ML20140B479
| ML20140B479 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/14/1986 |
| From: | Kuncl L NEBRASKA PUBLIC POWER DISTRICT |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| CNSS860170, NUDOCS 8603240190 | |
| Download: ML20140B479 (12) | |
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l CNSS860170 March 14,1986 Mr. James M. Taylor, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, P.C.
20555
Subject:
Notice of Violation and Proposed Imposition of Civil Penalty NRC Inspection Report No. 298/85-31
Dear Mr. Taylor:
This letter is written in response to the NRC letter dated February 13, 1986 transmitting Notice of Violation and Proposed Imposition of Civil Penalty as a result of Inspection Report No. 50-298/85-31.
Therein it indicated that four of our activities were in violation of NRC requirements and that two of these violations were being assessed a civil penalty. Attached are statements of the violations and our responses in accordance with the referenced letter and 10CFR2.201. addresses the violations assessed a $50,000 civil penalty and Attachment 2 addresses the remaining violations.
We have carefully reviewed the February 13, 1986, letter and have concluded that additional clarification is warranted regarding the violations assessed a civil penalty; however, mitigation will not be requested pursuant to 10CFR2.205 and payment of the civil penalty is enclosed.
If you have any questions regarding this response, please contact me.
Sincerely,
(
LM B603240190 860314 L. G. Kuncl PDR ADOCK 05000298 Vice-President G
PDR Nuclear Power Group JMP/RB/JMM/DMN/lb:lk14/6(9B) cc:
Regional Administrator U. S. NucIcar Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 (E:'Y
Mr. Jamts M. Te.ylor Page 2 March 14,1986 STATE OF NEBRASKA)
)ss PLATTE COUNTY
)
L. G. Kuncl, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this information on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.
MC L. G/ Kuncl Subscribed in my presence and sworn to before me this /k day of
%d)
, 1986.
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NOTARY PUIfLIC mem a m aanamma COLLEEN M. KUTA El$MEL E5 Aug(W
Attcchm;nt 1 10CFR2.201 Response to Violations Evaluated as Severity Level III Civil Penalty - $50,000 - Assessed Equally Between Violations I. Violations Assessed A Civil Penalty A.
Technical Specification 3. 7.C.1 requires that secondary containment integrity be maintained when irradiated fuel is handled inside the reactor building.
Technical Specification 3.7.B.1 requires that both standby gas treatment systems (SGTS) be operable at all times when secondary containment is required.
Secondary containment integrity is defined in the Cooper Technical Specification paragraph 1.V, in part, as all automatic ventilation system ssolation valves operable or secured in the isolated position.
Technical Specification 3. 7.B.3 allous one SGTS to be inoperable for up to seven days only if the other SGTS is operable.
Technical Specification Section 6.3 requires that detailed uritten procedures be used to conduct surveillance activities.
Surveillance Procedure 6.3.7.5, paragraph VIII. A.14 requires that electrical jumpers be removed at the con;pletion of testing.
Contrary to the above, on November 14, 1985, secondary containment integrity was not maintained as required when irradiated fuel was moved in the reactor building in that the automatic start capability of both trains of the SGTS was inoperable and the automatic isolation feature of the reactor building ventilation system was inoperable.
The violation occurred because electrical jumpers used during surveillance testing vere not removed after testing was completed.
Admission or Denial of the Alleged Violation Admission, with the following clarification.
Surveillance procedures require that electrical jumpero be removed at the completion of testing.
Contrary to this, on November 13, 1985, electrical jumpers were not removed as required and remained installed for five days.
These electrical jumpers, which were installed on the auxiliary trip units of the reactor building ventilation radiation monitors, would have prohibited automatic reactor building isolation and standby gas treatment initiation upon a reactor building ventilation monitor high radiation signal.
Admittedly, this condition constitutes a violation of CNS Technical Specifications;
- however, it should be recognized that instrumentation and control room annunciators which would identify a reactor building high radiation condition remained operable during the period the electrical jumpers were installed.
In addition, the SBGT system during this time period was operable as were all automatic ventilation system isolation valves. The SBGT system was inhibited from an automatic start only from the reactor building ventilation monitor high radiation initiation signal.
All other SBGT system initiation signals were functional, as well as the manual start capability. The automatic ventilation isolation valves were inhibited from an automatic closure only from the reactor
building ventilation monitor high radiation signal.
All other automatic ventilation isolation valve closure initiation signals ware functional, as well as the manual ventilation isolation valve closure.
While the CNS Technical Specifications were violated during the period the electrical jumpers were installed, both trains would have met the requirements of these sections if manually initiated.
Reason for the Violation The violation is primarily attributable to personnel error by the I&C Technicien involved.
The technician signed Surveillance Procedure 6.3.7.5, Rev. 7, Step VIII.A.14 prior to completion of the action required by the step.
