ML20206R511
| ML20206R511 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/29/1998 |
| From: | Marschall C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9901190355 | |
| Download: ML20206R511 (29) | |
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lY j Ik UNITED STATES l 4jf, y,
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'611 RYAN PLAZA DRIVE. SUITE 400 ARLINGTON TEXAS 76011 8064 l
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G. R. Hom, Senior Vice President L
_ of Energy Supply L
Nebraska Public Power District l
- 141415th Street Columbus, Nebraska 68601 L
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SUBJECT:
INSPECTION PLANNING REVIEW (IPR) - COOPER NUCLEAR STATION
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Dear Mr. Horn:
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' On December 2,1998, the NRC staff completed a unique inspection Planning Review (IPR) of j
Cooper Nuclear Station. The staff normally conducts Semiannual Plant Performance Reviews
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- for all operating nuclear power plants to develop an integrated understanding of safety performance and adjust inspection resources. However, due to the suspension of the l;
, Systematic Assessment of Licensee Performance process, we implemented an abbreviated i
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= Inspection Planning Review for plant issues and to develop inspection plans. The IPR for E,
Cooper Nuclear Station involved the participation of both Reactor Projects and Safety divisions -
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.in evaluating inspection results and safety performance trends for the period of April 23 to
. October 28,1998..This lPR provided NRC management with a current summary of licensee l
performance trends since the last Plant Performance Review.-
I
' Based on the results of this review, inspection resources have been prioritized and scheduled as listed in the inspection plan. We will continue our assessment of your implementation of the Strategy for Achieving Engineering Excellence. We plan to conduct two focus inspections in L the next 8 months to support this assessment. contains an historical listing of plant issues, referred to'as the Plant issues
. Matrix (PIM), that was considered during this IPR process to arrive at an integrated view of f
P licensee performance trends. The PIM includes only items from inspection reports and other
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- docketed correspondence between the NRC and the Nebraska Public Power District. The IPR I
L may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the, p
..last NRC inspection report was issued, but had not yet received full review and consideration.
L is a general description of the PIM table labels. This material will be placed in the NRC Public Document Room.
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This letter also advises you of our planned inspection effort resulting from the Cooper Nuclear Station IPR. _ lt is provided to minimize the resource impact on your staff and to allow for-
- scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Enclosure 3 details our inspection plan for Cooper Nuclear Station over the next 8 months. The rationale or basis for each inspection outside the core inspection program is i'
1provided so that you are aware of the reason for emphasis in these program areas. Resident y
e 9901190355 991229
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'4 Nebraska Public Power District Inspections are not listed because of their ongoing and continuous nature. We will inform you of any changes to the inspection plan.
If you have any questions, please contact me at (817) 860-8185.
Sincerely,
(,6 Charles S. Marschall, Chief Project Branch C Division of Reactor Projects Docket No. 50-298 License No. DPR-46
Enclosures:
- 1. Plant issues Matrix
- 2. General Description of PIM Table Labels
- 3. Inspection Plan cc w/ enclosures:
John R. McPhail, General Counsel Nebraska Public Power District i
P.O. Box 499 Columbus, Nebraska 68602-0499 J. H. Swaites, Vice President of Nuclear Energy
- Nebraska Public Power District P.O. Box 98 -
Brownville,' Nebraska 68321
- B. L Houston, Nuclear Licensing and Safety Manager Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 Dr. William D. Leech MidAmerican Energy 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303-0657 Mr. Ron Stoddard Lincoln Electric System 1040 O Street 4
1
- i, Nebraska Public Power District-P.O. Box 80869 Lincoln, Nebraska 68501-0869 Randolph Wood, Director.
l Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street
~ Auburn, Nebraska 68305 1
Cheryl Rogers, LLRW Program Manager Environmental Protection Section
. Nebraska Dopartment of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 R. A. Kucera, Department Director of intergovemmental Cooperation Department of Natural Resources.
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P.O. Box 176 Jefferson C_ity, Missouri 65102 Jerry Uhlmann, Director State Emergency Management Agency
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6 Nebraska Public Power District.,,
E-Mail report to T. Frye (TJF)
E-mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
E-Mail report to Richard Correia (RPC)
E-Mail report to Frank Talbot (FXT)
- bec to DCD (IE01) bec distrib. by RIV:
Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/C)
MIS System Branch Chief (DRP/TSS)
RIV File Project Engineer (DRP/C)
Carol Gordon The Chairman (MS: 16-G-15)
Record.s Center, INPO Deputy Regional Administrator C. A. Hackney Commissioner Dieus B. Henderson, PAO Commissioner Diaz B. Murray, DRS/PSB Commissioner McGaffigan SRis at all RIV sites Commissioner Merrifield W. D. Travers, EDO (MS: 17-G-21)
Associate Dir. for Projects, NRR Associate Dir. for Insp., and Tech. Assmt, NRR SALP Program Manager, NRR/lLPB (2 copies)
J. Hannon, NRR Project Director (MS: 13-H-3)
D. Wigginton, NRR Project Manager (MS: 13-H-3) l 100021 DOCUMENT NAME: G:\\DRPDIRJPR\\CNS To receive copy of document. Indicate in pox: "C" = Copy wthout enclosures "E" = Copy with enclosures "N* = No copy RIV:C:DRP/C D:DRS[ l DD:DRP P D:DRP l)f l
CSMarschall;df*
ATHd%Il KEBroefman TPGwynn (f V 12/16/98 (DPL) 12/$98 if /98 12/ h98
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- previously concurred OFFICIAL RECORD COPY i
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Nebraska Public Power District ' DEC 2 91998 E-Mail report to T. Frye (TJF)
E-mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
' E-Mail report to Richard Correia (RPC)
E-Mail report to Frank Talbot (FXT) bec to DCD (IE01) bec distrib. by RIV:
Regional Administrator Resident inspector DRP Director DRS PSB Branch Chief (DRP/C)
Branch Chief (DRP/TSS).
MIS System RIV File Project Engineer (DRP/C)
Carol Gordon i
The Chairman (MS: _16-G-15)
Records Center, INPO Deputy Regional Administrator C. A. Hackney
' Commissioner Dicus -
B. Henderson, PAO Commissioner Diaz B. Murray, DRS/PSB
- Commissioner McGaffigan.
SRis at all RIV sites
- Commissioner Merrifield 1
- W. D. Travers, EDO (MS: 17-G-21)
Associate Dir, for Projects, NRR Associate Dir for insp., and Tech. Assmt, NRR SALP Program Manager, NRR/lLPB (2 copies)
J. Hannon, NRR Project Director (MS: 13-H-3)
D. Wigginton, NRR Project Manager (MS: 13-H-3) 1
' DOCUMENT NAME: G:\\DRPDIR PR\\CNS To receive copy of document, Indicate in x: "C" = Copy without enclosures "E" = Copy with encipeures "N" = No copy RIV:C:DRP/C D:DRSL DD:DRP /
D:DRP J
CSMarschall;df*
ATHd@ ell KEBrpdiman TPGwynn d
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12/16/98 (DPL) 12f)h98 if /98 12/ $98
- previously concurred
- OFFICIAL RECORD COPY i
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e PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 9/16/98 NEG IR 98-06 NRC OPS 1A 1C Inspectors identified that operations issued a nonconservative standing order, which hsted the incorrect temperature (92 degrees versus 91 degrees) at which the reactor equipment cooling system would become inoperable. The licensee issued a Problem ident:fcation Report to review the effects on operability.
9/7/98 POS 1R 98-06 NRC OPS 1C 18 2A The development and review of the specialinstructions for securing Reactor Feedwater Pump A for troubleshooting the speed control system was very thorough. The instructions were reviewed by the operators, performed on the simulator, and approved by the Station Operations Review Committee. OceMtors pertormed the special instructions in a we!! contro!!ed manner with appropriate oversignt by the senior licensed reactor operators.
8/22/98 POS IR 98-05 NRC OPS 4C 5A SC Plant management was generally successful in demanding support and improved standards from the licensee organization. Although performance has improved over time, continued management attention to improving problem identification and resolution is warranted.
