ML19351G076
| ML19351G076 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/15/1981 |
| From: | Dean S, Dubois D, Gagliardo J, Spangler R, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351G066 | List: |
| References | |
| 50-298-80-17, NUDOCS 8102230070 | |
| Download: ML19351G076 (8) | |
See also: IR 05000298/1980017
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No.
50-298/80-17
Docket No.
50-298
License No. DPR-46
Licensee:
Nebraska Public Power District
P. O. Box 499
Columbus, Nebraska 68601
Facility Name:
Cooper Nuclear Station
Inspection At.
Cooper Nuclear Station, Nemaha County, Nebraska
Inspection co
uc'. d:
November 18-21; December 16-19, 1980
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Principal
Inspector:
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\\p R\\. G. Sparipler, Reactor Inspector
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4gSeactor Projects Section No. 1
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Accompanying
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Personnel:
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S~. Dean,
actor Inspector
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D. DuBois, Seactor Inspector
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Approved by
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T. F. Westerman, Chief
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Reac or Projects Section No. 1
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Reviewed by:
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'% E Gaglfardo, Chief
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Inspection Summary
Insoection on November 18-21 and December 16-19, 1980 (Recort No. 50-298/80-17)
Areas Insoected:
Routine, unannounced inspection of followup to previously
identified items, maintenance program, maintenance, followup to IE Circulars
and Bulletins, and followup on LER's.
This inspection involved 92 inspector
hours on-site by three NRC inspectors.
Results:
Within the areas inspected one Level y Violation was identified
(failures to fully meet requirements of ANSI N18.7 - 1972, paragraphs 3 and 4).
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DETAILS
1.
Persons Contacted - NPPD
P. Borer, Operations Supervisor
- L. Lessor, Station Superintendent
R. Noyes, Engineering Supervisor
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- Indicates presence at the axit meeting.
2.
Insoector Followuo on [,eviously Identified Items
(Closed) Item of Noncompliance 8011-1 (Inspection Report 80-11, paragraph
5A):
Fire barrier breached since 1977.
The inspector and the Station Superintendent discussed the adequacy of
the surveillance procedure for monitoring fire barrier penetration
integrity.
It was concluded that procedure 6.4.5.16 can be adequately
accomplished.
(Closed) Item of Noncompliance 8013-01 (Inspection Report 80-13, paragraph
3A):
Failure to administer the Requalification Program in a continuous
manner.
The licensee's response dated December 3,1980, adequately addresses the
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policy issues raised by this noncompliance.
The NPPD management policy
outlined in this letter is acceptable to Region IV management.
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(Closed) Open Item 8013-05 (Inspection Report 80-13, paragraph 3C):
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promise of the requalification examination.
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The response referenced above adequately addresses this item.
(Closed) Open Item 8015-02 (Inspection Report 80-15, paragraph 4):
QAI
addressing the QA surveillance program.
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The inspector found that QAI-4 addresses the QA surveillance program.
3.
Maintenance Program
The objective of this portion of the inspection is to ascertain that the
licensee's maintenance program is in conformance with the technical specifi-
cations, quality assurance commitments, and the industry standard ANSI
N18.7 - 1972Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7 - 1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
To accomplish this, the inspector reviewed the following
licensee procedures:
(a) Administrative Procedure 1.7, Station Maintenance
(b) Administrative Procedure 1.7.1, Work Item Tracking
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(c) CNS Instruction Letter #75-1, System Codes and Essential Designation
(d) QAI-10, QA Instruction - Nonconformance Report Issurance, Control and
Corrective action.
(e) QAP-700, QA Plan - Nonroutine Maintenance
(f) QAP-1100, QA Plan - Routine Maintenance
As the result of this review the inspector had the following findings.
The inspector noted that the maintenance program does not explicitly assign
responsibility nor contain a programmatic mechanism for evaluating the
experience with failed equipment to determine whether or not a repir2ement
component of the same type can be expected to perform its function reliably.
Based on reviews of nonconformance reports and licensee event reports the
inspector is convinced that CNS management conscientiously attempts to
evaluate the cause of failure and informally considers repetition failure
in making maintenance decisions; however, the failure to address this issue
in the maintenance program represents a deviation from the requirements
of American National Standard (ANSI) N18.7 - 1972, Administrative Controls for
Nuclear Power Plants, paragraph 5.1.6.1.