Then as a result of a distraction, he failed to remove the installed electrical jumpers.
The violation is also attributable to procedural deficiency.
Specifically, steps in Surveillance Procedure 6.3.7.5 which require the installation and removal of the electrical jumpers were unclear.
In addition, the procedure lacked a requirement for independent verification that the electrical jumpers were removed.
This would have ensured that the reactor building ventilation radiation monitors were returned back to an operable status following testing.
Corrective Steps Which Have Been Taken and the Results Achieved The involved I&C Technician was immediately removed from surveillance testing and maintenance on plant critical systems.
In addition, all temporary modifications (electrical jumpering, fuse removal, etc.) conducted by the technician between October 5,1985, (the date when CNS shut down for a. turbine vibration problem) and the date of the event were verified to be correctly implemented and completed.
The I&C Technician was counseled by the Operations Manager and the I&C Supervisor.
Further disciplinary action involved suspension without pay for a period of two days and his demotion to the next lower position.
Surveillance Procedure 6.3.'7.5,
" Reactor Building Ventilation Radiation Monitor Calibration And Functional / Functional Test", was reviewed and revised. The revision included:
(a) clarification of the procedural steps requiring installation and removal of electrical jumpers, and (b) independent verification of electrical jumper removal.
A review of all CNS surveillance procedures has been completed in order to identify procedures requiring independent verification steps. Approximately 70 procedures were identified and 70% of these have been revised to date.
The I&C Department personnel have been counseled by the Operations Manager and the I&C Supervisor about the importance of completing all the action required by a procedural step prior to signing the step as completed.
Corrective Steps Which Will Be Taken to Avoid Further Violation The recaining procedures identified in the aforementioned review will be revised in order to provide independent verification steps.
These enhancements to the surveillance testing program should preclude further violations in this regard.
Date When Full Compliance Will Be Achieved Full compliance was achieved on November 18, 1985, when the installed jumpers were found and subsequently removed. The on-going revision of procedures to minimize the potential for future problems of this type will be completed by May 31, 1986.
B.
Technical Specification Section 6.3 requires that detailed written procedures be used to conduct surveillance activities. Surveillance Procedure 4.6.H.2 requires that inspection shall verify that there are no visible indications of damage or. impaired operability for safety-related enubbers.
Technical Specification 3.6.H requires that during all modes of operation except for cold shutdown or refueling, all safety-related enubbers be operable.
Contrary to the above, surveillance inspections performed during July 1985 by the licensee did not identify tuo dryvell enubbers that had visible indicatione of impaired operability.
As a result, from August 20 to October 5, 1985, Cooper Nuclear Station vae in operational modes other than cold shutdoun or refueling with these enubbers inoperable. Also from August 20 to October 5, 1985, about 23 additional safety-related enubbers vere inoperable while the facility vae in operational modes other than cold shutdown or refueling.
Admission or Denial of the Alleged Violation Admission, with the follosing clarification.
As written, the violation indicates that CNS operated for a period of time with inoperable snubbers installed. However, as can be determined from the detailed description contained in Appendix A to NRC Inspection Report 50-298/85-31, all of the snubber problems noted by the NRC Inspector, as well as those found by CNS inspectors, were
" potential" problems which may have rendered the af fected snubbers inoperable.
In each case, the problems noted had to do with attachments of questionable adequacy and potential interferences.
While a rigorous engineering analysis would likely have shown that many of the snubbers were capable of acceptable performance, the District chose to take a most conservative course of action.
Each snubber was conservatively considered to be inoperable and its apparent problem corrected; however, it is important to note that in no case was a snubber clearly verified to be incapable of performing its intended function. Upon careful examination of the snubbers, it is the District's engineering judgement that had a seismic event occurred, each snubber would, in all probability, have performed
adequately.
On the other hand, our review of this matter will lead to the elimination of some weaknesses in the CNS Snubber Inspection Program and enhance the overall safety status of the plant.
Reason for the Violation This violation is the result of two general problems with the CNS Snubber Inspection Program. These are discussed in detail below:
1.
Inadequate Procedural Guidance A review of the history of the Snubber Inspection Program revealed that, in the past, the CNS Engineering Department had conducted the required in situ inspections, with a contractor providing operability tests on removed snubbers. The involved CNS personnel were trained on the details of the in situ inspections and a general procedure was provided to document the inspection results.
Potential interferences and questionable snubber attachments were resolved by the CNS Snubber Engineer based on engineering judgement as they were identified by the inspectors. Due to the location of several of the snubbers (inside the Drywell) and the number of qualified Engineering personnel who could perform the inspections, individual personnel radiation exposure became a problem.
Therefore, the in situ inspection portion of the Snubber Inspection Program was transferred to the CNS Maintenance Department.
However, the aforementioned procedure was not revised in sufficient detail to enable these personnel to adequately conduct the inspections.
