ML20128F086

Insp Rept 50-298/85-15 on 850401-30.Violation Noted:Failure to Perform Safety Question Determination for Installed Temporary Jumpers & Failure to Have Procedures for Activities Affecting Quality

ML20128F086
Person / Time
Site:	Cooper
Issue date:	05/20/1985
From:	Boardman J, Dubois D, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20128F051	List: ML20128F047 ML20128F067 ML20128F086
References
50-298-85-15, NUDOCS 8505290553
Download: ML20128F086 (18)

See also: IR 05000298/1985015

Text

.

.

APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/85-15 License: DPR-46

Docket: 50-298

Licensee: Nebraska Public Power District (NPPD)

P. O. Box 499

Columbus, Nebraska 68601

Facility Name: -Cooper Nuclear Station (CNS)

Inspection At: Cooper Nuclear Station, Nemaha County, Nebraska

Inspection Conducted: April 1- 0, 1

Inspecto . ////  % b

Resid t Inspector (SRI) Date

LT0pois[Se&f

na 9A

. R .! Boar mrn, Re ctor In pector

Iubf

Date '

Special P Jects d Engi ering Section

k b Reac r oje Branc

Approved: s 3 3d

. P. Qaudop,'Chie% Noject Section A, Dat'e

eactorPfojectBranch1

L

Inspection Summary .

Inspection Conducted April 1-30,1985 (Report 50-298/85-15)

Areas Inspected: Routine, unannounced inspection of operational safety

verification, monthly surveillance and maintenance observations, and licensee

action on previous inspection findings. The inspection involved

119 inspector-hours onsite by two NRC inspectors and 18 inspector-hours at the

Columbus General Office by one NRC inspector.

8505290553 850522

PDR

G ADOCK 05000298

PDR

-

.

i

-2-

Results: Within the four areas inspected,'four violations were identified

(failure to perform a safety question determination for installed temporary

jumpers, paragraph 2; superseded procedures located in the control room,

paragraph 2; failure to have procedures for activities affecting quality,

- paragraph 2; failure to follow procedures, paragraph 2).

.

%

L...

-_

-

.

-3-

DETAILS

1. Persons Contacted

Principal Licensee Personnel

• L. G. Kuncl,. Assistant General Manager Nuclear

• J. M. Pilant, Technical Staff Manager Nuclear Power Group

+#*oP. V. Thomason, Division Manager Nuclear Operations

• R. E. Wilbur, Division Manager Nuclear Services

• G. A. Trevors, Division Manager Quality Assurance (QA)

+#*J. M. Meacham, Technical Manager, CNS

+oD. A. Whitman, Technical Staff Manager, CNS

1. oR. B. Brungardt, Acting Operations Manager, CNS

1. oV. L. Wolstenholm, QA Manager, CNS

+L. L. Roder, Admintrative Services Manager, CNS

+#*oE. M. Mace, Plant Engineering. Supervisor, CNS

.+#D. Norvell, Acting Maintenance Manager, CNS

• J. H. Ferneau, Records Supervisor, Records Administration Dept.

+#oC. R. Goings, Regulatory Compliance Specialist, CNS

.

• oJ. R. Sayer, Senior Technical / Radiological Advisor, CNS

00.' L. Reeves, Training Manager, CNS

The NRC inspectors also interviewed other plant, general office, and

contractor personnel, including engineering, administrative, and

clerical.

+ Denotes presence at exit interview held April 4, 1985

1. Denotes presence at exit interview held April 16, 1985

• Denotes presence at exit interview held April 18, 1985

oDenotes presence at exit interview held April 26, 1985

2. Licensee Action on Previous Inspection Findings

(Closed) 8421-02 (Unresolved). ThisitemwasidenkifiedbytheNRC

Performance Appraisal Team (PAT) and concerned the lack of 10 CFR 50.59

reviews of installed jumpers and bypasses in plant equipment. The SRI

reviewed 47 records of installed jumpers, bypasses, and fuse removals in

plant equipment over the period December 1984 through April 1985 and

verified that none of the records indicated the performance of an

evaluation to determine if the temporary alterations involved an

unreviewed safety question. Eighteen of the 47 alterations affected

safety related or important to safety equipment. Discussions with shift

supervisory personnel indicated that they would consult with mechanical,

electrical, and/or instrument and control (I&C) personnel prior to

! installing the temporary alterations in order to determine the effect on

i

. . . - . - - - . . - , ,, . . . , . - . - -

-

.

