IR 05000298/1993019
| ML20057C652 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/24/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9309290226 | |
| Preceding documents: |
|
| Download: ML20057C652 (4) | |
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R "E co UfdlT ED $TATES v..
h-NUCLEAR REGULATORY COMMISSION
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REGION IV
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i Docket:
50-298 License: DPR-46 Nebraska Public Power District ATTN: Guy R. Horn, Vice President - Nuclear P.O. Box 98
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Brownville, Nebraska 68321 SUBJECT:
NRC INSPECTION REPORT N0. 50-298/93-19 (NOTICE OF VIOLATION)
Thank you for your letter of August 5, 1993, in response to our letter and Notice of Violation dated July 6, 1993.
Based on our review of your response
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to Violation 298/9319-01, we have no furtbar questions at this time on your proposed corrective actions.
However, as a result of our review of your response to Violation 298/9319-02,
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we find that additional information, as discussed with Mr. J. Meacham on Septernber 1 and Mr. M. Deen on September 17, is needed.
It was noted that Nuclear Perf)rmance Procedure 10.21, Revision 6, "Special Nuclear Materials Control and Accountability Instructions," which provided the instructions for moving the fJel bundles out of and back into the reactor vessel, did not require the s r.a precautions, limitations, administrative limits, and instructions specified in the fuel movement procedures. During the NRC staff review of the proposed corrective actions for this violation, NRC identified that the response did not address how the other fuel movement procedures were utilized during the subject fuel movement. We, therefore, request that your supplemental response identi: y which additional fuel movement controls were utilized and why they were not effective in preventing the violation from occurring.
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We will review the implementation of the corrective actions for Violation 298/9319-01 during a future inspection to ensure they have been effective in precluding future noncompliance. With regard to j
Violation 298/9319-02, please provide the supplemental information within
30 days of the date of this letter.
Sincerely, y
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A. Bill Batch, Director
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Division df Reactor Projects cc:
(see next page)
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9309290226 930924 l
PDR ADDCK 05000298 G
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Nebraska Public Power District i
ATTN:
G. D. Watson, General Counsel-P.O. Box 499
Columbus, Nebraska 58602-0499
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Nebraska Public Power District ATTN: Mr. David A. Whitman
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P.O. Box 499 Columbus, Nebraska 69602-0499 Nebraska Department of En<irur, ental Control
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ATTN:
Randolph Wood, Director
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P.O. Box 98922 Lincoln, Nebraska 68509-8922
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Nemaha County Board of Commissioners
ATTN: Larry Bohlken, Chairman
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Nemaha County Courthouse r
1824 N Street
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Auburn, Nebraska 68305 Nebraska Department of Health
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ATTN: Harold Borchert, Director
Division of Radiological Health
301 Centennial Hall, South P.O. Box 95007
Lincoln, Nebraska 68509-5007 Kansas Radiation Control Program Director t
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J. L. Milhoan Resident Inspector Section Chief (DRP/C)
Lisa Shea, RM/ALF, MS: MNBB 4503
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MIS System DRSS-FIPS Section Chief (DRP/TSS)
Project Engineer (DRP/C)
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(DRP/C)
Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS Section Chief (DRP/TSS)
Project Engineer (DRP/C)
RIV File Senior Resident Inspector - River Bend i
Senior Resident Inspector - Fort Calhoun i
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GENERAL OFFICE
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> 0 BOX 499. COLUMBUS. NEBRASKA 686024499 TELEPHONE i402) 564-8561 Nebraska Public Power D*a/ aict m = 36>sssi
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August 5, 1993 lj.vr}
U.
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Nuclear Regulatory Commissiot g
Attention:
Document Control Desk
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._l Washington, DC 20555 Subject:
NPPD Response to Inspaction Report 50-298/93-19 (Reply to a Notice of Violation)
Gentlemen:
During an NRC inspection conducte1 on April 25 through June 5, 1993, certain licensed activities were identifi d as being in violation of NRC requirements.
The first violation concerned some 250 VDC battery cells where electrolyte levels were slightly above the maaimum level indication mark.
The second violation was in regard to two fuel assemblies that were loaded into the reactor core without having all control rods fully inserted.
The following is a restatement of the violations an d our responses in accordance with 10 CFR 2.201.
