ML20154D100
| ML20154D100 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/10/1988 |
| From: | Bennett W, Holler E, Plettner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154D093 | List: |
| References | |
| 50-298-88-07, 50-298-88-7, NUDOCS 8805190046 | |
| Download: ML20154D100 (11) | |
See also: IR 05000298/1988007
Text
.
-
.
.
I
APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-298/ 88-07
License:
Docket:
50-298
Licensee: Nebraska Public Power District (NPPD)
P. O. Box 499
Columbus, NE
68601
Facility Nanie: Cooper Nuclear Station (CNS)
Inspection At: Cooper Nuclear Statiori, tiemaha County, Nebraska
Inspection Conducted:
itarch 1-April 15, 1988
Inspectors:
. N. / d /suo
I//TI /
C A. Plettner, Resident Inspector, (RI)
Date'
~
fdkt'
Y b>l//
II.~R. Dennett, Senior Resirient inspector, (SRI)
Date
- '
'
( fo 9[
Approved:
E. J.
. oiler, Chief, Project Section C,
Date '
Reactor Projects Division
8805190046 880511
ADOCK 05000298
O
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
.
%
0
2
Inspection Summary
Inspection Conducted March 1 through April 15, 1988 (Report 50-298/88-07)
Areas Inspected:
Routine, unannounced inspection of operational safety
verification, containment local leak rate-test, monthly surveillance and
maintenance observationt, ESF walkdown, outage, refueling, shutdown,
radiological protection, and security.
Results:
Within the areas inspected, one violation was identified (failure to
follow a health physics procedure, paragraph 11).
-
l
3
r
i
._
- _--___
.-. _
-. -
__
n
-
..
.
.
.
..
t
3
DETAILS
'
1.
Persons Contacted
Principal'L'icensee Employees
- G. R. Horn, Olvision Manager of Nuclear Operations
- R. D. Black, Operations Supervisor
- 0. M. Norvell, Maintenance Manager
- J. V. Sayer, Radiological Manager
- G.
E. Smith, Quality Assurance _ Manager
- L. E. Bray, Regulatory Compliance Specialist
- G. R. Smith, Licensing Supervisor
The NRC inspectors also interviewed other licensee employees during the
inspection period.-
- Denotes those present during the exit interview conducted on April 15,
1988.
2.
Licensee Action on Previous Inspection Findings
(Closed) Open Item 298/8709-01:
Deficient As-Built Instrument Drawing -
This item involved discrepancies between System Operating
Procedure (50P) 2.2.20, Revision 23, Appendix A "Valve Checklist
Number 2" and Cooper-Bessemer as-built drawing KSV-46-5; and between
S0P 2.2.12, Revision 8, Appendix A, "Valve Checklist" and Burns & Roe
as-built drawing Nos. 2077 and 2011, Sheet 1.
Drawing Change
Notice (DCN) 87-1682 was issued to correct labeling deficiencies on
KSV-46-5.
DCN 88-29 was issued to correct labeling deficiencies on
Drawing No. 2011, Sheet 1.
DCNs87-154 and 88-174 were issued to correct
labeling defit:iencies on Drawing No. 2077.
The RI compared 50P 2.2.20, Revision 27, Appendix A, to Drawing KSV-46-5;
and S0P 2.2.12, Revision 10, dated October 22, 1987, Appendix A, to
Drawings 2011 and 2077, and found no discrepancies.
This item is closed.
(Closed) Open Item 298/8712-01:
10 CFR 50.59 Conflict with USAR - This
item involved conflict between the CNS Updated Safety Analysis
Report (USAR) Section 13, paragraph 9.5, and the Safety Review and Audit
Board (SRAB) Instructions and Guidelines, Section 1.2.
The conflict
involved the academic requirements of board members.
The USAR required
that all members have degrees.
The SRAB Instructions and Guidelines
stated that they shall have a B.S. degree, or equivalent experience.
The
. __
_ _ _ _
.
.
.
.
.
4
licensee submitted to the NRC a change to the USAR which was approved on
July 22, 1987, to resolve the conflict.
The RI verified agreement between
the USAR and the SRAB Instructions and Guidelines.
This item is closed.
(Closed) Violation 298/8728-03:
Failure to Maintain Secondary Containment
Integrity - This item involved the reactor building railroad airlock
doors. With the inner door open while the outer door was closed, air gaps
existed between the outer door and the ground.