,

'

-4-

the system resulting from the alteration; but they had not performed nor

documented a safety question review as required by 10 CFR 50.59.

CNS Engineering Procedure (EP) 3.3, Revision 1, " Station Safety

Evaluations," provides the mechanism for determining whether a change to

the plant constitutes an unreviewed safety question; designates the

!

design engineer to perform safety evaluations for station design changes;

provides documentation of that safety evaluation; and directs that the

safety evaluations be reviewed and approved by the Station @ erations

Review Committee (SORC). CNS Procedure 2.0.2, Revision '1, d0perations

Logs and Reports,"Section II.F., provides guidance for maintaining the

Jumper Log (Attachment B to Procedure 2.0.2). Procedure 2.0.2 specifies

that the shift supervisor (SS) must authorize initiation of a jumper but

the requirements for the performance of a safety review are not

addressed. The licensee is committed to ANSI 18.7-1972, " Administrative

Controls For Nuclear Power Plants," which requires a review of changes

made to equipment to comply with 10 CFR 50.59 and that procedure controls

be implemented to identify equipment in a controlled status. Further,

the procedures are to require independent verification to ensure that

necessary measures were implemented correctly. ANSI N45.2.11-1974,

" Quality Assurance Requirements For the Design of Nuclear Power Plants,"

requires the licensee to evaluate the effects of changes to previously

verified designs on the overall design. The failure of the ifcensee to

perform a necessary safety evaluation of the placement of jumpers in

plant equipment is an apparent violation of 10 CFR 50.59 (8515-01).

The jumper installed in 1979 and still in effect to modify a flow input

to the plant process computer will be removed or changed to a permanent

design change as determined by the wiring requirements being performed as

a result of the installation of a new process computer that is presently

in progress.

Based upon the above violation, unresolved item 8421-02 is closed.

(Closed) 8421-04 (Unresolved). The PAT determined that the licensee

had four outdated procedures located in the control room. Subsequent

review by the SRI determined that the licensee had replaced the

out-of-date procedures with present revised editions. However, the SRI

identified that the Control Room Emergency Procedures Handbook, which is

located in the SS's office, contained Revision 3 instead of current

Revision 4 of CNS Procedure 5.7.1, Attachment B, "CNS Emergency Plan -

Classification Checklist." The failure to maintain current approved

procedures for use in the plant by station operators is an apparent

violation of 10 CFR Part 50, Appendix B. Criterion V, and the licensee's

approved Quality Assurance Plan (QAP), Sbction 2.5, both of which require

documented procedures for the performance of activities affecting quality

or having nuclear safety significance. Also, the licensee failed to

adhere to the requirement of CNS Procedure 1.10, which states that

m

-

.

-5-

superseded pages/ documents are to be destroyed, stamped " Superseded," or

returned to the Administrative Services Department for disposition-

(8515-02).

Based upon the above violation, unresolved item 8421-04 is closed.

(Closed)- 8421-07 (Unresolved). 'This PAT-identified' item concerned the

licensee's failure to implement a training program. Also evident was an

apparent lack of direction and management commitment to the CNS training

effort. The licensee committed to adhere to the guidance provided in

ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant

Personnel." ANSI N18.1-1971 requires the licensee to establish a

training program and an implementation schedule in order to develop and

maintain a fully qualified plant staff. The SRI and region-based

inspectors have documented and are-presently tracking items in the area

of training as listed below:

. 8113-069 Training Offsite Personnel

. 8113-107 QA for Effectiveness of Training

. 8212-001 Training Program Not Fully Implemented

. 8227-003 Lack of a Formal Training and Retraining Program for

Radiochemistry Personnel

. 8236-001 Failure to Conduct Requalification Training (Violation)

. 8316-001' Quality and Quantity of Requalification Training

. 8319-002 Training Program for Radwaste Operators

. 8328-001 Failure to Follow an Approved Guard Training and

Qualification Plan (Violation)

. 8412-002 The CNS Training Department Has Not Developed an Approved

Official Training Program

. 2412-003 The Licensee Has Not Developed and Implemented a Formal

Training Program for Offsite Technical Support Personnel

. 8412-004 The Licensee Has Not Developed an Approved General

Employee Training Program

. 8412-005 Mechanical Maintenance Training Program

. 8412-006 Instrument and Control Training Program

f -

-

e

-6-

,.