8/22/98 POS
!R 98-05 NRC OPS 1A SA Operators maintained good control room formality, routinely demonstrated self-checking and peer-checking, used two-part communication in response to annunciators and other plant parameters, and routinely used three-part communication while providing instructions to other operators and maintenance craft. In addition, vigilance and high standards prevented a number of operational errors, especially during implementation of improved Technical Specifications.
7/23/98 NEG IR 98-05 NRC OPS 1A 5A 4B The licensee did not address all relevant aspects of the safety function of a degraded service water valve until questioned by inspectors. Subsequent testing demonstrated that the valve remained operable despite the degraded condition. This demonstrated a lack of questioning attitude and a failure to understand operability requirements. Although no violations of NRC requirements occurred, significant inspector involvement was required to ensure that the licensee addressed all consequences of the valve failure.
7/12/98 WEAK IR 98-05 NRC OPS SC The licensee's failure to perform a valid common cause evaluation is an example where the IR 97-08 licensee's implemented corrective actions did not address the concem. After many months and IR 96-26 inspector involvement, the licensee re-performed the common cause evaluation, and the evaluation demonstrated that there was no common mode failure; therefore, the safety consequences were minimal.
7/11/98 NEG IR 98-04 NRC OPS SB SC Inspectors determined that corrective action for enforcement of past inadequate corrective action was not formal and that the license performed narrow evaluations of very recent past corrective actions. These selections of past corrective actions were not cased on programmatic or systematic criteria. In response the licensee initiated a sampling process which included a broader scope of past corrective actions issues and involved systematic evaluation of the findings of those assessments.
October 28,1998 1
COOPER NUCLEAR PLANT
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PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 7/11/98 POS IR 98-04 NRC OPS 1A Operators demonstrated generally strong standards, responded promptly to challenges such as pipe leakage and serve weather, and successfully demanded engineenng support for these challenges. The operators also routinely initiated a large number of insightful and self-critical problem identification reports both within and outside of the operations area, demonstrating a strong focus on safety.
7/11/98 WEAK 1R 98-04 NRC OPS 5B SC Inspectors identified that the licensee closed commitment action items without obtaining the associated performance improvements. As a result, the commitment tracking system d!d not effectively monitor corrective actions for identified deficiencies, and inspectors could not determine whether the licensee had completed actions to address the deficiencies identified in NRC Inspection Reports 50-298/97007 and 97012, 7/11/98 POS 1R 98-04 NRC OPS SA SB SC Plant management continued to demonstrate intrusive involvement in plant activities and successfully demanded resolution of specific safety issues as well as increased site performance on issues both within and outside of the plant organization. Examples included prompt evaluation of incorrect check valve installation and resolution of complex torus level limit concem.
6/10/98 WEAK IR 98-05 NRC OPS 3A SB SC As a result of untimely implementation of corrective actions, the licensee failed to prevent a fifth IR 97-12 example of improperly restoring a radiation monitor to service. After inspector involvement, the licensee implemented acceptable interim corrective actions and expedited appropriate permanent corrective actions.
5/30/98 STR 1R 98-03 NRC OPS 1C 2B Plant management continued to demonstrate intrusive involvement in plant activities tesulting in examples of improved safety performance. Examples included identification and correction of weak setpoint change implementation and correction of inadequate service water system flow balancing. Strong expectations for improved performance continued. Plant staN addressed some specific issues in a more timely and thorough manner, 5/30/98 POS IR 98-03 NRC OPS 1A 3A 3B The operations control room staff performance continued to be generally good, with many examples of outstanding communications and command and control. However, in a few cases under a high routine work load, control room communications and command and control were much less formal. Management demonstrated strong involvement and crew management i
demonstrated a safety focused, proactive response to off-normal plant and offsite condetions.
Shift supervisor standards and demands for plant support of emergent control room issues were generally excellent. However, shift supervisors frequently did not provide strong leadership while running the plan-of-the-day meetings.
l October 28,1998 2
COOPER NUCLE.AR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 5/15/98 VIO IR 98-02 NRC OPS SB SC A violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action was cited with two SL IV LER 96-examples.
013 A violation for the failure to require verification of Technical Specification operability requirements before increasing operating modes was not properly corrected. The licensee did not identify all operability verification requirements during the corrective action process.
In response to an NRC violation for improper incorporation of three design modifications in emergency operating procedures, the licensee identified that modifications before 1991 were not required to be reviewed for effects on emergency operating procedures. However, the licensee's corrective action failed to evaluate the extent of condition of this concem to determine if similar problems occurred with other modifications before 1991.
5/15/98 POS IR 98-02 NRC OPS 1A 1B Plant management demonstrated intrusive involvement in successfully demanding focus on and resolution of priority issues, allocating and directing engineering resources to reduce operator work arounds, and understand plant anomalies. Plant management raised standards for staff performance in response to several specific issues during this inspection period, in the areas of work control, operations, Maintenance, and engineering.
5/4/98 POS 1R 98-03 NRC OPS 1A The operability evaluations performed during this inspection period were generally good, with some exceptions. This represented an improvement over past inspection periods (Section 02.2).
4/6/98 POS IR 98-02 LIC OPS 1C 3B When a crew did not rneet operations and training management expectations during dynamic simulator training, remediation was initiated. Inspectors observed that the remediation process was self-critical and was based on many specific observations of crew behaviors during simulator training. Operations management demonstrated strong self-critical standards and continued close involvement with crew performance over the training cycle.
4/1/98 NEG 1R 98-01 NRC OPS 1C Prior to the outage, inspectors identified that contingencies associated with an inadvertent mode change due to high decay heat had not been systematically evaluated. The licensee nad not performed a review to assess vulnerabilities and identify potential contingency actions.
Contingency plans were developed and distributed before entry into the shutdown condition.
Two minor weaknesses were observed in implementing these contingencies during the outage.
October 28,1998 3
COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMFLATE ITEM CODES 4/1/98 POS tR 98-01 NRC OPS 1A Operations, turnovers, watch standing, and control of plant conditions continued to improve.
Shift tumovers of complex plant status were comprehensive, effectively managed, and of minimal disruption to crew function. During the shutdown for the midcycle outage, operations demonstrated strong POS control of plant conditions. Crew management controlled the schedule to ensure crew performance was not challenged. Crew communications, command, and control were generally excellent. Inspectors observed higher training standards and strong management involvement in the training process.
4/1/98 STR 1R 98-01 NRC OPS SA 1C Shift technical engineers demonstrated several examples of strong safety performance. They.
identified that the off-gas building, which housed seismically qualified standby gas system support equipment, was not seismica!!y qualified. They also identified that an eye bolt retaining the drywell equipment hatch had failed in a manner indicating a need to inspect a!! hatch eye bofts. Shift Technica Engineers, with suppo-t of shift supervisors, have continued to successfully demand timely resolution of specific plant safety issues and higher performance from engineering and Maintenance. This was due in part to strong support by operations crews and operations and plant management.
3/13/98 STR LR 98-02 NRC OPS 1A During a reactor startup and power operations, control room crews operations evidenced strong safety focus. Inspectors observed multiple examples of strong command and control, awareness and assessment of plant conditions, questioning attitude. Technical Specification adherence, configuration control, and procedural adherence. Management involvement was strong. Minor weaknesses were promptly corrected.
2/23/98 POS IR97-11 NRC OPS SA 4A Operations demonstrated a strong questioning attitude for plant support for an unexpected door condition. They ultimately identified an inadequate 1994 modification and reduction of design margin for the control room ventilation fans. This indicated a strong safety focus across turnovers by the operations crews, and an insistence that problems be fully addressed.
2/23/98 VIO IR 97-11 NRC OPS 1A 1C SA The inspectors identified that the control room crew did not recognize and comply with Technical SLIV Specification action statement requirements regarding reactor sample line isolation requirements. The control room crew did not have a clear understanding of all steps necessary to implement the Action Statement. The licensee showed some weakness in the implementation of a 4-hour sample requirement. The licensee did not distinguish between
" sample time" and
- analyzed time" and consequently used the 25 percent surveillance extension twice consecutively.
1/12/98 WEAK IR 97-10 NRC OPS SB Three examples where operability assessments did not address all the relevant aspects of untimely 4160V preventative Maintenance. No operability assessment conclusion was determined to be incorrect.