Corrective actions taken
by the licensee were to generate two new procedures, which provide
detailed instructions to verify integrity of secondary containment
penetrations, and to fabricate and mount signs on the airlock doors
stating "Prior to shutting either railroad airlock door, insure that the
associated railseal plates are installed." The RI reviewed Surveillance
Procedure 6.3.10.17, "Secondary Containment Penetration Inspection,"
Revision 0, dated March 1, 1988, and Maintenance Procedure 7.0.10,
"Railroad Airlock Door Operations," Revision 0, dated March 1, 1988, to
verify that corrective actions were complete and adequate.
The RI
verified that signs were mounted on the railroad airlock doors.
This item is closed.
3.
Operational Safety Verification
The NRC inspectors observed operational activities throughout the
inspection period.
Control room activities and conduct were observed to
be well controlled.
Proper control room staffing was maintained.
The NRC
inspectors observed selected shift turnover meetings and noted that
information concerning plant status was communicated to the oncoming
operators.
Tours of accessible areas at the facility were conducted to confirm
operability of plant equipment including the fire suppression systems and
other emergency equipment.
The NRC inspectors performed a walkdown of the
Residual Heat Removal (RHR) System.
Results of this walkdown are
documented in paragraph 7 of this report.
Operators were cognizant of maintenance being performed during the outage
and how it affected operation of the plant.
Limiting conditions for
operation (LCOs) were properly entered when safety equipment was
inoperable for maintenance.
Required surveillance testing was properly
performed when LCOs were in effect.
A tagout desk was setup outside the control room (CR) during the outage.
This allowed qualified personnel to review work packages and initiate
tagouts for work performance without having extra personnel in the CR
area.
This greatly reduced the congestion in the CR and aided the
on-watch operators in maintaining plant status.
No violations or deviations were identified in this area.
-
- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _
_ _ _ _ - _ _ _ _ _ _ _
. _ _ _ _ _ _
.
.
.
.
.
5
4.
Containment Local Leak Rate Test
The R1 performed direct observation, record review, and independent
calculations associated with the Containment Local Leak Rate Test (LLRT)
program conducted by CNS.
The purpose of this inspection was to verify
that primary containment local leak rate tests, as required by CNS TS were
performed to ensure that leakage through testable containment penetrations
and isolation valves would not exceed the allowable leakage specified.
The RI observed the performance of Surveillance Procedure (SP) 6.3.1.1,
"Primary Containment Local Leak Rate Test," Revision 22, dated
February 25, 1988, Attachment 3, for RHR MOV-M021A, M026A, M031A, M0166A,
and M0167A.
Personnel performing the test were cognizant of all
precautions associated with the test and performed the test in accordance
with applicable procedures.
The RI performed independent calculations of
LLRT data for the above listed valves and for other valves tested by the
procedure.
These calculations were in agreement with those performed by
licensee personnel during performance of the test.
The sum of as-found leakages determined during LLRTs exceeds the
requirement of TS.
The licensee will evaluate valves for repair and
perform applicable LLRTs subsequent to any repairs.
The licensee will
issue a Licensee Event Report (LER) to document exceeding requirements for
allowable leakage.
No violations or deviations were identified in this area.
5.
Monthly Surveillance Observations
The NRC inspectors observed and reviewed the performance of Nuclear
Performance Procedure (NPP) 10.5, "LPRM Calibration," Surveillance
Procedure (SP) 6.3.12.1, "Diesel Generator Operability Test," SP 6.3.5.1,
"RHR Test Mode Surveillance Operation," SP 6.2.3.3., "Drywell Air Sampling
System Calibration and Functional / Functional Test," and SP 6.3.8.2, "SLC
Pump Operability Test."
NPP 10.5, "LPRM Calibration," Revision 19, dated February 1,1988,
At'=chment 1, "Tip System Operation": This test was performed on
Marci,1, 1988, to verify that Local Power Range Monitors were within
calibrotion.
The RI observed that the test was performed by
qualified personnel who were cognizant of all precautions associated
with the test.
The test was performed in accordance with all
applicable procedures.
SP 6.3.12.1, "Diesel Generator Operability Test," Revision 22, dated
November 19, 1987:
This test was performed on March 29, 1988, to
verify operability of No. 2 Diesel Generator (DG) after performance
of the annual inspection. The SRI observed that the test was
performed by qualified operators who were cognizant of all
surveillance requirements.
Maintenance identified a potential
problem with one cylinder during the test.
A broken ring and scored
9
.
