ML20154L090

Forwards Emergency Operating Procedure Insp Rept 50-298/88-200 on 880627-0715.Weaknesses Involving Adequacy of Containment Venting Procedures,Ability to Reenter Reactor Bldg to Perform Procedures During Accident Identified

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: IR 05000298/1988200 ML20154L090
References
NUDOCS 8809260094
Download: ML20154L090 (6)

See also: IR 05000298/1988200

Text

F

___ _ _ _ _ _ _ _ _ _ _ .

_ _ _ - _ _ - - _ _ _ - - _ - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

v caug ",

• / O

~,, UNITED STATES

'[

$,. g NUCLE AR REGULATORY COMMISSION

5 cAswiNotoN. o. c. 20sss

.

5,*****e' September 21, 1988

_

-

Docket No. 50-298 -

Mr. George A. Trevers. Division Manager -

Nuclear Support

Nebraska Public Power District ,

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

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 l

plant using existing equipment, instrumentation, and controls; and that the

'

plant staff could correctly perfortn the procedures. ,

The inspection included: review of the E0Ps, the documents used to develop

the E0Ps, the E0P validation and verification program, the E0P training

i

program, and the E0P ongeing evaluation program; walkdown of the E0Ps in L

the control room and plut; observation of operator perfomance of table-top ,

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 I

i observations by the NRC inspectors. The inspection findings are documented -

in the enclosed inspection report. j

The team determined that the E0Ps meet the above criteria. However, the team  !

identified a number of weaknesses relating;to the development and implementation  !

of the E0Ps. These weaknesses involved the need for further evaluation of con-

tainment vs.nting capabilities, including equipn,ent limitations and coordination i

of releases with emergency plan activities; the need for further evaluation of t

limitations on personnel access to the reactor building under accident condi- l

tions; and the fact that the E0Ps were cumbersome to use because of the numerous  !

concurrent actions that the operators must perform and track during zertain  !

events. Ynese and other specific deficiencies are discussed in the enclosed

report. i

i

,

L

l

l

,

8809260094 880921

PDR ADOCK 050CO298

0l$ l  !

F PDC ( l

l

. -- _- - . . .- - - _ _ - _

_ - . _ _ - - _ . - - - _ _ - . - - - _ -

"

,, M r c,: George A. Trevors -2- September 21, 1988

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

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

I

.

'

,

1

!

.

!

.

l .

I

l

l

l

_ _ - _ .

. .

. Ad$GeorgeA.Trevors -3- September 21, 1988

-

cc w/ enclosures:

Mr. G. D. Watson, General Counsel

Nebraska Public Power District -

P. O. Box 499 ~

Columbus, Nebraska 68601 7_ .

Mr. Guy R. Horn, Division

Manager of NJclear Operations

Cooper Nuclear Station

P. O. Box 98

Brownville, Nebraska 68321 ,

Dennis Grams, Director

Nebraska Department of Environmental '

Control

P. O. Box 89822

Lincoln, Nebraska 68509-8922

Mr. Larry Bohlken Chairman

-

Nemaha County Board of Conmissioners

Nemaha County Courthouse I

1824 N Street .

,

Auburn, Nebraska 68305  !

l

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

'

Mr. Harold Borchart, Director

Division of Radiological Health

Department of Health ~

301' Centennial Mall, South ~

P. O. Box 95007 i

Lincoln, Nebraska 68509-5007 i

.

l  !

i

G

e

!

m

, -

- - - - - - - - - - - - - - - - - - _ _ _ _ _ . _

,

,

Mr. George A. Trevors -4- September 21, 1988

.

Distribut'on

F m,. sp.. s

'DRIS R/F

RSIB R/F

POR

LPDR

BGrimes NRR

CHaughney, NRR

Elmbro, NRR

JKonklin, NRR

LNorrholm, NRR

JCuninins, NRR

Inspection Team

TMurley, NRR

JSniezek, NRR

JCalvo. NRR

WLong, NRR

PNoonan, NRR

JJaudon, RIV

GConstable, RIV

Regional Administrators

Regional Division Directors

ACRS (3)

OGC (3)

15 Distribution

!

!

l

i

I

!

!

!

D PIM /Nb ADR4 [3g,

JCalvo LRubenstein

09/al/88 l

n n

-cd,09/1I/88 /  !

0FC :RSIB:DRI5:hRR :RSIT ORIS:NRR:51R RIS:hRR: Dip 1 R R:(A)AD:0R5P35:(A) g f p t  !

.....:.. ......:.. j ..... .

.f . . . . : ., . .. ...: ..... ...:. ..,......:........ l

NAME :J /vj :L y o lm inel< )B .e :M ilio :G lehan  :

.....:.... .........:....c....... ...........p...........:.. .. .....:............:........ [

!DATE :09/a1/88 :09/ T/88 9/(3 /88 :09//c/88 :09/ /8 :09/p//88  :

'

l %a t//6 *g l

l aq

OP/

l

/I  !

'

- - . . - - _ - _ - _ - _ _ _ _ _ - - _ _ . _ _ _ _ _ -

l

.. ..

I

,. . .

l

l

~

, EXECUTIVE SUMMARY

INSPECTION REPORT 50-298/88-200

COOPER NUCLEAR STATI0h 1

~._

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 '

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

- reviewed the documents used to develop the E0Ps

- reviewed the E0P validation and verification program '

-

reviewed the E0P training program

- walked down the E0Ps in the control room and the plant

- observed operator performance of tabletop E0P exercise scenarios

- performed a human factors evaluation of the E0Ps.

SUMMARY OF SIGNIFICANT FINDINGS

J The E0Ps were technically accurate and, with a few exceptions, had been developed

in accordance with the owners' group emergency procedure guidelines. Even though

the E0P format was in accordance with the guideline reconinendations, tracking

J

and placekeeping (finding and keeping the correct place in the E0Ps) could be '

major problems during their performance.

! 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- l

a because the licensee, in developing the E0Ps, deviated in several instances from

! the hRC-approved Boiling Water Peactor Owners' Group (BWROG) emergency procedure

j 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, ,

t The team determined that plant equipment, instrumentation, and contrgls were

adequate for carrying out the E0Ps. However, tools required to perfom certain

I actions in the E0Ps were not staged as dedicated tools and were not always in .

]

the most convenient location for performing the required actions.

-

1

i

,

. - . _ _ _ _ . _ _ . _ _ _ _ _ _ , ,_ -___._ . _ -.__,_ __ __ _ _ _ . _ _ _ _ . _ _ _ _ _ - - _ . _ _ . _,~_ -

__ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

.," , ,

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.

.

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.

,

~

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.

.

e