October 28,1998 4
COOPER NUCLEAR PLANT
t PLANTISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 1/12/98 STR 1R 97-10 NRC OPS 1A Operations Maintained proper control room conduct in which good self-checking techniques, communications, and briefing techniques were used. The inspectors also observed that operations management exercised a strong presence and involvement in control room and plant activities.
1/12/98 WEAK 1R 97-10 NRC OPS 1C The inspectors identified procedure weaknesses and ambiguities when the plant was placed in an afternate configuration. The procedures did not account for the attemate configuration and the licensee fai!ed to identify contingency actions to compensate for these procedure weaknesses and ambiguities.
12/19/97 POS IR 97-09 NRC OPS 1A 3A SC The control room personnel demonstrated strong conservative decision making and procedural adherence during a Technical Specification 24-hour shutdown. The licensee coordinated timely and conservative corrective action for both procedures and equipment problems (Section 04.1).
12/19/97 STR 1R 97-09 NRC OPS SA 1A Plant management and operations staff demonstrated safety-focused leadership, identified and expanded several safety issues, and successfully demanded licensee staff attention to several emergent issues. This was considered an improvement over past performance. Inspectors also noted more examples of problems identified by operations as well as expansion of prob!em statements to address programmatic issues (Section 01.1).
12/19/97 NEG IR 97-09 NRC OPS SA 58 SC The inspectors found that the licensee inappropriately 6eturned the 250 Vdc Battery Charger 1 A in service after it had tripped, without determining the cause of the trip or evaluating the effects that a potential fault could have had on the system. Additionally, the licensee did not initially consider the option of placing the attemate charger in service (Section O4.4).
12/19/97 STR 1R 97-09 NRC OPS 1A Operations shift turnovers were safety focused and continued to improve due to operations initiative and a self-critical approach. Routine control of plant equipment appeared appropriate (Section O1.2).
12/19/97 POS 1R 97-09 NRC OPS 1A Inspectors observed an example of good safety focus, questioning attitude, and prioritization of engineering support by the operations staff to obtain evaluation of cumulative effects of slow control rod drive times on rod scram times (Section O4.2).
12/10/97 POS IR 97-17 NRC OPS 1C The licensed operator requalification program had improved implementation of a systems approach to training since the last inspection in this area (50298/96-16). Examination security implementation was a noted strength (Section 05.4).
10/20/97 NEG IR 97-08 NRC OPS SC Inspector attempts to review 26 open items in a 2-week period, found that 1 item had been prepared satisfactorily for closure. The remaining items had not been assigned to staff for resolution or had not been completed. Quality assurance had noted the untimely resolution of NRC open items and Quality Assurance items in an earlier audit and in a Significant Condition Adverse to Quality.
October 28,1998 5
COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 10/20/97 NEG IR 97-08 NRC OPS 1A inspectors identified that the core power / flow graph posted on the main control board, used as an operator aid, was taken from the prior (superseded) revision of a procedure. A quality assurance audit of operations, including operator aids, also found poor control of operator aids.
The audit did not review the operator aids used in the cuntrol room and, thus, was a missed opporturuty for quality assurance to identify the out-of-date power-to-flow graph 10/20/97 POS 1R 97-08 NRC OPS 1A Operations activities observed during this inspection period were genera!!y good 10/20/97 POS IR 97-08 NRC OPS 1A initiatives resulted in an improvement in control room command and control dur'ng the tumover process. The effort was initiated by a control room supervisor.
10/20/97 NEG IR 97-03 NRC OPS 5B The inspectors identified a weak operability evaluation in which the licensee did not address all of the functions of a failed valve 10/3/97 POS IR 97-12 NRC OPS SA Inspectors noted increased instances of problem identification, and determined these to be examples of some improvement in the licensee's implementation of the Problem Identification Report process 10/3/97 VIO IR 97-12 NRC OPS SA 2A Although discharges of hundreds of gallons of water to the Z-sump had been observed in SL !!!
February and April of 1997, the licensee failed to recognize, until July 1997, that volumes of EA 97 water in that sump greater than approximately 250 gallons would result in stsndby gas system 424 inoperability. Dispositioned by NRC letter of 12/1/97. Part of violation included above.
10/9/98 POS 1R 98-21 NRC MAINT 2A Foreign material exclusion area controls for the reactor building refueling floor were good.
2B Water clarity of the fuel pool during the installation of the General Electric reactor inspection system (automated ultrasonic examination of the reactor pressure vessel circumferential and longitudinal seam welds) was exce!!ent.
10/9/98 POS IR 98-21 NRC MAINT 3A Management oversight for the installation of the General Electric reactor inspection system was good, in that effective guidance and communications were noted.
10/9/98 POS IR 98-21 NRC MAINT 2B The third 10-year laterval inservice inspection program was well defined and generally implemented the requirements of Section XI of the ASME Boiler and Pressure Vesset Code, 1989 Edition, no addenda. The licensee clearly identified, in the third 10-year intervat inservice inspection program plan, the ASME Code Class components to be examined. The licensee l
appropriately submitted relief requests in accordance with the requirements of 10 CFR 50.55(a)(3) and (g)(5) for those Code Class weld examinations where100 percent of full examination coverage was not achieved.
October 28,1998 6
COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 7/21/98 NEG IR 98-05 NRC MAINT 2B 3A 5C Mechanics reassembling diesel generator air system check valves were not knowledgeable of IR 97-02 the work package and failed to follow the work instructions. The work instructions were inadequate because the restoration steps would have increased the risk of damaging the O-rings, and incorrect drawtngs were incorporated into the work packages. The licensee's corrective actions failed to address or correct all the problems identfied. The licensee had not completed formulation of corrective actions prior to the end of the inspection period.
7/11/98 POS IR 98-04 NRC MAINT 3A 38 Licensed operators assigned to the work control staff demonstrated strong safety focus, control
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of plant configuration and communications with both control room and Maintenance work crews.
Plant configuration was continually monitored by the work control staff resulting in significantly improved safety, work flow, and scheduling.
7/11/98 POS IR 98-04 NRC MAINT SA Maintenance demonstrated an appropriately low threshold of identification of problems regarding equipment failures, lack of procedural acceptance criteria, and other quality administrative concems in problem identification reports. This safety conscience regard for identification of problems appeared to be an significant improvement over past performance in this area.
7/11/98 POS 1R 98-04 NRC MAINT 5A Maintenance demonstrated an appropriately low threshold of identification of problems regarding equipment failures, lack of procedural acceptance criteria, and other quality administrative concems in problem identification reports. This safety conscience regard for identification of problems appeared to be an significant lmprovement over past performance in this area.
7/11/98 POS IR 98-04 NRC MAINT 2B 3A Maintenance during this inspection period was generally good. Supervisors were at the work sites, and technicians used appropriate radiologk:al practices. Maintenance managers imposed a stand down after two instances of improper work practices.
6/28/98 NEG IR 98-04 LIC MAINT 2A 3A SC After a scheduled replacement, an essential service water booster pump indicated unexplained oil level drops from the high to the low level marks on it's operating band. Maintenance staff could not correct the problem despite troubleshooting performed at intervals over a month.
Maintenance staff found that, while rebuilding the pump, a vendor installed an undersized shaft and improper oillevel marks.
6/28/98 NEG IR 98-04 LIC MAINT 2A 3A SC After a scheduled replacement, an essential service water booster pump indicated unexplained oil level drops from the high to the low level marks on it's operating band. Maintenance staff could not correct the problem despite troubleshooting performed at intervals over a month.
Maintenance staff found that, whila rebuilding the pump, a vendor installed an undersized shaft and improper oillevel marks.
6/2/98 URI IR 98-05 NRC MAINT 4B SA SC l The licensee failed to recognize that replacement relays that failed testing, but actually October 28,1998 7
COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 5/21/98 STR IR 98-03 NRC MAINT 2B SC Over the past few months, Maintenance has improved somewhat. Most of these improvements have been specific corrective actions implemented by the licensee's corrective action program.
Some improvements resulted from involvement of management and supervision with Maintenance technicians to articulate and Maintain higher standards for Maintenance work and program implementation.
