IR 05000298/1997013

Insp Rept 50-298/97-13 on 970728-0814.Violation Noted.Major Areas Inspected:Surveillance Procedure

ML20216J628
Person / Time
Site:	Cooper
Issue date:	09/12/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20216J621	List: IR 05000298/1997013 ML20216J617 ML20216J623
References
50-298-97-13, NUDOCS 9709180014
Download: ML20216J628 (12)

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.ENCLOSURER j

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U.S. NUCLEAR REGULATORY COMMISSION REGION IV  ;

Docket No.: 50 298

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- License No.: DPR 46 ,

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Report No.: _50-298/97 13 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station

Location: P.O. Box 98 [

, Brownville, Nebraska Dates: July 28 through August 14,1997 4 Inspectors: P. C. Gage, Reactor inspector, Maintenance Branch W. M. McNeill, Reactor Inspector, Maintenance Branch LApproved By: Dr. Dale A. Powers, Chief, Maintenance Branch Division of Reactor Safety ATTACHMENT: Supplemental information -

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I 9709180014 970912 "

PDR ADOCK 05000298-G PM

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5-The inspectors noted that the instrument and control shop equipment use log did not include certain instruments drawn from the instrument and control group shop, which were used by operations personnel. The inspectors confirmed that the operations department had no similar equipment use log, nor computer records that would allow timely identification of what tests would be suspect given a calibration f ailure. The inspectors noted that operations, as well as all other departments, annotated the instruments used for testing in the surveillance testing records. The log enhancement perrnitted an efficient record retrieval system to provide a timely evaluation should a calibration failure occu During a surveillance test on primary containment, performed on July 29,1997, in accordance with Procedure G.PC.503, "Drywell to Suppression Chamber Leakage Test," Revision 2, the inspectors noted that Step 8.2.7.2 required the operators to raise drywell pressure to a value between 0.55 and 0.60 psig (3.79 - 4.14 kPa).

The irispectors verified that the maximum drywell pressure permitted during the surveillance was correctly identified in a note as 0.75 psig (5.17 kPa). However, the note was located before Step 8.2.9, two steps after the initial raising of drywell pressure instead of prior to initial drywell pressurization. The inspectors noted that Step 8.2.9 required the operators to use indicating Device PC PIC-513 to establish drywell to suppression chamber differential pressure between 14 and 15 inches of water (3.48 - 3.73 kPa). The inspectors observed that the referenced indicating device was not capable of supplying the necessary information required by '

Step 8.2.9, since it did not measure a differential pressure, but instead measured pressure with units of psig, not inches of wate The inspectors found several examples of incomplete or inaccurate data sheets and discrepancy sheets documenting the results of various safety system surveillanc The inspectors noted that Surveillance Procedure 6.EE.601, "125V/250V Station and Diesel Fire Pump Battery Weekly Check," Revision 3, Step 7.5 required the applicable procedure number be recorded on an attached discrepancy sheet. T_he inspectors identified that the discrepancy sheet for the weekly battery check performed on July 7,1997, did not have a procedure number identified, yet Step 7.2.5 was initialed as being performed. The inspectors noted that Step 6. required that the measuring and test equipment data be recorded on Attachment The inspectors found that Attachment 1, measuring and test equipment data sheet, for the weekly battery check dated July 23,1997, f ailed to identify the steps, which were performed using the documented equipmen 'The inspectors identified two examples of omitted data from surveillance testing involving the main steam safety valves. The inspectors noted that the as-left seat leakage pressure was not documented in the as-left test data sheet, dated November 27,1995, even though the satisfactory block was checked in the adjacent block. The inspectors observed that no initials, or date, were annotated to signify that nuclear licensing and safety department had been notified of the test summary results being unsatisfactory for surveillance testing performed on April 9, 199 r

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6-i . In addition to the omitted data deficiencies previously noted, the inspectors identified numerous examples of inaccurate or inconsistent information documented on various surveillance procedures and their corresponding data sheets. . For example, the inspectors noted that minimum Technical Specification values for specific gravity of the 125V and 250V Class 1E station batteries were.1.195 for the _

weekly check and 1.190 for the quarterly check. : However, the inspectors observed that the values referenced in the appropriate data sheets as Technical Specification limits were identified as 1.198 for the weekly check and 1.193 for the quarterly check. -Section 2.17 of Administrative Procedure 0.26, " Surveillance Program,"

