IR 05000298/1993007
| ML20035B961 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/02/1993 |
| From: | Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20035B962 | List: |
| References | |
| 50-298-93-07, 50-298-93-7, NUDOCS 9304060047 | |
| Download: ML20035B961 (12) | |
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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-298/93-07
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Operating License: DPR-46 Licansee: Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499
Facility Name: Cooper Nuclear Station (CNS)
Inspection At: CNS, Brownville, Nemaha County, Nebraska
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Inspection Conducted: February 8-12 and 22-26, 1993 Inspector:
M. E. Murphy, Reactor Inspei e, Plant Support Section
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Division of Reactor Safety
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Approved:
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Y243 G. L. Constable / Chief, Want 'SuppoFt Section Date DivisionofRealtorSafety Inspection Sumary Areas Insoected: Routine, announced inspection of the licensee's self-
assessment capability, program for feedback of operational experience information, and followup of licensee event reports.
Results:
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The licensee's organizations responsible for self-assessment were
determined to be constituted and conducted in accordance with the
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approved procedures. The Technical Specification requirements for both
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onsite and offsite safety review organizations were satisfied (Section 1.1.3).
The licensee had established methods and programs for self-assessment.
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The lack of assessments, evaluations, and/or conclusions in the trending l
and summary reports was considered a weakness in the program (Section 1.2).
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The licensee had implemented a good program for feedback of operational
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experience information. A strength was identified in the area of information evaluation and feedback in the training area (Section 2.1).
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Sumary of Inspection Findinos:
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Licensee Event Reports92-009 and 92-016 were closed (Section 4).
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Attachments:
Attachment 1 - Persons Contacted and Exit Meeting
I Attachment 2 - Documents Reviewed
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DETAILS 1 SELF-ASSESSMENT (40500)
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The objective of this inspection was to determine the effectiveness of the
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licensee's self-assessment capabilities and actions associated with identified
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problems. To accomplish this objective the inspector focused on determining that the licensee's program contributed to the prevention of problems by monitoring and evaluating plant performance, providing assessments and findings, and comunicating and following up on corrective action recomendations.
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1.1 Oraanizations Resoonsible for Self-Assessment
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There were four basic organizations responsible for identifying and assessing issues related to safety at CNS.
In addition to the normal Quality
Assurance / Quality Control organization, these groups were the Nonconformance i
Overview Comittee (NOC), the Station Operations Review Comittee (SORC), and
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the Safety Review and Audit Board (SRAB). The establishment of the SORC and
SRAB satisfied the Technical Specification requirements for the. review and audit of safety issues.
j 1.1.1 Nonconformance Overview Comittee (NOC)
The NOC was a standing subcomittee of SORC. The NOC reviewed all new l
nonconformance reports (NCR) and closecut packages. Their first t
responsibility was to ensure consistency in NCR review and root cause
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analysis. They also confirmed accountability and corrective action
assignments. NOC provided trending and tracking to monitor generic concerns
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and the recurrence of nonconforming events.
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The NOC met on the average of once per month, the last meeting was held on i
February 3, 1993, just prior to this inspection. The inspector reviewed the j
meeting minutes for that meeting (NOC Meeting 93-2) and discussed them with a
comittee member. The reviews for closure were thorough, comprehensive, and well documented.
It was not possible for the inspector to evaluate the review i
of new NCRs because any coments or changes were not identified in the minutes
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and only a copy of the Nuclear Power Group action item retrieval system page was attached to the minutes. This provided only a basic sumary of the NCRs.
The licensee identified to the inspector that any comments from the NOC meeting would be incorporated in the NCR tracking documents and sent back.to
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the responsible individual.
From interviews with NOC members, the inspector determined that generally the coments pertained to a lack of detailed information and the adequacy of the root cause analysis. The inspector also reviewed copies of the minutes of NOC Meetings 92-14, 92-15, 92-16, 92-17, and 93-1.
The inspector concluded that the NOC assured consistency in NCR review and i
root cause analysis, and because of the thorough closecut review, l
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t-4-accountability and corrective action assignments were valid. The NOC reviews provided a trending and tracking function for a first line review of NCRs for generic concerns and the recurrence of events.
1.1.2 Station Operations Review Comittee (SORC)
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The 50RC functioned as an advisory body to the SORC Chairman.
