ML20011F563

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Responds to NRC 900131 Ltr Re Violations Noted in Insp Rept 50-298/89-31.Corrective Actions:Numbered Lead Seal Installed & Logged When Found Missing on 891113 & Procedure 0.9 Reviewed W/Personnel
ML20011F563
Person / Time
Site: Cooper Entergy icon.png
Issue date: 03/02/1990
From: Trevors G
NEBRASKA PUBLIC POWER DISTRICT
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CNSS903571, NUDOCS 9003060276
Download: ML20011F563 (9)
v • d • e


Text

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[ -+ CNSS903571 , March 2, 1990 'r L' U. S. Nuclear Regulatory Commission L-Attention: Document Control Desk Washington, DC 20555

Subject:

NPPD Response to inspection Report 50-298/89-31 f_' Gentlemen: L' This letter is written in response to your letter dated January 31, 1990, which transmitted Inspection Report No. 50 298/89 31. Therein, you identified two violations. The following is a statement of each violation and our S respective response in accordance with 10CFR2.201. With regard to the Notice of Violation, paragraph A, " Failure to Follow Procedures / Inadequate - Procedures", each specific finding and the associated response has been segregated for clarity. Sy tement of Viola 112.D A. Failure to Follow Procedures /Inadeaunte Procedures Criterion V of Appendix B to 10 CFR Part 50 states, that, 

                                            " Activities affecting quality shall be prescribed by documented                                             ,

instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." Four instances were identified in which license: cersonnel either " 15 failed to follow procedures or in which licensee procedures were 

      ;_                                     inadequate.                                                                                                 -

A. Failure to Follow Procedures /Inadeaunte Procedures ITEM 1. Cooper Nuclear Station (CNS) Operations Procedure 2.0.2, 

                                                   " Operations Logs and Reports," Revision 13, required that                                      =
              $                                    valve LV 123W-11, Core Spray pump 1B suction from the Torus, be sealed in the open position.

Contrary to the above, on November 13, 1989, the inspector observed that valve LV 123W-11 was in its required open position but was not sealed as required. 

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    . CNSS903571 March 2, 1990 USNRC page 2 Reason for Violation The reason for the missing seal could not be determined. A seal was in place on September 12, 1989, when the sealed valves were last audited.      ,

Between September 12, 1989, and November 13, 1989, no maintenance was performed in the vicinity that would have involved the subject valve. Corrective Steos Which Have Been Taken And The Results Achieved A numbered lead seal was installed and properly logged immediately after it was found missing on November 13, 1989. Corrective Steos Vhich Vill Be Taken To Avoid Further Violations A following audit, performed on December 14, 1989, discovered no additional discrepancies. Based on the positive results of the December 14, 1989 audit and previous quarterly audits the only remaining action is to review the procedural requirements for the audit to verify clarity and adequacy. Date When Full Comoliance Will Be Achieved Compliance was achieved on November 13, 1989 with the replacement of the missing seal. Any necessary procedural upgrades resulting from the committed procedural review will be completed by July 1,1990. Statement of. Violation A. Failure to Follow Procedures /Inadenuate Procedures IYEM 2. CNS procedure 0.9, " Equipment Clearance and Release Orders," Revision 9, Section IV.A.1 required that personnel obtain an equipment clearance and release order for work or operation of CNS systems requiring that the system (or portion of the system) not be operated or that it be placed in a specific configuration (not normal) for the safe conduct of the work or operation. Contrary to the above, the team identified the following four instances in which appropriate clearances were not used - I to tag the equipment taken out of service as required:

a. MVR 89 2189 replaced the service water flow indicator (SV FI 385A). Both mechanical tubing and electrical leads had to be disconnected and reconnected but were not tagged.

n-r-- - _ _ _ 4 

             . CNSS903571-March 2; 1990 i

f USNRC 

 ;               Page 3                                                                              l i
 !                                     b. MVR 89 2728 lifted and relocated limit switch rotor    f leads on Drywell Spray Loop A Inboard Isolation Valve  ;

L RHR MO M013A. The lifted leads were not tagged as 

 !:                                           required, and no electrical clearance was established, t
 !                                                                                                   i F
c. MWR 89-2876 removed the motor from steam supply to augmented off gas downstream shutoff valve (RHR.MO.