Revision 29 C1, states, in part, that the Technical Specifications limit as the

' allowable value stated or referonced in Technical Specifications. The inspectors verified that the documented differences between the limits found in Technical Specifications and those identified as such on the Class 1E battery data sheets were inconsisten The inspectors found that Attachment 3 for the weekly battery check provided the specliic gravity correction associated with electrolyte level within the tested battery

- cell. The inspectors observed that the only reference to using Attachment 3 was provided in the administrative limits section of the procedure for the weekly check of the battery, but no reference to Attachment 3 was provided in the quarterly battery procedure, although the data sheets indicated that the attachment was use The inspectors noted an inconsistency involving the administrative limit regarding individual cell voltage. The inspectors observed that in both the weekly and quarterly battery checks, an administrative limit requires that the system engineer be contacted in the event individual cell voltage was less than 2.15V. The inspectors noted that this limit was on the data sheet for the quarterly _ battery check, but was not on the weekly data shee '

The inspectors identified an inconsistent approach regarding the use of initials or annotating at "not applicable" a step within various surveillance procedure Surveillance Frncedure 0.26, " Surveillance Program," Revision 29 C1, Section 8.4, required that a step marked not applicable shall be recorded as a discrepancy unless

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the step clearly indicates it is not applicable. While reviewing Surveillance

- Procedure 6.EE.601, "125V/250V Station and Diesel Fire Pump Battery Weekly

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Check," Revision 3, the inspectors noted that documentation of the completion of

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Step 7.4.5 (adjustment DMA 35), Step 7.4.6 (if different DMA 35 selected),

~ Step 8.3.2 (system engineer review), and Step 8.4 (acceptance criteria) of the weekly Class 1E battery checks performed during the month of July 1997, was not

= consistent. Two records, reviewed by the inspectors, and discussed below, had

.~ steps inappropriately marked as not applicabl !

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Surveillance Test Record 6,2PCIS.303, "PCIS Main Steam Line High Flow Calibration and Function / Functional Test (Div 21," Step 8.4.15.2, dated July 3, 1997, read: "(For Calibration Only) Adjust instrument scale as necessary." Test-personnel marked Step 8.4.15.2 not applicable; however, Attachment 4, Table 2 showed a scale calibration was performed in addition, Surveillance Test Record 6.2RCIC 301, " ADS Reactor Pressure Permissive Calibration and Functional

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and Logic Tests (Reactor in Run) (C y 1)," Step 8.12.2, dated July 1,1997, stated,

"(Calibration only) Adjust instrument scale as necesmry." Test personnel documented Step 8.12.2 not applicable: however, atachment 1, Table 4 indicated that a scale callLration was accomplished.

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In Surveillance Test Record 6.2PCIS.301, "PCIS Main Condenser Low Vacuum Calibration and Function (Div 2)," Step 8.1.9, dated June 3,1997, a dit.crepancy was documented involving the failure to obtain the as found data on the first ,

attempt. This occurred because the main condenser test pressure on MS-PS-1038 was released too fast. Test personnel documented on the discrepancy sheet that a second attempt was in tolerance, and the corresponding data recorded in the as-found column, with no actions identified to address the resolution of the discrepancy. Also, the inspectors noted a similar occurrence in the performance of

Surveillance Test Record 6.1 ADS.301, Step 8.30. The record identified a discrepancy in that a second attempt and consecutive attempts to calibrate a

. pressure switch were in tolerance, and that the avleft data were satisfactory without adjustments, " Nh no' actions identified for resolution of the initial

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discrepancy.

