ML20205P123

Insp Rept 50-298/86-07 on 860224-28.Deviation Noted: Engineers Not Documented as Trained by Applicable Procedures & Procedure Inadequate.Open Item Re Classification of Alternate Shutdown Sys Noted

ML20205P123
Person / Time
Site:	Cooper
Issue date:	05/12/1986
From:	Jaudon J, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205P110	List: ML20205P107 ML20205P119 ML20205P123
References
50-298-86-07, 50-298-86-7, NUDOCS 8605210166
Download: ML20205P123 (6)

See also: IR 05000298/1986007

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC 'nspection Report: 50-298/86-07 License: DPR-46

Docket: 50-298

Licensee: Nebraska Public Power District

P. O. Box 499

Columbus, Nebraska 68601

' Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS Site, Brownville, Nebraska

Inspection. Conducted: F ruary 24-28 1986

Inspector- A4/ / 8d ~

9. M elll, PNject Engineer, Project Date

S ect n A, Reactor Projects Branch

Approved: /1// [///l C/

P Jau n, Chief! Pr6je~ct Section A, Dat'e

R cto Projects Branch

Inspection Summary

I Inspection Conducted February 24-28, 1986 (Report 50-298/86-07)

Areas Inspected: Routine, announced inspection of the actions taken with regard

to previously identified inspection findings.

Results: Within the area inspected, one deviation was identified (inadequate

preventive action).

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' 8605210166 860516

PDR ADOCK 050002 8

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DETAILS

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1. Per' sons Contacted

NPPD

L. F. Bednar, Senior Staff Engineer

R. D. Brown, I&C Specialist

J. E. Dunn, Records Control Specialist

R. Fentiman, Purchasing Analyst

S. S. Freborg, Lead Mechanical Engineer

C. R. Goings, Regulatory Compliance Specialist

• G. R. Horn, Nuclear Operations Division Manager

J. Larson, QA Engineer (GO)

E. M. Mace, Plant Engineering Supervisor

• J. M. Meacham, Technical Manager

• J. V. Sayer, Technical Staff Manager

G. Smith, Senior QA Specialist

J. Smith, Technical Welding Specialist

G. G. Stuchal, Construction Manager

• P. V. Thomason, Senior Nuclear Advisor

V. L. Wolstenholm, QA Manager

• Denotes personnel attending exit meeting.

2. Actions on Previously Identified Inspection Findings

(Closed) Violation (298/8501-01): Failure to detect discrepancies during

vendor documentation reviews.

The licensee established that the documents in question did have incorrect

heat numbers on the heat trace and ultrasonic examination reports.

Licensee corrective actions included verifying traceability of corrected

subvendor documentation based upon the vendors unique " Mill Work Number"

identification system; replacing all incorrect heat trace and ultrasonic

examination reports with corrected reports; QA verification that trace-

ability methods and information was accurate; review of additional heat

trace and ultrasonic examination reports to verify that the problem was

limited to those items listed in the violation; and revision of the

construction management procedure, CMP 8-1-3, to require training of

contract personnel in this area.

The NRC inspector reviewed the above licensee actions and documentation

changes and determined that those immediate and preventive actions were

complete.

This item is closed.

(Closed) Unresolved Item (298/8512-01): Need to establish a formal method

of incorporating changes to the inservice test program.

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The NRC inspector verified that the licenaee revised design change

procedure EP 3.4 to require that changes be reviewed in light of their

impact on the inservice inspection and inservice test programs. The NRC

inspector noted that changes internal to the program were to be handled as

if they were procedure changes. At the time of the inspection, it was

also found that the formal methods of handling these latter type changes

was being reviewed by the licensee because of a licensee nonconfonaance

report. ,

This item is closed.

(Closed) Unresolved Item (298/8512-02): Preinservice inspection of a

questionable weld.

This item concerned whether or not coverage from both sides of the weld

was possible (as required by the ASME Code,Section XI, Article III - 4420

and4430). The weld in question (RL-A-15 (SW-1)) was ultrasonically

tested by the inservice inspection vendor, General Electric, and this was

documented in General Electric reports to the licensee, which the NRC

inspector reviewed. The weld in question is a 6 inch, branch type

connection to the reactor water clean up system, on a 90 elbow of the 20

inch residual heat removal supply piping. The NRC inspector verified the

ASME Code and the procedure requirements are for one side coverage, as a

mininum, when it is not possible to cover both sides.

This item is closed.

(Closed) Violation (298/8512-03): Failure to identify a linear

indication.

The licensee subsecuently repaired this weld. The NRC inspector reviewed

the post repair radiographs and determined that the repairs were

satisfactory. Licensee preventive action included the requirement that

all radiographs asiociated with the pipe replacement project were to be

reviewed by a CBI JNT-TC-1A level III inspector. The NRC inspector

reviewed and evaluated five radiograph packages in order to verify that

they were reviewed by the level III inspector. The NRC inspector verified

that a non-qualified CNS individual also reviewed all radiographs. The

individual did have some qualifications. As a result of the CNS review,

some additional rework did occur.