921MV) to extract stainless steal lockwire that was L jamming the motor drive. No electrical clearance was i set for disassembly of the valve actuator,

d. NWR 89 3206 repaired Service Water Solenoid Pilot 7 Valve SW.SOV SPV857, including replacement of a wetted ;

solenoid. No clearance was set for the electrical i circuitry involved. Reason For Violation f Circumstances associated with each of the above MWRs are as follows: MVR 89 2189 - Service Water Flow Indicator Performance of work under MVR 89 2189 is not considered to have been accomplished in violation of procedure 0.9, " Equipment l Clearance and Release Orders". During the initial work planning, the foreman and the technician deterWined that the NWR, with the , Shift Supervisor's approval, provided adequate control for the safe conduct of this corrective maintenance function. A clearance order was not required because this local flow indicator could be isolated using.the installed local instrument valves. The instrument in question was a low pressure fluid instrument with no l other attached equipment. Note that with regard to the statement , J of violation, the local flow indicator has no electrical leads i attached. During performance of the maintenance activity, the , valves were under the direct control of a qualified technician. MVR 89 2728 - Limit Switch leads  ; I A clearance order _to implement MWR 89 2728 repairs should have 'i been established. This is considered to be a failure to follow L.- specific procedural requirements by the involved craft. MVR 89-2876 - Jammed MOV Motor t A clearance order to implement MWR 89-2876 repairs should have been established. This is considered to be a failure to follow specific procedural requirements by the involved craft.

i L " I CNSS903571 

 ;            March 2, 1990
 ;            USNRC Page 4 L

i gyR 89 3206 - Solenoid Replacement 

 !                          Electrical isolation of this specific solenoid pilot valve was not practical since it would have resulted in de energizing other components supplied from the same source which were required to be operable. This concern is considered to be caused by inadequate procedural guidance.

In summary, the reasons for the violacion are a failure to follow procedures and inadequate procedural guidance regarding equipment release and clearance orders. - Corrective Steps Which Have Been Taken And The Results Achieved , Using the aforementioned MWRs as examples, the specific requirements of CNS Procedure 0.9, Equipment Clearance and Release Orders, detailing the responsibilities of CNS personnel for obtaining Equipment Clearance and Release Orders for work or operation of CNS systems has been reviewed with both Instrument 6 Control and Maintenance Department personnel. The purpose for the procedure and the various steps involved in procedure implementation and the consequences for failure to comply were emphasized. , Corrective Steps Which Will Be Taken To Avoid Further Violations , CNS Procedure 0.9 will be revised to include procedural guidance for the performance of work in those situations where it is necessary to work on or near energized electrical equipment, and who must approve the conduct of such work. In regard to procedure adherence concerns, this event will be reviewed in the next Industry Events Training course for 16C

  • l technicians, Maintenance and Operations personnel.

Date When Full Comoliance Will Be Achieved full compliance will be achieved by July 1, 1990. Statement of Violation A. Failure to Follow Procedures /Inadeounte Procedures

  • I ITEM 3. Cooper Nuclear Station, " Quality Assurance Program for Operation, Policy Document," Revision 5, dated June 7,1989, Section 2.13, committed the licensee to follow the guidance of ANSI N45.2.2 1971. ANSI N45.2.2-1972, " Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants."

L l

1 i e L . CNSS903571  ! 

 !     March 2, 1990                                                                            l USNRC                                                                                   j i

Page 5 t I l 

 !                            Section 2.7.1 of this standard defines Level A items as           I those items exceptionally sensitive to environmental conditions and require special measures for protection from one or more of the following effects:    temperature, humidity  ;

and vapors, physical damage, and airborne contamination. 