Consequently, those inspections failed to identify questionable snubber attachments and potential interferences and, therefore, these apparent problems were not resolved.
2.
Insufficient Training of Snubber Inspectors As described in Item 1. nbove, the in situ snubber inspections were transferre.1 to the CNS Maintenance Department to lower individual radiation exposures.
The resulting increase in the number of personnel involved in the snubber inspection program required extensive training in order to properly conduct the snubber inspections.
The referenced training provided these individuals was insufficient. This, coupled with the deficient procedure, led to the failure to identify questionable snubber attachments and potential interference problems.
Corrective Steps Which Have Been Taken and the Results Achieved Prior to plant startup from the October-November 1985 Outage, all snubbers that were apparently inoperable were identified and the problems were corrected'.
This immediate corrective measure was accomplished by engineering personnel experienced in the specific types of problems which were being encountered.
The Architect
Engineer, Burns and Roe, was consulted to verify a clear understanding of the inspection requirements. The inspection of all safety related snubbers was then conducted and all potential operability problems corrected.
Corrective Steps Which Will Be Taken to Avoid Further Violation The following longer range steps are being taken to avoid further violations:
1.
CNS Maintenance Procedure 7.2.34, " Snubber Inspection", 7.2.52,
" Snubber Removal And Installation", and related Inservice Inspection procedures are being revised to include specific inspection criteria.
2.
A comprehensive training program which will include lesson plans, training aids, and visual inspection qualification is being developed.
3.
A program is being developed - to assure that designated inspectors will be trained and qualified prior to conducting any related inspections.
4.
A program is being developed to assure that supportf.ng drawings will be reviewed and updated as necessary to better define the criteria for each snubber, including the snubber, e.ttachments, and potential interferences.
Date When Full Compliance Will Be Achieved Full compliance was achieved prior to plant startup from the October-November, 1985, outage.
The longer range steps described above are intended to minimize the possibility of recurrence of the type of problem and potential noncompliance, will be completed by October 1, 1986, the date of the next scheduled Refueling Outage.
Attcchrant 2 L
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1 10CFR2.201 Response to Violations Not Assessed A Civil Penalty II.
Violations Not Assessed A Civil Penalty 1
A.
Technical Specification, Section
- 6. 3 requires that there be procedures implemented for fire protection.
Cooper Nuclear Station Administrative Procedures, "CNS Fire Protection Plan, " A. P. -0. 23, Revision 0, dated August '8, ' 1985, (paragraph V. A.2.a.b) statec, " good housekeeping practices are l
essential for fire safety.
rage, paper, and other foreign materiale must not be allowed to accumulate...."
Contrary to the above, poor houeekeeping practices and the accumulation of materiale adverse to fire safety -vere found on November 20-21, 1985, in certain areas of the reactor building as evidenced by the fottooing examples:
1.
Several large boxes of efuse and other trash were found in the doorways and access areas of the RHR heat exchanger "B" room and the HPCI room (in the southwest quad).
This material vould have limited accese of personnet and fire equipment.
Admission or Denial of the Alleged Violation Admission.
Reason for the Violation The material involved in the violation consisted of expended and used protective clothing.
The method used to ' collect ' this protective clothing is to deposit it in containers ~ located near the exit to step-off pads of contaminated areas.. In some instances, these containers are located near doorways to contaminated' areas and' have the potential to limit access if initial placement is not performed with care or through inadvertent management thereafter.
Corrective Steps Which Have Been Taken and the Results' Achieved i
A survey was made and similar potential problems were corrected.
Also, the personnel involved in maintaining ~these areas have been instructed to periodically monitor the location of containers and to remove or relocate those containers which could impede personnel and equipment access to these areas.
j.
Corrective Steps Which Will Be Taken to Avoid Further Violation i
t An extensive housekeeping effort has been. underway since plant startup from the previous extended. outage to replace : the IGSCC.
I related piping.
All excess material has been removed and properly stored or disposed of.
I k
Date When Full Compliance Will Be Achieved We. achieved full compliance af ter 'the corrective actions,' described above were completed.
2.
A fire hose in the southwest quad at 882' elevation was covered with personnel clothing.
Admission or Denial of the Alleged Violation Admission.
Reason for the Violation A CNS employee had disrobed to put on protective clothing to work in a nearby contaminated area and had inadvertently placed his personal clothing on the referenced hose station.
Corrective Steps Which Have Been Taken and the Results Achieved The referenced clothing was immediately removed and all similar areas checked for compliance.
The individuals who were working in this area of the plant have been instructed not to place personal clothing on plant equipment that could reduce plant effectiveness.
Corrective Steps Which Will Be Taken to Avoid Further Violation This topic will be reemphasized with station personnel at the next Safety Meeting. This will ensure that personnel are aware of the requirements and the importance of complying with' the Fire Protection Plan.
