ML20248C212
| 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:
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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
. Gentlemen-
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'Thank you for.your letter of July,5,1989, in response to our letter and. Notice
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of Violation dated ~ June 8,1989... As.a result of our review, we find that your .
- 7 basis for the' violation denial is not substantiated. This was discussed with
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,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.
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
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' calibration programs.v These programs exist at CNS in the form of your
Surveillance. Test; Program and your Preventive Maintenance (PM) Program..
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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.
RIV:C:PSS* ~
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8908090458 890803
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Nebraska Public Power District
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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
Violation. Consequently, we find your response to be adequate and no
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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
P. O'Connor, NRR Project Manager (MS:
13-D-18)
P. Wagner
T. Stetka
A. Singh
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CNSS895796
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& I O 1989
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July 5, 1989
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U. S. Nuclear Regulatory Commission
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Attention: Document. Control Desk
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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
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The motor current ammeter for the Core Spray System Pumps, which is
specified for use during routine surveillance tests.
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This is.a Severity Level IV violation. (Supplement 1)(298/8919-01)
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-' Reason for Violation'
' Installed instrumentation at Cooper Nuclear Station (CNS) is calibrated
by-one of two programs:
the Surveillance Test Program or the
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. Preventative Maintenance (PM) Program. As noted by the Inspector in
Appendix B of the inspection report, the Surveillance Test Program, which
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covers the calibration of instruments listed in the Technical
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Specifications,-is'a good program and, furthermore, he ". . . found both
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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
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addresses Technical Specification-related instrumentation in its
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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
kd.S.NuclearRegulatoryCommission
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Regiona' Office - Region IV
{
NRC Resident Inspector
Cooper Nuclear Station
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