. 8412-007 Engineering Department Training Program

. 8412-008 QA Department Training Program

. 8504-007 No Formal Training / Retraining Program for Health Physics

,

Personnel

,

Since the PAT findings are being tracked under the above numbers,

. unresolved item 8421-07 is closed for record purposes.

(Closed) 8421-08 (Unresolved). This item was identified by the PAT and

concerns qualification, training, and independence of licensee QC

inspectors. The licensee acknowledged the apparent procedural weaknesses

in these areas. Corrective actions include hiring a QC coordinator who

will be assigned to the plant QA organization (target date of July 1,

1985). The QC coordinator will develop necessary procedures (target date

of February 1,1986) covering QC inspector qualification, training and

organizational independence. The QC coordinator will implement these

procedures, and will also supervise assigned QC inspectors to assure

- their organizational independence. The licensee is presently drafting

Revision 2 of the NPPD nuclear QA policy document. This revision, which

will make a commitment to a later version of ANSI N45.2.6, will delete

previous exceptions to this standard and will clarify the required

independence of QC inspectors. The licensee will approve and issue

Revision 2 by the end of April, 1985.

Regulatory action taken on the identified lack of licensee procedures for

,

qualification, training,-and independence of QC inspectors is addressed

in the summary below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-08 is closed.

(Closed) 8421-09 and 8421-10 (Unresolved). These items were identified

by the PAT and concerned audit program procedure inadequacies resulting

in an apparent failure to report properly deficiencies and to address

specific QA program audit objectives. Audits were referenced that did

not address all objectives of the QA Program. The NRC inspector found

that the licensee believed that it was not practical to address all

,

objectives of a specific QA plan in every audit. The NRC inspector

i

concluded that if such were the case, this should be clearly documented

on this specific audit. The QA staff has been instructed that all QAP

objectives must be addressed in an audit report whenever possible. In

addition, the format of the report of an audit has been revised to

include a separate attachment which states each QAP audit objective

achieved, how it was accomplished, and a list of QAP objectives which

were not addressed during the audit. QAP audit objectives not addressed

during an annual audit will be carried over to the next audit scheduled

l

i

.

-

.

-7-

for the QAP. QAI-5, " Guidelines for QA Audits," was revised in July 1984

to clarify the definitions of audit findings and observations and to

require justification in an audit for why an observation is not

classified as a finding. Significant audit observations now require

responses and follow-up to assess the effectiveness of the corrective

actions.

The QA audit program has been upgraded to address the weaknesses noted in

the PAT inspection. Continued monitoring of audit reports and training

of the QA staff will ensure that the licensee's audit program becomes

stronger.

Regulatory action taken on the identified lack of licensee procedures for

accomplishing audits is addressed in the summary below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved items 8421-09 and 8421-10 are closed.

(Closed) 8421-16 (Unresolved). The PAT identified an apparent failure

by the licensee to have procedures that required corrective action for

- vendors having identified QA program deficiencies. The licensee's

corporate QA department had approved sole-source suppliers even though

the supplier QA programa did not meet certain parts of 10 CFR Part 50,

Appendix B. In recognition of this weakness, licensee procedure QAI-16,

" Supplier Approval," Revision 9, issued in December, 1984, required

additional c,uality controls (QCs), such as alternative supplier QA

programs, and receipt tests or inspections for components purchased from

this type of supplier. In addition, the NPPD QA staff conducted supplier

evaluations resulting in an improved list of. qualified suppliers. More

detail is now required in specifying QA requirements in purchase

documents to ensure that adequate QC is applied to material purchased

from sole-source suppliers.

