ML20235T848

Insp Rept 50-298/89-02 on 890123-27.Violation Noted.Major Areas Inspected:Engineering & Technical Support Capabilities & Activities

ML20235T848
Person / Time
Site:	Cooper
Issue date:	02/27/1989
From:	Barnes I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235T837	List: ML20235T834 ML20235T848
References
50-298-89-02, 50-298-89-2, NUDOCS 8903080497
Download: ML20235T848 (13)

See also: IR 05000298/1989002

Text

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APPENDIX

U.S. NUCLEAR REGULATORY. COMMISSION

REGION IV

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NRC Inspection Report: 50-298/89-02 Operating License: DPR-46

Docket: 50-298

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Licensee: Nebraska Public Power District (NPPD)

P.O. Box 499-

Columbus, NE 68602-0499

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: NPPD Offices, Columbus, NE

Inspection Conducted: 1 January 23-27, 1989

Inspectors: L.-Gilbert, Rcactor Inspector, Materials and Quality

Programs Section (M&QPS), Division of Reactor Safety-(DRS)

R. Stewart, Reactor Inspector, M&QPS, DRS

A.' Singh, Reactor Inspector, Plant Systems Section (PSS), DRS

P. Wagner, Reactor Inspector, PSS, DRS

Approved: d8% 24.7/97

lan Barnes, Chief, Materials and Quality Date

Programs Section, Division of Reactor Safety

Inspection Summary

Inspection Conducted January 23-27, 1989 (Report 50-298/89-02)

Areas Inspected: Special, announced inspection of the engineering and

technical support capabilities and activities for the CNS which were provided

by the NPPD offsite staff. The NRC inspectors ' reviewed the NPPD Nuclear Power

Group organization, concentrating mainly on the Nuclear Engineering and

Construction Division. The staffing and expertise of the organization together

with the procedural controls and interactions with other organizations was

evaluated. The NRC inspectors also reviewed records of audits of the

engineering function which had been conducted by NPPD Quality Assurance (QA)

Division.

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The NRC inspectors, selected ten design change packages for detailed review in

order to evaluate the quality and completeness of the engineering activities.

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>The packages were selected from changes implemented on the residual heat

removal (RHR) system over the plant life,.to obtain a perspective on past and

present activities over a variety of engineering disciplines. The NRC

inspectors also discussed the NPPD Configuration Management Plan.

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Results: The NRC i'nspectors identified one violation (failure to update a

drawing properly, paragraph 3.d) during the inspection of design change

packages. The NRC inspectors found the other design changes to have been

implemented acceptably. The NRC inspectors found the NPPD engineering

organization and procedural controls to be acceptable but noted that both had.

been recently revised. The~NRC inspectors found that the QA audits of

engineering had been of sufficient scope and depth to detect engineering

division weakness.

The NRC inspectors also discussed the NPPD Configuration Management Plan with

involved NPPD personnel to gain an understanding of the scope and status of

this undertaking. The NRC inspectors qLestioned the schedule for the Plan and

were informed that the NPPD schedule was consistent with the schedule at other

facilities implementing similar plans.

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DETAILS

1. Persons Contacted

NPPD

T. Arlt, Licensing Specialist

~A. Boesch, Instrument and Control Engineering Supervisor

K. Dowe, Mechanical Engineering Supervisor

W. . Fisher, Electrical Engineering Supervisor

A. Heymer, Manager, Configuration Management

L. Kohles, Manager, Nuclear Projects and Construction

L. Kuncl, Nuclear Power Group Manager

S. McClure, Manager, Nuclear Engineering

H. G. Parris, Vice President, Production

M. Siedlik, Civil / Structural Engineering Supervisor

G. Smith, Acting Division Manager, QA

G. Trevors, Division Manager, Nuclear Support

K. Walden, Licensing Manager

R. Wilber, Division Manager, Nuclear Engineering and Construction

Other NRC Personnel

L. Constable, Chief, Projects Section C

The above personnel attended the exit interview conducted on January 27,

1989.

The NRC inspectors also contacted and interviewed other 1.icensee employees

during the course of the inspection.