5/15/98 POS IR 98-02 NRC MAINT 2B During observations of routine Maintenance, inspectors observed procedural adherence, radiation protection, and ALARA practices and found them generally good. Acceptance criteria were properly referenced and followed. Cases in which data were not within acceptance criteria, or anomalies were found, were dispositioned with problem identification reports and/or documentation on a discrepancy sheet. The appropriate standards for initiation of problem identification reports appeared to have been met when problems were encountered.
4/28/98 NEG IR 98-03 NRC MAiNT SB 4B The licensee idemified that a surveillance procedure intended for outages only was i
inappropriately scheduled for power operation. The procedure was not implemented, but no restrictions had been documented in the procedure. The evaluation did not consider that the original 10 CFR 50.59 evaluation may have been inadequate. Also, the licensee did not recognize that service water backup cooling could be prevented by a single failure.
4/1/98 POS IR 98-01 NRC MAINT SC in a followup effort on nonsafety-related fuse sizing, the licensee performed multiple circuit walkdowns. This assessment of extent of condition was prompt and thorough and demonstrated effective leadership by Maintenance and coordination with operations. Thirteen fuses were found in nonsafety related applications which were of improper size. No safety significant concerns were identified.
4/1/98 STR 1R 98-01 NRC MAINT 1C 3C Tagout/ clearances were significantly improved over the previous outage. The licensee had assigned two additional licensed operators to assist clearance and tagout activities during the outage, significantly improved the layout of the clearance desk to facilitate interdiscipline reviews, and planned clearance points before the outage. During the midcycle outage, no clearance order or tagout errors were noted. This violation was identified by the licensee but involved five separate failures.
s 4/1/98 NEG 1R 98-01 NRC MAINT 2B After a small change in reactor equipment cooling inventory, the licansee implemented procedures to identify if a leak had occurred. During subsequent troubleshooting of the reactor equipment cooling heat exchanger, inspectors identified several weaknesses, including failure to plan for contingencies, procedural omissions and inconsistencies, and failure to clarify required system configuration.
October 28,1998 8
COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 4/1/98 NEG IR 98-01 LIC MAINT 2B A few days before the midcycle outage, operations identified that the feedwater startup valves, which had failed in a manner which complicated past shutdowns and startups, had not had preventive Maintenance or testing before the scheduled outage. Subsequent testing revealed a startup valve controller failure which would have complicated the plant shutdown. This indicated poor implementation of lessons teamed by Maintenance.
4/1/98 WEAK IR 98-01 NRC MAINT 3A The pilot valve replacement was performed according to instructions. During a drywell walkdown, a work order document and about a yard of emery paper. Subsequent detailed walkdowns by plant management identified other foreign material in the drywell.
3/21/98 NEG IR 98-02 NRC MAINT 2A 3A 3B Maintenance responded promptly and provided a repair to a failed circulating water valve.
However, the valve was repaired with a modification without appropriate administrative controls.
Maintenance did not promptly verify safety-related valves with similar designs. Also, similar essential valves were not promptly verified to determine if the same mechanism may be a concern until after inspector involvement.
3/8/98 POS IR 98-02 NRC MAINT 3A 18 Maintenanca remonse to a snowstorm which blocked routine access to the site for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was outstanCng. Two shifts of emergency response organization were formed onsite as well as two shifts each of operations, security, and Maintenance staff to address plant operations, outage work, and effects of the snowstorm. For ti= majority of activities, Maintenance and the outage organization took on a leadershig.se and property prioritized and coordinated site activities.
2/23/98 POS IR 97-11 NRC MAINT SA 2B The quality assurance organization performed a credible and insightful audit of the measurement and test equipment calibration program. Numerous examples of poor practices and standards were identified. The Maintenance organization has identified corrective actions, and a followup quality assurance audit is planned.
2/23/98 VIO IR 97-11 NRC MAINT SC Maintenance failed to promptly process a group of 25 problem identification reports within about SLIV a month. These reports had been initiated to document earlier failures to document problems encountered during surveillance testing.
2/23/98 VIO IR 97-11 NRC MAINT 4C SC The licensee's procedures did not require dedication of fuses for essential applications. The SLIV licensee concluded that systems remained operable. Corrective actions to a 1994 self-assessment were inadequate.
2/23/98 VIO IR 97-11 NRC MAINT 5B 4B Two surveillance tests for secondary containment integrity did not adequately test door leakage.
SL IV Non-conservatism had been identified in this test during the last inspection period, and these inadequacies were not identified in the licensee's subsequent activities.
October 28,1998 9
COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 1/12/98 NEG IR 97-10 NRC MAINT 2A 2B The licensee addressed a steam leak and seat leakage promptly, although examples of poor planning, workmanship and troubleshooting were identified. The licensee declared the reactor core injection cooling system operable without re-installing the metal jacket on piping and failed to recognize it had been assumed to reduce the heat loading on the room in a calculation. The contribution to the heat loading was minimal but non-conservative.
1/12/98 NEG 1R 97-10 LIC MAINT 28 A Maintenance work order submitted to the control room which would have required a plant shutdown to perform testing, was rejected after clearances were hung but before the work order was implemented. This was the first significantly flawed work order submitted to the control room in over 4 months and represented a reduction in the frequency of challenges to the control room.
1/12/98 WEAK IR 97-10 LIC MAINT 2A Some examples of equipment condition deficiencies such as leaks were observed in some NRC cases, these items resulted in entry into action statements to repair equipment. These action statement entries could have been avoided in some cases if repair activities had been effected during the refueling.
12/19/97 POS IR 97-09 NRC MAINT 3A 2B Licensee technicians performed several 4160V breaker inspections and preventive Maintenance in a thorough and conscientious manner. The inspectors noted examples of lack of procedural detail during these observations (Section M3.2).
12/19/97 POS IR 97-09 NRC MAINT 3A Preparation for and execution of a turbine governor valve monitoring evolution were generally thorough (Section M2.3).
12/19/97 POS 1R 97-09 NRC MAINi 2B The documentation of Maintenance work and engineering support for one 24-hour period was generally complete and appropriate (Section M3.1).
12/19/97 WEAK IR 97-09 NRC MAINT 2A SB The control of foreign materialin 4160V breakers showed some weakness. The operability evaluation for a missing nylon fastener did not thoroughly address its effects on breaker contacts or mechanisms (Section M2.2).
12/19/97 POS IR 97-09 NRC MAINT 2A 5B SC After failure of a 416GV breaker charging motor, the licensee identified six safety-related 4160V breakers that had not been overhauled in 23 years. Some weaknesses in addressing this issue were observed by the inspectors. Plant management and operations were instrumentalin identifying the scope of the issue and obtaining timely assessment of the condition (Section M2.1).
12/19/97 STR 1R 97-09 NRC MAINT 3B The licensee implemented appropriate operations and training management standards for crew performance during cha!!enging simulator scenarios. Strong management involvement in the training and feedback to crews to improve performance were present (Section O5.1).
October 28,1998 10 COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES.
12/17/97 WEAK IR 97-18 NRC MAINT 2B A number of inconsistencies between the licensee's Maintenance procedures and the vendor recommendatens were identified and the licensee had either weak or insufficient justification for these d:fferences. This was characterized as a weakness in the Maintenance program.
12/17/97 WEAK IR 97-18 LIC MAINT 2A A history of 4160V breaker problems and failures had existed at the facility. Numerous breaker failures and deficiencies were first discovered in 1987, and a process to overhaul the breakers was instituted. During the period from 1989 to 1994,18 of the 24 safety-related breakers were overhauled. None of the non-essential breakers had been overhauled. In August of 1994 the overhaul process was terminated.
12/17/97 WEAK 1R 97-18 NRC MAINT SC The resolution to many of the Magne-Blast-related NRC Information Notices, and lack of resolution of associated service advice letters was indicative of a superficial implementation of the operating experience review program.
12/10/97 NEG IR 97-17 NRC MAINT 2A The material condition of the facility was generally good with the exception of the Emergency Diesel Generator 2. Numerous oil leaks and spi!Is in and around the diesel brought to the licensee's attention by the inspectors after several licensee staff in the area failed to do so (Section M2).
10/20/97 NEG IR 97-08 NRC MAINT 3A Inspectors identified a weakness in that replacement of a fuse was not documented.
10/20/97 NEG IR 97-08 NRC MAINT 5B The licensee's evaluation of a problem identification report was weak in that it did not establish the basis for the significance of a pressure spike before the pressure switch was returned to service. Also, no action was taken to determine the cause of the pressure spike.