Regulatory action taken on the identified lack of licensee procedures to

assure corrective action on supplier QA program deficiencies is addressed

in the summary below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-16 is closed.

(Closed) 8421-17 (Unresolved). The PAT identified an apparent failure

by the licensee to have procedures requiring verification of the validity-

of vendor certificates of conformance. The PAT questioned the validity

of supplier Certificates of Conformance for identical replacement parts,

and how NPPD QA was verifying those certificates. To correct this

deficiency, the QA Division no longer accepts a Certificate of

Conformance as the sole basis of approving a supplier for the procurement

of essential material, components, or services for CNS. When a

,

I

m

r

-

.

-8-

Certificate of Conformance is requested from the supplier as additional

quality documentation, the licensee now requires that the supplier

identify on the certificate the original date of part purchase for CNS

and a summary of all design changes that have been performed on the part

since the original purchase. Prior to using the part, each design change

must be evaluated by either CNS Engineering or NED to establish the

equivalency of the new part to the one originally purchased. This

requirement is specified on the Approved Supplier List. In addition,

receipt acceptance testing is required on these " equal to or better than"

parts prior to use. Revision 10 to QAI-16 will be issued by the end of

April, 1985, and will clarify this updated approach to the procurement of

parts from sole-source suppliers.

Regulatory action taken on the identified lack of verification of the

. validity of vendor Certificates of Conformance is addressed in the

summary below.

Based upon the licensee's corrective steps and the NRC regulatory actions

stated above, unresolved item 8421-17 is closed.

(Closed) 8421-18 (Unresolved). The PAT identified an apparent licensee

failure to have procedures requiring performance of additional receipt

inspection for items not examined or inspected at the source.

ANSI N45.2.2, Section 5.22, specifies additional receipt inspection

requirements for items not inspected or examined at the source. Licensee

procedures, such as CNS Procedure 1.5, Revision 0, " Receiving," did not

require the performance of the additional inspections.

The licensee committed to perform the following corrective actions:

. Hiring a receipt inspector as soon as possible who would be

dedicated solely to receipt inspections.

. Have in place within 6 months after hiring the receipt inspector,

procedures covering additional receipt inspections of

essential / safety-related items.

Regulatory action taken on the identified lack of procedural requirements

for additional receipt inspections is addressed in the summary below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-18 is closed.

(Closed) 8421-19 (Unresolved). The PAT identified an apparent failure

by the licensee to have procedures requiring proper storage for hazardous

material.

!

I

y. +. _ _--._s v -

.

-

....

-9-

ANSI N45.'2.2-1972LSection 6.3.3,- prohibits storage of hazardous

- chemicals, paints, solvents and othe'r materials in close proximity to

important nuclear plant items. The PAT inspector found hazardous

materials adjacent to.important nuclear plant items. Licensee procedures

did not address or prohibi_t such storage. The-licensee.has subsequently

m .' included, .in the CNS calendar year 1986 budget, a request for a building

'that would be dedicated to storage.of hazardous material. Necessary.

- procedures will be developed and implemented at that. time.

The PAT inspection report also discussed in observations 5.a and 5.b of'

the procurement section,. minor deficiencies in the care and storage of

spare parts. -The licensee committed to review these areas, to make

- necessary procedure revisions, and to correct identified problems by

December 1, 1985.

Regulatory action taken on the identified lack of procedural requirements

for proper storage of hazardous materials is addressed in' the summary

- below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-19 is closed.

i

(Closed)-l8421-20 (Unresolved). The PAT identified a licensee failure

to have procedures requiring the establishment of control of vendor--

technical information. In a letter from Mr. L. G. Kunc1 (NPPD) to .