2. Licensee Action on Previous Inspection Findings (92701)

(Closed) Open Item (298/8212-01): Training for offsite staff. An NRC

inspector determined, during this earlier inspection, that no formal

training plan for offsite personnel had been implemented in response to a

NPPD task force recommendation. As discussed in paragraph 3.b., below, a

training plan has now been implemented; therefore, this item is closed.

3 .' Engineering and Technical Support

The NRC inspectors evaluated the effectiveness of the NPPD r.orporate

engineering program in the areas of adequacy of staffing levels and

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experience, training, interfaces with other organizations, design changes,

I and QA audits. The evaluation consisted of documentation reviews and

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personnel interviews to verify that the license requirements included in

the Technical Specifications (TS) and Codes and Standards were being

implemented and that the commitments contained in the Updated Safety

Analysis Report (USAR) and other correspondence were being followed.

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'a. Organization and Staffing (40703)

L The licensee- sutimitted 'a change to.the USAR 'concerning the

organization- structure by letter dated ' January 13, 1989. The'NRCf

' inspectors questioned the status:of'the revised organization,

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including.the new Nuclear Power Group (NPG),fand were informed,that

the.new organization had recently.been implemented', Further' review

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disclosed that the license? amendment-requeststo revise..the

Organization Charts in Section 6.0 of the-TS had'not,las yet, been

- submitted forLNRC review and approval. The licensee. amendment-

request is presently being processed within.the lice'nsee's organization.

This change will be submitted to the NRC'in the near future.

- The NRC inspectors evaluated the new organization'to ascertain

whether the offsite technical support staff, functions.were performed.'

by qualified personnel in accordance with licensee approved.

administrative. controls.

The NPG, under the Vice-President, Production, has~ direct

responsibility for the operation'of CNS including providing technical- ->

support to the CNS site. -.The Nuclear Engineering and Construction

Division (NED) has direct responsibility'to provide offsite

technical support to CNS.

The NED is. comprised of six major disciplines.in the areas of-

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Electrical,' Mechanical, Civil / Structural, Projects. & Construction,

Configuration' Management:and Nuclear Fuels: Department. 'The NED

provides technical support for station operation and maintenance.

These activities are under the direction'of the Division Manager'who

reports directly to the Vice= President of Nuclear Power Group,

Production. 'It is the' responsibility of this group to ensure'and "

verify the safe, reliable,'and efficient operation of the station and

the adequacy and accuracy of records kept concerning the technical

aspects of operation. The engineering work requests for modification

to the plant or.' equipment are evaluated by this group.

The NED. consists of 67 individuals with specialized experience.

Members of the engineering staff are required to have as a minimum a

Bachelor's' degree in engineering or in an appropriate field. The

average total experience of the NED staff is 12.45 years with

approximately 4 years with CNS. The NRC inspector nottd that the

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majerity of the engineering staff are registered professional

engineers.

Review of personnel records and interviews with various members of'

the offsite technical staff did not identify any questions or

inconsistencies concerning individual qualifications. Each

department and group maintained administrative procedures which

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? described the responsibilities, lines of communication, and

interfaces with site personnel and organizations.

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The engineering work requests can be generated by anybody at CNS

and are reviewed by the applicable system engineer and department.

manager.at the site before submittal to the NED. 'The assigned design

engineer has the total responsibility from the beginning to the

c completion of the task. If the assigned task involves more' than

-$150,000s then the appropriate engineering services are contracted.

Design packages are prepared on the bases of.a 12 month refueling'

cycle. The nonoutage work packages are prepared at least 90 days

before they are required. The outage packages are prepared at least-

60 days before an outage. Consultants are used to prepare the

packages; these consultants are hired in time to allow them to meet

the scheduled outage dates. The licensee also stated that some

consultants are used year-after year. The licensee does not have a

qual.ified fire protection engineer on the staff but is considering

such an addition. A contractor, Engineering Project Management.(EPM),

is the licensee's permanent consultant for the fire protection

issues.

The turnover rate in the NED has been minimal. The turnover rate

was 2.4 percent in 1987 and 6.1 percent in 1988. It was noted that

the turnover rate included an individual who left the engineering

division for promotion wi Din the licensee's organization.