.
6
liner were discovered on one cylinder, and the ring and liner were
replaced.
SP 6.3.12.1 was repeated on April 5, 1988, and
subsequently, DG No. 2 was declared operable.
'
SP 6.3.5.1, "RHR Test Mode Surveillance Operation," Revision 27,
dated February 25, 1988:
This test was performed on April 6, 1988,
to verify RHR Loop B (Pumps B and D) operability subsequent to
maintenance performed on loop B.
The SRI reviewed the surveillance
and determined that all data was properly verified to be acceptable
per the procedure and TS.
The test was properly reviewed by all
required personnel.
SP 6.2.3.3, "Drywell Air Sampling System and Functional / Functional
Test," Revision 21, dated August 7,1986.
This test was performed on
April 7, 1988, as acceptance testing for maintenance performed on the
drywell particulate monitor per Work Item (WI) 88-1618.
This test
was performed by a qualified technician in accordance with approved
procedures.
The SRI noted that the procedure was written in such a
manner that, at times, it was difficult to follow.
Discussions with
licensee personnel determined that the procedure was being rewritten
and the revision was in the review and approval process.
SP 6.3.8.2, "SLC Pump Operability Test," Revision 27, dated March 3,
1988:
This test was performed on April 11, 1988, to verify
operability per TS 3/4.4 and to meet requirements for inservice
testing.
The test was performed by qualified personnel who were
cognizant of procedure requirements.
The SRI verified that all test
equipment used during the procedure was in calibration. The SRI
observed that independent verification was properly performed and
that seals were properly reinstalled on appropriate valves.
No violations or deviations were identified in this area.
6.
Monthly Maintenance Observation
The NRC inspectors verified that the maintenance activities were conducted
in accordance with approved procedures, regulatory guides, and industry
codes or standards, and in conformance with TS.
On March 16, 1988, the RI observed the performance of Preventive
Maintenance (PM) No. 03728, "Inlet and Outlet Cooler Tubes Inspection,"
and associated Equipment Clearance and Release Order 88-378, RRLO-HX A
and -HX B, dated March 15, 1988.
The RI observed maintenance personnel
performing the PM and noted that it was performed in a professional manner
and that the personnel were cognizant of all procedural requirements.
All
clearance order tags were appropriately identified and hung in accordance
with the equipment clearance and release order.
The NRC inspectors observed maintenance personnel perform Surveillance
Procedure (SP) 6.3.12.6, "Diesel Generator Annual Inspection,"
Revision 20, dated June 12, 1986, and associated Maintenance Work
._____________- __ __ ____
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
__ _____________________
.
.
.
.
.
.
7
Request (MWR) 88-0866 for DG No. 2.
This procedure was performed to meet
TS requirements that the diesel generator be inspected in accordance with
instructions based on the manufacturer's recommendations.
The NRC
inspectors observed that maintenance personnel were aware of the
requirements of the inspection, and performed the inspection in accordance
with the procedure.
DG No. 2 was declared operable on April 5, 1988,
af ter appropriate acceptance testing was performed.
On March 31, 1988, the SRI observed the performance of hydrostatic testing
on "B" RHR heat exchangers per WI 88-1009.
The hydro was performed as
acceptance testing following maintenance.
The SRI observed that the test
was properly performed in accordance with Maintenance
Procedure (MP) 7.0.8, "Pressure Testing," Revision 4, dated November 5,
1987.
The SRI noted that quality control hold points were properly
observed and that the proper test pressure was maintained throughout the
test.
No violations or deviations were identified in this area.
7.
Engineered Safety (ESF) Feature Walkdown
The NRC inspectors performed an independent walkdown of Loop B of the RHR
system.
The inspection was performed to verify operability, to confirm
that licensee system lineup procedures match plant drawings and the
as-built configuration, and to identify equipment conditions or items that
might degrade system performance.
This system was chosen because Loop B
had just been declared operable following maintenance performed during the
outage.
)
In preparation for performing the walkdown of the RHR system, the NRC
inspectors conducted a review and comparison of the following licensee
system checklist and applicable as-built drawings:
50P 2.2.69A, "Residual Heat Removal Valve Checklist," Revision 1,
dated March 3, 1988
As-Built Drawing - Burns & Roe 2040
"RHR System"
i
General Electric Diagram 729E211BB
"RHR System"
During the walkdown minor discrepancies involving missing labels were
noted which did not affect system operability.
