedure data packages listed in
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Attachment 2.
The inspectors found that TS required surveillances were being conducted at the required frequencies.
Furthermore, TS required systems and components had been proven operable as required.
Prompt actions had been taken to repair defective components and appropriate compensatory actions were
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taken when required. However, similar actions were not always taken for non-TS required components.
The inspectors noted that although not specifically
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required by procedure some employees recorded work item (WI) numbers on surveillance data forms to record equipment problems. This improved the
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traceability of problems through to resolution and was viewed as a good
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practice.
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-4-Surveillance documentation was sometime confusing. The following are among the documentation problems which the inspectors identified during the review of performance records for Surveillance Prccedure 6.4.5.1, " Fire Protection System Monthly Examination":
For the performance on August 21, 1992, Fire Doors D126 and D401 did not
close securely. They were d?spositioned as " witted," [ meaning work item (WI) generated) but no W1 numbers were noted. The test was approved as satisfactory with these doors apparently inoperable. These doors, which were not required for safe shutdown, were ultimately repaired and returned to service.
For the performance on November 13, 1992, Door N200 did not close
securely approximately fifty percent of the time and was dispositioned as " witted," with no WI number given. The test was approved as satisfactory with the door inoperable and thus noted in the shift supervisor and control room logs, with no mention of the inoperable door. One of the shift supervisors who was on duty during that time frame stated that he was aware of the inoperable door. The inspector determined that the door had been repaired under WI 92-2703 on November 16, 1992, and the retest had been approved on November 17, 1992.
For the performance on January 11, 1993, the Fire Pump D Diesel Engine
Overspeed Trip Capacitor Examination was not completed because the capacitor had been removed under Design Change 91-085.
In the disposition OD (operability determination),93-002 was noted. The test was dispositioned as unsatisfactory.
It was not clear whether further testing was required. A note that no further testing was required would have been appropriate. Also, it would have been helpful to note in the comments that a procedure change (TPCN 93-005) was being processed.
Although the above documentation problems did not impact the operability of TS required components, they could create confusion concerning the availability of fire protection systems and equipment.
The licensee was conducting surveillances at the required frequencies to demonstrate the operability of TS required plant fire detection and suppression systems. However the documentation, particularly for non-TS required systems and components, was not always clear.
1.3 Fire Protection Quality Assurance Quality assurance audits for the past 2 years were reviewed by the inspectors.
These audits were identified as: QA 91-09, " Fire Protection (Annual)," dated July 31,1991 and QA 92-10, " Fire Protection Audit (Triennial)," dated October 21, 1992. The audits addressed system and equipment alterations, tests, surveillances, maintenance, records, and overall fire protection program. Discrepancies identified were formally presented to the responsible
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organizations. Responses were tracked to close out and the actions taken were reviewed for adequacy by the appropriate organizations. The audits appeared to be thorough and the discrepancies identified indicated only minor problems.
j 1.4 Physical Observations from Fire Area Walkdowns
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A tour of accessible areas of the plant was conducted to assess general area
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conditions, work activities in progress, and the visual condition of fire protection systems and equipment.
Combustible materials and flammable and
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combustible liquids and gas usage were properly controlled in areas containing
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safety-related equipment and components.
Items inspected included position of
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selected valves, fire lockers, fire barrier conditions, hose stations, carbon dioxide and Halon system lineups, and fire extinguishers for type, location,
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accessibility, and conditions. All of the installations and fire brigade equipment including emergency breathing apparatus were found to be functional and tested in accordance with the requirements established in the fire l
protection program. There were no construction activities in progress in toured areas.
General housekeeping conditions were found to be very good.
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During walkdown in the cable spreading room at the 918 feet level, the inspectors noted two enclosed vertical cable risers, which had been enclosed by the use of Thermo-lag material.
These enclosed vertical risers should have been declared inoperable in accordance with the guidance provided in NRC Bulletin No. 92-01, Supplement 1, " Failure of Thermo-Lag 330 Fire Barrier
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System to Perform its Specified Fire Endurance Function," dated August 28, 1992. Contrary to the instructions provided in the above bulletin, the
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licensee did not declare these barriers inoperable and post a continuous fire i
watch on at least one side of the penetration within one hour in accordance
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with CNS TS 3.198. The inspectors told the licensee's representatives that the barrier should have been declared inoperable and a fire watch posteo when Bulletin 92-01, Supplement I was received. The licensee stated that the i
barrier in question did not fall into the guidelines of NRC Bulletin 92-01, i
Supplement 1, because NRC granted CNS an exemption from the one hour fire
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barrier requirement.
