IR 05000298/1997016

Insp Rept 50-298/97-16 on 970915-24.Violations Noted.Major Areas Inspected:Follow Up on Licensee Planned & Implemented Activities Associated W/Erosion/Corrosion Monitoring Program & Open NRC Items

ML20217H203
Person / Time
Site:	Cooper
Issue date:	10/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217H193	List: IR 05000298/1997016 ML20217H188 ML20217H196
References
50-298-97-16, NUDOCS 9710150077
Download: ML20217H203 (15)

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ENCLOSullE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50 298 License No.: DPR 46 Report No.: 50 298/97-10 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: P.O. Dox 98 Drownville, Nebraska Dates: September 15 24,1997 Inspector: Clifford A. Clark, Reactor inspector, Maintenance Branch Approved Dy: D', Dale A. Powers, Chief, Maintenance Branch Division of Reactor Safety ATTACHMENT: Supplemental Information l

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' 9710150077 971009 PDR ADOCK 05000290 0 PDR

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-2-EXECUTIVE SUMMARY Cooper Nuclear Station NRC Inspection Report 50 298/97 16 This inspection followed up on the licensee's planned and implemented activities associated with the crosion/ corrosion monitoring program and open NRC items. The inspection report covers a 1 week period onsite, with followup in the office performed until September 24, 1997, by one region based inspecto Malatenante

• The I;censee experienced problems implementing the long term erosion / corrosion monitoring program as a result of frequent program staffing turnover (Sections M1 and M3).

• An engineering evaluation of the remaining service life for Reducer SW DG 2 R 4, was performed incorrectly. The licensee's actions that had been taken based on the erroneous calculation were conservative in that the component was prematurely replaced (Section M3).

• Engineering component evaluation forms were not completed for Refueling Outage 17 crosion/ corrosion data prior to plant restart, in accordance with licensee management expectation * The licensee's corrective actions implemented for transient combustible material problems were not ef fective (Section M8.1).

• The licensee's failure to initiate a condition report for a f ailed safety related reducer in the service water piping to the lube oil heat exchanger for Diesel Generator 1 was a violation of Procedure 0.5 (Section M8.2).

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3-fleputLDatalls Summaty of_ Plant Status I

The plant was operating at 100 percent power during this 1: spection period, ikMamteuauto M1 Conduct of Maintenance l

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The inspector interviewed licensee personnel invob<ed in erosion / corrosion monitoring program activities and reviewed licensee activities in this area to determine whether or not management control problems or generic weaknesses existed relative to the licsnsee's implementation of its long term erosion / corrosion monitoring program. This inspection was a followup of licensee activities implemented as a result of erosion / corrosion monitoring data and information obtained during the 1997 Refueling Outage 17 (RF017). Observations and Findinas NRC Inspection Report 50-298/9704 noted that there had been failures of the cros'on/ corrosion program implementation that indicated a lack of consistent program ownership. The erosion / corrosion program experienced significant turnover of program ownership in the period from 1993 through August 1996. The licensee had filled the vacant erosion / corrosion program owner position prior to RF017 as part of the corre:tive actions implemented to prevent recurrence of similar erosion / corrosion program f ailure DLring this inspection the inspector noted the following:

NRC Inspection Report 50-298/9708 covered the inspection period of April 7-11,1997, and noted that Problem Identification Report (PIR) 2-12489 was not developed into a condition report. This PIR referred to a pinhole leak in a reducer in the service water piping to the lube oil heat exchanger for Diesel Generator 1. In response to *he inspector's question of where the condition report was for a failed reducer identified in PIR 212489, the licensee issued P'" 2 15918 on April 17,199 Problem Identification Report 2-15918 documented that PIR 212489 had been processed as a work item nnly, but should have been sent to the Corrective Action Program for categorizatio . -

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• The contractor performing the original RF017 field erosion / corrosion examinations was replaced prior to the end of the outage.

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The erosion / corrosion coordinator hired to filled the vacant erosion / corrosion l monitoring ptogram owner position for RFO17, lef t in May of 1997, prior to

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the end of the outage on May 22,199 * The licensee was unable to hire a trained replacement erosion / corrosion coordinato * A member of the licensee's staff, familiar with some erosion / corrosion program activities, was selected for the erosion / corrosion coordinator position

in June of 1997. While the new erosion / corrosion monitoring program i

coordinator had not received formal erosion / corrosion monitoring program training, this formal training was scheduled to stut September 17,199 *

The RFO17 erosion / corrosion examination data received a brief initiallicensee review as part of the restart readiness review for startup of the plant after RF017. This initial erosion / corrosion data review did not identify incomplete

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data records or incorrect calculations.

