ML20151W234
| ML20151W234 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/27/1988 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CNSS880209, NUDOCS 8805030332 | |
| Download: ML20151W234 (5) | |
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CNSS880209 April 27, 1988 U. S. Nuclear Regulatory Commission Docyment Control Desk Wasaington, D. C.
20555
Subject:
NPPD Response to IE Inspection Report No. 50-298/88-06 Gentlemen:
This letter is written in response to your letter dated March 29, 1988, which transmitted IE Inspection Report No. 50-298/88-06.
Therein you indicated that certain of our activities were in violation of NRC requirements.
Following are the statements of the violations and our responses in accordance with 10CFR2.201:
A.
STATEMENT OF VIOLAT_IO_N_
Failure to Determine Jet Pump Operability Technical Specification (TS) Limiting Conditions for Operation (LCO) 3.6.E.1 states, in part, that whenever the reactor is in the startup or run modes, all jet pumps shall be operable.
TS Surveillance Requirements (SR) 4.6.E.1 states in part, that whenever there is recirculation flow s
with the reactor in the startup or run modes, jet pump operability shall be checked daily.
TS Definition 1.0.J states, in part, that entry into ai operational condition shall not be made unless the conditions of the LCO are met without reliance on the actions specified in the LCO "nless othervira excepted.
Contrary to the above, p* wr tu lebruary 6,1988, jet pump operability generally was not checked by performing SR 4.6.E.1 during reactor startup
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until the reactor was at power in the run mode.
This is a Severity Lcvel IV violati'n.
(Supplement I)(298/8806-01) l I
REASON FOR THE VIOLATION l
Verification of jet pump operability requires that one of three criteria be eatisfied. These criteria are stipulated in Technical Specification Sections 4.6.E.1.a. b, and c.
The criteria contained in Sections 4.6.E.1.b and 4.6.E.1.c require accurate indication of jet pump flow. As discussed in General Ele cric Service Information Letter (SIL) 330, jet pump flow is subject to significant measurement inaccuracies at low thermal power or low core flow operation.
Therefore, during reactor O
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Document Control Desk April 27, 1988 Page 2 startup, jet pump flow cannot be measured with sufficient accuracy to satisfy the criteria contained in Sections 4.6.E.1.b and 4.6.E.1.c.
The requirements of Section 4.6.E.1.a. which verifies riser and nozzle assembly integrity, is the sole means of verifying jet pump operability during the stated plant condition.
The flow curves which had previously been developed for verification of jet pump operability were based on pump characteristics with the reactor at operating power levels equal to or greater than approximately twenty per cent.
Since core hydraulics with the reactor suberitical or at very low power levels are sufficiently different than those at operating power levels, the existing curves were invalid for use during startup.
,Therefore, jet pump operability below this power region could not be accurately verified as required by Technical Specification sections 4.6<E.1.a. b, and c.
CORRECTIVE STEPS WHICh HAVE BEEN TAKEN AND THL RESULTS ACHIEVED A new characteristics curve for recirculation pump flows has been developed and made available in the Control Room which is valid during subcritical reactor conditions.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Prior to startup from the 1988 Refueling Outage, this response end e copy of the new characteristics curve will be formally routed to all licensed operators.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by May 13, 1988.
B.
STATEMENT OF VIOLATION Failure to Follow Fire Protection Procedure IS Section 6.3.2, states,'in part, that written procedures and instruction including applicable checkoff lists shall be established.
implemented, and maintained for implementing procedures for the fire protection program.
CNS Surveillance Procedure 6.4.5.17. "Fire Fighting i
Equipment Monthly Inspection," Revision 14, dated July 15, 1987, Section 2 A states, in part, that a systematic inspection of all extinguishers j
shall be made every month.
l Contrary to the above, Surveillance Precedure 6.4.5.17. "Fire Fighting Equipment Monthly Inspection," Revision 14, dated July 15, 1987, Attachment A, was not performed during the month of Janusry 1988, for fi:e extinguishers located on var';us electric and oxygen-acetylene welders.
This is a Severity Level IV violation.