In addition to the Technical Specification requirements for procedure review and approval,
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the 50RC performed other duties. These duties included review of proposed
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changes or modifications to station systems or equipment as discussed in the USAR or which involved an unreviewed safety question as defined in 10 CFR 50.59. The 50RC also reviewed station operations to detect potential nuclear safety hazards. The 50RC investigated all violations of Technical Specifications, and performed special reviews and investigations as warranted.
SORC reviewed all reportable events as specified la 10 CFR 50.9(b),
10 CFR 50.72, 10 CFR 50.73, 10 CFR 73.71, and 10 CFR 21. The SORC reviewed all operability reviews and evaluations. The SORC also made determinations
regarding whether or not proposals considered by the Comittee involved unreviewed safety questions.
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The inspector reviewed CNS Procedure 0.3, " Station Operations Review Comittee," Revision 13. This procedure established the method of operation
of the SORC, stipulated membership, quorum requirements and voting rights.
Routinely, SORC met once a week; however, special meetings were called when r
required. The inspector attended the routine meeting held on February 11, 1993, and designated as Meeting S93-015. At this meeting, SORC considered a number of recomended CNS Operations Manual Procedure changes, one design change, the closeout of a minor software alteration, meeting minutes from NGC Meeting 93-1, and a revision to the Emergency Plan. The inspector attended
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two special SORC meetings that were held on February 25, 1993, which were
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called to review, assess and prepare recomended actians as a result of the
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investigation of a potential problem with two of the plant water systems meeting design criteria. As a result of these meetings, the service water
system and the reactor equipment cooling system were declared inoperable, compensatory measures were proposed, discussed, and agreed upon and a basis
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for continued operation was presented, reviewed, revised and finally approved.
The inspector also reviewed minutes from previous meetings, both routine and special, covering the period from November 12 through December 31, 1992.
The inspector observed that the meetings were conducted in a professional manner, presentations were brief but thorough, and there was indication that the comittee members had thoroughly prepared for the meetings. There was good dialogue between the comittee members and presenters.
Probing questions
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were asked and meaningful information was exchanged. There was an apparent F
strong concern for safety among all the participants.
1.1.3 Safety Review and Audit Board (SRAB)
The SRAB functioned to provide an independent review and audit of specified activities.
Some of the activities reviewed were the safety evaluations for e
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changes-to procedures, equipment or systems under the provisions of 10 CFR 50.59; proposed changes to procedures, equipment or systems which
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involved an unreviewed safety question; proposed changes to the Technical
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Specifications or the operating license; violations of codes, regulations,
orders, Technical Specifications, license requirements, or of internal i
procedures or instructions having nuclear safety significance; all reportable i
events specified in 10 CFR 50.73; minutes of the meetings of the SORC; and,
disagreements in the recommendations between the 50RC and the 50RC chairman.
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The audit activities were: procedure and license condition compliance; staff
training, qualification, and performance; the Emergency Plan; the Security i
Plan; the fire protection program; and the Radiological Environment Monitoring Program.
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The inspector reviewed the Corporate Policy Statement for the SRAB and the
SRAB Charter along with the roster for SRAB members and subcommittee members..
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The stipulated duties and personnel assignments appeared to meet the Technical Specification requirements in all respects. The SRAB was required to meet at least semiannually or when called by the Chairman. A review of the last four SRAB meetings, covering the period June through October 1992 indicated that the required meeting frequency was being met and exceeded. The SRAB meeting minutes content also indicated that the subject matter and results complied t
with the Technical Specification requirements.
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The inspector concluded from the document reviews that the SRAB was constituted, staffed, and was functioning in compliance with the Technical Specification requirements.
1.2 Self-Assessment Methods and Proarams t
The licensee had established and implemented programs for the use of station
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performance indicators, root cause analyses, QA/QC functional area trending, and the identification of strategic issues. The inspector reviewed these programs and a sample of the program outputs.
1.2.1 Root Cause Analysis The CNS root cause analysis program was implemented by Attachment 6 to CNS
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Procedure 0.5.1, "Nonconformance and Corrective Action." This attachment provided direction in the form of guidelines to be used when evaluating the root cause of an event. The analysis and assignment of cause codes was the responsibility of the department manager assigned to disposition an NCR.
The last SALP report identified an issue with the timeliness of root cause i
analyses.
