ML20246G344
| ML20246G344 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/15/1989 |
| From: | Bennett W, Constable G, Greg Pick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20246G323 | List: |
| References | |
| 50-298-89-25, NUDOCS 8908310313 | |
| Download: ML20246G344 (9) | |
See also: IR 05000298/1989025
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APPENDIX B
U._S.
NUCLEAR REGULATORY COMMISSION
REGION IV
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-NRC Inspection Report:
50-298/89-25
Operating License:
Docket:
50-298
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Licensee':
Nebraska Public Power District (NPPD)
.P.O.
Box 499
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Columbus, Nebraska
68602-0499
' Facility .Name:
Cooper' Nuclear Station (CNS)
-Inspection At:
- Inspection Conducted
July 1-31,1989
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Inspectors:
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G. A. ffpk/l\\ Resident Insg-tor, Project
Odte '
Sect %h G/, Division of Reactor Projects
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W. R. Bennett, Senior Resident Inspector
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Project Section C, Division of Reactor Projects
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Approved:
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G.W ConstabM, Chief - Project Section C
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Division of Reactor Projects
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Inspection Summary
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Inspection Conducted July 1-31, 1989 (Report 50-298/89-25)
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Areas Inspected:- Routine, unannounced inspection of followup on previously
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identified items,-licensee event report followup, operational safety
verification. and monthly surveillance and maintenance observations.
'Resultsf Within the areas inspected, cr.e apparent deviation was identified
(improper ~ records storage of permanent QA records, paragraph 3).
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The licensee demonstrated proactive planning by requesting a study to
demonstrate operation at higher-than-normal river water temperatures; however,
information in the initial justification for continued operation was not
comprehensive enough to demonstrate that safe operation could be assured. The
. licensee was taking initial steps towards establishing thermography as a
predictive maintenance tool.
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DETAILS
1.
Persons' Contacted
Principal Licensee Employees
- G.- R.' Horn, Division Manager of Nuclear Operations
- J. M. Meacham, Senior Manager Operations
- E. M.. Mace, Engineering Manager.
- J. V. Sayer, Radiological. Manager
'*R. Brungardt, Operations Manager
- J. W. Dutton, Training Manager
- R. L. Gardner, Maintenance Manager
'*G. E. Smith, Quality Assurance Manager
- G. R. Smith, Licensing Supervisor
- L. E. Bray, Regulatory Compliance Specialist
- M. Estes, Management Trainee
- Denotes those present during the exit interview conducted on
August 3, 1989.
The inspectors also interviewed other licensee employees and contractors
'during the inspection period.
2.
Plant-Status
The plant operated at essentially 100 percent power throughout the
inspection period.
3.
Followup on Previously Identified Findings (92702)
(0 pen) Violation (298/8831-01) Unescorted Access to Vital and Protected
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Areas with Training Expired - The. inspector reviewed immediate corrective
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actions and activities being implemented to prevent recurrence. The
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inspector verified that Nuclear Training Guideline (NTG) 113. " Site Access
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Monthly Report," Revision 0, dated December 2,1988, provided guidance for
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' identifying overdue training and for transmitting this information to
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BCCess Control.
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As stated in the licensee's response to the violation, an upgrade of the
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records system was being implemented. A consultant was hired in
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March 1989 to review the existing training records system. This report,
published in April 1989, recommended revalidation of existing records,
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development of record keeping procedures, and improved computer data entry
and reporting capabilities.
'The inspector reviewed ongoing activities relative to revalidation of
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existing records.
From discussions with the training manager and the
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training services coordinator, the inspector determined that formal
procedures were not created,' nor were they required, for revalidation of
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the existing records. However, oral instructions were provided to
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complement the record clerks' familiarity with the documentation to assure
that all required information was present on the records. The information
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required was determined by the training manager to be the " minimum amount
of information needed to make a complete record." The missing information
consisted of administrative type information such as course number, course
title, and revision number. The licensee stated that attendee names were
not added to.the training records. When information was missing from the
training foms, the clerks were required to gu to the responsible training
department supervisor to obtain the appropriate information. .The
supervisors were required.to initial next to the change indicating their
concurrence with the accuracy of the infomation.
