ML20057D439

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Insp Rept 50-298/93-23 on 930718-0828.Major Areas Inspected: Plant Status & Onsite Response to Events.Notes That Licensee Appropriately Implemented Emergency Procedure for Mo River Level Approaching Flooding Stage
ML20057D439
Person / Time
Site: Cooper Entergy icon.png
Issue date: 09/28/1993
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20057D438 List:
References
50-298-93-23, NUDOCS 9310040221
Download: ML20057D439 (14)


See also: IR 05000298/1993023

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report:

50-298/93-23

License:

DPR-46

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Licensee:

Nebraska Public Power District

P.O. Box 499

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Columbus, Nebraska

Facility Name: Cooper Nuclear Station

Inspection At:

Brownville, Nebraska

Inspection Conducted: July 18 through August 28, 1993

Inspectors:

R. A. Kopriva, Senior Resident Inspector

W. C. Walder, Resident Inspector

W. B. Jones, Project Engineer

M. E. Murphy, Reactor Inspector

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Approved:

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E. p gliardo, Chief, Project Section C

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Inspection Summary

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Areas Inspected:

Routine, announced inspection of plant status, onsite

response to events, operational safety verification, maintenance and

surveillance observations, and followup.

Results:

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The initial response to the area flooding was very good. The licensee

appropriately implemented its emergency procedure for the Missou.1 k'ver

level approaching flood stage.

The decision to shut down the plant

based on concerns with the states' abilities to adequately s'pport the

emergency plan and the closure of evacuation routes demonst,ated the

appropriate awareness for the unique flooding challenges.

The

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licensee's coordination with the states to assure that tie emergency

plan could be well implemented prior to proceeding with :he plant

restart was very good (Sections 2.1.1 and 2.1.5).

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A lack of management and plant personnel sensitivity to potentially

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degraded plant conditions was noted.

Significant water inleakage into

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the plant had occurred because of the flood conditions which had not

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been evaluated for the potential effects on plant equipment and

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components. Actions were also not promptly implemented to assure that

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building water inleakage was diverted away from plant equipment and

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components. The resident inspectors had expressed concerns about the

inleakage in mid-July (problem documented in Section 3.2 of NRC

Inspection Report 50-298/93-22), but a corrective action plan which

addressed plant recovery and actions required to restart the plant was

not developed until after further questioning by NRC-(Sections 2.1.3 and

2.1.4).

Appreciable licensee management involvement was required to assure that

the corrective action program was implemented in accordance with

management's expectations for the unexpected breaker trip in the 345 kV

switchyard (Section 2.2).

Shift turnover meetings were conducted in a manner that provided for

proper communication of plant status from one sh!ft to the other.

However, the operators demonstrated a willingness to accept an operator

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aide for the offsite electrical lineup which was incorrect

(Section 3.1).

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The standby gas treatment system duct expansion sleeves were degraded,

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The licensee did not conduct a comprehensive review of all the expansion

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sleeves which may have been affected until prompted by the inspector

5 weeks later (Section 3.3).

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Station security personnel appropriately implemented the security plan

for the NRC emergency site team access during the Notification of

Unusual Event (NOVE).

Security compensatory measures were well

implemented for flooding problems within the protected area

(Sections 2.1.2, 2.1.3, and 3.4).

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The maintenance and surveillance activities were well implemented. The

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technicians were knowledgeable of the recent hydrogen / oxygen analyzer

system design changes and revised test procedure (Sections 4.1 and 5.1).

The licensee's employee concern program provided several processes for

employees to voice concerns.

None of these processes specifically

emphasized the reporting of nuclear safety issues and the protection of

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employees who raised concerns (Section 6.1).

Attachments:

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Attachment - Persons Contacted and Exit Meeting

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DETAILS

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1 PLANT STATUS

At the beginning of this inspection report period, Cooper Nuclear Station was

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in Day 135 of the refueling / maintenance outage that was originally scheduled

to be 56 days in length.