The licensee was notified
of these discrepancies and initiated actions to correct them.
.
'
During the inspection, the NRC inspectors verified proper positioning and
tagging of valves associated with the A Loop of the RHR system which was
I
inoperable due to maintenance being performed on the system.
No violations or deviations were identified in this area.
l
-
I
!
!
'
. _ . _ . _ _ _ _
_
. _ _ _ _ _ _ _
_ __
_
__ ._ _ _ _
. _ .
_ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
.
.
. .
8
8.
Outage
The licensee commenced a refueling outage on March 5, 1988.
In addition
to refueling, numerous maintenance items and modifications are being
performed including diesel generation inspection, replacement of 125V
batteries, detailed control room design review human factors
modifications, motor control center upgrades, and Standby Liquid Control
System modifications.
The licensee performed maintenance on all "Loop B" safety systems
simultaneously while maintaining all "Loop A" systems operable.
Upon
completion of "Loop B" maintenance, the NRC inspectors monitored and
reviewed acceptance testing of "Loop B" safety systems as they were
declared operable.
The switchover from "Loop A to "Loop B" was performed
in a controlled, conservative manner.
The NRC inspectors observed that
acceptance testing and system lineups were properly performed.
Limiting
conditions for operations were properly observed at all times, and TS were
properly reviewed whenever a system or systems was inoperable.
The NRC inspectors observed the implementation of Design Change 87-029B
"MCC Qualification Upgrade," approved on February 25, 1988, and associated
Maintenance Work Request, MWR 88-1081.
The purpose of the upgrade was to
refurbish breakers located within the Motor Control Centers (MCC) to meet
environmental qualification standards.
The NRC inspectors observed the
electrical craft personnel performing their duties in a professional
manner, and in accordance with procedures.
Quality control hold points
were observed.
Quality control personnel performed their duties in a
professional manner.
The assigned system engineers were also observed
during the implementation of the design change and during performance of
acceptance testing.
On March 16, 1988, the RI observed the performance of Design
Change 87-043, "Replacement of NBI Pressure Switches," approved on
March 4, 1988, and associated MWR 88-1057.
The purpose of the design
change was to upgrade current pressure switches with environmentally
qualified pressure switches.
The RI observed the instrumentation and
control personnel perform their duties in a professional manner and in
accordance with the design change procedure.
The assigned system engineer
was also present at various times to observe the performance of the work.
The NRC inspectors observed the replacement of 125V battery 1B in
accordance with Design Change 87-073.
The design change was implemented
Procedure (SP)6.3.15.7,glicableprocedures.
in accordance with the ap
Surveillance
125V Batteries 1A and 18 Service Test,"
Revision 0, was approved on March 31, 1988, to perform the acceptance test
for the new battery.
The procedure was based on manufacturer's
recommendations and was performed in addition to testing previously
observed by licensee personnel at the battery manufacturers.
SP 6.3.15.7
4
was completed on April 4, 1988.
No violations or deviations were identified in this area.
1
, _ _ _ _ _
. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _
_ _ _ _ .
-
,
.
.
, . , .
9
9.
Refueling
The NRC inspectors held discussions with fuel handling and control room
personnel, observed fuel movement, verified fuel assemblies locations in
the spent fuel pool and the reactor, accountability records, and status
board updates during this inspection period.
The NRC inspectors also
.
reviewed the licensee's procedures and records concerning the movement of
fuel and storage of fuel assemblies.
Included as part of those reviews
were SP 6.1.2.7, "Refueling Platform Interlocks and System Functional
Tests," Revision 23, dated November 12, 1997, with attachments to the
procedure, NPP 10.21, "Special Nuclear Materials Control and
Accountability Instructions," Revision 1, dated May 14, 1987, NPP 10.25,
"Fueling," Revision 8, dated February 12, 1987, and NPP 10.26, "Working
Over or In Reactor Vessel Requirements," Revision 1, dated March 10, 1988.
Three different operating shifts were observed during this inspection
period.
Each operating shift was cognizant of the requirements of the
various procedures, and performed their duties in a controlled and
professional manner.
All required surveillances were performed including
daily surveillances of "A" Standby Gas Treatment and "A" Standby Liquid
Control when the "B" trains of those systems were inoperative for
maintenance.
On March 7, 1988, the SRI questioned the licensee's intent to lift the
reactor vessel head prior to demonstrating the ability of secondary
containment to maintain 1/4-inch of water vacuum under calm wind
conditions, as stated in TS 4.7 C.1.c.