It was determined that the scope and timeliness of NCR root cause
analyses caused a delay in corrective actions to assure safety. The licensee i
agreed with this and further determined that the administrative process did i
not adequately address safety significance and the potential impact to safety.
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The licensee revised the Administrative Procedure 0.5.1 to correct a perceived
problem with commitment date extensions and strengthened the process by
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requiring that safety significance be addressed prior to allowing a scheduled l
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-6-completion date to be extended. This action appeared to have corrected the timeliness concern. At the time of the inspection, there were no overdue nonconformance report actions and only a few active extension requests.
The licensee did not have a formal program for human performance investigation. They were evaluating the possibility of implementing such a program in the future.
1.2.2 Station Performance Indicators A station performance indicator status was issued by the Site Manager on a monthly basis as an attachment to the "CNS Monthly Report." The monthly report was a summary of activities in plant operations, surveillances, chemistry, radiation protection, radwaste, and CNS engineering. The report received limited distribution. There was no assessment of the activities or indicators and no conclusions drawn as to their significance.
The inspector concluded that this was potentially a useful self-assessment tool, but its usefulness appeared limited by the lack of distribution, assessment, and conclusions.
1.2.3 QA Trend Reports The QA department issued a quarterly trend report. This report was a collection of information from various sources, such as, correctivo action documents, QA/QC audits, NRC inspection reports, and NCRs.
The inspector reviewed the 2nd and 3rd quarter reports for 1992. They presented a thorough and comprehensive compilation of activities in the various areas. They did not highlight potential problems, nor did they provide any assessment or recommendations as a result of the indicated trends.
The inspector concluded that this was also a useful self-assessment tool and could be strengthened with the inclusion of trend assessments and recommendations for improvement.
1.2.4 SALP Action Plan The licensee had established a program that addressed issues raised in the
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SALP report. This program began by taking each SALP report issued, identified it with an internal tracking code, assigned it to a responsible manager, determined root cause, and initiated and tracked corrective actions.
Corrective action status and effectiveness were statused on a quarterly basis.
The inspector focused on the action items for the licensee's corrective action program, and reviewed the status of corrective actions and the licensee's followup assessment of the effected actions. There were four of these items.
The first was that a relatively high threshold existed for requiring items to be documented in a nonconformance report. The licensee determined that the apparent root cause was that the program was established to document
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reportable events and therefore conditions or events of lesser significance were not, in all cases, adequately documented or evaluated. The licensee had
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established as corrective action for this item the implementation of a lower threshold corrective action item called a " Deficiency Report" (DR). This was implemented by the issue of Procedure 0.5.2, " Deficiency Reporting," in
September 1992. The program appeared to be well established and generally well accepted by licensee personnel. This conclusion was based on the rapid growth in the Deficiency Report population in the first 6 months of program implementation. The number of DRs issued slightly exceeded the average annual number of NCRs.
Interviews with engineering, maintenance, and operations persorael determined that the new program was well received and provided a means for reporting and tracking more routine non-conformance items.
The second item concerned root cause analyses which was previously discussed in Section 1.2.1 of this report. The third item involved timeliness of evaluation of similar components that may have the same deficiency. The SALP concern was one of timeliners in 6termining safety significance. The
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corrective action implemented for the second item was also applied for this concern, with the additional action to expand the scope of periodic reviews of open nonconformance repo'c from quarterly to monthly. This action has proven effective in identifying nd resolving safety concerns in a more timely
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fashion.
The fourth item concerned the fact that corrective actions have not been fully effective with regard to addressing repetitive Reactor Water Cleanup (RWCU)
system isolations. The root cause analysis for this item resulted in a variety of initiating events and a number of corrective actions. The licensee's assessment, to date, was that the corrective actions have been effective in reducing the number of RWCU isolations. Continuing action on this item was to evaluate any isolations that occur in the future for
additional corrective actions.
2 FEEDBACK OF OPERATIONAL EXPERIENCE INFORMATION (90700)
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The objective of this inspection was to determine the effectiveness of the licensee's program to assess and feed back to plant staff any operational experience information pertinent to plant safety originating from events occurring either outside or inside the licensee's organization. The inspector
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verified the existence of a licensee program for identifying, assessing, and tracking operational experience information. The inspector also determined the overall effectiveness of the licensee's program by selecting and reviewing operational experience reports received by the licensee, and reports resulting from internally identified problems.