On July 21 a reactor startup was commenced. On July

23, with the plant at approximately 15 percent thermal power, a reactor

shutdown was initiated based on concerns with the surrounding states' and

local authorities' ability to adequately support the emergency plan because of

flooding of the Missouri River and its tributaries. At 6:19 p.m. (CDT) the

same day, an NOUE was declared, as required by the licensee's emergency action

level, when the Missouri River level increased to 899 feet (mean sea level)..

On July 27, at 5:10 p.m. (CDT) the NOUE was exited, in part because the river

level was at 897.4 feet mean sea level and decreasing.

On July 29, after verifying that the state and local authorities would be able

to support the emergency plan if required, the licensee commenced a reactor

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st artup. At the end of the report period the plant was operating at

100 percent power.

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2 ONSITE RESPONSE TO EVENTS (93702)

2.1 Site and Area Flooding

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2.1.1

Plant Shutdown

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On July 21, 1993, the licensee commenced a reactor startup from the

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refueling / maintenance outage. At the time the licensee decided to commence

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the reactor startup, the Missouri River level was at 896 feet and slowly

decreasing.

This was down from a previous high level of 898 feet on July 13.

However, on July 22 and 23 a rapid increase in river level occurred.

Later

that day, with reactor power at approximately 15 percent thermal power, the

licensee was notified by Atchison County, Missouri, emergency personnel that,

due to road and weather conditions, the county would not be able to support an

evacuation of county residents in the event of an accident.

The highways in

the county were in danger of flooding due to heavy rains, with the continuing

threat of additional rains.

Based on this information, the licensee made a

conservative decision to implement a precautionary reactor shutdown at

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10:35 a.m. (CDT) on July 23. At 3:46 p.m. the licensee had completed the

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reactor shutdown and was continuing to take the reactor to cold shutdown. The

plant was placed in cold shutdown early on July 24.

The licensee took actions in preparation for the possibility that river level

might exceed the levee level of 902 feet. These actions included installing

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water dams at all the ground level entrances to the turbine, radwaste,

augmented radwaste, and control buildings.

In addition, water dams were

installed at the entrances leading to the diesel generator rooms, service-

water pump room, and entrance to the radiological controlled area. Dams were

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not installed within the radiological controlled area and the technical

support center due to the fact that these barriers would have hampered access

and egress to those areas that were routinely toured by the licensee. Other

actions performed included verifying the availability of communication methods

outside the plant, sand bagging the openings to the water wells, filling the

potable water and demineralized water tanks to 100 percent capacity, and

securing additional emergency diesel fuel oil.

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2.1.2 NOUE Declaration

At 6:19 p.m. on July 23, the licensee declared a NOUE as required by its

emergency action level for the Missouri River level reaching an elevation of

899 feet. The required offsite notifications were completed within the time

established in its emergency plan. The licensee initiated the required-

communication link with NRC headquarters and the Region IV emergency response

facility, utilizing the emergency notification system. These communications

were maintained throughout the period the licensee was in the NOUE. The

licensee also supplemented the required plant staffing during the initial days

of the NOUE to ensure adequate personnel were available to support emergency

response activities for an Alert classification.

The river continued to rise throughout the night and into the morning of

July 24. At 12 noon on July 24, the river was at 900.2 feet. The increased

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river level resulted in the closure of several roads, including a portion of

Route 136 in the state of Missouri.

This closure isolated one of the planned

emergency evacuation routes for those individuals located within the 10-mile

emergency evacuation zone. However, individuals located near the Missouri

River levee, and within the 10-mile evacuation zone, were required to evacuate

their homes when the Missouri River levee failed upstream of the plant,

resulting'in extensive flooding across the river from the plant.

The licensee dismissed all nonessential personnel and the plant staffing was

maintained with a double shift of essential personnel, including security and

emergency response personnel. The essential personnel were to remain on site

until licensee management determined that the conditions would permit

unimpeded access to the plant.

NRC emergency response personnel arrived

during the period of July 23-24. Security personnel promptly implemented

aspects of the security plan which pertained to the NOVE declaration. On the

morning of July 24, 1993, NRC Region IV entered the monitoring mode in order

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to closely track the licensee's response activities.

2.1.3

Site Conditions

The inspectors conducted tours of the facility inside the protected area,

vital areas, and radiologically controlled areas. These tours were conducted

on July 24-25. The purpose of these tours was to assess the licensee's

actions to mitigate any effects the flood waters had on the plant.