Date When Full Compliance Will Be Achieved Full compliance was achieved on November 21, 1985.
The - planned discussions with station personnel will be completed by May 1,1986.
3.
The electric motor associated with radiation vaste effluent monitor (TB-486) at elevation 903' on the south vall of the reactor building was found to have a plastic pait on the top of i
it.-
Admission or Denial of the Alleged Violation Admission.
Reason for the Violation Since cleanup and. decontamination efforts had.been underway near the-vicinity of the motor, it is postulated that a worker-inadvertently left the bucket atop the motor.
~
Corrective Steps Which Have Been Taken and the Results Achieved The pail was removed.
A survey was made through the plant and similar problems were corrected. Cleanup and decontamination crews were reminded that CNS standard practice requires them to remove cleaning gear from areas when assigned tasks have been completed.
To reduce further the potential for the inadvertent placement of cleaning gear on plant equipment, all cleaning gear is now required to be returned to the tool crib and is checked out to perform specific tasks.
Corrective Steps Which Will Be Taken to Avoid Further Violation First line supervisors, by procedure, will now monitor work areas to ensure good housekeeping is being maintained.
Date When Full Compliance Will Be Achieved We achieved full compliance on November 21, 1985.
4.
In the 4160 volt suitch gear room a number of aerosol cans of flammable materials vere found uithin three to four feet of cuitch gear equipment with electric heaters.
Admission or Denial of the Alleged Violation Admission.
Reason for the Violation The aerosol cans noted in the violation are used during maintenance activities and had been inadvertently lef t near the switch gear equipment.
Corrective Steps Which Have Been Taken and the Results Achieved Cabinets designed for the storage of flammable materials have been purchased and placed in areas where flammables are utilized for maintenance activities.
Flammables are now being stored in these cabinets when not in use.
Corrective Steps Which Will Be Taken to Avoid Further Violation Appropriate personnel have been instructed to utilize the newly installed safety cabinets and to comply with written procedures for the control of flammable liquids.
Work areas are to be monitored for compliance by Maintenance supervision.
Date When Full Compliance Will Be Achieved We achieved full compliance upon removal of the aerosol cans identified.
B.
Failure To Properly Log And Sign Off Surveillance Discrepancies Technical Specifications, Section G.3 requires that detailed written procedures be used to conduct surveillance test activities.
The Cooper Nuclear Station Surveillance Procedurce, " Fire Protection System Monthly Inspection",
S.P.-6.4.5.1, Revision 38, dated November 7, 1985, and " Fire Protection System Annual Inspection",
S.P.-G. 4.5.2, Revision 30, dated November 7, 1985, both require in paragraph V.B.1 that "all discrepancies shall be recorded in the Shift Supervisor's log".
In Attachment A of each procedure a checklist and report form provides space for the shift supervisor to sign off if a nonconformance report of vork item is initiated.
Contrary to the' above, discrepancies identified in the conduct of certain monthly and annual fire prevention inspectione vere not recorded in the Shift Supervisor's log.
Additionally, the Shift Supervisor had not signed off on Attachment A to the subject procedures when corrective actions for nonconformance vork iteme vere initiated as illustrated by the follouing examples:
1.
Annual inspectione dated February 13 and May 15, 1985, and monthly inspectione dated August 4 and September 28, 1985, identified discrepancies, yet they vere not recorded in the shift supervisor's log.
2.
During monthly inspectione dated August 4, September 2, September 28, and October 29, 1985, nonconformance vork items vere initiated but did not have the shift supervisor's (Attachment A) sign off on the subject procedures.
Admission or Denial of the Alleged Violation NPPD admits the alleged violation.
Reason for the Violation This violation resulted from a failure to follow CNS procedure.
Corrective Steps Which Have Been Taken and the Results Achieved The discrepancies resulting from the annual fire inspection dated February 13 and monthly inspections dated August 4 and September 29, 1985, have been recorded in the Shift Supervisor's log.
The discrepancies resulting from the annual fire inspection dated May 15, 1985 were previously recorded in the Shift Supervisor's log on May 17, 1985.
The monthly fire inspections dated August 4, September 2, September 28, and October 29, 1985, will be signed to indicate that work items were initiated.
Corrective Steps Which Will Be Taken to Avoid Further Violation A letter will be sent to all Shift Supervisors and Control Room Supervisors stressing the need to record.all discrepancies noted during the performance of surveillance procedures as required by the Administrative Limits section of surveillance' procedures.
This
.-letter will also state the need to complete the required sign-off in surveillance procedures if a work item or nonconformance report is initiated.
In addition, the Surveillance Coordinator will be instructed to verify the appropriate signatures have been received on completed surveillance procedures.
Date When Full Compliance Will Be Achieved We are presently in full compliance and the actions described above will be completed by March 31, 1986.
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