ML20148N222

Insp Rept 50-298/88-06 on 880201-29.Violations Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings, Operational Safety Verification,Ler Followup,Ie Bulletin 84-02 Followup,Monthly Surveillance & Maint Observations

ML20148N222
Person / Time
Site:	Cooper
Issue date:	03/28/1988
From:	Bennett W, Holler E, Plettner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148N188	List: ML20148N222
References
50-298-88-06, 50-298-88-6, IEB-84-02, IEB-84-2, NUDOCS 8804060397
Download: ML20148N222 (9)

See also: IR 05000298/1988006

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APPEN0!X 0

f) , S . MK L E M REGUL COP.Y C0."J:15510h

REGION !Y

NRC Inspection Report: 50-293/88-06 License: DPR-46

Cockat: 50-298

1.icensee: Nebriska Public Power District (NPPD)

P. O. Box 499

Columbus, NE 68601

facility hame: Cooper NJelear Station (CN5)

Inc,pection At: Cooper Nuclear Station, Nmah County, Nebraska

Inspection Conducted: February 1-29, 1988

Inspectors .

. M. IT[th _

E. A. Plettner, Destdent !v rector, (RI)

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E. J, Iblier, Chie.', Prejc:t wtion C,

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Date

Reactor Projects Division

8804060397 000329

PDR ADOCK 05000290

G PDR

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I Inspection Summary  ;

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! Inspection Conducted through, 1987 (Report 50-298/86-06) l

Areas Insoected: Routine, unannounced inspection of licensee actions on  !

previous inspection findings, operational safety verification, licensee event i

report followup, IE Bul?; tin 84-02 followup, monthly surveillance and i

maintenance observations, radiological protection, and security.

Results: Within the areas inspected, three violations were identified

(failure to vei *y jet pump operabili e, paragraph 3, failure to follow fire

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protection p.o adures, paragraph 3, and failure to perform adeqr '

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DETAILS

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1. Persons Contacted

Principal Licensee Employees  !

• G. R. Horn, Division Manager of Nuclear Opere'ons .

"J. M. Heacham, Senior Manager, Technical Supp., I

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• LuAnn Bray, Regulatory Compliance Specialist

• G [. Smith, Manager, Operations Quality Assurance

• R. D. Black, Supervisor, Operations

• D M. Norvell, Manager, Maintenance

• M. D. Hamm, Supervisor, Security  !

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'R. Brungardt, Manager, Operations

• E. M. Mace, Manager, Engineering i

The NRC inspectors also interviewed other licensee employees during the l

course of the inspection.

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• Denotes tnose present during exit interview March 1, 1988, t

2. Licensee Action on Previous Insrection Findings  ;

(Closed) Violation 298/8601-01: Failure to Have Procedures for ,

Preventative Maintenance. [

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This item involved the lack of Preventative Maintenance (PM) procedures l

for all of the plant equipment that could affect nuclear safety. Cooper  ;

Nuclear Station did not have pr( iures which pre;cribed the manner in i

which the existing PM program ht , ten developed, or which required the e

station program to be maintained trent with changing vendor [

recommendations. Corrective acu taken by the licensee was to initiate

a PM upgrade program. The prograu nsisted of comparing the existing

station PM requirements to the ven, recommendation, and resolving the

differences either by generating ..e PMs or surveillance procedures, or by

an engineering evaluation to provide a doct.mented disposition for not

performing vendor recommended actions. The NRC Resident Inspector (RI)

reviewed Cooper Nuclear Station's Operation Manual Procedure 0.24

"Generating and Dispor.itioning Vendor Manual Change Requests," Revision 2

dated July 30, 1987, and CNS Procedure 0.25, "Vendor Manual Change Order

Review and Approval," Revision 3, dated December 23, 1987 to verify that

formal procedure controls for maintaining the program were implemented.

Vendor manuals relating to plant equipment that could affect safety were

reviewed to verify that vendnr manual updates had been received.

This item is closed.