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• As of September 16,1997, the RFO17 erosion / corrosion examination data had not received a final erosion / corrosion program review and analysis, with the results of the analysis trended and documented in a licensee outage report. The erosion / corrosion monitoring program supervisor stated that the above analysis and report would be completed once the new crosion/ corrosion coordinator completed the training required to perform the task *

As of September 16,1997, the licensee had not completed a final review and acceptance of a contractor provided CHECWORKS Pass 1 analytical model for predicting the relative wear rates for components included in the Cooper Erosion / Corrosion Monitoring Program. The new erosion / corrosion coordinator stated that the CHECWORKS Pass 1 analytical model review would be completed once he had completed the training required to perform the review.

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• As of September 16,1997, the erosion / corrosion examination data from 1993,1994,1995,1996, and 1997 had not been entered into the contractor provided CHECWORKS Pass 1 analytical model to obtain an updated CHECWORKS Pass 2 analytical rnodel. The new erosion / corrosion coordinator stated that the above CHECWORKS Pass 2 analysis would be completed prior to RFO 18, once he had completed the training required to perform the tas _ _ _ _ - . , _ __ _ __

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• A review of RF017 erosion / corrosion examination data records found examples of incomplete data records and incorrect calculations, which are discussed in Section M3 of this repor * The licensee had implemented an evaluation of an operating experience report on the April 21,1997, extraction steamline rupture at Fort Calhoun Statio The licensee's representative notified the inspector that they were in the process of revising the initial responses to PIRs 212489 and 215918 to address additional corrective actions required to resolve this item. The NRC review of the final corrective actions implemented for PIRs 212489 and 215918 was incomplete in that outage data had not received final review and analysis. The NRC review of this outstanding issue and other problems encountered in implementation of the licensee's erosion / corrosion monitoring program is an inspection followup item (50-298/9716 01). Condualons implementation of the licensee's long term erosion / corrosion monitoring program was adversely impacted as a result of frequent turnover of program ownership in 1997.-

M3 Maintenance Procedures and Documentation M3.1 fleylaw_olErosion/ Corrosion Monitodno Records insoection Scone (49001)

The inspector interviewed licensee personnel involved in erosion / corrosion activitie The inspector also reviewed a portion of the erosion / corrosion monitoring documents completed for RF017 as of September 19,1997, to determine if the examination data and data evaluations were processed in an acceptable manner, Qhigtyations and Findinos in accordance with Section 8.2.2 of Procedure 3.10, " Examination and Evaluation of Pipe Wall Thinning," Revision 4.4, the erosion / corrosion coordinator shall ensure calculations are performed to determine component wear rates and remaining service time based on inspection data. These calculations are required to be performed in accordance with methods outlined in Procedure 3.10 and documented on the applicable inspection results evaluation form, Attachment 2. in the procedure or a similar form. Procedure 3.10 did not specify a time period for completion of the inspection results evaluation form . ,. .

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It was licenseo management expectation that the inspection results evaluation forms would be completed for all the erosion / corrosion monitoring program examinations performed during an outage, prior to restart of the plant. Otherwise, it would be difficult to perform an appropriate evaluation of the acceptability of components for return to service at the end of that outage. Refueling Outage 17 ended May 22, 1997. The inspector reviewed Attachment 2, inspection results evaluation forms for the examinations identified below by component inspection areal number and noted:

• Components 1SWO88C1,1SWO88C2,1SWO88C3 and 1SWO88C4 (inspection areas on the body of Valve SW V 89Bh while the components were examined in March and April of 1997, the inspection results evaluation document was not completed, signed, and dated until September 16,199 * Component 1RF043C (the 18 inch outside diameter of the main run of Form Tee RF T 12509 2): had a " Prepared By" signature and date of April 20, 1997, but no date for a " Reviewed By" signatur * Component 1BS039C (BS E 3-EC93877P 1 A): a 24 inch diameter 90 degree elbow downstream of low pressure turbine nozzle; had a " Reviewed By" signature and date of June 2,199 * Component 1SWO63C (8 inch X 6 inch Reducer SW DG 2 R 4): a May 10, 1997, evaluation noted that using the Reedy Underthickness calculations, the remaining component wall thickness was not adequate for the next operating cycle and the component was replaced in accordance with PIR 21375 Based on review of the as found wall thickness recorded on the inspection results evaluation form for this component, the inspector requested the licensee's representative on September 19,1997, to provide additional information on the evaluations and corrective actions implemented for this component. On September 24,1997, the licensne's engineering staff provided the requested information to the inspector and noted an incorrect erosion / corrosion inspection results evaluation had been performed for this componen On September 24,1997, in response to the inspector's question on the evaluations and corrective actions implemented for Component 1SWO63C (SW DG 2 R-4)