(Supplement I)(298/8806-02)
Documtnt Control Drck April 27, 1988 Page 3 REASON FOR THE VIOLATION The monthly fire extinguisher Surveillance Procedure 6.4.5.17, scheduled for January 1988, was not performed until February 3, 1988. Although the fire extinguisher inspection had previously been performed on December 21, 1987, for the month of December, the inspection exceeded the 30 day plus or minus 25 percent window allowed by CNS Procedure requirements. The reason for exceeding the specified serveillance frequency was failure to establish a formal tracking system for the specified fire extingrieher inspection.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Preventive Maintenance Item Number 05054 has been established to direct the inspection of fire extinguishers on a monthly basis and within the specified interval.
In addition, the person responsible for this actielty has been counseled on the importance of performing surveillance testing within the specified time interval.
It should be noted that only the surveillance interval was exceeded.
The station fire extinguishers have been inspected ence for each calendar month during this period and no attempt was made to combine two months' inspections under one inspection.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Establishment of the monthly fire ex'_inguisher inspection frequency into the Preventive Maintenance Program will provide the required notification and overviev of future inspections to avoid further violations.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved April 1986.
C.
STATEMENT OF VIOLATION Failure to Perform Adequate Review 10 CFR Part 50, Appendir B, Criterion V, and the licensee's approved Quality Assurance Plan require that the act'.vities affecting quality j
shall be prescribed by documentes: instructione, procedures or drawings, j
Sectfon V.B.5 for Cooper Nuclear Station Procedare 0.26 "Surveillance Program," Revision 2, dated October 15, 1987, reeuires that sarveillance tests be reviewed for acceptance and completion by the individual who pe* formed the test, by the Shift Supervisor, and by one other responsible i
ino rsidual.
Contrary to the above, (1) test re:ults contained in curveillance Procedure 6.4.5.17. "Fire Fighting Equipment Monthly Inspection,"
Revision 14 dated July 15, 1987, Atcachment E, page 3 of 4, were inadequately reviewed because several "Verified-By" blocks were not i
initialed as completed for the months of December 1957 and January 1988, (2) Surveillance Procedure 6.4.5.1, "Fire Protection Syctem Monthly l
Inspection," Revision -
dsicd December 17, 1987, Actachment "A." page 7 l
Documsnt Control D2sk April 27, 1988 Page 4 of 10, was inadequately reviewed because an out-of-specifications reading was recorded for the month of December 1987, and (3) General Operating Procedure 2.1.1.2, "Technical Specifications Pre-Startup Checks,"
Revision 7, dated December 10, 1987, page 5 of 11, was inadequately reviewed because Item 13 was not signed as completed for the startup performed on February 7,1988.
This is a Severity Level IV violation.
(Supplement I)(298/8806-03)
REASON FOR THE VIOLATION This violation is a result of inadequate review of testing conducted in accordance with CNS Surveillance and General Operating Procedures.
The failure to properly review this testing for acceptaace and completion by the individual who performed the test, the Shift Supervisor, and one othtr responsible individual is a violation of CNS procedural requirements.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The procedural steps in CNS Surveillance Procedures 6.4.5.17 and General Operating Procedure 2.1.1.2 which were not signed off as being completed, vere subsequently reviewed and signed by the individuals who originally performed the specific tests. These individuals, as well as individuals involved in the procedural reviews, were counseled on the need to conduct a thorough review of testing performed to ensure required signatures and test data are complete and accurate.
The out-of-specifications reading recorded in CNS Surveillance Procedure 6.4.5.1 was reviewed originally by the responsible site engineer and was determined rot to be a concern, this engineer has since reviewed the out-of-specifications reading to verify the results of his original 1
evaluation and noted in the discrepancy section of Surveillance Procedure 6.4.5.1 that the ret. ding for the identified non-safety related parameter is not considered a concern to continued reliable performance of the system.
CORREC1IVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS To ensure that out-of-specifications readings recorded in Surveillance Procedure 6.4.5.1 are noted and reviewed for importance, the procedure will be revised to require recording of out-of-specifications readings in the discrepancy section of the procedure.
In addition, the present methodology for performance of procedural reviews will be enhanced, as necessary, to ensure that surveillance tests and procedures are accurately reviewed.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance vill be achieved by May 31, 1988.
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Document Cont:01 Disk April 27, 1988 Page 5 If you have any questions regarding this response, please contact me or G. R. Horn at the site.
Sincerely, 7.
. A.
revors Division Manager Nuclear Support GAT:GRH:ya cc:
U. S. Nuclear Regulatory Commission Region Office - Region IV NRC Resident Inspector Cooper Nuclear Station l
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