ML20246G344

Insp Rept 50-298/89-25 on 890701-31.Violation Noted.Major Areas Inspected:Previously Identified Items,Ler Followup, Operational Safety Verification & Monthly Surveillance & Maint Observation

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: ML20246G320 ML20246G333 ML20246G344
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: DPR-46

Docket: 50-298

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Licensee': Nebraska Public Power District (NPPD)

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.P.O. Box 499

Columbus, Nebraska 68602-0499

' Facility .Name: Cooper' Nuclear Station (CNS)

-Inspection At: CNS, Nemaha County, Nebraska

Inspection Conducted

July 1-31,1989

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: / _ &5 1

G.W ConstabM, Chief 3- Project Section C Date~

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) 1

,7 Areas Inspected:- Routine, unannounced inspection of followup on previously -

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

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(improper ~ records storage of permanent QA records, paragraph 3).

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

Areas with Training Expired - The. inspector reviewed immediate corrective ]

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actions and activities being implemented to prevent recurrence. The ]

inspector verified that Nuclear Training Guideline (NTG) 113. " Site Access l

Monthly Report," Revision 0, dated December 2,1988, provided guidance for  !

' identifying overdue training and for transmitting this information to  !

BCCess Control. I

As stated in the licensee's response to the violation, an upgrade of the ,

records system was being implemented. A consultant was hired in l

March 1989 to review the existing training records system. This report,  :

published in April 1989, recommended revalidation of existing records, ,

development of record keeping procedures, and improved computer data entry

and reporting capabilities.

'The inspector reviewed ongoing activities relative to revalidation of

l. existing records. From discussions with the training manager and the i

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

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

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has not'had a fire hazards analysis conducted to determine the combustible

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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l 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. In

addition, the licensee committed to replace those relay coils, which were

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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 I

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

safety question existed.

The inspectors verified that selected ectivities of the licensee's

radiological protection program were implemented in conformance with

I 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

surveillance observed

procedures p(erformance of and/or reviewed the following

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

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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October 21, 1988

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.

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No violations er deviations were identified.

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- 4

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.

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

vibration readings identified on Service Water Booster Pump "A." The

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"

s 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 -

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

failure to haveconcluded that thesimilar

firm Lttachment p(ointtocontact of the stick-type

the magnetic probe, the

probe), and

variables introduced by different people using the stick-type probe .i

created the higher readings. The licensee intends to change the procedure

to specify measurements in the horizontal plane with a magnetic probe and i

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  !

(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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