examination results, the licensee's engineering staff identified that an incorrect Reedy Underthickness calculation had been performed for the as found wall thickness. The licensee's representative stated that a new calculation performed on September 22,1997, using the RF017 examination data, found that the original component did not have to be replace On September 24,1997, the inspector notified the licensee's representatives that the identification of this incorrect RF017 erosion / corrosion results evaluation for Component 1SWO63C (SW-DG 2-R-4), raised the question of the accuracy of other

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crosion/ corrosion inspection results evaluations performed for other components examined during RF017. The licensco's representativo agreed with the inspector, and noted that PIR 2 13389 was issued on September 22,1997, to document performance of the incorrect erosion / corrosion evaluation for Component 1SWO63C (SW DG 2 R 4) and to recommend corrective action The inspector reviewed PIR 213389 on September 24,1997, as part of the inoffico followup inspection activities. Problem Identification Report 213389 recommended a review of all RF017 data and evaluations for components with as found wall thickness readings below the erosion / corrosion program minimum wall thickness, to ensure either the previous evaluations were accurate, or to revise those records, which were found to be inaccurate. Problem identification Report 213380 also noted that the replacement of Component SW DG 1 R 4 was a conservative station management decision based on the failure of similar Component SW DG 1 R 2 in the parallel diesel service water line prior to RFO17. The licensco staff noted that, as a result of losing the RF017 erosion / corrosion coordinator, they were still reviewing RFO17 erosion / corrosion monitoring program dat As a followup to the f ailure of Reducer SW.DG 1 R 2 in the service water piping to the lubo oil heat exchanger for Diesel Generator 1, the inspector reviewed the licensee's initial response to PIR 2 12489. The inspector noted that immediate Action item 7 of the " Corrective Action Plan," stated that the f ailed section of the reducer had been sent to a qualified laboratory for metallographic analysis to aid in long term planning for the affectad service water piping. The inspector requested a copy of the final report on the findings of the metallographic analysis of the f ailed reducer. On September 18,1997, the licensee provided the inspector with a copy of Southwest Research Institute Project 06-8381-133, " FINAL REPORT," dated June 26,1997, which contained the metallographic analysis of the failed reduce The licenseo noted the following:

• As of September 18,1997, the report had not been formally reviewed by the engineering grou * During a quick engineering review of the document, just prior to providing a copy to the inspector, the licensee's representative noted that an incorrect service life was referenced in the repor * The report stated that the failed reducer had been in service since 1982 l (15 years). The reducer was actually installed in 1991 to replace a reducer that f ailed due to a similar mechanis The inspector noted that this incorrect service life was used to determine an incorrect average corrosion rate in the f ailed area of the reducer. The licensee's representative stated a formal review of the June 26,1997, report would be performed and any inaccurate data coriecte . _ . . _ .

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. The NRC review of the final corrective actions implemented for PIRs 212489 and 2-13389 and other document problems encountered in implementation of the licensee's erosion / corrosion monitoring program will be a part of inspection followup item (50 298/9716-01), Conclusions The above examples of erosion / corrosion records signed after the end of RF017, the incorrect erosion / corrosion evaluation performed for Component SW DG 1 R-4, and the use of an incorrect service life for the metallographic analysis of the failed Reducer SW.DG 1 R 2, were additional examples of ineffective program implementation the license was experiencing as the result of continuing turnover of program ownership in 1997.

l M8 Miscellaneous Maintenance lasues (92902)

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M8.1 [Qasnl Violation 60 298/9625 07: Failure to identify transient combustion problems.