2.1 Operational Experience Feedback Program The licensee's program consisted of administrative procedures, directives and instructions. These were identified to the inspector by the licensee and are listed in the second attachment to this report.
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The inspector's review of these procedures identified that the program used the following sources for operational experience: NCRs and DRs; QA Surveillances, Audits, ard their responses; NRC Inspection Reports; NRC Information Notices, Bulletins, Generic Letters, and their responses; American Nuclear Insurers reports; Licensee Event Reports; NCR evaluations; and the licensee's Operating Experience Review (GER) program.
The OER program sources included Westinghouse Availability Improvement Bulletins, Westinghouse Customer Advisory Letters, General Electric Service Advisory, INPO Guidelines, INPO Good Practices, Westinghouse Operations and Maintenance Memos, Operations and Maintenance Reminders,10 CFR 21 Reports, General Electric Rapid Information Communications Services, Significant Event Notifications, Significant Event Reports, General Electric Services Information Letter, and Significant Operating Experience Reports.
The review also determined that the procedures identified the organizational responsibilities for review and prioritization of operational experience information, the feedback of pertinent operational experience information to operators and other personnel, and the incorporation of such information into personnel training and retrcining programs. The procedures also provided for incorporating recommendations from operational experience assessments into plant procedures, lesson plans, and design changes; provided for immediate dissemination of information to ensure timely notification and use of critical items; provided for distribution of critical information by category; assured that conflicting or contradictory information was not distributed; and provided for periodic audits in all areas o ' +he operational experience program.
The inspector concluded that the licensee had implemented a program for identifying, assessing, and tracking operational experience information; and, that the program was effectively dociaented in approved procedures.
2.2 Operational Experience Feedback Program Assessment In order to determine the overall effectiveness of the licensee's program the inspector reviewed ten licensee documents that assessed operational experience information received from various sources. He determined that appropriate corrective action had been taken as applicable and that the senior manager responsible for the action item had been involved in the corrective action process. The inspector selected six of these items for a more in depth analysis. The_ items were: General Electric Probabilistic Concern 91-12, RWCU Line Break with Check Valve Failure; Significant Event Report 10-92, which concerns escorting workers by health physics personnel in high radiation areas; AIB 9106, "EH Contr Unloader Valve Modification"; 10 CFR 21 report on
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Rosemount Models 1152, I* ' 3 and 1154 transmitters; Cooper-Bessemer
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Bulletin 749, concerning.he replacement of the housing gasket on the pillow i
block bearing; and, General Electric letter concerning the potential flooding
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of the high pressure coolant injection turbine.
The inspector determined that the licensee's review and assessment of the selected operational experience reports was both timely and complete.
As an example, CNS received AIB 9106, which concerned chattering of the unloader valves on some EH systems. These valves were used for pressure
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control of the EH fluid supply. One of the two recommended corrective actions for this problem was to install constant pressure pumps, which the licensee did install. The unloader valves were then used as relief valves and the problem described in the AIB no longer occurred at CNS. Corrective actions taken or planned by the licensee, for the other items, were found to be both appropriate and timely.
Followup reviews of selected procedures, and design changes verified that corrective actions had been completed where the action item tracking system indicated action complete.
The reviews, with concurrent evaluations and potential training improvements, conducted by the Document and Event Review Committee (DERC) were considered by the inspector to be a strength in the operational experience review program.
The inspector attended a meeting of the DERC on February 25, 1993. There were 31 items on the agenda covering a variety of subjects, such as, NCRs, vendor notices, significant event reports, audit results, and procedure changes. The items were presented by the chairman with a brief description, determination t
was then made as to whose area of interest it was in, training work requests were identified for any item determined to have a potential-effect on operations, maintenance, or engineering. The meeting was deliberate and professional. Discussions and information exchanges were uninhibited, and i
participating personnel appeared very knowledgeable of their areas of expertise.
The inspector concluded that the operational experience feedback program appeared to be effective, with a particularly strong feedback tool in place for the training program.