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STATEMENT OF VIOLATION 10 CFR 50, Criterion V, Instructiins, Procedures, and Drawings, states that activities affecting quality shal. be prescribed by documented instructions, procedures, or drawings, of a typ appropriate to the circumstances and shall be accomplished in accordance wit these instructions, procedures, or drawings.
Instructions, procedur-s, or drawings shall include appropriate quantitative or qualitative accep ance criteria for determining that important
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activities have been satisfactori.y accomplished.
Technical Specification Surveillar :e 4.9. A.4.b.1 states that the electrolyte level of each connected cell is be; ween the minimum and maximum level
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indication marks, to be verified e'ery quarter with the actual values measured and logged.
Maintenance Work Request 93-1855 wai implemented to adjust electrolyte levels in safety-related 250 VDC Batteries A and B, as necessary, on May 7, 1993, because of low electrolyte level.
i Contrary to the above, adjusting the electrolyte level on safety-related 250 VDC Batteries A and B on May 7, 1193, was not prescribed by instructions appropriate to the circumstances in t:at Maintenance Work Request 93-1855 did not include instructions to determine that safety-related 250 VDC Battery electrolyte level was between the maxinum and minimum level indication marks.
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On May 17, 1993, 6 cells in the A 250 BC battery and 11 cells in the B 250 VDC battery were found with electrolytt levels above the maximum level indication mark.
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Document Control Desk j
August 5, 1993
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I This is a Severity Level IV violation (298/9319-01)(Supplement I).
i PEASON FOR THE VIOLATION i
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On May 5, 1993, Surveillance Procedure 6.3.15.1, 125V/250V Station and Diesel
Fire Pump Battery Quarterly Check, was performed. As a result, some battery
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cells in both the 125 VDC and 250 VDC battery banks were identified as having
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low levels.
In this case, the levels ranged from approximately 1/8 to 3/8 inches below the maximum mark, with the majority of the cells being at the
maximum mark.
The minimum and maximum marks are approximately 1 inch apart.
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It is common practico at CNS to initiate a Maintenance Work Request (MWR) to
add water to battery cells whenever any cell level decreases to approximately
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mid-level as a means of controlling and documenting the work activity for historical purposes. MWR (93-1855) was written to " Adjust electrolyte levels i
as necessary" in the 125 VDC and 250 VDC batteries, and the work was performed on May 7, 1993.
It is important to note that the highest level recorded on May 17 for these 17 cells was 1/16 inches above the maximum mark.
This
situation was rectified in accordance with the work item before declaring the
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batteries operable.
The evaluation of the occurrence identified the cause for the electrolyte in
some cells to be above the maximum mark as parallax error when reading the
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cell levels on May 5 and attention to detail during the addition of water to j
the electrolyte on May 7, 1993.
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CORPECTIVE STEPS TAKEN AND PESULTS ACHIEVED Immediately after the condition was identified, the Shift Supervisor declared
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both 250 VDC batteries inoperable and suspended fuel movement. Maintenance personnel perfczmed an inspection of the batteries, identified and recorded levels of the 17 cells with levels above the maximum mark, then removed the excess electrolyte from those cells. The levels were lowered to just below the maximum mark.
The 250 VDC batteries were subsequently declared operable.
CORPECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATION A Technical Specifications (TS) change request was submitted by NPPD on.
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February 25, 1992, and approved on July 7, 1993, which modified the TS to clarify the performance criteria and surveillance requirements for the DC
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power systems, adding new specifications and surveillance requirements,
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consistent with BWR/4 Standard Technical Specifications.
The'new upper level i
limit is $1/4 inches above the maximum level indication mark, with an
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allowable value of "not overflowing," in accordance with IEEE 450 (IEEE
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Recommended Practice for Maintenance, Testing, and Replacement of large Lead y
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Storage Batteries for Generating Stations and Substations).
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Document Control Desk August 5, 1993 Page 3 r
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In considerir.g the cause of this violation, the District concluded, based on
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the required craft knowledge levels, that the current practice of refilling l
the battery cells via Maintenance Work Request (without special instructions or independent verification) is within the skill of the craft.