Interviews with the
training department supervisors indicated that the missing information for
training records had been supplied at the request of clerks.
As revalidation of the training records was completed, the data on the
records was input to computer data base. Five temporary employees were
hired to input data related to the historical records. The data required
to be entered was requested by computer prompts, which provided "the
minimum amount of information needed to make a complete record." This
software package is an interim measure and a more comprehensive software
package is expected to be operational in September 1989, as committed to
ty the licensee. Concurrent with development of the training records,
computer software is the development of procedures for records receipt and
inspection, training file data entry, and preparation of training records
packages. These procedures will require, in part, that incomplete records
be returned to the department supervisor for completion prior to
acceptance in the records area,
The training department estinates an entry-on-duty date of August 1,1989,
for a " records specialist" who, the training manager stated, should bring
needed experience to continue enhancement and improvement of the training
records system.
The inspector reviewed the training audits for the past 2 years. The
training department was responsive to quality assurance (QA) findings and
QA observations contained in the 1987 audit. Responses to the 1988 audit
findings were_ being completed; however, the site QA organization was not
being apprised of the corrective action status. A memorandum, dated
May 30, 1989, from the QA Departmer.t to the Division Manager Nuclear
Support and the Division Manager of Quality Assurance indicated that
corrective actions had not been implemented by the scheduled due date.
The memorandum requested that new, estimated completion dates be provided
as soon as possible, but no later than June 15, 1989. The necessity to
issue this t.emorandum indicated a failure to request an extension in a
timely manner. Additionally, prior to the memorandum being generated,
several telephone contacts requesting an estimated completion date had
been made with no results. The inspector determined that estimated
completion dates had been provided to the QA Department by memorandum on
July 28, 1989, from the Division Manager Nuclear Support. The response
was 6 weeks late. The inspector noted that a QA Specialist had reviewed
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the corrective actions related to 'wo of the QA findings and determined
them to be acceptable.
The' inspector inspected the area where the training records are stored.
These records are not duplicated elsewhere and include some that are
considered QA records, such as records that support the qualification
status of licensed operators.
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- The records area has the outer building cinder block walls on two sides
and on the other two sides are interior temporary gypsum walls with
aluminum studs. The records are kept in file cabinets rated at 350'F for
I hour. Additionally, four sprinkler heads in the room are actuated at
165*F. The interior walls of the room are not coated with any sealant to
protect the records from moisture or condensation. The training building
has not'had a fire hazards analysis conducted to determine the combustible
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loading for the storage of records. There was no documentation indicating
that frames and hardwere have a 4-hour rating. The door for entry into
the room is made of wood. Additionally, a window is located in the room
with .no provisions to prevent vandalism.
ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance
of Quality Assurance Records for Nuclear Power Plants," specifies in
Section 5.5 conditions for safekeeping of records to prevent larceny and
vandalism and in Section 5.6 construction requirements of record storage
fccilities. Section 5.6 requires that: the walls are reinforced
concrete, concrete block, masonry, or equal construction; sealant be
applied over walls as a moisture or condensation barrier; an adequate fire
protection system be installed; and structures, doors, frames and hardware
be constructed to meet a 4-hour fire rating. The CNS Quality Assurance
Policy Document Section 2.6, " Document Control," connits the facility to
the requirements of ANSI N45.2.5-1974.
The failure of the training records storage area to provide protection
from larceny or vandalism and to be constructed in accordance with plant
comitments as described above is a deviation (298/8925-01).
The Nuclear Support Group was slow in responding to QA findings. Estimated
com.oletion dates for corrective actions were not provided as required by
procedure. Provisions are being implemented which should assure adequate
controls over training records when the computer system upgrade is
completed.
4.
Licensee Event Reports (LERs) Followup (92700)
(Closed) LER 88-023: This LER documents a Reactor Water Cleanup (RWCU)
System Valve Closure (Group 3 Isolation) due to relay failure. The cause
of the event was determined to be a failed General Electric Model CR 120A,
115VAC relay.
Immediate corrective action was to replace the failed relay coil.
In
addition, due to this failure and other similar CR 120A relay failures,
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the licensee determined that the expected inservice life of the CR 120A
relay coils is 12-15 years. The licensee subsequently placed all
safety-related CR'120A relay coils on a 10-year replacement cycle.