Paragraph 4.7.C of TS Bases
implies that this test should be done prior to the time that primary
containment is opened for refueling.
Discussions were held among the
licensee, SRI, NRR project manager, and NRC Region IV management.
It was
agreed that the test to demonstrate secondary containment need only be
performed prior to fuel movement.
The licensee committed to reviewing TS
to determine if a change to TS 4.7.C Bases was required.
The test
(SP 6.3.10.8, "Secondary Containment Leak Test, Revision 9, dated
December 17, 1987) was completed satisfactorily on March 9, 1988, prior to
commencing fuel handling operations.
No violations or deviations were identified in this area.
10.
Shutdown
The NRC inspectors held discussions with operations shift personnel and
reviewed control room records including log entries, record traces, and
computer printouts associated with the scheduled shutdown.
The shutdown
started at 4:30 a.m., on March 6, 1988.
The shutdown was required in
order to perform the refueling of the reactor, preventive maintenance
activity on selected equipment, and install approved plant design changes.
The RI reviewed General Operating Procedure (GOP) 2.1.4, "Normal Shutdown
from Power," Revision 27, dated December 10, 1987.
Other procedures which
were revcewed in whole or in part were GOP 2.1.10, "Station Power
- _ - _ . _ _
_ _-__ _
__.
--
_
-. .
. - _ _
-
_ _ _ _ _
.
.
.
.
...o
10
Changes," Revision 15, dated December 10, 1987, and GOP 2.1.20, "RPB
Refueling Preparation," Revision 12, dated February 18, 1988.
During the
shutdown, two safety system challenges occurred:
A Group II, III, and VI Isolation was received at 4:31 a.m. on
March 5, 1988, because of a reactor vessel low-water setpoint
(+12.5 inches) being reached.
The event was attributed to a reactor
vessel water level "shrink" which occurs on a reactor scram. The
manual scram was initiated at 25 percent power as part of the normal
shutdown procedure.
A Group III Isolation was received at 2:40 p.m. on March 5, 1988,
because of an indicated reactor water cleanup (RWCU) system high-flow
condition.
The incorrect indication was the result of pump
cavitation due to the loss of net positive suction head to the pump.
Notification of each event was made to the NRC headquarters operation
central duty officer as required.
In addition, the SRI was notified when
the events occurred.
No violations or deviations were identified in this area.
11.
Radiological Protection Observations
The NRC inspectors verified that selected activities of the licensee's
radiological protection program were implemented in conformance with
facility policies, procedures, and regulatory requirements.
Radiation
work permits contained appropriate information to ensure that work could
be performed in a safe and controlled manner.
Radiation and/or
contaminated areas were properly posted and controlled.
Radiation
monitors were utilized to check for contamination.
During a routine plant tour on March 28, 1988, the RI observed an
individual inside a posted radiation area in the heater bay room with shoe
covers and gloves, which is normal attire for a tour and inspection of the
area.
However, in this case, Special Work Permit (SWP) 88-3-46, issued on
March 21, 1988, for the area, did not allow for tour and inspection, and
required additional protective clothing.
No other SWP was assigned to the
area.
The RI questioned the individual to ascertain whether permission
had been received from health physics personnel to be in the area with
only shoe covers and gloves.
The individual responded that no permission
had been received.
Failure to comply with Health Physics
Procedure (HPP) 9.1.1.4, "Special Work Permit," Revision 16, dated
April 15, 1987, and SWP 88-3-46, titled, "Bypass Valves," is an apparent
violation.
(298/8807-01)
The licensee took immediate corrective actions when notified of the
problem.
No other violations or deviations were identified in this area.
.- -
U
. _ _ _ _ _
.
.
.
.
....
11
12.
Security
The NRC inspectors observed security personnel perform their duties of
vehicle, personnel, and package search.
Vehicles were properly authorized
and escorted or controlled within the protected area (PA).
The PA barrier
had adequate illumination and the isolation zones were free of transient
material.
Compensatory measures were implemented in a timely manner when
equipment failed or when security doors were required to be open for work
being performed during the outage.
These observations verified that the
physical security plan was being implemented in accordance with the
requirements established in the CNS Operating License.
No violations or deviations were identified in this area.
13.
Exit Interview
An exit interview was conducted on April 15, 1988, with licensee
representatives (identified in paragraph 1).
During this interview, the
SRI reviewed the scope and findings of the inspection.
- . - _ .