ML20246D461
| ML20246D461 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/05/1989 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS895796, NUDOCS 8907110339 | |
| Download: ML20246D461 (3) | |
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COOPER NUCLEAR STATION
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.1 CNSS895796.
July'5, 1989-t Ij U. S. Nuclear Regulatory Commission
. Attention: Document Control Desk Wash'ington, DC 20553 R
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Subject:
NPPD Response to Inspection Report 50-298/89-19 l
- q Gentlemen; j
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1 This-letter is written in response to your letter dated June 8, 1989, which transmitted' Inspection Report No. 50-298/89-19.
Therein, you identified a l
. violation.
Following is the statement of violation and our response thereto in accordance with 100FR2.201.
j Statement of Violation j
Technical Specification (TS) 6.3.3.D requires test procedures for the routine calibration of instrumentation used to verify equipment j
operability.
Contrary to the above, there were no. test procedures for the routine calibration of the following instrumentation used to verify equipment operability:
1.
The-lube oil filter inlet rnd outlet pressure gauges, and the voltage, frequency and current meters for the Emergency Diesel
.l Genclocors, which are specified to be used for a shutdown from j
outside of the Control Room; r..id 1
2.
The motor current ammeter for the Core Spray Systen. Pumps, which is specified for use during routine surveillance tests.
This is a Seveg ty Level IV <folation. (Supplement 1)(298/8919-01) i l
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i CNSS895796 EJuly 3, 1989
.Page 2 i
Reason for Violation Installed instrumentation at Cooper Nuclear Station (CNS) is calibrated 1
by one of two programs:
the Surveillance Test Program or the Preventative Maintenance (PM) Program. As noted by the Inspector in Appendix B'of the inspection report, the Surveillance Test Program, which covers the calibration of instruments listed in the Technical Specifications, is a good program and, furthermore, he ".
found both the calibration frequency and the functional test complexity to be more than usually experienced." The District agrees with the Inspectors' comments and is confident that the Surveillance Test Program adequately addresses Technical Specification-related instrumentation in its entirety.
The scope of instrumentation which must be included in the Surveillance Test Program can be readily determined by a review of the Technical Specifications. On the other hand, determining the scope of the remaining station instrumentation which must be calibrated (per the FM Program) is not as easily identified.
The instrumentation which is presently contained in the PM Program was identified in the past in order to fully meet the intent of Section 6.3.3.D of the Technical Specifications. However, the criteria used in making this determination were judgemental and have not been well documented. As a result, it has not been possible to determine definitely why the instrumentation noted in the Notice of Violation was not included in the PM Program.
The reason for the violation, theref're, is the lack of clear, documented guidance on which instruments should, and which should not, be included in the PM Pregram.
Regarding the apparent violation of CNS Technical Specifications, it is our opinion that no violation occurred. The instrumentation included within the Technical Specifications As intended to assure that the necessary quality of systems and components is maintained to ensure nuclear oafety, and our program for calibrating this instrumentation was recognized as being very good. We acknowledge that additional instrumentation is required to be calibrated and our PM Program does require a significant amount.
In order for a violation of Technical
. Specifications to have occurred, however, we believe that it would have to be shown that instrumentation which was not included in the PM Program would have actually jeopardized the operability of required systems or components. To date, we do not believe this has been the case.
Corrective Steps Which Have Been Taken And The Results Achieved In response to the noted calibration program weakness when it was identified during the exit interview, an upgrade effort was immediately initiated.
The CNS Senior Manager of Operations was assigned to obtain any required assistance, evaluate the various calibration program elements, and develop an integrated program control document. An initial review was conducted which substantiated the general findings addressed in the NCV (i.e., the Surveillance Test Program adequately addresses the L-
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CNSS895796 a
July 5, 1989 Page 3 instrumentation contained in the Technical Specifications, while che FM Program does not address all other instrumentation used to monitor safety related equipment). As a result, a knowledgeable consultant was retained to review the overall program and provide recommendations for correcting existing discrepancies. This effort is described in more detail below.
Corrective Steps Which Will Be Taken To Avoid Further Violations A procedure is currently under development to integrate the various programmatic elements which comprise the overall CNS Calibration Program.
When completed, this procedure will contain clear guidance as to which station instruments will fall within the Calibration Program.
The procedural requirements will then be used as a basis fet reviewing installed instrumentation used to monitor safety related equipment and ensuring that each instrument is either included in the Surveillance Test Program or FM Program, or that documented justification is provided as to why it is not.
Date When Full Compliance Will Be Achieved The aforementioned procedure will be approved for implementation by September, 1989. The review of station instrumentation against the procedural requirements, and the subsequent calibration of the instruments, will be cor.pleted prior to startup from the 1990 Refueling Outage. This time frame is necessary since it is anticipated that some added instruments may require shutdown conditions to adequately calibrate them, and is justified since the existing program has proven adequate to date regarding actual equipment operability.
Should you have any questions concerning this matter, please contact my office.
Sincerely, G.
. Trevors Division Manager of Nuclear Support GAT:sg:ju cc:
U.S. Nuclear Regulatory Commiss.)n Regional Office - Region IV NRC Resident Inspector Cooper Nuclear Station
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