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addition, the licensee committed to replace those relay coils, which were
not changed out during'1988, prior to plant startup after the 1989
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Maintenance and Refueling Outage.
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=The inspector reviewed the licensee's documentation to ensure that all
mquired relay coils were replaced during the 1989 outage.
In addition,
the inspector verified that preventive maintenance items were established
to place required relay coils on a 10-year replacement cycle.
LERs88-012 and 88-025 document similar failures of CR 120A relay coils.
Cornctive action and closure are similar to that documented above.
The licensee demonstrated a good corrective action program in conjunction
with repetitive failures of CR 120A relay coils.
LERs88-023, 88-012, and 88-025 are closed.
5.
Operational Safety Verification (71707)
The inspectors observed operational activities throughout the inspection
period. Control room activities and conduct were observed to be well
controlled. Proper control room staffing was maintained. Discussions
with operators determined that they were cognizant of plant status and
understood the importance of, and reason.for, each lit annunciator. The
inspectors observed selected shift turnover meetings and noted that
information concerning plant status was communicated to the oncoming
operators.
Tours of accessible areas at the facility were conducted to confirm
operability of plant equipment including the fire suppression systems and
other emergency equipment.
Facility operations were performed in
accordance with the requirements established in the CNS Operating License
and Technical Specifications (TS).
In anticipation of the higher-than-cverage river water temperatures due to
continued drought conditions in the area, CNS contracted with General
Electric (GE) in May 1989 to evaluate whether the plant safety analysis
would be valid with river water temperatures as nigh as 90*F. The safety
analysis assumed an upper limit on the service water (SW) temperature of
85'F. The SW supply is river water and is used to provide cooling to
safety-related equipment such as the diesel generator room coolers, HPCI
lube oil, and reactor equipment cooling heat exchan
The licensee
wrote a Justification for Continued Operation (JCO)gers.
based on the GE report
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utilizing engineering judgement. NRC voiced concern about the lack of
quantitative data needed to provide perspective in the JCO, during a
conference call with CNS on July 13, 1989. NRC questioned whether
existing analysis supported their conclusions. A JC0 with additional data
was prepared on July 19, 1989. The data in the supplemental information
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supported the conclusions reached in their 10 CFR 50.59 analysis, which
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demonstrated the TS margin of safety was not reduced and no unreviewed
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safety question existed.
The inspectors verified that selected ectivities of the licensee's
radiological protection program were implemented in conformance with
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facility policies, procedures, and regulatory requirements. Radiation
and/or contaminated areas were properly posted and controlled.
Radiation work permits contained appropriate infomation to ensure that
work could be performed in a safe and controlled manner. Radiation
monitors were properly utilized to check for contamination.
The inspectors observed security personnel perform their cuties of
vehicle, personnel, and package search. Vehicles were properly authorized
and escorted or controlled within the protected area (PA).
The PA barrier
had adequate illumination and the isolation zones were free of transient
material . Site tours were conducted by the inspectors to ensure that
compensatory measures were properly implemented as required. Tne PA
barrier had adequate illumination and the isolation zones were free of
transient naterial.
During this period, the licensee completed work on the security systems
upgrade. The inspector witnessed portions of the testing on the upgrade
and walked down the system with licensee personnel. The licensee verified
the operability of the system prior to removing the protected area fence
guards who were being used for compensatory measures during the system
upgrade.
No violations or deviations were identified within this area. NPPD
demonstrated proactive planning by requesting the study for operating at
higher-than-normal river water temperatures; although the information in
the initial JC0 was not sufficiently detailed to provide assurance of safe
operation, the supplemental JC0 was found to be satisfactory.
6.
Monthly Surveillance Observations (61726)
The inspectors observed p(erformance of and/or reviewed the following
surveillance procedures SP):
SP 6.3.3.1, "HPCI Test Mode Surveillance Operation," Revision 32,
dated June 1, 1989
SP 6.ii'.8.3, "ARI and ATWS/RPT Reactor Vessel High Pressure
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Calibration and Functional Test," Revision 14, dated April 13, 1989
SP 6.2.2.1.3, "CSCS Reactor Low Pressure Valve Permissive Calibration
and Functional / Functional Test," Revision 18. dated November 18,
1988
SP 6.2.1.1, "PCIS Reactor Hich Pressure Calibration and
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Functional / Functional Test," Revision 15, dated September 11, 1989
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SP 6.3.4.1, "CS Test Mode Surveillance Operation," Revision 25,' dated
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SP 6.3.3.1 was w rformed on July 14, 1989, as the monthly TS operability
l test of.the higi pressure coolant injection (HPCI) pump. Test data was
- within specifications. The operator conducting the test was knowledgeable
about the precautions W limitations contained in the procedure.