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it was observed that the required security compensatory postings had been

implemented for the protected area boundaries which had been adversely

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affected by the flood waters.

The sewer drains within the protected area were

observed to be filled, resulting in an elevated water table along the

buildings.

The licensee had installed water dams at all the ground level

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entrances to the turbine, radwaste, augmented radwaste, and control buildings.

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These dams were found to be effective in mitigating water intrusion into the

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plant from the water sitting above ground after heavy rains.

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The vital area rooms outside of the radiologically controlled areas were found

to be relatively dry, with minor water inleakage occurring through the

concrete walls located below the ground elevation. However, the below grade

rooms located within the turbine building and the reactor building, which were

inside the radiologically controlled area, were found to have extensive water

inleakage.

In some cases, the water inleakage significantly challenged the

capacity of the floor drains. An example was noted for water inleakage within

the turbine building.

The lower hallway was found to have standing water,

with additional inleakage occurring around safety-related cable trays. The

turbine-driven feedwater pump rooms were found to have water dripping on

control boxes, and the floor drain system had backed up such that standing

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water from within identified radiologically contaminated areas had migrated

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out into designated clean areas.

It was observed that plant personnel had not

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taken actions to identify the areas where building water inleakage was

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occurring and had not established measures to divert the water away from the

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plant components.

Similar problems were observed in the reactor building quadrant rooms and in

the torus room.

The water inleakage into the reactor building quadrant room

containing the reactor core isolation cooling (RCIC) pump had water impinging

on RCIC electrical components. The water inleakage inside the torus area was

impinging on electrical junction boxes and other electrical components.

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On the morning of July 25, the inspectors and an NRC manager discussed the

conditions identified inside the turbine and reactor buildings with licensee

management.

It was determined that the licensee had not initiated specific

actions to quantify and determine the effect the water inleakage may have had

on plant equipment and components.

In addition, NRC questioned whether there

may be other specific areas in the plant where the water inleakage was

occurring but had not been identified. After being questioned by NRC

management about the excessive water inleakage, the licensee pumped the sewer

drains with portable pumps and significantly reduced the inleakage into the

turbine building.

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2.1.4

Plant Recovery

The licensee subsequently tasked three maintenance engineers to work with the

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operations department to quantify and identify the areas and plant equipment

which was impacted by the water inleakage. Actions were also initiated to

begin diverting water away from plant equipment and to remove the standing

water from the building floors and clear the floor drains.

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The subsequent morning the inspectors reviewed the licensee's actions to

quantify, identify, and reduce the water inleakage. The licensee had

quantified the inleakage at approximately 50 gallons per minute. The

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activities performed by the operations department and maintenance engineers

had identified the areas where the water inleakage was occurring. However,

the inspectors concluded, based on their review, that these individuals had

not been sensitized to the potential impact that the inleakage could have on

vital equipment and, as such, had only provided a general assessment of the

areas and equipment affected.

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Later on the morning of July 26 the licensee initiated a task force to conduct

a thorough review of the building leakage concerns.

The team was managed by

the engineering manager and each building was designated with a team leader.

The quality assurance organization subsequently became involved to

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independently assess the adequacy of the inspections performed. The

inspectors noted that, at this time, plant personnel and management

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sensitivity was appropriately directed at identifying and correcting the

building water inleakage concerns.

A recovery and startup plan was subsequently developed which identified the

scope of the inspection activities, the corrective actions which were taken or

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would be taken to divert or seal the areas where the inleakage was occurring,

and the actions which were required to be completed prior to restarting the

plant. The licensee's plan was reviewed by the NRC Region IV staff and by

representatives of NRR. The plan was found to be acceptable in addressing the

NRC's concerns.

2.1.5 Plant Startup

The inspectors observed the licensee's inspection activities relative to

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equipment which could have been adversely affected by the water inleakage.

This included the inspection of cable conduit and junction boxes. One

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electrical junction box inside the torus room contained a small amount of

water, but no adverse effects were noted by the licensee or the inspectors.

An annunciator was subsequently received for a ground in the RCIC 250 Vdc

electrical circuitry.