4-The inspectors inquired as to the basis for no documented resolution of a discrepancy identified in Surveillance Test Record 6.2PCIS.304, " Main Steam Line Low Pressure Calibration and Functional (Div 2)," Step 8.1.2, dated June 4,199 The record stated that no allowed outage time was required to perform the surveillance test. The inspectors noted that the resolution of the discrepancy failed

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to identify that Instrument MS-PS 134B was inoperable before the surveillance test, and that a maintenance work request was written as justification for the acceptability of the discrepancy. Following the inspectors' request for the basis of resolution of the discrepancy, the licensee's staff added clarifying information to the resolution section of the test record.

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The inspectors noted that Administrative Procedure 0.26, " Surveillance Program,"

Revision 29 C1,' did not require resolution of discrepancies be documented on the

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- discrepancy sheet. The inspectors found, therefore, that the lack of a requirement for documentation of resolutions to discrepancies was a weakness in Procedure 0.26.

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Test personnel noted a discrepancy when an inconsistent response was observed as

- they attempted in accordance with Step 8.27 of Surveillance Test Record 6.1 ADS.301, dated July 23,1997, to verify that pressure switch contacts were closed. Instead the contacts were found open, and the reason for their being

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8-open was unknown. The discrepancy noted further that test personnel raised the pressure to establish the " closed contacts" condition, and then continued the test.

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The test personnel stated that "no resolution of the discrepancy was necessary

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because set points were in tolerance and appropriate action was taken." The

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inspectors found the pressure increase to be a nonapproved deviation from the procedure (a condition adverse to quality).

-The inspectors determined that Administrative Procedure 0.5, " Problem identification and Resolution," Section 14.2, Revision 11 C1, requires all personnel to report problems that are, or potentially could be, conditions adverse to quality through the problem identification and resolution program, in this caso, the potential condition adverso to quality consisted of surveillance steps not being

- performed as specified. The inspectors determined that the consequences of not initiating a problem identification and resolution report were twofold: (1) a failure to approve a deviation from the test procedure, and (2) a f ailure to evaluate the generic impact of the calibration discrepancy. The inspectors identified the

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failure to writo a problem identification and resolution report in accordance with Procedure 0.5 as a violation (50-298/9713 02).

Following the onsite inspection, the licensee's staff provided to the inspectors Problem Identification and Resolution Report 2 22597, which documented a discrepancy sirnilar to that which oxisted during the surveillance test discropancy, which occurred on July 23,1997. Af ter unsuccessful attempts to demonstrate the relationship of this report to the above described condition which existed on July 23,1997, the licensoo's staf f initiated Problem identification and Resolution Report 2 16718 on August 12,1997, in addition, the inspectors found that surveillance test records for Procedure 6.1 ADS.301, performed on July 15,1997, referenced Problem identification and Resolution Report 2 22598. The licenseo's staff reported to the inspectors that no record existed for Problem identification and Hosolution Report 2 22598, but Raport 2-22600 was issued on the same dato and had identified the same discrepanc The inspectors noted that the licensee's staff had trended problems by collecting similar problem identification and resolution reports into a condition report. The inspectors found that Condition Report 971078 did not include Problem Identification and Rosolution Report 2 22569, dated June 24,1997, which addressed a similar calibration tolerance proble The inspectors noted that the licensee's staff initially documented the problem regarding contacts failing to bo in the correct designated position during surveillance testing, on July 15,1995, in Problem identification and Resolution Report 1-11535,

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and subsequently, in Report 1 21864, dated April 30,1996, and again in Report 2 22597, dated 101997. In addition, the inspectors found that pressure switches were frequently, either out of instrament or calibration tolerancos. The inspectors found that instrument tolerances determined when equipment required adjustment, and calibration tolerances determined when equipment required repai . . .--,

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. The inspectors noted that the licensee documented this continuing problem in the following problem identification and resolution reports with their corresponding dates:

Report Data 1 20350 January 12,1996

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1-20351 January 12,1996 1 20352 January 12,1996 1 20353 January 12,1996-

2-02616 July 16,1997 2-05402 September 17,1996 1 21484 February 27,1997 2-22744 May 28,1997 2 22628 June 17,1997 2 22589 June 24,1997 2-22621 June 26,1997 2-22600 July 15,1997 2 22602 July 16,1997 During discussions with the licensee's staff, following the onsite inspection, on the problem identification and resolution reports and the associated condition reports, the licensee's representative stated that an engineering evaluation was being performed to consider an option of installing nonenvironmentally qualified pressure

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switches in an effort to address the surveillance discrepancies over the past few years regarding these component The inspectors noted that environmentally qualified pressure switches as typically used on safety-related equipment are required to meet the regulatory requirements of 10 CFR 50.49. The NRC review of the corrective actions taken for pressure switches and the use of nonqualified pressure switches is an inspection followup item (50-298/9713-03).