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(Closed) Open Item 8724-01: Labeling Deficiencies

This item identified labeling deficiencies among System Operating

Procedures (SOP) 2.2.23, "120 V/240 V AC Instrument Fower System,"

Revision 14, dated December 28, 1986, Appendix "B" Breaker and Fuse Index,

Revision 12; S0P 2.2.24, "250 V DC Electrical System," Revision 13, dated

February 6,1986, Appendix "B" Breaker and Fuse Index, Revision 10;

S0P 2.2.25, "125 V DC Electrical System," Revision 16, dated February 20,

1987, Appendix "B" Breaker and Fuse Index, Revision 10; and 50P 2.2.26,

"24 V DC Electrical System," Revision 7, dated March 5,1987, Appendix "B"

Breaker and Fuse Index, Revision 4. The licensee's corrective actions

were to issue correct labels on the breaker boxes and submit new revisions

to Appendix "B" for each of the S0Ps listed above. The RI reviewed the

latest revisions to the'above S0Ps dated January 14, 1988, and compared

those revisions to various breaker panels to verify that licensee's

corrective actions were completed and adequate.

This item is closed.

3. Operational Safety Verification

The NRC 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 NRC inspectors observed selected shift turnover meetings

and noted that information concerning plant status was communicated to the

oncoming operators.

On February 7,1988, the NRC Senior Resident Inspector (SRI) observed a

reactor startup. The plant had experienced a reactor scram on January 28,

1988, which was documented in NRC Inspection Report 50-298/87-33. All

conditions for startup were properly met and documented in General

Operating Procedure (GOP) 2.1.1.2, "Technical Specification Pre-Startup

Checks," Revision 7, dated December 10, 1987. The startup was conducted

in a controlled, professional manner in accordance with GOP 2.1.1, "Cold

Startup Procedure," Revision 48, dated December 10, 1987.

Some difficulty was initially encountered in verifying normal jet pump

indication as required by GOP 2.1.1.2 and jet pump operability as required

by Technical Specification (TS) 3.6.E.1. The December 10, 1987, revision

to GOP 2.1.1.2 added a reference to CNS Surveillance Procedure (SP) 6.2.4.1,

which does the daily jet pump operability check. When the surveillance

test was run, it failed. Subsequently, TS requirements were met when log

readings for the previous startup were compared with actual readings. The

SRI asked operations personnel how jet pump operability had been verified

for previous startups and was informed that it had generally not been done

until the reactor was at power. Subsequent questioning of other senior

operators verified that the TS was not specifically checked until the

reactor was at power, however, several operators stated that they checked

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jet pump differential pressure to verify it was normal prior to startup.

This failure to verify jet pump operability prior to startup is an

apparent violation (298/8806-01) of TS 3.6.E.1.

Tours of a:cessible 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 TS.

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On February 8,1988, the NRC inspector was performing a normal routine

plant inspection. While reviewing fire extinguisher monthly inspection

tags for fire extinguishers located on electric welders and oxygen-

acetylene welders, it was noted that inspections had not been performed

during the month of January. Review of SP 6.4.5.17, "Fire Fighting

Equipment Monthly Inspection," Revision 14, dated July 16, 1987, performed

January 1988, confirmed that the monthly inspection had not been periormed

on fire extinguishers located on electric and oxygen-acetylene welders.

Interviews conducted with the individuals involved verified that the

surveillance procedure had not been performed.

The results of the interviews indicate the rocc cause of the missed

surveillance to be both a programmatic problem and a personnel error. The

programmatic problem is that no formal program exists to alert other

individuals of surveillance requirements when the regularly assigned

person is not available for an extended period of time. The personnel

error in this case was that the individual regularly assigned for

scheduling the surveillance forgot to update his desk calendar when the

new year started. The desk calendar was the means he used to identify the

time frame for the surveillance.

Failure to perform SP 6.4.5.17, "Fire Fighting Equipment Monthly

Inspection," Revision 14, dated July 15, 1987, Attachment "A," for fire

extinguishers located on vario u electric and oxygen-acetylene welders

during January 1988 is an apparent violation. (298/8806-02)

The RI reviewed the test results of completed SP 6.4.5.17 covering the

time from August 1987 to January 1988. During the review it was noted

that the "verified-by" block had not been initialed as completed on page 3

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of Attachment E for 23 entries for the inspection performed during the

month of December 1987. The "verified-by" block had not been initialed as

completed on page 3 of Attachment E for 1 entry for the inspection

perfonned during January 1988. The documents were reviewed by the

surveillance coordinator and reviewed and signed by the system engineer.