This ground appeared to have been caused by water

inleakage into a RCIC starter rack.

The condition was promptly repaired.

The licensee's efforts to remove the water from the protected area drains and

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to route the water inleakage away from plant components was effective in

reducing the amount of water inleakage and in protecting plant equipment and

components.

The licensee was effective in working with the local and state emergency

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management agencies as well as the regional and headquarters Federal Emergency

Management Agency.

The status of the offsite notification sirens and the

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abilities. of the state agencies to support the emergency plan were thoroughly-

assessed and personnel evacuation issues were resolved prior to initiating a

plant restart.

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The river level continued to decline following its peak on July 24.

Region IV

exited the monitoring mode on the afternoon of July 25. A levee failure north

of the plant on the Missouri state side contributed significantly to an

initial decline in the Missouri River level. The river level decreased below

the 899.0 foot elevation on July 26 at approximately 4 p.m.

The licensee

subsequently terminated the NOVE on July 29 at 5:45 p.m.

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On July 29, the licensee commenced preparations for a reactor startup after

completing the appropriate surveillances, including those on equipment which

were affected by the water inleakage. At 5:45 p.m. the licensee exited the

limiting conditions for operation pertaining to river level being greater than

895 feet, as river level was at 894.8 feet and decreating. The reactor mode

switch was placed to start up at approximately 11:31 p.m.

The reactor was

taken critical at 1:45 a.m. on July 30.

The licensee synchronized the main

generator to the grid on August 1, ending their refueling / maintenance outage.

There were no subsequent equipment or component failures identified which were

attributed to the water inleakage problem through the end of the inspection

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period.

2.2 Loss Of power Supply To 345 kV Switchyard

On August 18, the licensee received annunciators indicating an electrical

malfunction in the 345' kV switchyard.

Upon investigation it was determined

that a 400 amp circuit breaker had tripped. This breaker fed the 345 kV

switchyard power Panel PCI, which supplied power to the backup battery

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chargers, lights, air-conditioning, well pumps, and compressors used in the

switchyard.

Preliminary investigation indicated cracked insulation on the wire feeding the

400 amp breaker box, which shorted out, causing the breaker to trip.

The wire

made a sharp bend into the breaker box which could have contributed to the

wire failure.

Approximately 5 minutes after the breaker tripped, a fire

protection annunciator was received in the control room. A station operator

was dispatched to the 345 kV switchyard that observed smoke but no fire. The

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plant remained at 100 percent power throughout the event. The licensee

entered Abnormal Procedure 2.4.6.6, "480 V Transformer or Electrical

Distribution Panel Failure." A section of wiring and the breaker was

replaced.

The inspectors noted that appreciable licensee management involvement was

required to assure that the plant staff utilized the corrective action process

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to evaluate the breaker trip. The licensee documented the breaker trip in

Deficiency Report 93-367 and is in the process of evaluating additional

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breaker boxes which could have similar wiring problems. Additionally, as

discussed in NRC Inspection Report 50-298/93-22, Section 3.1, the licensee

determined that a better definition of boundaries pertaining to who is

responsible for certain activities within the switchyard (plant personnel or

Nebraska Public Power District line crews) was needed. A licensee review of

procedural controls for switchyard work is ongoing.

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2.3

Conclusions

The licensee effectively implemented its emergency procedure for site area

flooding.

Licensee management's initial response to the area flooding was

very good. The decision to shut down the plant based on concerns with the

states' abilities to adequately support the emergency plan demonstrated the

appropriate awareness for the unique flooding challenges.

The declaration and

offsite notifications required for the NOUE were well performed. The

coordination with the states to ensure the emergency plan could be well

implemented prior to proceeding with the plant restart was very good.

A lack of management and plant personnel sensitivity to potentially degraded

plant conditions was noted. Significant water inleakage had occurred because

of the flooded conditions which had not been evaluated for the potential

effect on plant equipment.

Corrective actions were not promptly implemented

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to assure that the building water inleakage was diverted away from plant

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equipment and components. A corrective action plan which addressed plant

recovery and actions required to restart the plant was not developed until

after questioning by NRC.

