ML20154L090
| ML20154L090 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/21/1988 |
| From: | Holahan G Office of Nuclear Reactor Regulation |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20154L094 | List: |
| References | |
| NUDOCS 8809260094 | |
| Download: ML20154L090 (6) | |
See also: IR 05000298/1988200
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UNITED STATES
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NUCLE AR REGULATORY COMMISSION
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September 21, 1988
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Docket No. 50-298
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Mr. George A. Trevers. Division Manager -
Nuclear Support
Nebraska Public Power District
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P.O. Box 499
Columbus, NE 68601
Dear Mr. Trevors:
SUBJECT:
COOPEREMERGENCYOPERATINGPROCEDUREINSPECTION(50-298/88-200)
This letter forwards the report and the executive sumary of the emergency
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operating procedures (EOPs) inspection conducted by Mr. J. E. Cumins of this
office and NRC consultants froci June 27 through July 15, 1988.
The activities
involved are authorized by NRC Operating License No. DPR-46 for the Cooper
Nuclear Station. The team discussed the findings with Mr. J. M. Meacham and
other members of your staff at the conclusion of the inspection.
The purpose of the inspection was to verify that the E0Ps were technically
accurate; that their specific actions could be physically carried out in the
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plant using existing equipment, instrumentation, and controls; and that the
plant staff could correctly perfortn the procedures.
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The inspection included:
review of the E0Ps, the documents used to develop
the E0Ps, the E0P validation and verification program, the E0P training
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program, and the E0P ongeing evaluation program; walkdown of the E0Ps in
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the control room and plut; observation of operator perfomance of table-top
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E0P exercise scenarios; and performance of a human factors avaluation of the
E0Ps. The inspection consisted of selective examination of procedures and
representative records, interviews with personnel, plant walkdowns, and
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observations by the NRC inspectors. The inspection findings are documented
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in the enclosed inspection report.
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The team determined that the E0Ps meet the above criteria. However, the team
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identified a number of weaknesses relating;to the development and implementation
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of the E0Ps. These weaknesses involved the need for further evaluation of con-
tainment vs.nting capabilities, including equipn,ent limitations and coordination
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of releases with emergency plan activities; the need for further evaluation of
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limitations on personnel access to the reactor building under accident condi-
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tions; and the fact that the E0Ps were cumbersome to use because of the numerous
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concurrent actions that the operators must perform and track during zertain
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events. Ynese and other specific deficiencies are discussed in the enclosed
report.
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8809260094 880921
ADOCK 050CO298
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M r c,: George A. Trevors
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September 21, 1988
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No response to this letter is required, howev r, you should direct your
attention to the three unresolved items identified in paragraph 3.1.1 of the
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ericioseo inspection report to ensure that you have provided adequate justifi-
cation for technical differences between your E0Ps and the owners' group
emergency procedures genert. tion guidelines.
In addition, the weaknenes
discussed above involving the adequacy of your containment venting precedures,
the ability to reenter the reactor building to perform the E0Ps durirg an
accident, and the cumbersome nature of your E0Ps, are areas which will require
your attention.
In accordance with 10 CFR 2.790(a), a copy of this letter and enclosures will
be placed in the NRC Public Document Room.
Should you have any questions concerning this inspection, please contact me or
Mr. J. Cumins (301-492-0957) of this office.
Sincerely,
N
Gary M
laha , Acting Director
Division of Reactor Projects !!!,
IV, Y and Special Projects
Office of Nuclear Reactor Regulation
Enclosures:
1.
Executive Sumary
2.
Inspection Report 50-298/88-200
cc w/ enclosures:
See next page
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Ad$GeorgeA.Trevors
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September 21, 1988
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cc w/ enclosures:
Mr. G. D. Watson, General Counsel
Nebraska Public Power District
P. O. Box 499
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Columbus, Nebraska 68601
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Mr. Guy R. Horn, Division
Manager of NJclear Operations
Cooper Nuclear Station
P. O. Box 98
Brownville, Nebraska 68321
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Dennis Grams, Director
Nebraska Department of Environmental
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Control
P. O. Box 89822
Lincoln, Nebraska 68509-8922
Mr. Larry Bohlken Chairman
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Nemaha County Board of Conmissioners
Nemaha County Courthouse
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1824 N Street
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Auburn, Nebraska 68305
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Senior Resident Inspector
U.S. Nuclear Regulatory Commission
P. O. Box 218
Brownville, Nebraska 68321
Regional Ad.ninistrator, Region IV
U.S. Nucletr Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
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Mr. Harold Borchart, Director
Division of Radiological Health
Department of Health
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301' Centennial Mall, South
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P. O. Box 95007
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Lincoln, Nebraska 68509-5007
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Mr. George A. Trevors
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September 21, 1988
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EXECUTIVE SUMMARY
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INSPECTION REPORT 50-298/88-200
COOPER NUCLEAR STATI0h
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From June 27 through July 15, 1988, an NRC team consisting of six inspectors
performed an inspection of the emergency operating procedures (EOPs) at the-
Cooper huclear Station (CNS) in order to verify:
that the CNS E0Ps were
technically accurate; that their specified actions could be physically carried
out in the plant using existing equipment, instrumentation, and controls; and
that the plant staff could correctly perform the procedures.