10/9/97 WEAK IR 97-16 NRC MAINT 4B 3C The licensee experienced problems implementing the long-term erosion / corrosion monitoring program as a result of frequent program staffing turnover.
10/9/97 VIO IR 97-16 NRC MAINT SA 5B The licensee's failure to initiate a condition report for a failed safety-related reducer in the SLIV service water piping to the lube oil heat exchanger for Diesel Generator 1 was a violation of Procedure 0.5.
10/9/97 NEG IR 97-16 NRC MAirJT 4C Engineering component evaluation forms were not completed for Refueling Outage 17 erosion / corrosion data prior to plant restart, in accordance with licensee management expectations.
10/9/97 NEG IR 97-16 NRC MAINT 48 An engineering evaluation of the remaining service life for Reducer SW-DG-2-R-4, was performed incorrectly. The licensee's actions that had been taken based on the erroneous calculation were conservative in that the component was prematurely replaced.
10/9/97 WEAK IR 97-16 NRC MAINT SC The licensee's corrective actions implemented for transient combustible material problems were not effective.
October 28,1998 11 COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 10/3/97 VIO IR 97-12 NRC MAINT SA SB 2A Inspectors identified a significant problem in that the heat exchanger test program failed to SL lit detect a degraded heat exchanger. At the end of the inspection, the licensee had not EA 97 formulated or implemented corrective actions to address the program. Dispositioned by NRC 424 letter of 12/1/97. Part of violation included above.
10/3/97 VIO IR 97-12 NRC MAINT SA SB 2A The licensee failed to recognize that blockage of the residual heat removal heat exchanger SL lit tubes could be safety significant, and failed to document the as-found condition of the heat EA 97-exchanger. Considerable NRC intervention was required to ensure the safety significance was 424 addressed. Dispositioned by NRC letter of 12/1/97; $110,000 CP imposed.
7/24/98 NEG IR 98-05 NRC ENG 3A 4B SB The licensee failed to prioritize contracted efforts planned over several months to address IR 96-06 instrument loop uncertainty for Technical Specification equipment, the control room did not obtain timely resolution of reactor equipment cooling system temperature indicator instrument loop uncertainty, and an appropriately conservative administrative limit for the maximum temperature was not set. Also, the station operations review committee identified and corrected i
a specific failure to address instrument uncertainty in troubleshooting instructions and with plant l
procedures, but failed to address the programmatic nature of the issue and require changes to administrative procedures.
7/11/98 NEG 1R 98-04 NRC ENG 2A 28 SB Engineering response to a through-wall leak in the non-essential service water system was prompt, supporting operations demands, but was not comprehensive regarding analysis of r
piping integrity or adequacy of the flooding analysis.
I 7/11/98 NEG 1R 98-04 NRC ENG 4B 58 The replacement component evaluation and procedures associated with an equivalent component replacement of safety related relays did not insure adequate testing. The equipment used to test the old design relays caused false failure indications when testing the replacement relays.
6/30/98 POS IR 98-04 NRC ENG 4A 4B SB After significant inspector and plant management involvement, engineering performed thorough and complete technical evaluation of a complex issue, and effectively integrated operations and licensing staff in the evaluation and interim resolution. Engineering assessed the potential effects of hydro-dynamic loading on torus strainers, caused by high torus levels allowed by emergency operating procedure and severe accident guidelines. The 1censee concluded that the guidelines had not considered these effects, implemented interim compensatory actions and presented the issue to the BWR Owners Group (BWROG).
6/28/98 POS 1R 98-04 NRC ENG 2A 3A SC Engineering involvement was not intrusive until the final troubleshooting of an essential service water booster pump, but that involvement resulted in strong ownership, coordination with maintenance, and safety focused evaluation that resulted in a decision to immediately replace the pump.
I October 28,1998 12 COOPER NUCLEAR PLANT
=
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 6/11/98 URI 1R 98-05 1.
ENG SB SC The licensee identified that an improperty installed check valve allowed a siphon from the suppression pool to the radwaste system via the reactor core isolation cooling barometric condenser. The hcensee promptly corrected the condition, identified ciner cases in diesel generator air and containment isolation systems where these valves were improperly installed, and promptly corrected or evaluated them to be operable. Engineering response to this issue demonstrated an example of significantly stronger timeliness of response, breadth of technical review scope, correction of extent of condition, and coordination and support of plant activities.
5/20/98 NEG 1R 98-03 NRC ENG 58 48 Although battery room temperatures have been maintained within operabihty requirements, the hcensee enters an abnormailow battery room temperature procedure every summer, since the essential ventilation keeps temperatures low enough to potentially cha!!enge the battery operability. Procedures which required operators to set up temporary heaters when required contained minor weaknesses. Engineering has not yet provided a permanent resolution for the work-around.
5/15/98 NEG IR 98-02 LIC ENG 4A 48 4C Procedures for use during a loss of coolant accident and loss of offsite power directed that core LER 98 spray be throttled to 4750 gpm per pump, although 6100 gations were required for core 003 coverage, by the Updated Safety Analysis Report accident analysis.
5/15/98 VIO IR 98-02 NRC ENG 4A 4B 4C A violation of 10 CFR Part 50, Appendix B Criterion V, with three examples:
SLIV The licensee failed to property implement corrective actions for inadequate torquing instructions which had caused safety system inoperab!!ity. Administrative controls were not implemented to ensure the word tight or tighten would be used appropriately in new or revised procedures, the licensee failed to identify a!! maintenance procedures affected by the concem, and no permanent corrective action for uncontrolled fastener installations were addressed.
The length of fuel had been increased from 144 to 150 inches. However, calculation changes to
(
implement the design change failed to change the reference point for the top of active fuel on fuel range level indicators and emergency operating procedure parameters. This caused a nonconservative bias in the fuel range indication of 6 inches. The emergency operating procedure was not updated to reflect this change. The licensee evaluation concluded that, i
although this bias was nonconservative, it did not exceed the existing design margin.
3 The licensee did not recognize that paint applied in the reactor building cor.tained an unacceptably high percentage of volatile organics. The initial evaluation and restrictions on the painting, as well as the evaluation of the effect of this painting on standby gas treatment, did not
[
accurately address the technical issue or the iodine release profile. and the control room was not informed of later developments. The procedure controlling painting was not adequate.
[
October 28,1998 13 COOPER NUCLEAR PLANT i
+
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 5/15/98 WEAK IR 98-02 NRC ENG 4A 4C SA Engineering failed to implement clear instructions for controlling the electrical load profile, in URI emergency operating procedures. This profile is the basis for the Technical Specification 7 day diesel fuel inventory requirement. Operations had not been instructed that this profile must be used if the design basis accident occurred.
5/15/98 WEAK 1R 98-02 NRC ENG 1C For a modification to the Z-sump, engineering did not ident:fy all affected operating procedures.
Inspectors found that, if the nonessential power to the essential heat trace was lost due to electrical component failure, no requirements or actions were provided to operators in abnormal or alarm response procedures, to respond to this loss.
5/6/98 NEG IR 98-03 NRC ENG 4B 5A SB An indication light failed on the high pressure coolant injection steam admission valve.
Subsequent troubleshooting did not identify the cause of failure. The engineering evaluation was weak. Applicable industry information was not addressed, the potential effect on valve control switches was not addressed, and operability was concluded without identifying the source of the foreign material which was concluded to have caused the problem. Significant inspector involvement was required before relevant aspects of operability were addressed.
4/1/98 NEG IR 98-01 NRC ENG 4C The licensee's use of risk information was not comprehensive. Inspectors identified that the PRA model fault tree inaccurately modeled the RCIC controller and the diesel generator controls. Licensee evaluation determined that neither of these inaccuracies resulted in significant changes in risk assessment. Inspectors also identified that the licensee's proposed plant modifications were not evaluated to assess risk. Licensee event reports were also not evaluated for risk. The licensee has subsequently decided to evaluate these items.
2/23/98 NEG IR 97-11 NRC ENG 4B 2A The licensee did not document facts critical to the conclusion of an operability assessment for a stuck service water check valve. The operability evaluation also did not consider the potential effects of water hammer.