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Appreciable licensee management involvement was required to assure that the

corrective action process was properly implemented in accordance with its

expectations for the unexpected breaker trip in the 345 kV switchyard.

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3 OPERATIONAL SAFETY VERIFICATION (71707)

3.1 Control Room Observations

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On a daily basis, when on site, and periodically during back shift

inspections, the inspectors observed control room operations and shift

turnover activities.

The operators exhibited adequate communications with

personnel inside and outside the control room.

Shift turnover meetings were

conducted in a manner that provided for proper communication of plant status

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from one shift to the other. Discussions with the operators indicated that

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they were aware of plant and equipment status and reasons for lit

annunciators. The inspectors observed that Technical Specification limiting

conditions for operation were properly documented and tracked.

Plant

management was observed in the control room on a daily basis.

The inspectors routinely reviewed control room valve and switch indications

for proper alignment of systems such as safety injection, containment

integrity, and normal and emergency power supplies. The operators' and shift

supervisor's logs were reviewed and found to properly document plant status.

One instance was identified in which operators demonstrated a willingness to

accept an operator aide, which did not reflect the actual plant electrical

lineup. On July 24, the inspectors noted that an operator aide located next

to the shift supervisor's cubicle did not reflect the actual onsite and

offsite electrical lineup.

The lineup had been inadvertently marked with an

indelible pin which could not be erased.

The depicted lineup condition had

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been in effect since before the plant startup on July 21, 1993.

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inspectors questioned the control room operators about the operator aide and

the actual plant electrical lineup. The operators demonstrated that they were

cognizant of the current lineup and what actions would be required to backfeed

through the main transformers if the offsite power supply was interrupted.

The inspectors determined that the immediate safety significance was minimal.

The operator aide was subsequently removed.

3.2 Plant Startup Following Refueling / Maintenance Outage

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The inspectors observed plant startup activities following the completion of

the refueling / maintenance outage. The operators conducted appropriate

briefings to assure that all personnel involved with the plant _startup were

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cognizant of their responsibilities. The plant startup and power ascension to

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15 percent thermal power was conducted in accordance with the procedure

requirements.

3.3 Plant Tours

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On July 28, the inspector conducted a tour of the control, reactor, and

turbine buildings. The inspector noted a large quantity of heavy brown paper

and a large quantity of opaque white polyethylene plastic being used for

masking purposes in preparation for painting. This was observed in the

reactor water cleanup system filter precoat area at Elevation 958 of the

reactor building.

In the control building corridor, Fire Area VIII, Fire

Zone 19A, there was a large amount of radiological contamination protection

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clothing, (e.g., plastic boots, caps, and anticontamination coveralls). This

was located on wooden bins and shelves. Only a small area in the building

corridor was protected by an active fire suppression system.

The inspector discussed this observation with the Fire Protection and

Industrial Safety Supervisor. The inspector was informed that the

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polyethylene was purchased as fire retardant material; however, the Fire

Protection and Industrial Safety Supervisor was not aware of the brown paper.

After further review, the licensee determined that the craft personnel had

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obtained a transient combustible permit for the painting activity,

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reviewing the transient combustible permit, a determination was made that the

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brown paper was not specifically included in the permit; however, the fire

loading resulting from the paint products negated the fire loading resulting

from the paper.

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The inspector was informed that the protective clothing in the hallway did not

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exceed the established fire loading for that area.

It was noted that a design

change had been initiated to extend the sprinkler coverage to account for

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increased fire loading in the area since the hall was used as a primary

storage area.

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3.3 Walkdown of Essential Ventilation Systems

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Th'e inspector conducted a walkdown of the accessible portions of the

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ventilation systems in the reactor, control, and turbine buildings. The

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inspection included an assessment of the physical condition of the ventilation

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equipment.

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On July 12, the inspector observed a hole in one of the four cross-connect and-

discharge duct expansion sleeves for the standby gas treatment system. This

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was brought to the attention of the licensee, who subsequently initiated a

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work request and replaced all the expansion sleeve material on the standby gas

treatment system. The expansion sleeve material was replaced utilizing

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Maintenance Work. Request.93-2908. The work activity was completed on July 20.