The level
margin provided by the TS amendment will provide the necessary buffer to prevent exceeding the prescribed level limit as a result of parallax errors in
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The incident was also discussed with Electrical Maintenance personnel as part-of the required corrective action to sensitize the craft
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with the issues of parallax and width of the cell indication markings, the
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requirement for exact compliance with technical specifications, and the importance of attention to detail in performing all maintenance work.
In addition, although not a part of the corrective action, the Technical
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Specifications amendment will be presented as part of the Electrical Maintenance Training Program.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l
NPPD is curre'ntly in full compliance.
STATEMENT OF VIOLATION l
Technical Specification 3.lO.A.2 states that fuel shall not be loaded into the
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reactor core unless all control rods are fully inserted or unless the spiral unload / reload technique is used.
- Contrary to the above, on May 28, the licensee loaded two fuel assemblies
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(YJO358 and YJO349) into the reactor core without having all of the control l
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rods fully inserted and the spiral unload / reload technique was not used.
Control Rod 14-39 was fully withdrawn.
This is a Severity Level IV violation (298/9319-02) (Supplement I).
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REASON FOR VIOLATION
r Following the completion of fuel loading and during control rod drive friction l
testing, it was determined that a fuel support piece may be misaligned.
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order to reposition the fuel support piece, four fuel assemblies had been f
i removed and the associated control rod withdrawn. The detailed in-core
movement instructions to accomplish this task were subsequently revised when
it became necessary to remove two additional fuel assemblies in adjacent cells
to allow the removal tool greater access to the fuel support piece in i
question.
The revision to these detailed instructions did not recognize the
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Technical Specifications requirement to have all control rods fully inserted
prior to loading fuel (unless the spiral unload / reload technique is used).
l Upon removal of the fuel support piece to the fuel pool for inspection, the j
two additional fuel assemblies that had been removed for improved access were l
reloaded into the adjacent cells, a violation of Technical Specifications.
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Document Control Desk August 5, 1993 Page 4
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EQRRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED The error was corrected by fully inserting the withdrawn control rod per the
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subsequent steps in the revised instructions. This placed CNS in compliance
with Technical Specifications.
The Reactor Engineer and Licensed Operators responsible for preparation and review of the revision to the fuel movement instructions were counseled and a copy of LER 93-023, which initially reported this violation, was routed to all licensed operators to encure they are aware of the circumstances surrounding this event.
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A review of applicable CNS procedures determined that there was insufficient guidance or warning provided to personnel performing revisions to fuel
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movement instructions and that enhancements would be necessary.. Reactor Engineering and Operator training program reviews determined that enhancements
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to these training programs are also needed with additional emphasis placed on Technical Specification 3.10.A.2 and its requirement for full insertion of all
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COBRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l
I Procedure 10.21, Special Nuclear Materials and Accountability Instructions
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will be revised to emphasize the Technical Specification 3.10.A.2 requirements
for fuel movement and control rod positioning, with special focus on l
performance of on-the-spot revisions. The procedure will be revised by December 31, 1993.
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i The Reactor Engineering pre-outage refueling training lesson plan will be revised to clarify and emphasize Technical Specification 3.10.A.2 requirements
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for fuel movement and control rod positioning. The lesson plan will also
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focus on the performance of on-the-spot revisions of control rod movement
instructions and this violation. The lesson plan will be upgraded by
December 31,-1993.
This revised lesson will be presented prior to the-next j
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refueling cutage.
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The' Operator pre-outage refueling training lesson plan was revised on June 28, i
i 1993.
The revision incorporated Technical Specification 3.10.A.2 requirements for fuel movement and control rod positioning, the circumstances resulting in
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LER 93-023 and. Procedure 10.25.1, Refueling - Core Reload.
This revised j
lesson plan will also be presented prior to the next refueling outage.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED NPPD is currently in compliance with the requirements stated in the violations.
The follow-up actions identified above, with the exception of the reactor engineering and operator pre-outage refueling training, will be.
completed by December 31, 1993.
The reactor engineering and operator pre-
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Document Control Desk August 5, 1993 Page 5 f
outage refueling training will be completed prior to the next refueling
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outage.
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Should you have any questions regarding this matter, please contact me.
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Sine [ rely,
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Nub +-ar Power Group Manager
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I CRH/VWS/RWK:cml-51tl vfiegional Administrator
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USNRC - Region IV
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NRC Resident Inspector
Cooper Nuclear Station i
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