 ;                             Section 6.4.1 of the standard prescribed for items in

[ storage the requirements for periodic inspection and examination and the subsequent documentation of the results. Section 6.6. required preparation of written records that include such pertinent information as storage location, , t inspection results, protection, and personnel access.  ! r Contrary to the above, Plant Services Procedure 1.7, 

                               " Warehouse Storage," Revision 5, dated December 23, 1987, did not comply with these ANSI requirements in that:           !
a. No temperature or humidity limits were identified for protection of the Level A storage items,
b. No provisions were implemented for recording temperature and humidity conditions for Level A items.
c. Requirements for periodic inspections and examinations >

were specified, but not implemented. Reason For Violation Plant Services Procedure 1.7, " Warehouse Storage", did not contain a specific requirement for recording temperature and humidity conditions, nor for periodic inspections and examinations. Therefore, the reason for the violation is considered to be lack of adequate procedural guidance. It ehould be noted that a monthly inspection of the warehouse facility is performed in accordance with CNS Procedure 0.11, " Station Inspections". Comments or concerns resulting from this inspection are documented on the " Monthly Manager and Supervisor Tour Report", which is an attachment to Procedure 0.11. Corrective Stens Which Have Been Taken And The Results Achieved i A review of ANSI N45.2.2 was performed to identify those Class A storage y requirements to be included in the procedure. Subsequently, a survey of other power plants was conducted to determine typical paraneter limits. Based on these efforts, calibrated thermometers have been temporarily installed in the Class A storage area and a sling psychrometer has been obtained. Procedures have been temporarily changed to establish interim temperature and humidity limits and to require their monitoring on a periodic basis. l l

CNSS903571 l March 2, 1990 USNRC  : Page 6  ; The temporary change also provides for recording of the monitored 

  .            parameters and, additionally, establishes requirements for periodic inspections of the warehouse, including documenting the conditions found.

Corrective Steps Which Will Be Taken To Avoid Further Violations Plant Services Procedure 1.7 will be revised to:

1) Identify the temperature and humidity limits for the CNS warehouse
                      " Level A" storage area.
2) Add a data log to document the specified parameters, i
3) Include a specific warehouse inspection report.

Date When Full Compliance Will Be Achieved 

    .          Full compliance will be achieved by July 1,1990.

Statement of Violation A. Failure to Follow Procedures /Inadeouate Procedures ITEM 4. Plant Services Procedure 1.6, " Warehouse Marking and Tagging," Revision 5, dated June 4,1988, Sect!on V.3.2.a(2) , required that parts scheduled for future troubleshooting or evaluation shall be identified with a " HOLD" tag. Contrary to these requirements, on December 4, 1989, the , inspectors observed untagged electrical parts on a dolly in the licensee's warehouse. Similarly, ASCO solenoid valves located in Level A storage had an " ACCEPT" tag attached to the valves, which were marked to indicate that the shelf-life of the internal components had expired, and that it was l necessary to get a rebuild kit prior to installing the , valves in the plant. The " HOLD" tag required by the above procedure was not attached to the valves. 1 This is a Severity Level IV violation. (Supplement 1)(298/8931 01) I l

[ 4 CNSS903571 .I March 2, 1990 l USNRC  ; 

           ' Page 7                                                                                                              .t

[ Et& Eon For Violation , i In both cases, the reason for the violation was failure to adhere to i procedural requirements by the responsible CNS personnel.  ! The untagged electrical components were on a dolly awaiting disposition '! instructions from Engineering. The components would not have been l released from the warehouse without those instructions. These i components should have been tagged upon their entry into the warehouse,  ! [- but had not been, in anticipation of prompt instructions from Engineering. t With regard to the ASCO valves, the " ACCEPT". tag identified the necessity to install a rebuild kit prior to installation of the valves. the valves would not have been released from the warehouse prior to  ! installation of the rebuild kits. However, the valves should have been l affixed with " HOLD" tags when it was determined that the valves needed f I to be rebuilt due to the shelf life limit. Corrective Steos Which Have Been Taken And The Results Achieved l The untagged electrical material located in the varehouse had previously i been removed during design change activities. Subsequent to the inspection, the material was either dispositioned off site, or appropriately tagged and returned to storage. , The ASCO solenoid valves identified with an expired shelf life were affixed with " HOLD" tags and relocated to the " HOLD" area.  ? These situations have been discussed with warehouse personnel and the procedural requirements were reviewed. Warehouse personnel have been directed to comply with the current procedural requirements which specify promptly tagging all components upon entry into the warehouse and not accepting components returned to the warehouse unless properly , identified. Corrective Stens Which Will Be Taken To Avoid Further Violations Plant Services' Procedure 1.6,." Warehouse Marking and Tagging", will be ' revised to further clarify that components (such as the noted ASCO valves) with expired shelf life material, shall be retagged to a " HOLD" status and segregated to the designated " HOLD" area, ' _ --_- ___-___ _.. ______ _ m _ _ _ _ _ _ _ _ _ _ _ _ _ _ - .