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On August 19, the inspector conducted a walkdown of the ventilation system

ducts in the reactor, control, and turbine buildings. The inspector

identified that expansion sleeves on the ventilation ducts in both emergency

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diesel generator rooms had holes in them and appeared to need replacement.

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The inspector discussed the condition of the emergency diesel generator

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expansion sleeves with the licensee and whether inspections of other

ventilation system expansion sleeves had been performed. The licensee

indicated that additional inspections had been conducted on other ventilation

systems after the degraded expansion sleeve on the standby gas treatment

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system was identified; however, the inspection had not included the emergency

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diesel generator ventilation duct expansion sleeves.

Because the plant was in the refueling outage when the defective sleeve in the

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standby gas treatment ducting was discovered, the licensee decided that there

was no safety significance to the event, and an operability determination was

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not performed. The licensee did not perform an operability determination for

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the defecting expansion sleeves in ducts of the diesel generator rooms because

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they believed that the holes in the sleeves were minor and would not impact on

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the ventilation system's ability to perform the safety function.

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The inspector reviewed Nonconformance Report 93-172, which was initiated on

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July 19, 1993, to document the degraded standby gas treatment system cross-

connect and discharge duct expansion sleeves. On August 19, the inspector

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inquired about the status of the nonconformance report. The licensee

identified that the report would exceed the 30-day evaluation due date_because

of a backlog resulting from an increase in the number of nonconformance

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reports being written. On August 23, the licensee provided a litter

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(CNSS937211) which identified that the control room ventilation, diesel

generator ventilation, and battery room exhaust fans (nonessential) should be

replaced during the next outage. The four main reactor building quadrant fan

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coil units showed signs of aging but should only require inspection during the

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next outage.

The licensee's preliminary

view identified that the degraded expansion

sleeves resulted frorr the inck of periodic or preventive maintenance on the

sleeves.

The inspector

mied that the licensee had not been effective in

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identifying the degraded expansion sleeve conditions until noted by the

inspector. The inspector concluded that the licensee's initial review of this

concern following the identification of the degraded condition on the standby

gas treatment system was not thorough in that they did not consider the

emergency diesel generator ventilation system. -This is another example of a

continuing implementation weakness with the corrective action process.

3.4 Security Observations

On July 6, the licensee instituted security compensatory measures due to high

water levels inside the protected area around the elevated release point

tower. The compensatory measures are still in effect due to cleanup and loss

of some of the normal security surveillance equipment around the previously

flooded area.

The inspector observed the security staff and found them attentive during

performance of these compensatory measures on the day shift and the back

shift. Also personnel and packages entering the protected area were observed

to be properly searched.

3.5 Radiation Protection Activities

Health physics technicians generally demonstrated a heightened awareness for

the potential spread of contamination outside the posted areas.

Frequent

sampling of water within the radiologically control area provided for the

prompt identification of contamination outside the posted areas. No

identifiable increase in personnel contaminations was noted-by the licensee

because of the building water inleakage.

3.6 Conclusion

Shift turnover meetings were conducted in a manner that provided for proper

communication of plant status from one shift to the other.

However, the

operators demonstrated a willingness to accept an operator aide for the

offsite electrical lineup which was incorrect.

The essential ventilation systems were found to be appropriately aligned.

The

licensee's walkdowns of the sytems had not been effective in identifying the

degraded expansion sleeves and in promptly identifying all the ventilation

which may have been affected.

The licensee was generally effective in controlling transient combustibles.

Security and radiological compensatory measures were well implemented for the

problems resulting from the protected area flooding and building water

inleakage.

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4 MAINTENANCE OBSERVATIONS (62703)

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4.1 Repair of 250 V Starter for RCIC System

On July 25, 1993, the inspector observed corrective maintenance activities

associated with the repair of the RCIC 250 Vdc starter rack for the barometric

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condenser vacuum pump. A ground condition had resulted because of water

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inleakage into the starter rack. Maintenance Work Request 93-2956 was issued

to dry out the 250 Vdc starter rack, clean the relay and fuse contacts, and

replace the power fuses.

The postmaintenance test was performed in accordance

with the established test instruction and demonstrated operability of the RCIC

barometric condenser vacuum pump.