The RI reviewed the test results of SP 6.4.5.1, "Fire Protection System

monthly Inspection," Revision 44, dated March 19, 1987, and Revision 45,

dated December 17, 1987 performed from August 1987 to January 1988.

During the review it was noted that an out-of-specifications reading was

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recorded in Attachment "A," page 7, Section E, performed on December 19,

1987. The main output amps reading for fire protection tank 1A was

recorded as 0.16 amps with the limits printed next to the reading as

(0-0.15 amps.) This procedure was reviewed by a shif t supervisor and the

surveillance coordinator, and reviewed and signed by the system engineer.

The SRI reviewed GOP 2.1.1.2 "Technical Specifications Pre-Startup Checks,"

Revision 7, dated December 10, 1987, performed on February 7,1988.

During the review it was noted that Item 13 on page 5 was not signed as

completed. This procedure was reviewed by the shift supervisor. The

procedure does not require review in addition to that of the shift

supervisor. The NRC inspectors were able to determine through interviews

that the SPs and G0P had been completed as required. Failure to perform

an adequate review of the SPs and G0P identified above is an apparent

violation. (298/8806-03)

No other violations or deviations were identified in this area.

4. Licensee Event Report (LER) Followup

(Closed) LER 87-009, "Unanticipated Reactor Scram and Group Isolations Due

to Low Reactor Vessel Water Level Caused by Inadvertent Manual Trip of the

Operating Reactor Feedwater Pump."

This event occurred when a station operator (nonlicensed) locally tripped  !

the only running reactor feed pump during a local trip test for placing

the second feed pump in service. This action resulted in a low reactor

water level scram. Normal scram recovery procedures were implemented and

the plant was placed into cold shutdown. A contributing factor to this

event was a lack of human factor labeling of plant components and

equipment. Corrective actions taken by the licensee included:

(a) discussion of the event with operations department shift personnel

during weekly meetings, (b) a comprehensive review of plant  :

component / equipment identification and the marking for human factors

consideration, and (c) an engineering evaluation to determine the basis

for the local trip test. The RI reviewed attendance forms for weekly

meetings for operations department shift operating personnel and

interviewed sev-~1 operators to verify that the event was discussed with

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the required personnel. The licensee completed the plant

component / equipment identification program in December 1987. All major

plant components were appropriately labeled with large placards painted on

the item to clearly mark the component. The licensee through its

engineering evaluation determined that the local trip test should be

performed during a startup after a planned outage. System Operating

Procedure (S0P) 2.2.28, "Feedwater System," Revision 43, dated July 1,

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1987, contained the appropriate revision.

This item is closed,

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5. IE Bulletin 84-02

IE Bulletin 84-02 concerns failures of General Electric Type HFA relays in

use in class 1E safety systems. The licensee, in Letter NLS8400018, dated

July 16, 1984, committed to replace all HFA relays assnciated.with

safety-related systems at CNS during the Fall, 1984 refueling outage.

This bulletin was interpreted by the licensee to require changeout of AC

HFA relays only. This bulletin was closed out in NRC Inspection Report

50-298/84-20.

During review of the bulletin, the licensee determined that the bulletin

required replacement of all (AC and DC) HFA relays. This error was

discussed by the licensee with the SRI, and the licensee committed to

issue a supplemental response to IE Bulletin 84-02 explaining the

additional actions which will be taken in response to the bulletin. The

bulletin is considered open for purposes of tracking.

No. violations or deviations were identified in this area.

6. Monthly Surveillance Observations

The NRC inspectors observed and reviewed the performance of Surveillance

Procedure (SP) 6.3.5.1, "RHR Test Mode Surveillance Operation,"

SP 6.2.4.1, "CS Test Mode Surveillance Operation," SP 6.3.5.5, "RHR Pump

Opersbility Test," and SP 6.3.3.1, "HPCI Test Mode Surveillance

Operation."