The inspection
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was conducted in accordance with the guidelines in Temporary Instruction
2515/92. "Emergency Operating Procedures Team Inspections."
SCOPE OF INSPECTION
During the inspection the team:
reviewed the E0Ps
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reviewed the documents used to develop the E0Ps
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reviewed the E0P validation and verification program
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reviewed the E0P training program
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walked down the E0Ps in the control room and the plant
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observed operator performance of tabletop E0P exercise scenarios
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performed a human factors evaluation of the E0Ps.
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SUMMARY OF SIGNIFICANT FINDINGS
The E0Ps were technically accurate and, with a few exceptions, had been developed
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in accordance with the owners' group emergency procedure guidelines.
Even though
the E0P format was in accordance with the guideline reconinendations, tracking
and placekeeping (finding and keeping the correct place in the E0Ps) could be
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major problems during their performance.
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The licensee did not submit the plant-specific technical guidelines as part
of'the procedures generation package to the NRC for review as required by
NUREG-0737, Supplement 1. Item 7.2.b.
This omission appeared significant-
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because the licensee, in developing the E0Ps, deviated in several instances from
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the hRC-approved Boiling Water Peactor Owners' Group (BWROG) emergency procedure
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guidelines (EPGs) without providing adequate documented justification.
The licensee's method of detemining the entry-luel temperature for drywell
temperature control (DW/T) for E0P-2 did not strictly adhere to the method
recontrended in the BWROG EPGs. The team believed that the method used by
the licensee for determining the entry-level teroperature could have resulted
in a higher than warranted entry condition temperature,
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The team determined that plant equipment, instrumentation, and contrgls were
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adequate for carrying out the E0Ps. However, tools required to perfom certain
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actions in the E0Ps were not staged as dedicated tools and were not always in
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the most convenient location for performing the required actions.
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The effects of accident radiation levels in the reactor building on the
operators' ability to perform local operations had not been analyzed.
NUREG-0737, item II.B.2 required the evaluation of personnel access to the
reactor building during emergencies.
In its respnnse, prepared b'efore the
current symptom-based E0Ps were issued, the licensee cor:cluded that Tadiation
levels would preclude reactor building entry, but that the previous event-
based E0Ps and plant design would support accident mitigation without reactor
building reentry.
The symptom-based E0Ps required entry to compensate for.
equipment failures but the licensee had not reevaluated its former position
and analysis.
The procedures for containment venting provided only minimal venting capability
because the licensee had not completed all the engineering evaluation it
believed necessary to support venting through large diameter flow paths.
Further, the venting procedure and corrpleted evaluations did not address
several significant considerations such as vent equipment design limitations,
and coordination of radioactive releases with emergency plan activities.
Licensee evaluation of containment venting methods was continuing at the end
of this inspection.
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The plant was clean and orderly, and habitability conditions, such as nonnal
lighting and ample work space, were generally good. However, it did not appear
that the emergency lighting in the control room would be adequate for reading
the E0Ps.
With the exception of training in the areas of tracking and placekeeping, the
operators appeared to be well trained and capable of performing the E0Ps.
CONCLUSION
It appeared to the team that the E0Ps could be cumbersome to use because of
the numerous concurrent actions that mest be performed at once and the large
volurie of material that has to be read.
Placekeeping would be difficult in a
fast-moving event. However, it also appeared that the E0Ps, when used by
trained knowledgeable operators, would serve to mitigate the consequences of
an accident.
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The team was concerned that the cumbersome E0Ps could encourage the operators
to take actions in response to plant parameters from memory, before they could
find and follow the steps in the E0Ps.
In this case, the operaters could be
making conclusions as to the required actions without benefit of the accident
mitigation strategy and supplemental information (i.e., cautions, notes, and
special operator instructions) contained in the E0Ps that were developed on the
basis of the operation of the entire plant and its interrelated systems.
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