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1 . Conclusions

- Although.the individual items identified by the inspectors in surveillance performed

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on safety systems were of minor safety significance, the large number of deficiencies, including omission of data, inaccurate identification of calibration due -

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dates, inconsistent application of procedure signature, failure to identify discrepancies, and inadequate resolution of discrepancies, was indicative of a lack of attention to detailin the implementation of the surveillance progra The failure to correctly label and enter appropriate information regarding the

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calibration due dates for measuring and test equipment used to perform surveillance activities involving safety systems constituted a noncited violatio The failure to initiate a problem identification and resolution report to resolve a nonapproved deviation from a surveillance test procedure of the automatic depressurization system represented a violation of Procedure The review of nonenvironmentally qualified pressure switches will be tracked by an inspection followup ite M8- Miscellaneous Maintenance issues M8.1 Violation 50-298/9612-01 (Closed): Failure to include certain structures, systems,

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. and components in the scope of the Maintenance Rule progra During this inspection, the inspectors verified that the licensee's corrective actions described in the response letters were implemented. The inspectors verified that-the implemented corrective actions were adequate and identified no additional problem M8.2 ' Violation 50-298/9612-02 (Closed): Failure to demonstrate that reliability performance criteria for certain structures, systems, and components preserved the assumptions used in the probabilistic risk assessmen During this inspection, the inspectors verified the implemented corrective actions

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s described in the licensee's response letters. The inspectors identified no additional problem '

M8.3 Violation 50-298/9612-03 (Closed): Failure to monitor the unavailability of certain functions performed by the automatic depressurization, emergency diesel generator,

- high pressure coolant injection, and residual heat removal systems when the plant status required the functions to be availabl ,

~ During this inspection, the inspectors verified that the implemented corrective

- actions were adequate and identified no additional problem y 1,im+a -v' - g y y- ,--k g- ,--- r-y-,-- 4 g-- w mg -~ y w- r ,m-

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-11-M8.4 ylotation 50-298/9612-04 (Closed}: Failure to provide adequate instructions to ensure 'isk assessments were performed when removing safety-related equipment from service for monitoring or preventive maintenanc During this inspection, the inspectors verified that the implemented corrective actions were adequate and identified no additional problem M8.5 Violation 50-298/9612 05 (Closed): Failure to initiate a risk-significant window checklist before removing the emergency diesel generator from service for planned maintenanc During this inspection, the inspectors verified that the implemented corrective actions were adequate and identified no additional problem V. Manecement Meetinas X1 Exit Meeting Summary The inspectors discussed the progress of the inspection on a daily basis and presented the inspection results to members of licensee management at the conclusion of the onsite portion of the inspection on July 31,1997. In addition, supplemental telephonic exits were held on August 14 and September 10,1997, to discuss the enforcement findings from the inspection. The licensee personnel acknowledged the findings presented and stated that they would review the issues to determine if they had any differing position The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie ... _ . . . _ . -_ _ - , . .. -. .. .. - . ... _ _ . _ ._ . _. ._.- . . . _ . . .

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ATTACHMENT -

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SUPPLEMENTAL INFORMATION -

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PARTIAL LIST OF PERSONS CONTACTED-Licensee'-  ;

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J[Dorn, Containment Engineering Supervisor c c. Gaines._ Maintenance Manager- ,

R. Gardner, Operations Manager

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P.- Graham, _Vice President Nuclear

.W. Hofmeister, Senior Maintenance Engineer B. Houston, Licensing Manager -

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D. Madsen, Licensing Engineer

- B. Newell, Assistant Maintenance Manager O. Olson, Plant Engineering Manager B. Seidl, Operations Support Engineer i R. Wachowiak, Reliability Engineering _ Supervisor NBC M. Miller, Senior Resident inspector C.-Skinner, Resident inspector Other

L. Dugger, Institute Nuclear Power Operation

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- INSPECTION PROCEDURlS_,QffR

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IP 61725 Surveillance Testing and Calibration Control Program

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ITEMS OPENED, CLOSED, AND DISCUSSED .