SP 6.3.5.1 "RHR Test Mode Surveillance Operation," Revision 26, dated

October 8, 1987; SP 6.3.4.1, CS Test Mode Surveillance Operation,"

Revision 21, dated September 11, 1987; and SP 6.3.5.5, "RHR Pump

Operability Test," Revision 15, dated October 8, 1987. These

surveillances were performed on February 7, 1988, to prove

operability after testing and maintenance (described in paragraph 7

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of this report), and prior to startup. SP 6.3.5.5 verified

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operability of RHR Pump "B' and flow verifications for Pump "B" and

loop "B" (pumps "B" and "0"). These surveillances were performed by

qualified operators who were cognizant of all surveillance

requirements. Limiting conditions for operations were properly

entered for the surveillance testing. .The SRI observed that the

operators performing the tests were aware of all precautions

associated with the tests, and performed the tests in accordance with

applicable procedures. All data was properly reviewed and verified

! to be acceptable per the procedures and TS.

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The RI observed in its entirety the performance of SP 6.3.3.1, "HPCI

l Test Mode Surveillance Operation," Revision 27, dated October 29,

1987. The surveillance was performed on February 24, 1988, to meet

the HPCI Pump Monthly Operability Requirement of TS. Testing was

performed by two licensed reactor operators in accordance with the

procedure which included minor changes as designated by a temporary

procedure change notica The operators performed the procedure in a

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professional manner and were cognizant of all procedure requirements.

The NRC Resident Inspector reviewed the completed procedure to verify

that all test results conformed with TS and procedtre requirements.

No violations or deviations were identified in this area.

7. Monthly Maintenance Observation

The NRC inspectors verified that the maintenance activities were conducted

in accordance with approved procedures, regulatory guides, and industry

codes or standards and in conformance with Technical Specifications.

The SRI monitored maintenance action associated with "B" Residual Heat

Removal (RHR) pump. On January 28, 1988, "B" RHR pump breaker tripped

when the pump was started to transfer water following the reactor scram

which occurred on the same day. Troubleshooting determined that there was

a ground in the motor. The motor was subsequently removed and saipped to

General Electric tc determine the source of the ground. It was

subsequently determined that there was an "end turn" ground on one of the

coils of the motor. No root cause for the ground has been determined as

yet. To ensure that the ground was not associated with other ECCS pumps,

the licensee performed a polarization index mea:;urement on all ECCS pump

motors to evaluate the insulation. In additica, an AC hipot test was

performed on RHR pump "C" and "D" motors to demonstrate ample ground wall

insulation strength. After testing proved operability of all other ECCS

pumps, RHR "B" pump motor was replaced with another motor whict was

equivalent. The new motor was qualified by the licensee and replaced in

accordance with Design Change 88-071 "RHR Pump Motor Replacement" and

Maintenance Work Request 88-0598.

No violations or deviations were identified in this area.

8. Security

The NRC inspectors observed security personnel perform their duties of

vehicle, personnel, and package search. Vehicles were properly authorized

and escorted or controlled within the protected area (PA). The RI

reviewed an employee time report for assigned security personnel for

February 10, 1988. The review was performed to verify that manning

requirements stated in the security plan in the CNS operating license were

in compliance. Site tours were conducted by the NRC inspectors to ensure

that compensatory measures were properly implemented as required because

of some nonfunctional security equipment. Tha PA barrier had adequate

illumination and the isolation zones were free of transient m'aterial.

No violations or deviations were identified in this area.

9. Radiological Protection Observations

The NRC inspectors verified that selected activities of the licensee's

radiological protection program were implemented in conformance with

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facility policies, procedures, and regulatory requirements. Radiation

work permito contained appropriate information to ensure that work could

be performed in a safe and controlled manner. Personnel in radiation

controlled areas were wearing the required personnel monitoring equipment

and protective clothing. Radiation and/or contaminated areas were

properly posted and controlled based on the activity levels within the

area. Radiation monitors were utilized to check for contamination.

No vic ions or deviations were identified in this area.

10. Exic Interviews

An exit interview was conducted on March 1, 1988, with licensee

representatives (identified in paragraph 1). During this interview the

SRI and the RI reviewed the scope and findings of the inspection.

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