2/23/98 VIO IR 97-11 NRC ENG 4B SC The licensee did net promptly correct a non-conservative Technical Specification surveillance SLIV requirement. The licensee was aware that setting the standby liquid control relief valves at the low end of the range allowed by Technical Specification Surveillance Requirement 4.4.A.2.a.
t could result in the failure of the standby liquid control system during an anticipated transient without scram. They implemented administrative controls to address the safety issue, but they did not correct the license.
2/5/98 URI 1R 97-201 NRC ENG 4A 4C The design bases for the RHR pump flow were not properly translated into test procedure acceptance criteria as required by 10 CFR 50, Appendix B, Critorion III, " Design Control"(URI 50-298/97-201-01) (Section E1.2.1.2.a.)
t October 28,1998 14 COOPER NUCLEAR PLANT
~.
c, PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 2/5/98 URI IR 97-201 NRC ENG 4A 48 18 TS Setting Limit for Undervoltage Relays Technical Specification Table 3.2.B. page 3. specifies a second level undervoltage relay setting limit of 3880 +/- 52 volts for the emergency buses.
Calculation NEDC 88-0868,'Setpoint Determination of Second Level Undervoltage Relays,"
Revision 7, specifies an analyticallimit of 3847 volts for the degraded voltage, which is above the lower TS limit of 3828 volts. The current TS allows second level undervoltage relay settings to be less than the analytical limit for the emergency bus degraded voltage. Therefore, it is possible for a relay to drift below the analytical limit and still be considered operable by current TS limits. The design basis in the calculation was not correctly translated into the technical specifications. (URI 50-289/97-201-11) (Section E1.2.2.2.a.)
2/5/98 URI 1R 97-201 NRC ENG 2C Test procedures for the REC heat exchangers did not assure that adequate test instrumentation was used and that test results were evaluated to verify that test requirements were satisfied as required by 10 CFR 50, Appendix B, Criterion XI, " Test Control." (URI 50-298/97-201-27)
(Section E1.3.1.2.e.)
2/5/98 URI 1R 97-201 NRC ENG 4A 2C The team concluded that design bases for RHR pump minimum flow requirements were not correctly translated into procedures and instructions as required by 10 CFR 50, Appendix B.
Criterion 111," Design Control." (URI 50-298/97-201-04) (Section E1.2.1.2.e.)
2/5/98 WEAK IR 97-201 NRC ENG 4A The team noted several discrepancies in the USAR, TS, and system design criteria documents.
i The design criteria document (DCD-13) for the RHR system contained several incorrect statements that were inconsistent with the current system design.
2/5/98 NEG IR 97-201 NRC ENG 4A 4C Previous NRC inspections had ident:fied weaknesses in factoring instrument uncertainties into test acceptance enteria and operating procedures. The team noted that the procedure for monitoring SW temperature and the surveillance test procedure for RHR pumps dK! not consider applicable instrument uncertainties.
2/5/98 NEG IR 97-201 NRC ENG 4A The team noted that nonconservative assumptions and design inputs were used in the calculations for estimating the RHR pump room temperature and for venfying the capability of the service water (SW) system to provide adequate back-up cooling for safety-related equipment in the REC system. (URI 50-298/97-201-20) 2/5/98 NEG IR 97-201 NRC ENG 4A 2A The team identified that the design change to the REC system for the insta!!ation of the filter demineralizer in 1991, the associated safety analysis, and the operating procedure did not address the importance of maintaining water inventory in the closed REC system. The REC system would not have been at2e to support its long-term cooling functions in the event of a design basis accident, because the minimum available volume of water in the surge tank would have been depleted within a day through the sampling valves that were left open apparently.
(URI 50-298/97-201-23)
October 28,1998 15 COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION G
DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 2/5/98 URI 1R 97-201 NRC ENG 4A 2C During the inspection, the licensee also identified this concem with the calculation in problem report PIR 2-21090, dated October 29,1997. The licensee issued a night order on October 29, 1997, to secure one of the RHR pumps in a quad if the fan coit unit in that quad became inoperable. The team was concerned that the design requirements were not translated into procedures or instructions us required by 10 CFR 50, Appendix B, Criterion 111, ' Design Control."
(URI 50-298/97-201-24) (Section E1.3.1.2.c.)
2/5/98 URI 1R 97-201 NRC ENG 4A 4C The licensee issued PIR Nos. 2-19692,2-19746, and 2-20200 during the inspection to address and resolve these issues. The design bases for the SW back-up to the REC system were not correctly translated into the design input for calculation NEDC 97-074. (URI 50-298/97-201-30)
(Section E1.3.4.2.a.)
2/5/98 WEAK IR 97-201 NRC ENG 2A 4A 4C Some of the deficiencies discussed above challenged the capability of the systems to perform their full design bases functions. The contributory causes for these deficiencies appear to be a lack of understanding of the design bases of the systems, use of nonconservative assumptions j
and design inputs in calculations, and not maintaining control over the configuration of the design bases reflected in various plant documents.
2/5/98 URI 1R 97-201 NRC ENG 4A 1C SW Design Temperature: the SW system design basis was not appropriately translated into procedures as required by 10 CFR 50, Appendix B, Criterion ill,
- Design Control." (URI 50-298/97-201-22) (Section E1.3.1.2.a.)
2/5/98 WEAK 1R 97-201 NRC ENG 4A 4B The team also identified other issues, such as: weaknesses in performance monitoring of RHR not considering the potential for pumping post-accident leakage from ECCS to the radwaste system.
2/5/98 URI 1R 97-201 NRC ENG 4A 2C The acceptance limit in the test procedure and the evaluation of the test results were not adequate to demonstrate that the heat exchanger would perform satisfactorily in service as required by 10 CFR 50, Appendix B, Criterion XI, " Test Control." (URI 50-298/97-201-06)
(Section E1.2.1.2.f.)
2/5/98 URI 1R 97-201 NRC ENG 4A USAR / TS Discrepancies: the team identified several examples that indicate that the USAR had not been updated to include the latest material developed and the effects of all changes made to the facility or procedures, as required by 10 CFR 50.71(e). (URI 50-298/97-201-21) (Section E1.2.6)
October 28,1998 16 COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 2/5/98 URI 1R 97-201 NRC ENG 4A The teara identified that although the plant was not operated in the steam condensing mode, the inadequate design of powor sources to the containment isolation valves should have been reported. The licensee further reviewed CAO 96-0634, determined that the reportability analysis for CAO 96-0634 incorrectly concluded that the lack of power supply diversity for primary containment isolation valves RHR-MOV-MOl66A(B) and RHR-MOV-MOl67A(B) was not reportab!e, and issued LER 97-n17, dated December 31,1997 in accordance with 10 CFR 50.73. (URI 50-298/97-201-10) (Section E1.2.4.2.h.)
i 2/5/98 URI 1R 97-201 NRC ENG 4A 4B The team requested the 10 CFR 50.59 safety evaluation for LCR 94-0049 which deleted timing requirements for RHR test line isolation valves. The licensee indicated that a 10 CFR 50.59 evaluation for the USAR change had not been completed. (URI 50-298/97-201-09) (Section E1.2.1.2.g.)
1/12/98 NEG IR 97-10 NRC ENG 4B Inspectors identified that three manual valves were used as emergency core cooling system primary containment boundaries during insta!!ation of a modification, without an evaluation of their ability to perform this function under design basis conditions.
1/12/98 STH 1R 97-10 LIC ENG SA 58 SC The licensee appropriately identified, bounded, and add-assed the seismic aspects of valve operators of higher weight then specified. The error had been introduced in a 1979 modification. The equipment remained operable.
1/12/98 VIO IR 97-10 NRC ENG 4A A surveillance test of secondary containment door leakage used non-conservative leakage SL IV values in calculating operability and margin for the standby gas treatment and secondary containment systems.
1/12/98 NEG 1R 97-10 LIC ENG 4B An error in troubleshooting by engineering resulted in an operable safety system being unnecessarily removed from service for 5 days.
12/19/97 STR 1R 97-09 LIC ENG SA 2A A nonconservative erosion-corrosion prediction calculation was identified for turbine cross-under piping (Section E4.1).