The inspectors determined from the associated safety evaluation report that the exemption was based on the use of Thermo-lag i
material which had been tested as a one hour fire barrier in other configurations. Because NRC Bulletin 92-01, Supplement 1 instructed licensees to declare one hour fire barriers constructed from Thermo-lag material
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inoperable and initiate appropriate actions, the failure of the licensee to
assign continuous fire watch at this barrier is a violation (298/9305-01) of i
TS 3.19B.
Also during the walkdown, the inspectors interviewed a fire watch person assigned in the residual heat removal system service water booster pumps and service air compressor area and determined that he was unaware of an inoperable Thermo-lag fire barrier located on the south wall behind an air d ryer. The senior fire protection engineer stated that this fire watch person was suppose to monitor that barrier. This is another example of a violation
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(298/9505-01) of TS 3.198. The licensee took the appropriate corrective actions immediately by establishing a continuous fire watch at the barrier in
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-6-the cable spreading room and providing remedial training to the fire watch personnel assigned to the pump room.
1.5 Plant Fire Brioade/Trainino The licensee has organized to provioe one five-person fire brigade per shift in support of the CNS. The basic qualifications requirements and training were established for CNS. The inspectors also reviewed selected lesson plans, training attendance records, and fire brigade drill and practice session records. This review confirmed that the licensee was covering the required topics, providing the required drills and practice sessions, and meeting the required frequency of training elements.
1.6 Observed Fire Brioade Drill The inspectors observed an unannounced fire brigade drill.
The drill scenario involved the lube oil reservoir room, turbine building North-903 feet.
The brigade assembled in a timely manner, properly utilized the turnout gear, and checked out their self-contained breathing apparatus. The fire brigade leader received a brief of conditions from the control room, consulted the fire preplans, and directed the brigade members to bring special equipment, such as the foam nozzle. The brigade's approach to the fire area was satisfactory and indicated an appreciation of potential conditions and hazards. The licensee's provisions for area control and support personnel was considered. good. ' The practice of immediate debriefing of the brigade members following a fire drill provided feedback for future training. The training department representative acknowledged that a number of significant improvements have been made in the program as a result of post-drill feedback.
1.7 Fire Brioade Eouioment The inspectors checked the fire brigade equipment provided in the different areas of the plant.
The fire brigade equipment is also maintained in the building that houses the protected area fire truck.
Each location seems to have adequate equipment and had maintained the required inventory.
1.8 f_gnclusions The licensee had maintained an overall effective fire protection prevention program. The licensee's administrative controls and general housekeeping were considered a strength in the fire protection program. However, the documentation of surveillance procedure performance particularly for non-Technical Spec 1fication required systems and components, was not always clear and is considered a weakness. One violation was identified involving a failure to assign a fire watc (?
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2 LICENSEE ACTIONS ON PREVIOUS INSPECTION FINDINGS (92701)
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[ Closed) Insoection Followuo Item (298/9120-011: 4160 Volt Breaker
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Malfunctions
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The purpose of this item was to track the completion of corrective actions involving a series of licensee identified 4160 volt breaker malfunctions that
have occurred since 1987. The failures were apparently caused by grease i
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hardening in the trip latch / cam follower assembly. The licensee had determined that the root cause was inadequate maintenance and contributing causes were high ambient operating temperatures and use of a petroleum based lubricant instead of the teflon based lubricant specified by the manufacturer.
The switchgear room ventilation was modified in 1987 to reduce ambient temperature.
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The inspector reviewed Memorandum CNSS925554, dated January 31, 1992, which
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addressed the licensee's actions with respect to this item.
It stated that all trip latch / cam follower assemblies on 4160 volt safety related breakers had been cleaned and relubricated or replaced. Also, the trip latch / cam
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follower assemblies on selected non-essential breakers were regreased or replaced. The inspector noted that Procedure 7.3.17, Revision 11, " General
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Electric 4160 Volt Breakers, Maintenance, Testing, and Setting," had been revised to add a section applicable to cleaning, lubrication, and/or
replacement of latch rollers and cam follower rollers.
It required the use of grease approved by the vendor. The inspectors noted that Preventive
Maintenance Work Item 00312 required inspection of these breakers in accordance with Procedure 7.3.17 each refueling outage.
In addition, the
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inspectors reviewed several work items associated with inspection and repairs of the subject breakers. The above actions should preclude similar i
malfunctions of the subject breakers.