No violations or deviations were identified in the area of

organization and staffing.

b. Training (40703)

The NRC inspector reviewed the licensee's training program for.the

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offsite technical staff in the NED. 'The licensee implemented a new-

training plan on July 8, 1988, which the NRC-inspectors found to be

acceptable. All new engineering staff members. are required to spend

a minimum of 6 months at the site before coming into the NED. All

staff engineers are required to attend sixty hours of~ video taped-

seminars on the respective systems of the CNS. . The staff members are

also encouraged to: attend the seminars.such as EPRI and INP0

meetings.

No violations or deviations were identified in the area of training,

c. Interfaces with Internal and External Organizations (37700 and 40703)

The NRC inspectors performed an inspection of the licensee's

interfacing policies and procedures related to internal and external

. coordination in the" design and engineering activities of the CNS.

The NED is the primary design engineering department within the

district's NPG, located at the NPPD facilities in Columbus, Nebraska.

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h Two additional engineering organizations', operations; engineering'and

plant engineering, may provide design engineering,- but have

operational support and maintenance support as their. primary activities.'

Both plant" engineering-and operations engineering are in the

. Technical: Department of.the Nuclear Operations Division'(N0D) located

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n s. at the CNS site.- -Both NED and N0D ultimately; report to the Manager, '

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NPG, a'nd all three engineering organizations share.the common task ofJ

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providing. engineering support to CNS.. ,

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The NRCj nspectors reviewed the principal CNS engineering procedures ,

'which prescribe the engineering policies and activities. -These-

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proceduras included CNS Engineering Procedure 3.1, '" Engineering

Interfaces," and CNS Engineering Procedure l3.4, " Station Design

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During the' review',' the NRC inspectors examined ~ additional, associated

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l administrative directives and procedures (delineated in Attachment 1).

!?' and verified that engineering interfacing responsibilities.and j

activities included the following: .

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Timelyidentification,"evaluationandresolutkonofproblemsand:

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Interfacing work assignments'between corporate and site- l

engineering staffs.

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Engineering organization involvement in evaluation and >

resolution of LERs, 10 CFR Part 21 reports, NRC reporting

requirements, and NRC Bulletins. ')

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Evaluation and resolution of< issues generated within thei .;

engineering organizations and issues generated by-other .

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organizations; e.g., plant staff, QA/QC. ,

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Engineering reviews and activities associated with plant

G information with regard to equipment / component history and-

trending.

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During the inspection, the NRC inspectors interviewed several NED

staff engineers to ascertain their familiarity with the plant

site, frequency and purpose of plant visits, and opportunities for . ,

system walk-downs. The NRC inspectors had no significant concerns i

resulting from those interviews. l

During the inspection, the NRC inspectors met with the cognizant NED

licensing representative for the purpose of determining engineering

interfacing activities associated with external organizations. The ,

licensee representative provided the NRC inspectors with a-copy of j

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the "BWR Owners Group Activities and Participation Commitment

Summary," which reflects those committees in which NPPD participates

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~ as a member.- In' addition, the'NRC inspectors discussed NPPD :

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interfacing. activities with other. external.organizationsLand' owner-

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No violations or deviations'were identified.

- d .- Design Changes and Modifications (37700 and 37701)

- The NRC inspectors evaluated the results'of the. engineering / technical

support efforts through the review of completed engineering tasks.

The NRC inspectors reviewed the CNS procedures appli'able c to the

o NED

and found them to be of acceptable detail and content. .The reviewed ,

! procedures are listed in Attachment 1. The NRC inspectors noted,.

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however,;that the 3.4 series procedures:had'all been' revised (and new

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procedures added) in December 1988. The NRC inspectors were informed

L .e that most of.the. requirements which appears in the new, more task

specific' procedures, had been included as' parts of larger

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procedures.

The NRC. inspectors then selected a number of' design changes for

detailed review from a listing of those which~had been_ implemented on- ,

the RHR system. The NRC inspectors chose a system approach in order

to obtain'a variety ofetypes of design changes (DCs). 1The RHR system

was' selected because of its'importance to safety in both normal and-

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accident operating conditions. -The inspectors reviewed the DCn

packages to verify that procedural and regulatory requirements had

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been. fulfilled. The types of. items the NRC. inspectors ve'rified

included evaluations-for 10 CFR 50.59 determinations, proper

NRC reporting requirement considerations, fire protection and

.equipmentLqualification considerations, and calculation-

- checks.-In addition,'the NRC inspectors verified acceptable-

levels of' review and approval of the DC, including any changes to the

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original DC, and that closure of the DC included required.

procedure / drawing revisions and personnel training.

