IR 05000298/1987028

Insp Rept 50-298/87-28 on 871101-30.Violations Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings, ESF Walkdown,Monthly Surveillance & Maint Observations & Operational Safety Verification

ML20237E775
Person / Time
Site:	Cooper
Issue date:	12/15/1987
From:	Bennett W, Madsen G, Plettner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237E763	List: IR 05000298/1987028 ML20237E761 ML20237E771
References
50-298-87-28, NUDOCS 8712290182
Download: ML20237E775 (8)

Text

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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/87-28 License: DPR L6 Docket: 50-298 Licensee: Nebraska Public Power District (NPPD)

P. O. Box 499 Columbue, NE 68601 Facility Name: Cooper Nuclear Station (CNS)

Inspection At: Cooper Nuclear Station,'lemaha County, Nebraska Inspection Conducted: November 1-30, 1987 Inspectors: -

/2 !3 87 E. A. Plettner, Resident Inspector, (RI) Date[

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W. R. Bennett, Senior Resident Inspector, (SRI) Date Approved: N 4 U /2[///F7 G. L. 6ds'en, Acting Chief, Project Section C, Date Reactor Projects Division 8712290182 871221 PDR ADOCK 05000298 G PDR

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-g-Inspection Summary Inspection Conducted November 1-30, 1987 (Report 50-298/87-28)

Areas inspected: Routine, unannounced inspection of licensee actions on previous inspection findings, engineered safety feature walkdown, monthly surveillance and maintenance observations, operational safety verification, and radiological protectio Results: Within the areas inspected, two violations were identified (failure to follow procedures, paragraph 3, and failure to maintain secondary containment integrity, paragraph 6).

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-3-DETAILS Persons Contacted Principal Licensee Employees

• R. Horn, Division Manager of Nuclear Operations

• L. Peaslee, Surveillance Coordinator

• M. Norvell, Maintenance Manager

• D. Black, Operations Supervisor

• E. Smith, Quality Assurance Manager

• Brungardt, Operations Manager

• E. M. Mace, Engineering Manager

• L. E. Bray, Regulatory Compliance Specialist The NRC inspectors also interviewed additional licensee employees during the inspection period,

• Denotes those present during exit interview conducted on December 1, 198 . Licensee Action on Previous Inspection Findings The following open and unresolved items were reviewed by the NRC inspector to verify that the licensee's responses to the items identified in previous inspection reports are now in conformance with regulatory requirements and corrective measures were completed in a timely manne (Closed) Open Item 298/8627-08: Technical Specification (TS) Management Change - This item involved recent organizational changes implemented by NPPD which required subsequent CNS TS revision in the following areas:  ;

Paragraph 6.1 Organization {

Paragraph 6.2 Review and Audit j Figure 6. NPPD Nuclear Power Group Organization Chart j Figure 6.1.2 CNS Organization Chart j The District initiated action to update the TS as Change No. 45. In a letter to the Senior Resident Inspector, CNS, dated October 29, 1987, the NRC Office of Nuclear Reactor Regulation (NRR) confirmed the change submittal and recommended that~the item be closed. The NRC inspector reviewed Change No. 45 and concurs that the item be closed on the basis that it is a licensing issue to be resolved by NR .

I This item is close (Closed) Unresolved Item 298/8704-03: Records Documenting Performance of Procedure 7.3.1 - This item involved records relating to Maintenance Procedure (MP) 7.3.1 " Protective Relays Setting and Testing,"

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-4-Attachments "B," "C," and "D." -The licensee was unable to retrieve the requested. records within the 4-day time frame covered by the inspectio The records requested covered three testing. periods for the following:

u Attachment "B" performed each refueling cycle (covering 3 years)

Attachment "C" performed each second refueling cycle (covering 6 years)

1 ' Attachment "D" performed each third refueling cycle (covering 9 years)

The records were located and presented to the NRC inspector for revie The review revealed that MP 7.3.1, Attachments "B," "C," and "D" had been performed as required for three testing period This item is close . Engineered Safety Feature (ESF) Walkdown The NRC inspectors performed an independent walkdown of the Service Water (SW) System supply to the Reactor Equipment Cooling and Residual Heat Removal Systems. The inspection was performed to verify operability, to confirm that licensee system lineup procedures match plant drawings and the as-built configuration, and to identify equipment conditions or items that might degrade system performanc In> preparation for performing the walkdown of the service water system, the NRC inspectors conducted a. review of and a comparison between the following licensee system checklist and applicable as-built drawing:

. System Operating Procedure (SOP) 2.2.71, " Service Water System,"

Revision 21, dated October 8, 1987, Appendix "A," Valve Checklist, Revision 18

. As-Built Drawing Burns and Roe 2036 for Service Water System During the performance of the system walkdown the NRC inspectors noted that Valve SW-195 " Service Water / Demineralized Water (SW/DW) crosstie

.tell-tale drain" was incorrectly positioned as required by the Valve Checklist. The NRC inspectors informed the licensee of the incorrectly positioned valve and asked for an explanation. The licensee explained

.that the valve had been shut because leakage was detected in the lin The licensee had not issued a Work Item Tracking (WIT) request or an Equipment Clearance or Release Order to tag the valve with a caution ta Thus, the licensee had no means of tracking the trouble in the SW/DW crosstie lin CNS Procedure 0.4, " Preparation Review and Approval of Procedures,"

Revision 10, dated October 14, 1987, states that approved written station procedures shall be adhered to by all station personne _ - _ - ._-__-_ __ _ _ _ -

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I-5-Procedure 2.2.71, Appendix "A" " Valve Check 1 tst" lists the required position of valves in the Service Water System. Procedure 0.9, " Equipment Clearance and Release Orders," Revision 5, dated May 14, 1987, requires a ]

caution tag to be issued when any station personnel discover or recognize an abnormal condition where there is a need for additional instructions in regard to the safe operation of station equipment. A licensee representative stated that in this particular case a WIT, as required by Maintenance Procedure 7.0.1,. Revision 9, dated October 29, 1987, should j have been issued to determine the leaking valve and to repair as necessary. The licensee's failure to issue a Caution Tag and WIT as required by procedure is an apparent violation (298/8728-01).

The purpose of SW-195 is to control pressure in the cross connect piping !

and to indicate when one of the cross connect isolation valves develops j seat leakage. The NRC inspectors determined that SW-195 being closed did '

not effect operability of the system in that the system could still perform its intended function ,

The licensee, when notified of the error, initiated prompt corrective action and issued a caution tag and WIT on November 18, 198 No other violations or deviations were identified in this are . Monthly Surveillance Observations The NRC inspectors observed and/or reviewed the performance of Surveillance Procedure (SP) 6.3.3.1, "High Pressure Coolant Injection (HPCI) Test Mode Surveillance Operation," SP 6.3.13.2, " Safe Shutdown Emergency Lighting Functional Test," SP 6.3.12.4, " Diesel Fuel 1 011 Availability," and SP 6.3.12.1, " Diesel Generator Operability Test". i

. SP 6.3.3.1, "HPCI-Test Mode Surveillance Operation," Revision 22, l

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dated October 29, 1987: This surveillance was performed on November 4,1987, to meet the HPCI pump operability requirements of TS. The NRC inspector observed that the procedure was performed in a i professional manner by personnel qualified to perforn the test who ,

were cognizant of the surveillance requirements. Testing was performed in accordance with the procedure and suggestions to improve :

the procedure were made utilizing a procedure change form. Test results were verified by the NRC inspector to conform with TS and ,

procedure requirement . SP 6.3.13.2, " Safe Shutdown Emergency Lighting Functional Test,"

Revision 3, dated July 30, 1987: This surveillance was performed between October 30 and November 9,1987,- and reviewed by the NRC inspector on November 10, 1987. The NRC inspector determined that all acceptance criteria was met and deficiencies identifie Deficiencies were properly reviewed and resolved, and retesting was satisfactorily completed. The NRC inspector noted that three temporary procedure changes, dated October 30, November 2, and November 4,1987, were initiated and incorporated into the procedur i

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-6-Some confusion existed concerning the applicability of temporary procedure changes during performance of part of the procedure on November 9. The NRC inspector held discussions with licensee personnel concerning the applicability of temporary procedure changes when procedures are performed after the issuance of a temporary procedure change. The licensee has agreed to review the temporary change procedure to clarify when temporary procedure changes are applicable during subsequent performance of procedures. This clarification is considered an open item (298/8728-02).