12/19/97 WEAK IR 97-09 LIC ENG 2B For surveillance tests performed in close succession on the same equipment, such as the high pressure core injection system, the hcensee did not typicaffy evaluate the potential for preconditioning equipment or minimize starts and run time on equipment. The licensee identified a potential preconditbning vulnerability for one valve in the system and changed the procedure (Section E4.2).
12/17/97 WEAK IR 97-18 NRC ENG 4A The team identified weaknesses in the licensee's operability assessments associated with the potential degradation of the 4160V breakers.
October 28,1998 17 COOPER NUCLEAR PLANT
I PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 12/17/97 NEG 1R 97-18 NRC ENG 4A The 125V de load profile calculation contained a number of non-conservative errors.
Additionally, it was noted that the surveillance procedures associated with both the 125V and 250V de systems did not contain acceptance criteria and that the battery charger sizing calculation had not been updated.
10/20/97 NEG IR 97-08 NRC ENG 48 Inspectors identified that licensee's controls failed to require an engineenng evaluation of use of Teflon tape in applicatons where essential service or high radiation exposure equipment qualification was required. The interim actions to evaluate use of the tape during upcoming scheduled work were informal. Evaluation of the concem did not include assessing past use of the tape, assessing how use of an unqualified material was authorized by procedure without an engineering evaluation, or determining the extent of unevaluated consumable materials in plant systems 9/3/98 POS IR 98-20 NRC PS 1C Overall, performance in the physical security area remained strong. The Access Authonzation Program was effectively implemented. Strong senior management support for the program was evident. An excellent pogram for searching personnel, packages, and vehicles was maintained. Security procedures in place properly controlled personnel, package, and vehicle access to the protected area. Security personnel were well trained on program requirements.
An effective testing and maintenance program was conducted and properly documented.
Excellent protected and vital area barriers and detection systems were maintained. During performance testing of the detection system at the protected area, a!! attempts to intrude into the protected area were detected. A comprehensive security training program had been implemented. Security personnel were well trained on the program requirements.
9/3/98 POS IR 98-20 NRC PS 1C An excellent fitness-for-duty program was in place. The fitness-for-duty program audit was intrusive and performance based. A technical specialist was included as a member of the audit team. Effective procedures had been implemented to insure detection if individuals attempted to circumvent the test with false specimens. Fitness-for-duty procedures were in-depth, comprehensive, and current. Improvements were noted in the continuous behavior observation program. Behavior observation training for supervisors was being changed from training by computer to in-class attendance.
6/22/98 STR IR 98-16 NRC PS 3B The use of mock-ups, pictures, and staged props enhanced the exercise training value.
6/22/98 POS 1R 98-16 NRC PS 18 Overall, performance was good. The control room (CR), technical support center (TSC), and emergency operations facility (EOF) successfully implemented essential emergency plan functions including classificatK)n, notification, protective action recommendations, and personnel accountability.
6/22/98 STR 1R 98-16 NRC PS 5A The critique process was strengthened by using a peer evaluation group made up of representatives from other sites.
October 28,1998 18 COOPER NUCLEAR PLANT
PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 6/22/98 Weak 1R 98-16 NRC PS 3B 3C The operational support center (OSC) staff's performance was satisfactory. The response to the fire was not completely correct because entry into the fire scene was made 7 minutes before the hoses were charged and respiratory protection equipment was not properly tested. The manner in which teams were assigned, briefed, and dispatched, coupled with the level of activity (noise and distraction) in the OSC lead office area, detracted from the overalt effectiveness of the center and caused minor delays in team dispatch. An exercise weakness was identified for the failure to implement proper radiological contamination controls in the TSC and OSC.
6/11/98 STR 1R98-18 NRC PS 1C 3A 38 The radiation protection organization performed well. Improvements were noted in some aspects of the program. Good exposure controls were implemented. Controls placed on radioactive materials and contamination were effective. The licensee increased the level of expertise in both the radiation protection professional staff and the radiation protection technician staff. The 1998 quahty assurance audit and the 1997 radiation protection self-assessment were good examples of critical reviews that demonstrated good management oversight. The audit and assessment made good use of industry peers to identify problems and potential areas of improvement.
6/11/98 NEG 1R98-18 NRC PS 1C A high number of personnel contamination alarms (17,000 in 1997) were recorded. The licensee was evaluating afternate radiation detection instrumentation to address the situaton so trial radiation workers did not become desensitized to the alarms 6/11/98 STR 1R98-18 NRC PS 1C The ALARA program produced excellent results. The 1995-1997 person-rem average was the fouith best boiling water reactor average, nationally.
5/19/98 VIO
!R 98-03 NRC PS 1A 1C The licensee did not provide an explanation conceming why an inoperable radiation monitor was not fixed in a timely manner, in the Annual Radioactive Materials Report, as required by Technical Specifications 3.21.A.1.d. This situation was caused by operation of the service water system with the residual heat removal heat exchanger outlet valves leaking. Also, the licensee did not recognize the reporting requirements with liquid discharges occurring with the radiation monitors inoperable.
5/7/98 STR 1R 98-17 NRC PS 1A Program strengths were identified in the areas of access authorization, package and material control, compensatory measures, training and qualifications and management effectiveness 5/6/98 VIO 1R 98-17 NRC PS 1C A violation of the physical security plan, paragraph 1.5.2, was identified for improperty SLIV processing visitors into the plant protected area. Members of a tour group were not issued visitor badges.
October 28,1998 19 COOPER NUCLEAR PLANT
e PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 4/14/98 WEAK IR 98-12 NRC PS 1B 3B The failure of one crew to effectively implement key elements of the emergency plan (e.g.,
emergency director oversight, protective action recommendations, offsite agency notifcations, and emergency classification) during simulator wafkthroughs was identified as an exercise weakness. Appropriate remedial actions were implemented for the affected crew and actions were initiated to assess the generic implications by performing a root cause analysis.
4/14/98 STR IR 98-12 NRC PS 3A Overall, implementation of the emergency preparedness program was good. Emergency response facihties were operationally Maintained. Emergency preparedness management expanded the use of performance indicators to focus on creas of weak performance, and emergency preparedness staffing was strengthened. The emergency response organization training program was enhanced to increase emphasis on drill participation and performance evaluation. Program audits, surveillances, and self-assessments identified many good issues and program vulnerabilities.
4/14/98 NEG IR 98-12 NRC PS 48 SC Actions to address emergency evacuation waming for personnelin high-noise areas were slow and compensatory actions were insufficient for some plant areas. The issue stemmed from what appeared to be a weak response to a 1979 NRC Bulletin, since a subsequent study identified areas where the system was inadequate. Engineering support to correct system inadequacies has been lacking. In the interim, the emergency preparedness staff notified security personnel of the need to take compensatory measures in certain areas; however, two areas were missed.
4/10/98 POS IR 98-13 NRC PS 58 5C An effective self assessment program of the solid radioactive waste management and transportation programs was Maintained. Timely and effective corrective actions were completed for identified problems.
4/10/98 STR 1R 98-13 NRC PS 1C 2A 3B Overa!!, good solid radioactive waste management and radioactive waste / materials transportation programs were implemented. Documentation and packages were property prepared for shipment. Good facilities were Maintained for the processing, storage, and management of solid radioactive wastes and transportation activities. An effective radioactive waste inventory / accountability system was Maintained. Personnel involved in the transfer, packaging, and transport of radioactive materials and wastes were property trained and qualified. The amount of solid radioactive waste generated between 1994 and 1997 was below the boiling water reactor national average.
4/9/98 POS IR98-14 NRC PS 2A The liould and gaseous effluent radiation monitoring instrumentation was properly Maintained, tested, and calibrated. The post-accident sampling system was Maintained in a proper state of operational readiness. The radiochemistry counting room was equipped with properly Maintained and calibrated analytical instrumentation.
October 28,1998 20 COOPER NUCLEAR PLANT
o PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 4/9/98 POS IR 98-14 NRC PS 1C A good surveitlance program was implemented for the safety-related air cleaning ventilation systems.
4/9/98 STR IR 98-14 NRC PS 1C Overall, a good liquid and gaseous radioactive effluent waste management program was implemented which included proper implementing procedures, a qualified staff, and appropriate quality assurance oversight. Challenging performance goals were initiated in 1997 for the reduction of radioactive effluent waste releases; and improvement in liquid waste activity and volume released was noted in the fourth quarter of 1997 and the first quarter of 1998. Noted improvements were due to the formation of a task force in 1997 which had effectively reduced in-leakage into the radwaste systems.
