ML20245H113

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/89-18

ML20245H113
Person / Time
Site:	Cooper
Issue date:	08/04/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8908160318
Download: ML20245H113 (1)

See also: IR 05000298/1989018

Text

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. AUG 41989

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In Reply Refer To:

Doc ~ket: 50-298/89-18

TNebraska Public Power District

-ATTN:- George A. Trevers

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Division Manager - Nuclear Support

-P.O. Box 499

' Columbus, Nebraska' 68602-0499

Gentlemen:

Thank you for your letter of July 19, 1989, in response to our letter and

Notice of-Violation dated June 22, 1989. We have reviewed your reply and find

it responsive to the concerns raised in our Notice of Violation. We will

review the implementation of your corrective actions during a future inspection

to determine that full compliance has been achieved and will be maintained.

Sincerely,

4

James L. Milhoan, Director

Division of Reactor Projects

cc:

Cooper Nuclear Station

ATTN: Guy Horn, Division Manager

of Nuclear Operations

P.O. Box 98

Brownville, Nebraska 68321

Kansas' Radiation Control Program Director

Nebraska Radiation Control Program Director

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U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

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Washington, DC 20555

Subject: NPPD Response NRC Inspection Report No. 50-298/89-18

Gentlemen:  !

This letter is written in response to your letter dated June 22, 1989,

transmitting Inspection Report No. 50-298/89-18. Therein you indicated that

certain of our activities were in violation of NRC requirements.

Following is the statement of each violation and our response in accordance

with 10CFR2.201.

Statement Of Violation

Failure to Follow a Safety Procedure

10 CFR Part 50, Appendix B, Criterion V, states, in part, that

" Activities affecting quality shall be prescribed by documented -

instructions, procedures or drawings, of a type appropriate to the

circumstances and shall be accomplished in accordance with these

instructions, procedures, or drawings."

CNS Procedure 0,9, " Equipment Clearance and Release Orders", Revision 7,

dated February 23, 1989, specifies that the clearance order procedure

provide a means of safely isolating equipment fo: repairs.

Contrary to the above, on May 18, 1989, the NRC inspector found Main f

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Steam Line Drain Outboard Isolation Valve MS-MO-77 shut while

danger-tagged open by Clearance Order 89-442. In addition, Clearance

Order 89-827 utilized one tag to isolate seven valves for performance of

maintenance.

This is a Severity Level IV violation. (Supplement 1)(298/8918-01)

Reason For Violation

Main Steam Line Drain Outboard Isolation Valve MS-MO-77 was opened and the

control switch danger tagged per CNS Procedure 0.9, " Equipment Clearance And

Release Orders", to provide for water drainage from the Main Steam Isolation

Valve-(MSIV) cavity during performance of Equipment Specification Change (ESC)89-122. ESC 89-122 was being implemented to upgrade the Main Steam Isolation 'h

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, U.'S Nuclear R2guletory Commission  !

, July 19, 1989

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Valve stem and disc on Main Steam Lines B, C. und D. A Group I primary

containment isolaticn signal caused MS-MO-17 to close which was contrary to

the desired position per the Equipment Clearance and Release Order

(C0 89-442), The identified weakness in our clearance order procedure was

that it did not provide adequate instruction for isolating equipment which

received automatic isolation signals where personnel safety was not the

primary concern.

Several Clearance Orders, including Clearance Order 89-827, were issued to

isolate individual Control Rod Drive (CRD) Hydraulic Control Units (HCU)

during the refueling outage for maintenance. Only one danger tag was hung per

HCU to address that all the necessary valves to isolate the HCU were closed

for the maintenance activities. Although System Operating Procedure 2.2.8,

" Control Rod Drive System", specifies the proper sequence to isolate the HCU

and was used to tag out the HCU, it did not provide the level of safety

necessary to ensure the valves remained isolated while the maintenance

activities progressed.

Corrective Steps Which Have Been Taken And The Results Achieved

An additional danger tag was added to CO 89-442 to de-energize the power

supply to MS-MO-77 with the valve in the Open position. A Temporary Procedure

Change to 0.9, " Equipment Clearance And Release Orders", was immediately

initiated that instructed Operations personnel to tag out the motive force to

equipment, in addition to its control switch, to prevent automatic

repositioning of the equipment by an automatic initiating signal.