The following DCs to the;RHR system were selected from the licensee ~

provided list of changes to the RHR, service water, core spray, and

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high pressure coolant injection. systems. ^

DC 76-079 Addition-of Flow Restricting Orifices to the RHR-

Pump Discharge Liries -

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DC 76 aa5 Addition of Pressurization Valves

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DC 77-017 Addition of Loss of. Voltage Sensing Relays for

RHR/LPCI Motor Operated Valves (MOVs).

DC 77-053 . Addition of Test Jacks to the Motor Control

FCenters (MCCs) for RHR Suction Valves

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'DC 77-055 Addition of Reset Push' Buttons for' Testing RHR

-Valves

DC 77-089 Addition of Leak Test Connection for RHR

Containment Penetration Valves

.DC 86-111 Modification of RHR Pumps' Impeller Wear. Ring

DC 86-125 Removal of RHR Pump Minimum Flow Line Orifice

DC 86-148 Upgrade of Power Supply Cable and Fuses for RHR,

MOVs

DC 88-024 Modification of RHR Piping-Supports

With the exception of DC 76-079, which was the most technically.

involved modification reviewed, the NRC inspectors found the above

'DCs to be acceptable. "In a number of cases the NRC inspector

requested clarifying information. This information was usually in

the form of supplemental evaluations. Some problems with drawing

revision following completion of modifications were observed and are

discussed below.

DC 76-79. ,

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1 The addition of orifices to the RHR pump discharge lines, which was

implemented by DC 76-79, was recommended by General Electric >

Company (GE) in their letter to NPPD, RHL-76-156 dated August 2,

1976. The recommendation was made to provide additional flow

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resistance in each RHR pump discharge line which would,.in turn,

provide runout protection for the pump during the low pressure

coolant injection (LPCI) mode of operation. The GE letter went on to

recommend that when these pumps are used in the containment spray

mode that: " Hydraulic calculations should be performed to evaluate

possible flow limits due to the added resi;,tance.and to evaluate the

necessity of removal of some spray nozzles if the pressure drop

available at the nozzles is insufficient to permit proper droplet

formation. Although unlikely, the shutdown cooling mode may be

affected. This mode should be evaluated via testing or hydraulic  ;

calculation to verify that the present shutdown rated flow is not [

reduced by the added orifices."

The NRC inspector requested the results of the GE recommended i

hydraulic calculations and was shown a copy of a Burns and Roe

evaluation. That evaluation, however, concluded that the containment

spray flow rate would be 3.8 percent lower than the previously

assumed flow rate. The NRC inspector then requested the evaluation

of the acceptability of the lower flow rate. The NRC inspector was

informed on February 1, 1989, that the analyses which had been

performed concluded that containment spray flow was not required to

mitigate unacceptable containment responses to an accident. The NRC

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! inspector verified that USAR Section 6.3'.3.3 included'a Case D study l

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which concluded acceptableLresults for no containment spray. j

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The NRC inspector had also questioned how the addition of!the;  !

. orifices to the RHR pumps' discharge" lines had been' reported to the' ,

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NRC and was provided a copy of the NRC Safety Evaluation approving

the' proposed change and a-copyLof the NPPD Annual Operating'_ Report

forl1976 (letter to NRC dated _ March 1,.1977) which documented the1

completion- of the modification. *

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' ~ Additionally, tb? NRClinspector questioned how the operability of the

orific.es was be %g verified;11.e., how was' erosion and/orEcorrosion l .

monitored. .Ik w rector was provided a copy ~of Surveillance .

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Procedure 6.34 : which required monthly; fullsflow (>7700 gpm) tests

of the RHR pumps. .This test would provide assurance of-ac.ceptable

minimum flow rates but.not acceptable maximum flow rates. The NRC'

inspector was unable.to determine how maximum flow rates 'or. orifice

condition was being' monitored. The NRC' inspector was subsequently ^

informed that;the licensee would develop a surveillance test to

ensure proper' orifice performance.

i~ In order' to evaluate the RHR system configuration following the

installation of the flow restricting orifices, the NRC inspector; .

reviewed the' Piping;and Instrument ~ Drawing (P&ID) contained in the

USAR. .The NRC inspector noted, however, that'this modification, and

the modification implemented by.DC 76-085 had not been incorporated.