4/1/98 WEAK IR 98-01 NRC PS 3A 2B inspectors identified several weaknesses during an unannounced weekend fire drill. The appearance of the fire protection coordinator in the controi room at 7 a.m. on a weekend telegraphed the impending drill. Examples of weaknesses included lack of formality in communication, failure to evacuate all potentially affected areas, and lack of hazardous materials response for a fire drillin a paint storage room.
4/1/98 NEG IR 98-01 NRC PS 1C Inspectors noted that, although ALARA efforts achieved dose reduction within departmental and work group efforts, no activities were performed to coordinate across departments to achieve dose reduction. The licensee immediately addressed this concern. For example, the containment coordinator obtained required diagnostic photographs of equipment on his daily surveys instead an engineer making a separate entry into the drywell. This resulted in immediate reductions in radiation exposure below estimated doses.
4/1/98 POS IR 98-01 NRC PS 3A Security responded well to a quick succession of access point metal alarms. During a crowded morning outage cift change, several consecutive personnel metal alarms resulted in a condition in which the access station guard force could be quickly overburdened. The impending congestion at the security access area was promptly averted. Security demonstrated excellent coordination to obtain more guard staff and slow personnel entries. The multiple access metal alarms were processed in less than 2 minutes.
3/19/98 VIO IR 98-10 LIC PS 3A A violation for failing to follow fitness for duty requirements was identified. This violation was SLIV identified by the licensee but involved five separate failures.
3/19/98 URI 1R 58-10 NRC PS 3A An unresolved item was identified in the access authorization program. A transferred background investigation was inadequate in that references were not reviewed as part of an updated background investigation. The root cause of this problem was the failure to adequately review an NEI audit.
October 28,1998 21 COOPER NUCLEAR PLANT
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PLANT ISSUES MATRIX COOPER NUCLEAR STATION DATE TYPE SOURCE ID S FA TEMPLATE ITEM CODES 3/19/98 STR 1R 98-10 NRC PS 1C Overali, the physical security program was very effectively implemented. A very efficient vehicle access control program was in place. The assessment aids system provided excellent assessment of the perimeter detection zones. The addition of the video capture system was a significant addition to the assessment aids system. An excellent safeguards event log system for reporting safeguards events was in place. An excellent security plan and procedures program was in place. The audit and intemal self assessment programs were excellent.
3/8/98 POS IR 98-02 NRC PS 3A During the snowstorm when routine access to the site was cut off for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the emergency response organization promptly contacted state officiais and assessed personnel onsite to evaluate emergency response, and to fulfill requirements for 2 shifts of an emergency response organization.
2/23/98 POS IR 97-11 NRC PS 1C The licensee demonstrated initiatives that reduced projected dose and radioactive waste generation. In some cases dose was reduced greater than 50 percent of the projected value.
Minor weaknesses were noted and were promptly addressed.
1/12/98 NEG IR 97-10 NRC PS SA Maintenance planning and troubleshooting did not identify several opportunities to reduce radiation dose during Maintenance work.
12/19/97 WEAK IR 97-09 NRC PS 3A The inspectors identified a potential weakness in as-low-as-reasonably-achievable program practices in that the licensee did not always consider radiation dose implications when scheduled jobs were postponed and when two tests on the came equipment were performed in sequence (Section R1.1).
12/17/97 STR 1R 97-19 NRC PS 3B Good training and qualification programs were implemented. The knowledge and performance of the environmental management and technical staff were excellent.
12/17!97 STR 1R 97-19 NRC PS 3A 3C Overalt, good radiological environmental and rneteorological monitoring programs were implemented. Environmental sampling equipment was calibrated and properly Maintained.
Good radiological environmental monitoring implementing procedures were Maintained. The meteorological tower instrumentation was properly calibrated and Maintained.
12/17/97 STR 1R 97-19 NRC PS SB Good, comprehensive bienneial audits of the radiological environmental monitoring and meteorological monitoring programs were performed. Timely corrective actions were implemented.
10/20/97 NEG IR 97-08 LIC PS IB During an unannounced emergency response drill, the technical support center director did not respond to the site within the 1-hour time period. Despite this concern, the technical support center response appeared to have been adequate based on performance of an interim qualified indhridual acting as the technical support center director.
October 28,1998 22 COOPER NUCLEAR PLANT
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k ENCt_OSURE 2 ;
ENCLOSURE 2 GENERAL DESCRIPTION OF PIM TABLE LABELS 0
Actual date of an event or significant issue for those items that have a clear date of occurrence, the date the source of the information was issued (such as the LER date), or, for O###
inspection reports, the last date of the inspection period.
Type The categorization of the issue - see the Type Item Code table.
SFA SALP Functional Area Ccdes: OPS for Operations; MAINT for Maintenance; ENG for Engineering; and PS for Plant Support.
Sources The document that contains the issue information: IR for NRC Inspection Report or LER for Ucensee Event Report.
i AD Identificatbn of who discovered issue: N for NRC; L for Ucensee; or S for Self ident+fying (events).
issue Descrfption Details of the issue from the LER text or from tf=e IR Executive Summaries.
g b
Codes Template Codes-see table.
e TYPE ITEM CODES TEMPLATE CODES EA Enforcement Action Letter with Civil Penalty 1
Operational Performance: A - Normal Operations; B - Operations During Transients; and C -
ED Enforcement Discretion - No Civil Peralty Programs and Processes Strength Overall Strong Ucensee Performance p
Waakness Overall Weak Licensee Performance 3
Hun en Performance: A - Work Performance; B - Knowledge, Skills, and Abilities / Training; C -
- Escalated Enforcement item - Waiting Final NRC Action Work Environment VIO Violation LevelI,II. lis, or IV 4
Engineering / Design: A - Design; B - Engineering Support; C - Programs and Processes i
NCV Non-Cited Violation 5
Problem Identification and Resolution: A-Identification; B - Analysis; and C - Resolution i
DEV Deviation from Ucensee Commitment to NRC NOTES:
Positive Individual Good inspection Finding Eels are apparent violations of NRC requirements that are being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Negative Individual Poor inspection Finding Enforcement Action"(Enforcement Policy), NUREG-1600. However, the NRC has not reached its i
final enforcemerc decision on the issues identified by the Eels and the PIM ontries may be modified
[
LER Ucensee Event Report to the NRC when the final decisions are made. Before the NRC makes its enforcement decision, the licensee will be provided with an opportunity to either (1) respond to the apparent vlotation or (2) request a URI -
Unresolved item from inspection Report predecisional enforcement conference.
Licensing Ocensing lesue from NRR MISC Miscellaneous - Emergency Preparedness Finding (EP),
issue in question is art acceptable item, a deviation, a nonconformance, or a violation. However, Declared Emergency, Nonconformance issue, etc.
the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.
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October 28,1998 COOPER NUCLEAR PLANT i
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ENCLOSURE 3 COOPER NUCLEAR STATION INSPECTION PLAN IP - Inspection Procedure C:re Inspection - Minimum NRC Inspection Program (mandatory all plants)
Regional Initiative - Additional inspection based on performance concems INSPECTION TITLE /
NUMBER OF DATES TYPE OF INSPECTION / COMMENTS PROGRAM AREA INSPECTORS IP 71001 Requalification Inspection 1
2/1-5/99 Core Inspection - Lam Retake IP 37551 Focus inspection on 3
2/08-12/99 RegionalInitiative IP 92903 Engineering Strategy IP 81700 Physical Security 1
4/19-23/99 Core inspection IP 83750 Occupational Radiation 1
5/17-21/99 Core inspection Exposure IP 37551 Focus inspection on 1
5/24-28/99 RegionalInitiative IP 92903 Engineering Strategy IP 71001 Requalification Inspection 2
6/21-25/99 Core Inspection IP 41500 Corrective Action Program 3
8/9-13/99 Core inspection IP 84750 Radioactive Waste 1
8/23-27/99 Core inspection Treatment, Effluent, Environmental Monitor October 28,1998 COOPER NUCLEAR PLANT
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