1 Backaround:

During a plant tour on November 20,1996, to inspect combustible material controls, the NRC observed three instances where small quantities of transient combustible materials were left in the reactor building after the end of the work shift. The NRC noted that paragraph 8.1.11.1 of Procedure 0.7.1, " Control of Combustibles,"

required that all unnecessaty combustible materials be removed or properly stored and that the area be cleared at the end of each work shif The NRC also noted that Quality Assurance Audit 96 08, conducted in July 1996, identified weaknesses with the control of combustible materials. One of the corrective actions from this audit was to revise Procedure 0.7.1, " Control of Combustibles," to clarify combustible control requirements and to provide training on this procedure. Procedure 0.7.1 was revised to clarify the transient combustible control requirements; howevar, the training was not completed, in the interim, the corrective action was to conduct continuing plant walkdowns to check that transient combustible material controls were being followed. The NRC November 20,1996, tour identified that the licensee's plant walkdowns f ailed to identify and correct three transient combustible control problems. The licensee's f ailure to implement adequate corrective action for the control of transient combustibles was identified as a violatio _ .

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1 in reply to this violation, the licensee stated in Letter NSL970125, dated June 26, 1997, that:

• The specific examples of uncontrolled transient combustible material identified by the violation were resolve ,

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• Procedure 0.7.1 was revised to address programmatic weaknesses.

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• A performance indicator for transient combustible control had been developed to continually monitor and trigger management and supervisory intervention for proceduto adherenc *

Ongoing round table discussions had been held between the engineering support manager, maintenance manager, senior fire protection engineer, maintenance supervisors, and maintenance crew leaders concerning the requirements of transient combustible program and implementation ownership. During these discussions, the expectations of the senior fire protection engineer and the maintenance manager were clearly discussed and understood and this information was conveyed to the work force during daily meeting with crew leader * Training on the revision to Procedura 0.7.1 was to be completed by August 1,199 *

The licensee was to be in full compliance with respect to the cited violation upon completion of the trainin Observations and Findinas The inspector reviewed Quality Assurance Audit Report 97-08, * Fire Protection,"

issued July 2,1997, for the audit period of May 22,1997, through June 12,199 The inspector also reviewed the August 7,1997, Engineering Department Response ESD9714 to Audit Report 97-08. The inspector's review noted the following:

• The Audit Report 97-08 identified that training provided to Cooper personnel who must comply with the Procedure 0.7.1 requirements, for managing transient combustibles, was inadequat * Response ESD9714 noted that subsequent to the completion of Audit Report 97-08, Procedure 0.7.1 was revised to address the concerns raised during the audit, and those identified by the line organization in the course of performing work. Also, prior to making the new procedure effective, training was conducted for appropriate station personne _

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The inspector _ reviewed Procedure 0.7.1, Revision 8, issued June 19,1997. The inspector reviewed the corrective actions implemented to address this violation, and noted the following:

• The licensee provided " Attachment 1 Tailgate Attendance" sheets that indicated approximately 180 site personnel from the maintenance, operations, and radiation protection departments received training on

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Revision 8 of Procedure 0.7.1, as of July 28,199 * The performance indicators developed for transient combustible control, to continually monitor and trigger management and supervisory intervention for procedure adherence, had been established. Goals of no more than 30 housekeeping findings per year and three PIRs per year, were established ,

for these performance indicator * Since training on Procedure 0.7.1 was completed July 28,1997, as of

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September 17,1997, PIRs 216738 and 2 23294 had been issued in September of 1997 for examples of where the requirements of Procedure 0.7.1 were not adhered to. While these two PIRs involved small quantities of transient combustible naterials, they placed the licensee one PIR away from reaching their yearly goal of three PIR These two PIRs were issued within 5 weeks af ter the completion of Procedure 0.7.1 trainin * The fire protection supervisor notified the inspector that PIRs 216738 and 2 23294 were discussed at a morning meeting, and personnel were informed that additional training for Procedure 0.7.1 would be provided as require At this meeting, personnel were asked to notify the fire protection supervisor if additional training was required in their areas. A security department representative notified the fire protection supervisor, that since their personnel were touring and working in various areas of the plant, they would like their personnel to receive the trainin The inspector noted that PIR 2 15417 issued September 8,1997, was initiated to paint floors red in areas of " low combustible loads." The licensee's representative stated that they wanted to provide an aide to help identify certain areas in the plant that required extra attention for control of transient combustible matenals, Conclusions On the basis of the following, there was evidence that the licensee's corrective actions have not been adequate to resolve this proble .