I onto the P&ID; USAR. Figure IV-8-2, Revision No.'l dated September 21,

1978. The NRC inspector was informed that a similar. problem had been

recently discovered.by licensee personnel on a separate system. The

problems apparently'resulted from the existence of two sets of P&IDsg

one developed by Burns and Roe, the other by GE. The plant operators

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use the Burns & Roe P& ids. Licensee engineering personnel showed the. >

inspector that the Burns and Roe.P&ID (Drawing No. 2040, Revision N18-

dated July 10,1985) had been revised to include the modifications

and informed:the NRC inspector that the Burns and Roe P& ids were

utilized by both engineering and operations personnel.

The existence of drawings in the USAR which had not been

revised to include the effects of changes made in the facility is an

apparent violation of 10 CFR Part 50.71(e). Since the licensee had

initiated corrective actions and since'the violation was of minor

safety significance, no Notice of Violation is being issued in

accordance with Section V.A. of the NRC's Enforcement Policy.

The NRC inspector noted a similar occurrence during the review of

the Configuration Management Plan which is discussed in paragraph 4,

r below. Neither of the P& ids involved in that, problem, however, were

included in the USAR.

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e. Quality Ass'urance Audits (37702)

The NRC inspectors performed an inspection of the licensee's QA

audits.' conducted during 1987 and 1988 that were applicable to design

activities. The licensee schedules an annual audit of design' control

which was verified by reviewing ~the 1988 and 1989 audit schedules.

The annual. audit performed by-the licensee exceeds the 24 month

auditing requirement.specified in Section'6.0 of the TS. Two audit

reports were celected for review to verify that annual audits were

performed, aucitors were qualified, audit findings were reported to

senior management, corrective actions were implemented in a timely

fashion, and trend analyses were performed on audit findings. The

two audit reports selected are listed below:

. Audit'#87-01;lDesignControl,.datedMarch30,1987

Audit #88-02;< Design Control, dated 0ctober 21, 1988

The auditi were performed in accordance with the general guidelines .

of QA Instruction QAl-5 and the1 requirements of QA Plan QAP-1700 for

conducting audits of DC. The qualifications of two auditors and two

lead auditors who participated in the audits selected above were-

reviewed. The qualifications of the audit personnel were consistent

with the requirements specified in the NPPD QA Division Training and

Qualification Programi 'The scope of the audits were generally

programmatic in nature; however, the audits also incorporated QA - ,

surveillance, that had been performed since the previous audit,

which included technical assessments of performance. The audit

findings were reported to senior management staff at the plant and

the corporate office. Negative audit findings were assigned to

specific management personnel for resolution with a. response _due date

for corrective action. The resolution of audit findings for the-

above audits were reviewed and the dispositions were considered

thorough. The corrective actions for the audit findings were

considered to be implemented in a timely fashion. The audit and

surveillance findings'were trended in the audit reports and the

quarterly trend analysis.

No violations or deviations were identified.

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4. ConfigurationManagementPlan(407031

The NRC inspectors discussed the Configuration Management Plan for the.CNS

with involved licensee personnel to gain an understanding of the scope and

schedule for this undertaking. The NRC inspectors were informed that the

concept of design criteria collation was approved by NPPD in mid-1986. An

early review was performed on the core spray system (approximately

500 manhours of effort) in early 1987 and an independent review of the

high pressure coolant injection system is planned for early 1989

(approximately 1250 manhours).

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The present. NPPD plan;is~ divided .into four parts which work together and -

utilize information- from each other. The four parts include: As-Built'

Drawing Walkdowns, Data Base Management,', Design Cri_teria. Development' and

Probabilistic. Risk Analysis (PRA). . The NRC inspectors wereLinformed that

the as-built' effort had been completed on 79 drawings- and.had been

scheduled to be completed for; the remaining drawings (approximately;

p 2700 drawings) included in the program by mid-1993. The. licensee was-

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utilizing; original design criteria documentation in PRAs' to establish

component'and system priorities within the plan._' The NRC inspectors were

informed that' difficulties-were being encountered because NPPD lacks a

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considerable amount of the original design documentation. ~The NRC

inspectors were'also informed /that the implementation of the plan was

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being controlled by existing facility procedures.but that new interfacing,

' computer software QA and.PRA procedures would be developed.