The licensee, in their Quality
Assurance Program, has committed to meeting this standard.
This item
represents one example of the Level VViolation sited in the enclosed
Notice of Violation (NC 8017-01).
The inspectors expressed the following concern in the area of documentation
of post maintenance testing.
Although procedure 1.7.1, Work Item Tracking,
assigns the responsibility to all MWR approvers for listing post maintenance
testing (as a special instruction in Section III of the MWR form), it is
not clear (based on discussions with approval authorities; content of the
procedure 1.7.1, and a sampled review of MWR forms) that this section should
list the required surveillance testing that operations personnel now
arbitrarily decide to perform to demonstrate equipment operability.
In
some instances the Shift Supervisors have signed section VII of the MWR
form, denoting all followup requirements were completed, without comment;
while, in other instances the signing Shift Supervisor annotated the
surveillance procedure performed.
By clearly requiring that post main-
tenance surveillance testing be specifically documented on the MWR form
two items can be accomplished.
First, this documentation can aid in
determining the effectiveness of the testing in verifying equipment opera-
bility should future problems develop on the component in question.
Secondly,
from earlier discussions with licensee representatives it appears that
surveillance testing of safety-related equipment following maintenance
activities represents an essential link in the licensee's administrative
system for verifying equipment operability.
Documentation of these activities
should therefore be at a commensurate level.
This item is an open item
(8017-02).
An additional concern expressed by the inspector during the exit interview
concerned guidance in the maintenance program for determining when the
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complexity of the job is such that management deems detailed, written
maintenance procedures to be necessary.
Station Administrative procedures
1.7 and 1.7.1 do not appear to furnish this guidance nor do they furnish
guidance for the use of vendor instruction manuals instead of a formal
written procedure.
This item will remain as an open item (8017-03).
4.
Maintenance
The inspector reviewed maintenance records to verify that maintenance
activities on safety related components and systems were conducted in
accordance with license requirements.
The inspector sampled records
from November 1979 to the time of this inspection ensuring that the follow-
ing systems were reviewed:
Plant and Electrical Power Systems
Containment System
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Instrumentation
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Reactor Core
During this inspection the licensee's Adminisrcative Procedure 1.7.1 " Work
Item Tracking," Rev. O, dated October 1,1980, was reviewed to verify that
guidance therein was in accordance with the FSAR, volume V, section XIII;
Technical Specification 6.3.3.c, the Quality Assurance Program, and ANSI
N18.7 - 1972Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7 - 1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
The inspector reviewed Maintenance Procedure 7.1.1, " Pre-
ventative Maintenance Program," Rev. 3, dated May 24, 1979, to verify
that guidance therein was in accordance with ANSI !48.7 - 1972.
The in-
spectors noted that the licensee was proceeding to up7rade and further
develop the Preventative Maintenance Program.
The Equipment Control Program was reviewed as contained in Procedure 1.6.2,
" Equipment Clearance and Release Order," Rev 18 dated October 3,1980.
As stated in the procedure, "the purpose of the Equipment and release Order
is to provide a means of safety isolating equipment for repairs, or some
other purpose, that requires that the equipment shall not be in service or
used without the knowledge of the person working on that particular piece
of equipment."
The procedure is designed for assuring the safety of individuals and equip-
ment and is to be observed by all personnel.
The procedure requires that
the equipment cleared and the purpose be identified.
Tag locations are to
be specified and each tag is to be numbered.
The breaker or valve position
is also noted on the tag.
The shift supervisor is responsible for all
tagging activities and approves of the tagging by signing the clearance
order.
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ANSI N18.7 - 1972 section 5.1.5 states:
"5.1.5 Equipment Control Procedures.
Procedures shall be provided for
control of equipment, as necessary, to maintain reactor and personnel
safety and to avoid unauthorized operation of equipment.
These pro-
cedures shall require control measures such as locking or tagging to
secure and identify equipment in a controlled status.
The procedures
shall require independent verification, where appropriate, to ensure
that necessary measures, such as tagging equipment, have been imple-
mented correctly.
The licensee's program did not stipulate when or how an independent verifi-
cation would be performed.
This is an apparent deviation from the licensee's
commitment to ANSI N18.7 - 1972 and is a second example of the Level V
Violation sited in the enclosed Notice of Violation (NC 8017-01).
Furthermore, ANSI N18.7 - 1972, section 5.3.5.3, states the following:
" Post-Maintenance Check Out and Return to Service.