In addition, the RCIC condensate pump

250 Vdc starter was inspected because it had water on the outside of the

cabinet.

No adverse conditions were identified.

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4.2 Conclusion

The maintenance activity was performed in accordance with the work

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instructions, and the work activity was properly documented in the work order.

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5 SURVEILLANCE OBSERVATIONS (61726)

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5.1 Testing of Hydrogen /0xygen Analyzer

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On August 23, 1993, the inspector observed the monthly performance of testing

to calibrate and verify functionality of the analyzer used to provide

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indication of the drywell and torus hydrogen and oxygen concentrations. The

test was conducted in accordance with Surveillance Procedure 6.3.1.14,

Revision 11, " Division II H,/0, Analyzer Calibration and Functional Test."

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The inspector. reviewed Surveillance Procedure 6.3.1.14 for quality and .

adequacy and found that the procedure being used had handwritten procedure

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change markups in several places. The changes had been made in accordance

with the temporary procedure change requirements. The handwritten portions of

the procedure were clear and did not adversely affect the performance of the

test.

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The surveillance test was performed by a qualified instrumentation and control

technician. The test was performed in accordance with the test requirements-

and the acceptance criteria were met.

The inspector reviewed the test results

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and noted no discrepancies for the hydrogen or oxygen portion of the test.

Test results for the oxygen portion of the analyzer required a new internal

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calibration to be performed.

The inspector also verified the restoration of

the system and the complete documentation of the post-test results.

5.2 Conclusion

The technicians were knowledgeable of the test procedure and the recent design

changes which were implemented to the hydrogen / oxygen analyzer system.

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6 EMPLOYEE CONCERNS PROGRAMS FOLLOW UP (TI 2500/028)

The objective of Temporary Instruction 2500/028 was to determine the

characteristics of employee concerns programs that licensees have implemented

to provide employees, who wish to raise safety issues, an alternate path from

their supervisor or normal line management to express these concerns and to

encourage people to come forward with their concerns without fear of

retribution.

The inspector reviewed the licensee's Employee Concerns Program with plant and

management personnel. The Nebraska Public Power District has a district-wide

employee suggestion program, which rewards employees for suggestions which are

determined to help the district run more efficiently. They also have a

program called " Talk To The Top," which allows employees to ask top managers

in the district questions which are answered in the district newsletter. The

Cooper Nuclear Station has several additional programs,

i.e., Corrective

Action Program Overview Group (CAP 0G), and As Low As Reasonably

Achievable (ALARA) suggestions. The CAP 0G has been in existence for

approximately 4 months and ALARA since 1987. These programs place more

emphasis on concerns dealing with plant procedures and operations.

6.2 Conclusions

The licensee's Employee Concerns Program provided several processes for

employees to voice concerns.

None of these processes specifically emphasized

the reporting of nuclear safety issues and the protection of employees who

raised concerns.

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ATTACHMENT

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I PERSONS CONTACTED

1.1 Licensee Personnel

L. E. Bray, Regulatory Compliance Specialist

R. Brungardt, Operations Manager

J. W. Dutton, Training Manager

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J. R. Flaherty, Engineering Manager

M. D. Hamm, Security Supervisor

H. T. Hitch, Jr., Site Services Manager

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G. R. Horn, Vice President, Nuclear

E. M. Mace, Senior Manager Site Support

D. N. Madsen, Licensing Engineer

J. M. Meacham, Site Manager

C. R. Moeller, Technical Staff Manager

S. M. Peterson, Acting Plant Manager

J. V. Sayer, Radiological Manager

M. E. Unruh, Maintenance Manager

1.2 NRC Personnel

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G. E. k'erner, Resident Inspector, Commanche Peak

The personnel listed above attended the exit meeting.

In addition to the

personnel listed above, the inspectors contacted other personnel during this

inspection period.

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2 EXIT MEETING

An exit meeting was conducted on August 31, 1993. During this meeting,

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Mr. W. B. Jones and Mr. W.' Walker reviewed the scope and findings of this

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report.

The licensee did not identify as' proprietary any informat ion provided

to, or reviewed by, the inspectors.

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