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NPPD had

established mid-1994 as the completion schedule for.the plan.

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The NRC _ inspectors reviewed some of the findings from the as-built

activities. - The consultants performing the walkdowns report identified

problems to NPPD by. letter along with a recommended corrective action.

One of the walkdown findings was similar-to the violation described in

paragraph 3.d. When the emergency diesel generator ' air header system was

reviewed, the consultants' discovered differences between the Burns and Roe

-P&ID (Drawing 2077) and the vendor P&ID'(Drawing KSV-36-7). This problem-

was discussed in the consultants report, APA Problem'No. 5346, with the

recommendation that the vendor drawing be corrected. ~The NRC1 inspectors'

found the problem reporting and the_ resolution activities to be acceptable.

The-NRC inspectors quostioned the' completion schedules, especially'for the;

'as-built program, and were informed that NPPD' considered the time frame to'

be comparable to other such industry efforts. The NRC inspectors noted

that NPPD would.be in the Region IV office during the week of February 6,_

1989, to discuss the plan with~NRC management.

No violations or deviations were identified.

5. Exit Interview (30703) ,

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• An exit interview was conducted on January 27, 1989, with licensee

representatives (identified'in paragraph 1).

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During this interview, the

NRC inspectors reviewed the scope and findings of the inspection. Other

meetings between the NRC. inspectors and licensee management were held i

periodically during the inspection to discuss identified concerns. The

licensee did'not identify as proprietary any information provided to, or

reviewed by, the NRC inspectors'.

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ATTACHMENT

LIST OF DOCUMENTS REVIEWED

, CNS Procedure 0.5.3, Revision 0,r" Licensee Event Reports"

CNS Procedure 0.10.1, Revision 3, " Operating Experience Review"

CNS Procedure 1.10,~ Revision 2, " Document' Control"

CNS_ Engineering' Procedure'3.1, Revision 2, " Engineering' Interfaces"

- CNS Engineering' Procedure 3.2, Revision 2, " Systems Engineers and Engineering'

Specialists"

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CNS Engineering Procedure 3.3, Revision 8, " Station Safety Evaluations"

CNS Engineering' Procedure 3.4, Revision 8, " Station Modifications"

CNS Engineering Procedure 3.4.1, Revision 0, " Engineering Work Request and'

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Authorization"

CNS Engineering Procedure 3.4.2, Revision 1, " Basis of Design Document"

CNS Engineering Procedure 3.4.3, Revision 0, " Design Change"

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CNS Engineering Procedure 3.4.4, Revision 3, " Temporary Design' Change"

CNS Engineering Procedure 3.4.5, Revision 0, " Equipment Specification Change"

CNS Engineering Procedure 3.4.6, Revision 0, " Design Review' Checklists"

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CNS Engineering Procedure 3.4.7, Revision 0, " Design Calculations" _

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CNS Engineering Procedure 3.4.8, Revision 0, " Design Verification"

CNS Engineering Procedure 3.4.9, Revision 0, " Implementation and Acceptance

Testing Activities"

CNS Engineering Procedure 3.4.10, Revision 0, " Revisions, Amendments, and

On-The Spot Changes"

! CNS Engineering Procedure 3.4.11, Revision 0, " Status Reports"

CNS Engineering Procedure 3.4.12, Revision 0, "DC/ ESC Completion Reports"

CNS Engineering Procedure 3.11, Revision 1, " Vendor Contract for Verification

f' and Manuals"

CNS Engineering Procedure 3.20, Revision 0, "10 CFR 21 - Reporting of Defects

and Noncompliance"

CNS Surveillance Procedure 6.3.5.5, Revision 15, "RHR Pump Operability Test" l

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QA Instruc' tion.QAI-5, Revision 27,'" General Guidelines . Quality Assurance- -j

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.QA' Procedure QAP-1700, Revision 6, " Design Changes'(Major & Minor)"

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NPPD Quality Assurance " Division Training and. Qualification Program,"

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