Mr. D. G. Eisenhut -(NRC), dated November 4,1983, the licensee. stated,

" Vendor manuals at CNS are controlled distribution documents and are

-presently the responsibility of the CNS Engineering Department."' The PAT

oascertained that vendor manuals were not controlled documents. The NRC'

inspector found that the licensee had no documented program to respond.to

NRC Generic Letter 83-26 relative to control of.. vendor technical-

information. Licensee efforts in.the area of vendor manuals were limited

-

.to the assignment of one site engineer to review safety-related,

nonsafety-related, and facility' vendor manuals for. consistency. Site

engineering did not have copies of nor had they reviewed all

safety-related technical manuals that had been used by the maintenance

. department, particularly in the area of I&C. Reactor trip systems vendor'

technical information was not. controlled nor had reactor trip systems

equipment been classified as discussed in Generic Letter 83-28,

-Section'2. The licensee did have a consultant classifying safety-related

equipment, although no priority had been given to reactor trip systems.

The: licensee committed to the following actions prior to reactor start-up

.from the present outage:

. Classifying all safety-related equipment which function as reactor

trip system components required for shut down of the reactor.

-..- -.w.-..-._ - -.-z..- - -... -_.-, . - - , - . - . , ,

_. . _ _ _

-

.

-10-

. Inclusion of all necessary vendor technical information relating to

reactor trip systems into a document control system. This will

include assurance that the vendor technical information is correct

and current for CNS equipment.

. A schedule will be developed for inclusion of all other

safety-related vendor technical information into the document

control system.

. CNS Procedure 3.13, Revision 0, " Equipment Classification," will be

approved by May 15, 1985.

Regulatory action taken on the identified lack of procedural requirements

for control of vendor technical information is addressed in the summary

below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-20 is closed.

(Closed) 8421-21 (Unresolved). The PAT identified that a procedure did

.

'

not exist for controlling calibration of mechanical measuring and test

equipment (M&TE). Subsequently, the licensee originated and approved CNS

Procedure 7.1.1, Revision 0, " Mechanical Gauging Equipment Control and

Calibration," which provided the procedural controls for calibration of

M&TE. The NRC inspector reviewed Procedure 7.1.1, Revision 1, and noted

that it had not been fully implemented (e.g., all present onsite M&TE

calibrations were not controlled as directed by Procedure 7.1.1).

Licensee personnel stated that all M&TE used for safety-related work

since Procedure 6.1.1 was approved and implemented were controlled and

calibrated. Remaining M&TE calibrations will be controlled in accordance

with Procedure 7.1.1 prior to the instruments being used for any

safety-related activities.

Because a procedure did not exist for controlling calibration of M&TE at

the time of the PAT, regulatory action is being taken as addressed in the

summary below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-21 is closed.

(Closed) 8421-22 (Unresolved). The PAT identified that the licensee

utilized written instructions and guidelines called " shop guides" for

accomplishing safety-related activities. The shop guides had not

received the same level of review, approval, or control as other CNS

maintenance related procedures. The licensee has committed to perform a

complete review of all shop guides used in safety-related activities.

Shop guides will be converted to approved maintenance procedures, or, if

found to contain only recommendations or guidelines, will receive

'

/

- - - -

- - . . . . -

.

-

-11-

appropriate technical reviews and approvals, and will be controlled. All

of the actions are committed to be completed by June 1, 1986.

Regulatory action taken on the lack of procedural controls of shop guides

is addressed in the summary below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-22 is closed.

l (Closed) 8421-23 (Unresolved). The PAT identified that CNS EP 3.4,

" Station Design Changes," Revision 0, appeared inadequate in the

l

following areas:

.

l . Lack of documentation of design verification. l

l . Only 10 of the 28 design input requirements of ANSI N45.2.11 were

f addressed.

The licensee committed to revise EP 3.4 by Juna 1,1985, to correct these

inadequacies.

The PAT also identified that final close-out of minor design changes

(MDCs) were not timely. Licensee personnel acknowledged that closure

delays were a problem and attributed the delays to manpower restraints.

Though not documented in approved procedures, the licensee stated that

verification of completed MDCs included the following minimum checks:

. Affect on the CNS Technical Specification.

. Affect on the Updated Safety Analysis Report (USAR).

. Affect on the CNS Training Manual.

. Affect on CNS operational procedures.

. Need for interim revised drawings.

The licensee committed either to revise procedures to reflect a 2-stage

closure of MDCs or to modify the present procedures to provide guidance

for timely review and closure. The 2-stage method, if selected, will

consist of a release for operations and an administrative closure. All

actions will be completed by June 1, 1986.