w . . r <, c; F e

4 CNSS903571.

[ March 2, 1990 j L USNRC Page 8 I L - C I 

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o Date When Full Comn11ance Vill Be Achieved i L The station is presently in full compliance. Plant Services Procedure I 

                   -1,6 will be revised and SORC approved by July 1,1990.                          l u

i Statement of violation B. Emilure to Perform Reauired Ouality Control Inenections  ; Criterion X of 10 CFR 50, Appendix B, requires that "A program for I inspection of activities affecting quality shall be established P and executed by or for the organization performing the activity to i verify conformance with the documented instructions, procedures,  ; and drawings for accomplishing the activity. Such inspection  ! shall be performed by individuals other than those who performed  ; the activity being inspected. Examinations, measurements, or j tests of material or products processed shall be performed for  ! each work operation where necessary to assure quality. If ' mandatory inspection hold points, which require witnessing or' f inspecting by the applicant's designated representative and beyond 'i c which work shall not proceed without the consent of its designated , representative are required, the specific hold points shall be -{ indicated in appropriate documents." Quality control (QC) Procedure 12.5, "CNS QC Functions," Revision l 4, was established to implement this requirement and required that i 

                         -QC inspections be performed on maintenance activities such as critical reassembly steps, critical measurements and clearances,       l and verification of valve timing and timing clearances.

Contrary to the above, on May 16, 1989, licensee personnel performed maintenance, MVR 89 2344, on the emergency diesel , generator cam which included critical reassembly steps, critical measurements and clearances, and verification of valve timing and timing clearances. However, QC inspections of these activities ' were not performed. This is a Severity Level IV violation. (Supplement I)(298/8931-02) Reason For_ Violation While QC inspections of the maintenance activities were not performed in accordance with the requirements of Quality Control Procedure 12.5, "CNS QC Functions," the required examinations and measurements were performed and were verified to be correct under the direction of a vendor technical representative. The necessary quality checks were performed by the technical representative as evidenced by his signature after each critical job function performed.

CNSS903571 , March 2, 1990

_USNRC i Page 9  :

i > r The individual initially assigning QC to this job assumed that due to i the presence of the vendor technical representative, QC sign off upon completion of critical job functions constituted adequate QC verification. Corrective Stees Which Have Been Taken And The Results Achieved 1 The work package was reviewed to ensure that the factors affecting quality were adequately addressed. This review revealed that the discrepancy described in the statement of violation pertained only to the application of QC Procedure 12.5 sign off requirements. All technical requirements were met. Requirements associated with QC ' verification as prescribed in QC Procedure 12.5 have been discussed and re+ emphasized with Maintenance Department personnel. Corrective Steos Vhich Will Be Taken To Avoid Further Violations l l An effort is presently underway to upgrade the existing Maintenance Procedure 7.0.1, " Work Item Tracking Corrective Maintenance", by segregating the procedure into functional areas. As a result of this upgrade, improved adherence to functions such as QC will be facilitated. This program upgrade will be completed by September 1, 1990. Date When Full Compliance Will Be Achieved The station is presently in full compliance. Should you have any questions concerning this matter, please contact my office. - Sincerely, G. A. revors Division Manager of , Nuclear Operations GAT:CRH:bjs cc: U. S. Nuclear Regulatory Commission Regional Office - Region IV NRC Resident Inspector Cooper Nuclear Station _ __}}

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