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Opened'  ;

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<298/9713 01 NCV Failure to control calibration due dates associated with-measuring and test equipment used in surveillance activities ,

(Section M1.1)

L 298/9713-02 NOV - Failure to initiate documentation to identify a problem with a <

q surveillance procedure, and to provide for its adequate evaluation and resolution (Section M1.1)

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-298/9713-03- IFl Review of nonenvironmentally qualified pressure switches (Section M1.1)

Closed ,

298/9612 01 NOV Failure to include 4 nonsafety-ralated systems functions in Maintenance Rule program (Section M8.1)

298/9612 02 NOV Failure to demonstrate reliability performance criteria conformed to the probabilistic risk assessment

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(Section M8.2)

298/9612-03 NOV Failure to track unavailability when the reactor was subcritical (Section M8.3) .

298/9612 04 NOV- Inadequate procedure to require risk assessment when-

removing equipment from service (Section M8.4)

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298/9612-05 NOV Failure to initiate risk significant checklist when required 4- (Section M8.5)'

298/9713-01 NCV Failure to control' calibration due dates associated with measuring and test equipment used in surveillance activities (Section M1.1)

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LIST OF ADMINISTRATIVE PROCEDURES REVIEWED -

-PROCEDURE REV, TITLE Ouality Assurance Program 12.a - Cooper Nuclear Station Quality Assurance Program for Operations Policy Document Procedure 0.26 -29 C1 Surveillance. Program Procedure 0.37 3 Measuring and Test Equipment (M&TE) Calibration Program Guidelines -

-Procedure 0.38 3.12 Process instrumentation Calibration Program Procedure C1 Problem Identification and Resolution Procedure 7. Conduct of Maintenance c_ Procedure 7. .11 C1 Work Item Tracking - Preventive Maintenance LIST OF SURVEILLANCES REVIEWED PROCEDURE TITLE ,

6.EE.601 125V/250V Station and Diesel Fire Pump Battery Weekly Check 6 EE.602 - 125V/250V S'tation and Diesel Fire Pump Battery Quarterly Check '

6 EE.603 125V Battery Service Test 6.EE.607 125V Station Battery Performance Discharge Test 6.PC.503 Drywell to Suppression Chamber Leakage Test 6.1 APRM.301 - APRM System Excluding 15% Trip Functional Test (Div 1)

6.2AP.RM 301 APRM System Excluding 15% Trip Functional Test (Div 2)

J 6.1 APRM.305 APRM System (Flow Bias and Startup) Calibration and Functional Test'

(Div 1)

6.2 APRM.305 - APRM System (Flow Bias and Startup) Calibration and Functional Test -

(Div 2)

' 6.MS.401- . Main Steam Safety Valve (SV) Testing

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-4-6.HPCI.301 HPCI Steam Line Space Temperature Switch Functional Test 6.1 ADS.301 ADS Reactor Pressure Permissive Calibration and Functional and Logic Tests (Reactor in Run) (Div 1)

6.2PCIS.301 PCIS Main Condenser Low Vacuum Calibration and Function (Div 2)

6.2PCIS.303 PCIS Main Steam Line High Flow Calibration and Function / Functional Test (Div 2)

6.2PCIS.304 Main Steam Line Low Pressure Calibration and Functional (Div 2)

6.2 PRS.303 Turbine First Stage Pressure Permissive Calibration and Functional (Div 2)

6.2 PRS.300 Turbine Control Valve Fast Closure Calibration and Functional (Div 2)

6.2RCIC 301 RCIC Steam Line High Flow Calibration and Functional (Div 2)

6.2RCIC.303 RCIC Steam Supply Pressure Low Calibration and Functional (Div 2)