Regulatory action taken on the lack of licensee procedures for design

verification is addressed in the summary below.

Based on the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-23 is closed.

(Closed) 8421-24 (Unresolved). The PAT identified that the licensee

did not have procedures for the conduct and documentation of safety

evaluations for temporary lead shielding installed on systems or

components discussed in the CNS USAR. Further, the PAT found that static

L _ _ ____ - - - _ _ _ - - - - -

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ - _

-

.

-12-

stress calculations were documented for temporary lead shielding but

dynamic stress calculations and safety evaluations were not documented.

Subsequent to the PAT notifying the licensee of the above deficiencies,

the licensee .immediately implemented the following actions and plans:

. Proper analysis and documentation was implemented.

. A CNS EP, " Temporary Shielding Installations," will be developed and

approved by June 1, 1985. The procedure will contain necessary l

controls to preclude a recurrence of the deficiencies.

. Temporary installed lead shielding will be removed from two of three

areas prior to startup from the present outage.

. Temporary shielding in the remaining area of the scram discharge

volume will remain. The analysis for this area will be complete by

August 1, 1985.

Regulatory action taken on lack of licensee procedures for the conduct

and documentation of safety evaluations for temporary lead shielding

installed on systems or components discussed in the CNS USAR is addressed

in the summary below.

Based upon the licensee's corrective steps and NRC regulatory actions

stated above, unresolved item 8421-24 is closed.

l (Closed) 8421-26 (Unresolved). This PAT-identified item concerned the

licensee's practice of closing-out CNS Nonconformance Reports (NCRs)

l prior to completing all identified corrective actions. As a result, the

l licensee practice resulted in the removal of NCRs having significant

[ safe _ty implications from the NCR tracking system.

E

CNS Procedure 0.5, "Nonconformance and Corrective Action," was revised

subsequent to the PAT inspection. The present Revision 1,

Section III.A.15, states that the QA staff will perform the final review

of all NCRs, concur with all the recommended actions, sign and date their

con'currence, and close-out the NCR for record purposes. A NOTE following

the QA staffs' responsibilities permits close-out of NCRs prior to

completion of all corrective actions providing that the incomplete

action (s) is duly referenced on the NCR atid another tracking mechanism is

in place and monitored to verify completion of the action of which

exception was taken. In the case of MDCs referenced in the PAT findings,

an MDC tracking system is not closed out until all actions required by

the MDC are complete.

This item is closed.

(Closed) 8421-27 (Unresolved). This PAT-identified item concerned the

licensee's failure to adequately identify and discuss personnel errors in

Licensee Event Reports (LERs)84-003 and 84-007. LER 84-003 discussed an

L ,

-

.

-13-

. inadvertent trip of an operating reactor feedwater pump (RFP) by I&C

technicians during troubleshooting operations which indirectly resulted

in a reactor trip. -LER 84-007 discussed a plant shutdown required by the.

'CNS Technical. Specification which occurred when both trains of the

Standby Gas System (SGT) System were. rendered inoperable by inadvertent

wetting of the SGT system charcoal beds by the fire protection sprinkler

_

system.

Concerning LER 84-003, the PAT determined that the ifcensee failed to

discuss the fact'that an I&C technician had neither an approved procedure

for nor the SS's approval to troubleshoot a problem with the RFP. In

addition, the LER did not discuss whether the operator had failed to

' follow approved procedures or if the approved procedures were adequate.

The-SRI verified that I&C technicians were not performing troubleshooting

using an approved plant procedure or a maintenance. work request (WR).

An WR must be . approved by the SS prior to commencement of work

activities. Had an WR been issued prior to the start of troubleshooting

the.RFP,.it would have provided necessary approvals, controls, and

step-by-step guidance of the proposed activity to technicians and control

room personnel-alike. .The SRI determined that WR 84-01 was issued

a f ter-the-fact.

-The SRI'.s review of other related plant procedures indicated the

following:

. CNS Abnormal Conditions Procedure 2.4.9.4.3, " Loss of Single Feed.

