ML20245H113
| 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
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AUG
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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
bectoDMB(IE01)
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Nebraska Public Power District
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July 19, 1989
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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:
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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
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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.
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Contrary to the above, on May 18, 1989, the NRC inspector found Main
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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
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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.
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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-
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. 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
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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,
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'A review of the design change has shown the instructions were vague, since
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they only required the squib valve to be " electrically disarmed" without
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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
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connector pins with copper wire has proven to be an unsafe practice. What'
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actually' occurred was.that 1) the primer chamber wa; electrically disconnected
'from the firing circuit, and 4) the copper nice wee wrapped around the
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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
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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
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Explosive (Squib) Valve Insert Replacement", to confirm circuit operability.
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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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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.
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This event will be reviewed by all NPG engineering and CNS craft
personnel.
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'A permanent change will be made to Maintenance Procedure 7.2.25 to
confirm circuit operability through the use of resistance verifications
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whenever the squib valves are replaced.
Date Of Full Compliance
The corrective steps noted will be implemented and full compliance achieved by
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October 1989.
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if you have any questions regarding this response, please contact me or
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G. R. Horn at the site.
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Sincerely,
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G. A. Trevors
Division Manager of
Nuclear Support
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CAT:GRH:REW:ya
ec:b'U. S.; Nuclear Regulatory Commission
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Region IV
Arlington, Texas
NRC Resident Inspector
Cooper Nuclear Station
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