3 SUMMARY AND CONCLUSIONS
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The inspector concluded that the various organizations were carrying out both their administrative and license required responsibilities for self-assessment. The various programs implementing self-assessment were
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individually well managed and integrated. The lack of an assessment, t
evaluation, and/or conclusion in the monthly report, station performance indicator summary, and QA trend report, was considered a weakness in the
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overall self-assessment program since it placed the full responsibility for interpretation on the recipient without the benefit of the issuing organization's expertise. The feedback of operational experience information program was found to be well documented and effective. The strong feedback into the training program with the positive effect on training effectiveness from the DERC activities was considered to be a program strength.
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4 ONSITE REVIEW OF LICENSEE EVENT REPORTS (92700)
4.1 (Closed) Licensee Event Report 298/92-009: MOV Fire Induced Hot Short issue
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The licensee had completed the review of NRC Information Notice 92-18 which identified a generic issue with motor operated valves in that an electrical c
hot short caused by a fire could affect the control circuits. The licensee
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-10-determined that the root cause of the problem was the lack of consideration of this potential failure mechanism.
Immediate compensatory measures were implemented through procedure changes and personnel briefings.
Long term corrective action was to issue Design Change 92-109 to correct the identified problems. The licensee had scheduled completion of this work prior to startup from the upcoming refueling outage.
4.2 (Closed) Licensee Event Report 298/92-016: Alternate Shutdown Hot Short Concern with the EmercenCY Diesel Generator The licensee self-identified a potential discrepancy with the Diesel Generator 2 differential protection relaying cable H574. This ca'ule should have been isolated from the effects of a potential fire in the Auxiliary Relay Room and the Cable Spreading Room.
It was not protected in either area. The licensee's immediate corrective action was to issue a change to the operating procedure for the Diesel Generator 2 which provided a means to isolate'the protective relaying in the event of a fire in the affected areas.
Long term corrective action was to modify the circuit to add the isolation of the differential relays to an existing isolation switch. This modification was incorporated into the existing Design Change 92-109. The licensee intended to complete this work prior to startup from the upcoming refueling outag __
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ATTACHMENT I
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1 PERSONS CONTACTED 1.1 Licensee Personnel
- R. Beilke, Radiological Support Supervisor
- +L. Bray, Regulatory Compliance Specialist
- S. Bray, Operations QA Supervisor
- T. Chard, Health Physics Supervisor
- +M. Dean, Nuclear Licensing & Safety Supervisor
- J. Dutton, Training Manager
+R. Gardner, Plant Manager
- M. Gillan, Technical Training Supervisor
- M. Ham, Security Supervisor
- H. Hitch, Jr., Site Services Manager
+E. Hace, Senior Manager, Site Support
+J. Meacham, Site Manager
- +C. Moeller, Technical Staff Manager
- S. Petersen, Acting Plant Manager
- C. Putnam, Senior QA Specialist
- J. Sayer, Radiological Manager 1.2 NRC Personnel
+R. Kopriva, Senior Resident Inspector
- L. Ricketson, Regional Inspector In addition to the personnel listed above, the inspector contacted other personnel during this inspection period.
+ Denotes personnel that attended the exit meeting on February 12, 1993.
- Denotes personnel that attended the exit meeting on February 26, 1993.
2 EXIT MEETING Exit meetings were conducted on February 12 and 26, 1993. During these l
meetings, the inspector reviewed the scope and findings of the report. The
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licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.
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ATTACHMENT 2 DOCUMENTS REVIEWED CMS Procedure 0.15, "NPG Action Item Tracking," Revision 5 CNS Procedure 0.15.1, " Document Disposition and Action Item Assignment,"
Revision 1 CNS Procedure 0.10, " Industry and In-House Operating Experience Review Program," Revision 1 CNS Procedure 0.10.1, " Operating Experience Review," Revision 7 i
CNS Procedure 0.10.2, " Operating Plant Experience Report," Revision 2 CNS Procedure 0.10.3, " Industry Operating Experience Program Effectiveness j
Review," Revision 4
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l CNS Procedure 0.5.1, "Nonconformance and Corrective Action," Revision 9 CNS Procedere 0.5.2, " Deficiency Reporting," Revision 0 Nuclear Power Group Directive 3.8, " Correspondence and Document Control,"
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Revision 2 r
NPG Directive 3.8, " Action Item Tracking," Revision 1 l
Nuclear Training Department Instruction 10 " Training Documentation and Event Review Committee," Revision 5 i
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