Pump,". Revision.6, included a CAUTION which. stated, " Restarting the

tripped feed pump with a low. reactor level may start a cold water

injection transient unless precautions are taken to limit the

-initial' feed rate to an acceptable feed rate increase." The only

direction given to the operator following the above CAUTION was,

" attempt to restart the tripped pump."

. CNS Abnormal Conditions Procedure 2.4.9.4.4,'" Loss of Feedwater,"

Revision 7, assumes the reactor has tripped due to low . level so,.

therefore, it does not provide guidance to the operator for

~

attempting to prevent a reactor trip.

'

. CNS Alarm Procedure 2.3.2.1, " Panel A - Annunciator A-1," concerns a

.RFP-trip monitor. This procedure does not provide a CAUTION such as

given above when it directs..the operator to restart a. tripped RFP.

'It'is apparent from the above that CNS abnormal conditions procedures-

lack specificity concerning starting / restarting a tripped RFP. Also, the

abnormal conditions procedures do not reference normal feedwater startup

~ Procedure 2.2.28 which does provide clearer and more precise direction.

)

_

-

.

-14-

Concerning LER 84-007, the PAT determined that the LER did not discuss

whether the operators adhered to procedures or if the procedures were

inadequate. The SRI reviewed the following CNS procedures applicable to

the event that was described in LER 84-007:

. Alarm Procedure 2.3.2.40, " Fire Protection (Gate Valve Alarm and

Fire Pumps) - Annuciators 4-4 and 5-2," which gave corrective

actions for a fire header low pressure condition and fire pump

running conditions respectively.

. System Operating Procedure 2.2.30, " Fire Protection System,"

Revision 22.

The SRI's review of this unresolved item substantiates the PAT findings.

Although the licensee addressed personnel errors in LERs84-003 and

84-007, the LERs lacked specificity with regard to the extenuating

circumstances responsible for the initiation of personnel errors.

Extenuating circumstances not included in the LERs were:

. Failure to have an approved I&C procedure for troubleshooting RFP

controls / indication problems, or

. Failure to follow CNS Procedure 7.0.1, " Work Item

Tracking-Corrective Maintenance," which establishes work controls

using an MWR.

. Operations' personnel failed to remember and apply the CAUTION

stated above when restarting the tripped RFP.

. Failure to follow CNS Procedure 2.2.30, " Fire Protection System,"

Revision 22,Section X, titled, " Recovery From Header Inadvertent

Depressurization."

. Inadequacies exist in procedures 2.4.9.4.3, 2.4.9.4.4, and 2.3.2.1

as previously discussed above.

. Alarm Procedure 2.3.2.40 is inadequate in that it does not state

operator actions that should be performed to correct the alarming

condition except if the cause of annunciation is an actual fire.

. Procedure 2.2.30, Section K, should be an annunciator, abnormal, or

emergency procedure rather than a normal operating procedure.

The SRI reviewed two other LERs issued by the licensee during 1984 which

involved lack of procedural adherence and/or personnel error (LERs84-006

and 84-008). These LERs appeared to properly address causative effects

and extenuating circumstances surrounding the events. Also, the SRI

reviewed CNS Procedure 0.19, " Licensee Event Report Procedure,"

1

-

.

-15-

Revision 1, dated November 29, 1984, and determined that it requires more

narrative regarding personnel errors found to be a contributing factor in

an event.

Regulatory action taken on the failure to follow procedures is addressed

in the summary below. Based upon this action, unresolved item 8421-27 is

closed for record purposes.

SUMMARY

10 CFR Part 50, Appendix B, Criterion V, requires activities affecting

quality to be prescribed in appropriate documented procedures. Each

Pat-identified unresolved item listed below is an example of a failure to

have procedures:

. 8421-08

. 8421-09

. 8421-16

. 8421-17

. 8421-18

. 8421-19

. 8421-20

. 8421-21

. 8421-22

. 8421-23

. 8421-24

The failure to have documented procedures for activities affecting

quality constitutes an apparent violation of 10 CFR Part 50, Appendix B,

Criterion V. (298/8515-03)