. SP 6.3.12.4, " Diesel Fuel Oil Availability," Revision 12, dated June 11, 1987: This surveillance was performed on November 22, 1987, to verify'the amount of diesel fuel available as required by TS. The NRC inspector observed that the surveillance was performed in accordance with the applicable procedure and that discrepancies were properly documented and explained in the procedur . SP 6.3.12.1, " Diesel Generator Operability Test," Revision 21, dated July 30, 1987: This surveillance was performed on November 23, 1987, to verify diesel generator operability as required by TS. The NRC inspectors observed that all prerequisites were met and communications maintained throughout the test. The procedure was performed properly and operators were cognizant of the surveillance requirement No violations or deviations were identified in this are . Monthly Maintenance Observation The.NRC inspectors verified that the maintenance activities were conducted in accordance with approved procedures, regulatory guides and industry i codes or standards and in conformance with Technical Specification The.following station maintenance activities of safety-related systems and components were observed and reviewed by the NRC inspectors on the indicated dates:

November 16, 1987: Work Item (WI) 87-3501 RWCU-A0-FCU-15A and WI 87-3493 Filter Demin Unit A Dome Drain November 16-19, 1987: Design Change 87-069 Gamma Tip Installation i November 25, 1987: WI 87-3595 Breaker for RHR Pump C No violations or deviations were identified in this are . Op_erational 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 maintaine . - -

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-7-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. Maintenance requests were reviewed to verify that appropriate priority was assigned and that the maintenance was performed in a timely manne On November 17, 1987, at approximately 8 a.m., while operating at steady state power, an increase above normal operating temperatures in the generator for "8" Reactor Recirculation Motor Generator (RRMG) set was noted by control room personnel. Reactor operators decreased reactor power in an attempt to decrease generator temperatures. Decreasing reactor power did not result in decreasing generator temperatures. At 9:27 a.m. , reactor operators tripped "B" RRMG set because temperatures were continuing to increase to a level where damage to the equipment was imminent. Subsequently, the licensee cleaned and replaced the brushes on the generator. Upon completing this corrective maintenance, at 2:31 p.m.,

"B" RRMG Set was restarted and placed into service.- Generator temperatures were monitored and normal operating temperatures were observed. At 4:38 p.m., the "A" RRMG set was removed from service to clean and rebrush the generator. At 6:22 p.m., "A" RRMG Set was restarted and placed into service. The NRC inspectors observed the licensee's actions during the occurrence including the proper use of General Operating Procedure (G0P) 2.1.10, " Station Power Chanaes," Revision 14, dated April 30, 1987, andSystemOperatingProcedure'(S0P)2.2.68,

" Reactor Recirculation System," Revision 27, dated March 19, 1987 Tours of accessible areas at the facility were conducted to confirm

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operability of plant equipment including the fire suppression syste:as and other emergency equipment. The NRC inspectors performed a partial walkdown of the service water syste Results of this salkdown are ,

documented in paragraph 3 of this report. Facility operations were ;

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performed in accordance with the requirements established in the CNS Operating License and T During a tour, on November 9, 1987, the NRC inspectors noted that the inner door to the reactor building railroad air lock was open. Upon entering the airlock the NRC inspectors noticed light passing through the 1

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seal between the rail and the outer airlock door. Closer examination by the inspectors revealed that several gaps existed between the outer door and the ground. These gaps, in conjunction with the open inner door, constitute a failure to maintain secondary containment integrity. Failure to maintain secondary containment integrity with the reactor critical is 1 an apparent violation of TS 3.7.C.1 (298/8728-03).

When informed of the problem, the licensee took immediate action to repair the gaps that existed in the outer doo I i

No other violations or deviations were identified in this area.

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L-8- Radiological Protection Observations The NRC inspectors verified that selected activities of the licensee's radiological protection program were implemented in.conformance with facility policies, procedures, and regulatory requirements. Radiation work permits contained appropriate information to ensure that work could be performed in a safe and controlled manner. Personnel in radiation controiled 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 contaminatio .No violations or deviations were identified in this are . Exit Interviews An exit interview was conducted on~ December 1, 1987, with licensee representatives -(identified in paragraph 1). During this interview, the senior resident inspector and the resident inspector reviewed the scope and findings of the inspectio >

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