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ATTACHMENT 1
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1 PERSONS CONTACTED
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1.1 Licensee Personnel
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- F. Alderman, Fire Protection & Industrial Safety Supervisor
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- L. Bray, Regulatory Compliance Specialist
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- M. Dean, Nuclear Licensing and Safety Supervisor J. Dutton, Training Manager
- J. Flaherty, CNS Engineering Manager
- R. Gardner, Plant Manager (by telephone)
- H. Hitch, Site Services Manager
- S. Jobe, Acting Training Manager
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- J. Lechner, Senior Fire Protection Engineer
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- E. Hace, Senior Manager, Site Support
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J. Meacham, Site Manager
- C. Moeller, Technical Staff Manager
- S. Peterson, Acting Plant Manager
- G. Smith, Quality Assurance Manager, CNS
- V. Stairs, Assistant Operations Manager
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1.2 NRC Personnel
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- R. Kopriva, Senior Resident Inspector
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- W. Walker, Resident Inspector
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In addition to the personnel listed above, the inspectors contacted other
personnel during this inspection.
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- Denotes personnel that attended the exit meeting.
i 2 EXIT MEETING The inspectors met with licensee representatives on February 5,1993, and
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summarized the scope and findings of this inspection.
The licensee did not i
identify, as proprietary, any of the material provided to, or reviewed by, the inspectors during this inspection.
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ATTACHMENT 2
DOCUMENTS REVIEWED Procedure 0.7.1, Revision 2, " Control of Transient Combustibles"
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Procedure 0.7, Revision 8, " Flammable, Combustible, and Chemical Materials
Control"
Procedure 0.7.2, " Hazardous Material / Waste Control," Revision 2, December 12,
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1991 Procedure 0.16, " Control of Fire Doors," Revision 10, February 20, 1992
Procedure 0.23, " Fire Protection Plan," Revision 10, September 3, 1992 i
Procedure 0.23.1, " Fire Suppression Activities," Revision 1, September 12, i
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1991
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Surveillance Procedure (SP) 6.4.5.5, " Fire Detection System Semi-Annual E.umination," data packages for performances on February 11, 1992; June 22,
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1992; June 30, 1992; and August 10, 1992 i
SP 6.4.5.6, " Fire Detection System Circuitry Operability," data packages for performances on March 16, 1992 and August 31, 1992
SP 6.4.5.13.2, " Fire Detection System Tri-Annual Test (Gioup 2),"
data
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packages for performances on January 23, 1992; January 27, 1992; and
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February 7, 1992 t
SP 6.4.5.14, "High Pressure CO, Bottle Exam," data packages for performar.ces on May 18, 1992 and November 30, 1992
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SP 6.4.5.19, "Halon 1301 Southwest Pump Room Fire Suppression Surveillance Checks," data packages for performances on March 18, 1992; April 1, 1992; i
April 2, 1992; and September 23, 1992
i SP 6.4.5.20, "Halon 1301 Computer Room Fire Suppression Surveillance Checks,"
l data packages for performances on March 18,1992; July 27,1992; and
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September 23, 1992 SP 6.4.5.21, " Fire Protection Manual Pull Station Functional Test," data l
packages for performances on January 15, 1992 and July 11, 1992
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i SP 6.4.5.22, "Halon 1301 E0F Communications Room Fire Suppression Surveillance Checks," data packages for performances on March 30, 1992 and September 24, i
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1992 SP 6.4.5.1, " Fire Protection System Monthly Examination," data packages for
j performances on August 21, 1992; September 18, 1992; October 16, 1992; November 13, 1992; December 11, 1992; and January 11, 1993
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SP 6.4.5.17, " Fire Fighting Equipment Monthly Examinations," data packages for l
performances on October 20, 1992 and December 22, 1992 i
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SP 6.3.13.2, " Safe Shutdown Emergency Lighting Functional Test," Revision 8,
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April 11, 1991 SP 6.4.5.3, Fire Pump Monthly Operability Test," Revision 21, November 14, 1991
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SP 6.4.5.17, " Fire Fighting Equipment Monthly Examination," Revision 16, dated
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June 13, 1991
SP 6.4.5.7, " Diesel Generator CO, Operability Test," Revision 6, dated
January 30, 1992
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SP 6.4.5.9, " Diesel Fire Pump Inspection," Revision 9, dated August 13, 1992 SP 6.4.5.16.1, " Fire Damper Assembly Examination (Fire Protection system 18
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Honth Examination)," dated November 19, 1992 SP 6.4.5.16.2, " Fire Area Barrier / Fire Wall Visual Examination," Revision 3, dated February 20, 1992 i
SP 6.4.5.16.3, " Fire Area Barrier or Fire Barrier Assembly Fire Seal Visual j
Inspection (Fire Protection System 18 Month Inspection)," dated July 20, 1989 j
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