The CNS Technical Specification, Sections 6.3.2 and 6.3.3, requires that

procedures shall be provided and adhered to for corrective maintenance of

plant equipment that could have an effect on nuclear safety and for

actions to be taken to correct specific and foreseen potential or actual

malfunctions of safety-related systems or components. The licensee's

failure to follow CNS Procedures 7.0.1 and 2.2.30 is an apparer.t

violation of Technical Specification requirements. (298/8515-04)

The apparent inadequacies in CNS Procedures 2.4.9.4.3, 2.4.9.4.4,

2.3.2.1, 2.3.2.40, and 2.2.30 is an open item pending further reviews and

inspection. (298/8515-05)

,

b

. . . - .- _

--

-

.

-16-

3. Operational Safety Verification

The SRI observed control room operations, instrumentation, controls,

reviewed plant-logs and records, conducted discussions with control room

< operators, and conducted system walkdowns to verify that:

. Minimum shift manning requirements were met.

. Technical Specification requirements were observed.

. Plant operations were conducted using approved procedures.

. Plant logs and records were complete, accurate, and indicative of

actual system conditions and configurations.

. System pumps, valves, control switches, and power supply breakers

were properly aligned.

. Licensee systems lineup procedures / checklists, plant drawings, and

as-built configurations were in agreement.

. Instrumentation was accurately displaying process variables and.

protection system status to be within permissible operational limits

for operation.

. Plant equipment that was discovered to be inoperable or was removed

from service for maintenance was properly identified, redundant

equipment was verified to be operable, and applicable limiting

conditions for operation were identified and maintained.

. Equipment safety clearance records were complete and indicated that

affected components were removed from and returned to service in a

correct and approved manner.

. ~MWRs were initiated for equipment discovered to require repair or

routine preventive upkeep, appropriate priority was assigned, and

work commenced in a timely manner.

. Plant equipment conditions such as cleanliness, leakage,

lubrication, and cooling water were controlled and adequately

maintained.

. Areas of the plant were clean, unobotructed, and free of fire

hazards. Fire suppression systems and emergency equipment were

-maintained in a condition of readiness.

. Security measures and radiological controls were adequate.

_

,_

-

,

..

.

.

-17-

The SRI performed-lineup verifications of the following systems:

. Emergency Power Distribution System

. Service Water System

The tours, reviews, and observations were conducted to verify that

facility operations were performed in accordance with the requirements

established in the CNS Operating License and Technical Specification.

No violations or deviations were identified in this area.

4. Monthly Surveillance Observations

The SRI observed Technical Specification-required surveillance tests.

These observations verified that:

. Tests were accomplished by qualified personnel in accordance with

approved procedures.

. Procedures conformed to Technical Specification requirements.

. Test prerequisites were completed including conformance with

applicable limiting conditions for operation, required

administrative approval, and availability of calibrated test

equipment.

. Test data was reviewed for completeness, ac aracy, and conformance

with established criteria and Technical Specification requirements.

. Deficiencies were corrected in a timely manner.

. _The system was returned to service.

The reviews and observations were conducted to verify that facility

surveillance operations were performed in accordance with the

requirements established in the CNS Operating License and Technical

Specification.

No violations or deviations were identified in this area.

5. Monthly Maintenance Cbservation

The SRI observed preventive and corrective maintenance activities. These

observations verified that:

. Limiting conditions for operation were met.

. Redundant equipment was operable.

-

.

. =

-

O

.

-18-

. Equipment was adequately isolated and safety tagged.

. Appropriate administrative approvals were obtained prior to

commencement of work activities.

. Work was performed by qualified personnel in accordance with

approved procedures.

. Radiological controls, cleanliness practices, and appropriate fire

prevention precautions were implemented and maintained.

. QC checks and postmaintenance surveillance testing were performed as

-

required.

. Equipment was properly returned to service.

These reviews and observations were conducted to verify that facility

maintenance operations were performed in accordance with the requirements

established in the CNS Operating License and Technical Specification.

,

No violations or deviations were identified in this area.

6. Exit Meetings

Exit meetings were conducted at the conclusion of each portion of the

inspection. Then NRC Inspectors summarized the scope and findings of

each inspection segment at those meetings.

.

4

L-