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• There were two PIRs issued for inappropriate transient combustible material control within approximately a month of completion of new training on l Procedure 0.7.1 requirement *

There was additional site personnel who required Procedure 0.7.1 trainin Additionally, the corrective actions implemented for PIR 215417 did not address training requirements for licensee outage contractor personne * There were additionallicensee corrective actions required to improve control of transient combustible materia This issue will remain open pending further NRC review of the licensee's additional corrective action M8.2 (ClosedLUDtesolved 50 298/9704-01 (Closed): Problem in implementation of the erosion / corrosion monitoring progra As discussed in Section M1, PIR 212489 recommended disposition of the f ailed Reducer SW DG 1 R 2 as a work item instead of a condition report. This failure had resulted in the licensee declaring Diesel Generator 1 inoperable. At the end of the inspection period, the licensee was still researching whether a condition report was issued to document the reducer f ailure. The f ailed reducer, however, had been replace During this inspection, the licensee's representatives notified the inspector that:

Problem Identification Report 2 15918 was issued April 17,1997, to document that PIR 212489 was processed as a work item only, but should have been sent to the corrective action program for categorization. Problem identification Report 2 15918 was categorized as Condition Report 97 0681 on April 18,199 *

Problem identification Report 212489 was categorized as Condition Report 97 0803 on April 30,199 Administrative Procedure 0.5, " Problem Identification and Resolution," Revision 10 Section 3.1, requires, in part, that the PIR originator's supervisor shall . . . complete items 1517 of the problem identification report . . . and mark the appropriate block r

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as follows, using criteria provided in Attachment 5. Section 1 of Attachment 5 identified " example 1.9, equipment f ailures" as an example of when a condition report is appropriate. The inspector identified the failure to disposition PIR 2-12489 as a condition report in accordance with Procedure 0.5 as a violation (50-298/9710 02).

The licensee's representatives notified the inspector during this inspection that they planned to revise the initial response to PIR 212489 (Condition Report 97 0803), to address additional corrective actions they were going to implement to resolve problems encountered in implementation of the erosion / corrosion monitoring progra L_Managamant_McAllogs X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection. The licensee personnel acknowledged the findings presente The inspector asked the licenseo personnel whether any materials examined during the inspection should be considered proprietary No proprietary information was identifie . _ .

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LtTTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licanito T. Ackerman, Erosion / Corrosion Coordinator, Engineering Programs 8. Houston, Manager, Licensing J. Lechner, Fire Protection Engineer, Engineering Programs D. Madsen, Senior Engineer, Licensing J. Pelletier, Senior Manager, Engineering M. Spencer, Supervisor, Engineering Programs C. Taylor, Supervisor, Corrective Action Program Nf1C M. Miller, Senior Resident inspector C. Skinner, Resident inspector INSPECTION PROCEDURES USED IP 49001 Inspection of Erosion / Corrosion Monitoring Programs IP 92902 Followup Maintenance ITEMS OPENED, CLOSED, and DISCUSSED Opened 50 298/97016 01 IFl Problems encountered in implementation of the erosion / corrosion monitoring program (Section M1).

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50 298/05004 01 URI Problem in the implementation of the erosion / corrosion monitoring program (Section M8.2).

DISCUCSEQ l 50 298/96025-07 VIO Failure to identify transient combustion problems, i

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2-LIST OF DOCUMENTS REVIEWED Plateduta Revision Tlile 0. Control of Combustibles 3.10 Examination and Evaluation of Pipe Wall Thinning RF017 Erosion /Cafrosion insp.ection Results Evaluations. Identified bv Comoonent N SW DG 2 T 2A 1BS024C (BS-E 10 28121)

1BS039C (8S E 3 EC03877P-1 A)

1RF043C (RF T 2509 2)

1SWO94C (SW DC 1 T 3(MN))

1SWO88C1,1SWO88C2,1SWO88C3, and 1SWO88C4 (SW V 898)

ISWO63C (SW DG 2 R 4)

Audit Regatta OA Audit 97 06, " Outages," issued June 10,1997 OA Audit 97 08, " Fire Protection," issued July 2,1997 Condition Reggrig 97-0284 97 0681 97-0803 Problem identification Reoorts 2 13389 2 12489 2 12502 2 15417 2 15918 2-16738 2 23294

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l0 3-Other Docurnents i

" Cooper Nuclear Station Erosion / Corrosion Monitoring Pro 0 ram," dated January 10,1996 Southwest Research Institute letter, Subject: " Evaluation of Service Water Piping Reducer,"

i Nebraska Public Power District Purchase Order No. 97102B, Southwest Research Institute l Project No 06 8381 133, FINAL REPORT, dated June 26,1997 l

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