Instructions shall
be included, or referenced, for returning the equipment to its normal
operating status.
Operating personnel shall place the equipment in
operation and verify and document its functional acceptability.
Special
attention shall be given to restoration of normal conditions, such as
removal of signals used in maintenance or testing, and to systems that
can be defeated by leaving valves or breakers mispositioned or by
leaving switches in " Test" or " Manual" positions.
All jumpers shall
be controlled.
When placed into service, the equipment should receive
special surveillance until a run-in period has ended."
The licensee's Procedure did not include instructions for lifting tagging
in returning equipment to its normal operating status.
This is an apparent
item of deviation from the licensee's commitment to ANSI N18.7 - 1972 and
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constitutes the third example sited as a Level V Violation in the enclosed
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Notice of Violation (NC 8017-01)
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5.
Followuo to IE Circulars and Bulletins
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Ir Circulars
80-04 Securing of Threaded Locking Devices Fq Safety-Related Equipaent
(Closed).
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The licensee has determined that this item will be addressed on the
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QC checklist for work on safety-related equipment.
80-07 Problems with HPCI Turbine Oil System (Closed).
The licensee has added the action items of this Circular to the HPCI
PM program.
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80-10 Failure to Maintain Environmental Qualification of Equipment
(Closed).
This subject is being addressed in response to IEB 79-01 and NRC
Orders.
80-22 Confirmation of Employee Qualifications (Closed).
The Plant Superintendent has been charged with the responsibility for
ensuring that all employees meet minimum qualifications.
80-23 Potential Defects in Beloit Power System Emergency Generators
(Closed).
CNS does not have this type of emergency generator.
B.
Bulletins 80-23 Failures of Solenoid Valves Manufactured by Valcor Engineering
Corporation (Closed).
Valcor Solenoid valves are not used at CNS.
6.
Followup on LER's
80-36 (Closed) Failure of a PC isolation valve to stroke in less than 15
seconds.
This valve was sluggish in operation but recovered to meet the required
closure time limit after being cycled several times.
No definitive failure
mechanism could be identified.
The licensee has observed this type of
behavior in similiar air operators that remain in one nosition for extended
periods of time.
Procedure 6.3.1.4 has been revised to include the subject
valve in a monthly valve operability check rather than quarterly as done in
the past.
80-44 (Closed) Reactor cooldown rate in excess of 100 F/ hour occurs on a
plant transient.
The data from this event was evaluated by GE pe
anel who determined that
the event falls within an analyzed duty cycle f
the reactor pressure
vessel.
This evaluation was documented in 50RC .neeting #203.
The Engineer-
ing Supervisor has logged this cycle for the next annual operating report.
80-45 (Closed) Hydraulic Snubber found improperly installed.
The personnel involved in the work activity assoicated with the incorrect
installation of this snubber were identified and notified in writting of
their error.
This counseling is judged sufficient to prevent a recurrence.
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80-37
80-42 (Closed) These three LER's all deal with failures to SW-M0-89A and B.
80-43
The various failures of the SW-M0-89A and B valves reported above have
been attributed to incorrect valve selection for this service application.
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ihe vendor concluded that the failures of the disc and steams for these
valves, reported in 80-37, were due to cavitation across the valve disc.
New valves with a redesigned disc are to be installed at the next refueling
outage.
These valves have in the interim been rebuilt.
However, the
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additional LER's 80-42 and 80-43 which report failures associated with the
Limitorque valve operators led to a discussion concerning system reliability
between the inspector and the Station Superintendent.
One possible cause
for the events reported in LER's 80-42 and 80-43 is vibration associated
with valve cavitation.
The 89A and B valves and cracked open when the RHR
SW Booster Pumps are started and as flow increased the valves posit *0n
themselves to maintain 20 psid between the tube and shell side of the RHR
heat exchanger.
The cavitation occurs at pump start when the valves are
just cracked open.
As a result of the Limitorque problems the licensee
replaced the operator for SW-M0-89A with a spare, but determined that this
was unnecessary for SW-M0-89B.
Considering the above and the length of
service to failure (in excess of six years) and the fact that the velves
are to be replaced during an April 1981 refueling outage, the inspectors
concluded that the system is reasonably reliable.
7.
Exit Interview
An exit interview was conducted at the conclusion of each segment of the
inspection.
The above findings were identified to and acknowledged by the
Station Superintendent.
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