This item is closed.

(Closed)UnresolvedItem(298/8512-04): Concerns with the vendor's

radiographic program.

The specific welas identified in the NRC Report were 'reradiographed and,

with one exception, indications were verified to be film artifacts. The

exception, field weld N1A, was repaired. Audits by outside consultants,

i.e., Lambert and Hartford Steam Boiler Inspection & Insurance were

performed to upgrade and improve the CBI radiographic program. A review

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of later CBI radiographs by the NRC inspector found double film loading,

clearer interpreter recording and documentation of indications, and

greater film sensitivity.

This item is closed.

(Closed) Violation (298/8520-03): Failure to impose 10 CFR Part 21 in

procurement documents.

The licensee has established procedures which require that 10 CFR Part 21

be incorporated into purchase orders (P0s) for components identified as

" essential." The NRC inspector reviewed 15 current P0s and verified that

all " essential" component P0s had Part 21 incorporated. However, he noted

that some P0s associated with design change DC 86-21 (the alternate

shutdown modification) were not identified as essential and, therefore,

Part 21 was not incorporated into there P0s. The P0s in question included

instrumentation such as high pressure coolant injection turbine steam

inlet pressure (HPCI-PI-1111), torus level (PC-LI-110), residual heat

removal flow indication (RHR-FI-11338), reactor vessel level

instrumentation (NBI-LI-191B), and level instrument (NBI-LI-1858). The

licensee stopped further processing of the aforementioned P0s until the

instruments are correctly classified as " essential" or " nonessential."

The NRC inspector reviewed the licensee's equipment classification

procedure, EP 3.13 " Equipment Classification." He noted that fire

protection equipment could be classified as " essential" or " nonessential"

because of ambiguous procedure wording.

This item is unresolved pending: (1) correct classification of the

identified instruments, and (2) review and revision of procedure EP 3.13

to rid it of ambiguities in the area of fire protection equipment

(298/8607-01).

The preventive action designed to be taken by the licensee in this area

was to increase training of engineering personnel involved with

procurement of safety-related equipment. The training records were

reviewed by the NRC inspector, and it was noted that a new employee and

some senior general office (corporate level) employees were not trained on

this subject. This finding was similar to an observation that was

documented in NRC report (50-298/86-06). This was identified as a

deviation (298/8607-02).

This item is closed.

(Closed) Unresolved Item (298/8520-04): Apparent misuse of a heat

treatment test block.

The NRC inspector found that the licensee established that one of the

certified material test reports (CMTR) in question was in error. The

error was made by a subvendor's representative. A corrected CMTR has been

received. The NRC inspector verified that the corrected CMTR was in the

Purchase Order (PO) files.

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This item is closed.

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.- (Closed) Open Item (298/8204-04): Revision of procedures on establishing

quality classifications.

Licensee Administrative Procedure No.1.11 was replaced by new

procedures AP 1.4, 1.5, 1.7, and 1.8. Additionally, procedure EP 3.13

was issued. This procedure is more specific in the classifing components

than was procedure QAI-9 and CNS Instruction Letter No. 75-1, which

classified only systems. Essential and equipment ' qualification classifica-

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tions are defined in the Itcensee's procedure as requiring 10 CFR Part 21,

10 CFR Part 50, Appendix B and ANSI N45.2 on P0s. The licensee's procedure

identifies essential-commerical grade as requiring Appendi_x B and N45.2.

All essential, equipment qualification and essential-commerical grade

procurement are required by procedure to be given receipt inspection.

This item is closed.

(Closed) Open Item (298/8309-03): Completion of component classification.

This item is similar to the unresolved item opened in this report, and is

addressed with that unresolved item.

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" (Closed) Open Item (298/8520-01): Review of design change: records.

- The NRC inspector found that the design change file (DC 85-41) was

3; completed and reviewed by the licensee. He found that the 10 CFR 50.59

review was, completed July 11, 1985, by the licensee and that General

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Electric had performed the same analysis on May 8,1985. The completion

report was dated August 16, 1985.

This item is closed.

(Closed)OpenItem(298/8520.02): A change to the inservice inspection

program to include replacement jet pump beams.

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Revisian 3 of the inservice inspection program addresses in part 7.3, the

augmented inservice. inspection. The NRC inspector found that the replace-

ment jet pump besns are to be irspected at a frequency of once during the

second 10-year interval . At the time of this inspection, it was noted

that the inservice inspection program did not list or otherwise identify

each individual jet pump beam reouired to be inspected, nor was the

., ultrasonic test procedure listed that would be used to perform the

inspection of those components.

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This item is closed.

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3. Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether or not the items are acceptable, violations, or

deviations. The following unresolved item was discussed in this report:

Paragraph Item Subject

2 8607-01 Classification of the

Alternate Shutdown System

4. Exit Meeting

The NRC inspector conducted an exit meeting on February 28, 1986, with the

licensee personnel denoted in paragraph 1. The NRC senior resident

inspector also attended. At this meeting, the scope and findings of the

inspection were summarized.

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