ML20248C212

Ack Receipt of in Response to 890608 Notice of Violation Re Insp Rept 50-298/89-19.Util Basis for Denial of Violation Not Substantiated & NRC Concludes That Violation Did Occur

ML20248C212
Person / Time
Site:	Cooper
Issue date:	08/03/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8908090458
Download: ML20248C212 (2)

See also: IR 05000298/1989019

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[ , 'In Reply Refer.To:

, Docket: 50-298/89-19

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Nebraska Public. Power District

ATTN

. George.A. Trevors

,. Division. Manager - Nuclear Support

P.O.! Box /499

Columbust Nebraska'l68602-0499

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. Gentlemen-

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'Thank you for.your letter of July,5,1989, in response to our letter and. Notice l

of Violation dated ~ June 8,1989... As.a result of our review, we find that your .

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• 7 basis for the' violation denial is not substantiated. This was discussed with

,you during'a telephone call on August 1.1989. Specifically, your basis for

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tthe violation' denial is that you do not believe that noncalibrated instrumentation-

jeopardized the operability.of required systems or components.

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,, The Technical Specifications.(TS) at a ruclear facility include a listing of ^ '

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specific instrumentation that is, required to be calibrated. This listing does

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' not, nor was it ever intended to cover, the calibration of all the instrumentation

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) required.to verify, proper operation or operability of all. systems or components.

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1 To assure that 'all the instrumentation needed for proper system or component

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operation 31s calibrated, the TS require the implementation of additional

b ' calibration programs.v These programs exist at CNS in the form of your

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Surveillance. Test; Program and your Preventive Maintenance (PM) Program.. <

- During the performance of Inspection 50-298/89-19, the inspector selected

' instrumentation that was used in. test procedures and an emergency procedure to

either operate the equipment or to determine equipment operability. The test'

procedures selected ~are used to verify-the operability of the emergency diesel

generator (EDG)-(SP 6.3.1.2.1. EPG Operability Test Procedure) and the core

spray-(CS) system (SP 6.3.4.1, CS Operability Test).

The lube oil filter inlet and outlet pressure gauges discussed in the

inspection report are used as a. parameter to determine EDG operability. If

these gauges are not periodically calibrated, a degradation in lube oil filter

. performance may not be detected, potentially'resulting in an EDG-failure. The

local electrical meters discussed in the report are used in your Emergency

Procedure 5.2.1 (for shutdown outside the control room). If these meters were

out-of-calibration, improper EDG operation could occur, again resulting in

potential EDG failure.

The ammeter used to measure the motor current for the CS pump motor is utilized

in Procedure SP 6.3.4.1 as part of the inservice test data. This data is used

to ensure that the pump operability is not degrading. The failure to periodically

calibrate-this instrument could result in not detecting pump degradation and

. potential pump failure.

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Nebraska Public Power District -2-

You state in your response that you have determined that additional instrumentation

is required to be calibrated. Our findings and your acknowledgement that

additional instrumentation requires calibration clearly represents a weakness

in your PM progrem. We therefore conclude that a violation did occur.

Your response letter discusses the actions you are taking to correct this

situation and provides an acceptable schedule for completion of those actions.

We find these actions responsive to the concerns raised in our Notice of

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Violation. Consequently, we find your response to be adequate and no

r additional response to this violation is necessary.

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We will review the implementation of ycur corrective actions during a future

inspection to determine that full compliance has been achieved and will be

maintained.

Sincerely,

giginal Sipd W

g, L, hhlhoan

' 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

bcc to DMB (IE01)

bcc distrib. by RIV:

RRI R. D. Martin, RA

Section Chief (DRP/C) Lisa Shea, RM/ALF

RPB-DRSS MIS System

RIV File Project Engineer (DRP/C)

PSTS Operator DRP

P. O'Connor, NRR Project Manager (MS: 13-D-18)

DRS P. Wagner

T. Stetka A. Singh

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CNSS895796  ;

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July 5, 1989 'l I '

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U. S. Nuclear Regulatory Commission ~~~ f

Attention: Document. Control Desk -

Washington, DC 20555

Subject: NPPD Response to Inspection Report 50-298/89-19

Gentlemen:

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

violation.

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

with 10CFR2.201.

Statement of Violation

' Technical Specification (TS) 6.3.3.D requires test procedures for the

routine calibration of instrumentation used to verify equipment

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 and outlet pressure gauges, and the

voltage, frequency and current meters for the Emergency Diesel

Generators, which are specified to be used for a shutdown from

outside of the Control Room; and

2. The motor current ammeter for the Core Spray System Pumps, which is

specified for use during routine surveillance tests.

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l This is.a Severity Level IV violation. (Supplement 1)(298/8919-01)

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L -' Reason for Violation'

' Installed instrumentation at Cooper Nuclear Station (CNS) is calibrated

by-one of two programs: the Surveillance Test Program or the

l . Preventative Maintenance (PM) Program. As noted by the Inspector in

Appendix B of the inspection report, the Surveillance Test Program, which

D covers the calibration of instruments listed in the Technical

L Specifications,-is'a good program and, furthermore, he ". . . found both

L the calibration frequency and the functional test coaplexity to be more

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than usually experienced." The District. agrees with the Inspectors'

comments and is confident.that the Surveillance Test Program adequately

j addresses Technical Specification-related instrumentation in its

P' 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 instrumentatf.on which must be calibrated (per the PM

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, therefore, is the lack of clear, documented

guidance on which. instruments should, and which should not, be included

in the PM Program.

Regarding the apparent violation of.CNS Technical Specifications, it is

our' opinion that no violation occurred. The instrumentation included

within the' Technical Specifications is intended to assure that the

necessary quality of systems and components is maintained to ensure

nuclear safety, 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 weakneas 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 NOV (i.e., the Surveillance Test Program adequately addresses the

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CNSS393796

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instrumentation contained in the Technical Specifications, while the 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 procedur2 is currently under development to integrate the various

programmatic e.lements 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 for reviewing

installed instrumentation used to monitor safety related equipment and

ensuring that each instrument is either included in the Surveillance Test

Program or PM 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 thL

procedural requirements, and the subsequent calibration of the

instruments, will be completed prior to startup from the 1990 D.efueling

Outage. This time frame is necessary since it is anticipated that soms

added instrt ments may require shutdown conditions to adequately calibrate

them, and 3.s justif'.ed since the existing program has proven adequate to

date regarding actual equipment operability.

Should you have any ques * ions concerning this matter, please contact my

office.

Sincerely,

G. . Trevors

Division Manab-- of

Nuclear Support

GAT:sg:ju

ec: kd.S.NuclearRegulatoryCommission y

Regiona' Office - Region IV {

NRC Resident Inspector

Cooper Nuclear Station

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