The Clearance Orders on the HCUs were released and the HCUs returned to proper

velve lineup per System Operating Procedure 2.2.8, since the maintenance

activities had been completed. -

Corrective Steps Which Will Be Taken To Avoid Further Violations

A permanent procedure change to CNS Procedure 0.9 was initiated and approved

by the Station Operations Review Committee on June 8, 1989. The procedure

change implemented the following additional instruction: "Any component that

can be automatically positioned or started and is operated by some motive

force (electric, air, etc.) should have, in addition to its control switch,

its breaker or air supply, etc., tagged in the position to preclude operation

of the component by an initiation signal."

A procedure change to System Operating Procedure 2.2.8 was initiated and is

currently in routing for approval by the Station Operations Review Committee.

The procedure has been revised to only allow the isolation of a HCU for

operational purposes utilizing one danger tag. A note has also been added to

the procedure to require all associated valves be tagged if maintenance is to

be performed.

Date When Full Compliance Will Be Achieved

Full compliance will be achieved by August 17, 1989.

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Stat'e Of Violation-

l~ . Inoperable Reactivity Control System

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Technical Specifications 3.4.b.1 allows continued operation for only 7

days.when'a redundant component in the standby liquid control system is

inoperable. '

l- Contrary to the above, the Squib Valve A, a redundant component, was made

.. inoperable on May 15, 1988, and remained inoperable until May of 1989.

The reactor operated in all Modes during that period.

This is.a Severity Level IV violation. (Supplement 'I)(298/8918-02)

Reason For The Violation- ,

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The reason for the violation was 1) inadequate instructions in the design

changes package, 2)' failure of craftsmen to follow the instructions in the

design change, and 3) lack of training associated with squib valves, i

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'A review of the design change has shown the instructions were vague, since l

they only required the squib valve to be " electrically disarmed" without '

specifying how'it was=to be accomplished. The intent was to have the primer

chamber disconnected from the firing circuit, thereby " disarming" the valve.-

.The design change also instructed the' craftsmen to review the. precautions in

the squib valve. vendor manual, which specifically states that shorting the ,

connector pins with copper wire has proven to be an unsafe practice. What' i

actually' occurred was.that 1) the primer chamber wa; electrically disconnected

'from the firing circuit, and 4) the copper nice wee wrapped around the '

connector. pins to disarm the primer chamber prior to its removal from the

' system. Therefore, the design change instructions were not adequate and the-

vendor manual precautions were not adequs%1y reviewed by the craftsmen, as ,

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specified.

Corrective Steps Which Have Been Taken And The Results Achieved

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Upon determining that the "A" Squib Valve had not fired, the surveillance

procedure for "B" Loop was successfully completed, including the firing of the

"B" Squib Valve. Following the investigation into the cause of the failure.

the shorting wire was removed from the "A" Squib Valve pins and the connector

reinstalled. The "A" Standby Liquid Control Loop was then tested

satisfactorily. Both squib valves were subsequently replaced and firing

s- circuit.resi ance checks were made in' accordance with a Temporary Procedure

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Change to Maintenance Procedure 7.2.25, " Standby Liquid Control System ,

Explosive (Squib) Valve Insert Replacement", to confirm circuit operability. I

Personnel involved with writing design changes have been informed of this

event and instructed to consider the following in all future design changes:

1) Avoid the use of vague words that are subject to interpretation, and 2)

Include all precautions in the design change when practical, rather than

referring to another document.

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/ , ' U. S. Nuclear R:gulatory Commission ~

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July 19, 1989

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Page 4

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Corrective Steps'Which Will Be Taken To Avoid Further Violations

1. 'A training session associated with the squib valves will be developed  ;

covering installation and operation, and provided to CNS craft personnel. j

2.- This event will be reviewed by all NPG engineering and CNS craft

personnel.

3. 'A permanent change will be made to Maintenance Procedure 7.2.25 to

confirm circuit operability through the use of resistance verifications -

whenever the squib valves are replaced.

Date Of Full Compliance

The corrective steps noted will be implemented and full compliance achieved by ,

October 1989. ,

if you have any questions regarding this response, please contact me or

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G. R. Horn at the site. 4

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Sincerely, l

G. A. Trevors

Division Manager of #

Nuclear Support

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CAT:GRH:REW:ya

ec:b'U. S.; Nuclear Regulatory Commission ,

Region IV

Arlington, Texas

NRC Resident Inspector

Cooper Nuclear Station

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