SPs 6.2.8.3, 6.2.2.1.3, and 6.2.1.1 were conducted on July 14, 1989,'as TS
required functional tests of reactor protection instrumentation. The
instrunent and control (IkC) technician used proper radiological practices
and had good communication with his counterpart in the control room. He
had a good understanding of the ;arpose of the test. All test equipment
was properly calibrated. The I&C technician used caution'and good
judgenent during testing of these instruments.
SP 6.3.4.1 was performed on July 26, 1989, as a quarterly test which
included inservice test (IST) requirements as well as-TS required pump
operability requirements. Test activities were coordinated between the
reactor operator and the station operator. Pump vibration measurements
were taken by the qualified station operator with the magnetic probe. All
test data was within specifications. Proper approvals had been obtained
prior to' start of the test.
No violations er deviations were identified.
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7.
Monthly Maintenance Observation (62703)
The inspector observed a contractor performing thermography of both
recirculation pump motor generator exciter commutator rings to determine
-if any areas were at an elevated temperature, indicating a potential for
failure. Electrical engineering and electrical maintenance utilized these
services es a pilot predictive maintenance activity. The contractor had-
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taken infrared scans prior to the 1989 outage end identified several
components' with indications of elevated temperatures, including the
commutator rings. Repair or replacement of some identified parts occurred
during the outage. The contractor returned after the outage to verify
that corrective actions taken had resolved the identified deficiencies.
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Items which did not require immediate corrective actions were monitored
- for further degradation. The licensee is considering expanding this
program to include mechanical components.
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The< inspector-reviewed troubleshooting efforts related to the high
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vibration readings identified on Service Water Booster Pump "A."
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readings ~ were taken on July 18, 1989, during performance of SP 6.3.20.1,
"RHR Service Water Booster Pump Flow Test and Valve Operability Test,"
Revision 21, dated June 8, 1989. This IST was being performed monthly in
accordance with ASME Section XI requirements since the initial readings
taken on the installed spare rotating assembly were in the " alert" range.
The measurements indicated pump bearing vibrations were in the " action"
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range. All of the readings had been taken utilizing an unfiltered
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stick-type probe. Troub'ieshocting by the system engineer identified that
readings taken with the stick-type probe were erratic at the measuring
point; however, when the magnetic probe was used, the readings were in
agreement with the prior 2 months IST vibration measurements.
' Mechanics utilized a filtered stick-type probe and compared the readings
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to initial readings taken after installation of the rebuilt spare. The
new measurements indicated that the vibration at the points had slightly
decreased but were stili.in the alert range.
The licensee concluded that the p(oint contact of the stick-type probe, the
failure to have firm Lttachment similar to the magnetic probe), and
variables introduced by different people using the stick-type probe
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created the higher readings.
The licensee intends to change the procedure
to specify measurements in the horizontal plane with a magnetic probe and
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measurements in the vertical plane with the stick-type probe.
Initial
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values were taken using this arrangement. The licensee committed at the
exit to review other IST procedures to assure that proper instrumentation
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(stick versus magnetic, or a combination) is specified.
Inspector
followup of the licensee's review of other IST and actions to prevent
recurrenceisanopenitem(298/8925-02).
No violations or deviations were identified in this area. The licensee is
taking steps to implement thermography as a predictive maintenance tool.
8.
Exit' Interview (30703)
An exit interview was conducted on August 3,1989, with licensee
representatives identified in paragraph 1.
During this interview, the
inspectors reviewed the scope and findings of the inspection. Other
meetings between the inspectors and licensee management were held
periodically during the inspection period to discuss identified concerns.
The licensee did not identify as proprietary any information provided to,
or reviewed by, the inspectors.
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