IR 05000298/1986007

Insp Rept 50-298/86-07 on 860224-28.Deviation Noted: Engineers Not Documented as Trained by Applicable Procedures & Procedure Inadequate.Open Item Re Classification of Alternate Shutdown Sys Noted

ML20205P123
Person / Time
Site:	Cooper
Issue date:	05/12/1986
From:	Jaudon J, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205P110	List: ML20205P107 ML20205P119 ML20205P123
References
50-298-86-07, 50-298-86-7, NUDOCS 8605210166
Download: ML20205P123 (6)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC 'nspection Report: 50-298/86-07 License: DPR-46 Docket: 50-298 Licensee: Nebraska Public Power District P. O. Box 499 Columbus, Nebraska 68601

' Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS Site, Brownville, Nebraska Inspection. Conducted: F ruary 24-28 1986 Inspector- A4/ / 8d ~

9. M elll, PNject Engineer, Project Date S ect n A, Reactor Projects Branch Approved: /1// [///l C/

P Jau n, Chief! Pr6je~ct Section A, Dat'e R cto Projects Branch Inspection Summary

I Inspection Conducted February 24-28, 1986 (Report 50-298/86-07)

Areas Inspected: Routine, announced inspection of the actions taken with regard to previously identified inspection finding Results: Within the area inspected, one deviation was identified (inadequate preventive action).

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, Per' sons Contacted NPPD L. F. Bednar, Senior Staff Engineer R. D. Brown, I&C Specialist J. E. Dunn, Records Control Specialist R. Fentiman, Purchasing Analyst S. S. Freborg, Lead Mechanical Engineer C. R. Goings, Regulatory Compliance Specialist

• G. R. Horn, Nuclear Operations Division Manager J. Larson, QA Engineer (GO)

E. M. Mace, Plant Engineering Supervisor

• J. M. Meacham, Technical Manager

• J. V. Sayer, Technical Staff Manager G. Smith, Senior QA Specialist J. Smith, Technical Welding Specialist G. G. Stuchal, Construction Manager

• P. V. Thomason, Senior Nuclear Advisor V. L. Wolstenholm, QA Manager

• Denotes personnel attending exit meetin . Actions on Previously Identified Inspection Findings (Closed) Violation (298/8501-01): Failure to detect discrepancies during vendor documentation review The licensee established that the documents in question did have incorrect heat numbers on the heat trace and ultrasonic examination report Licensee corrective actions included verifying traceability of corrected subvendor documentation based upon the vendors unique " Mill Work Number" identification system; replacing all incorrect heat trace and ultrasonic examination reports with corrected reports; QA verification that trace-ability methods and information was accurate; review of additional heat trace and ultrasonic examination reports to verify that the problem was limited to those items listed in the violation; and revision of the construction management procedure, CMP 8-1-3, to require training of contract personnel in this are The NRC inspector reviewed the above licensee actions and documentation changes and determined that those immediate and preventive actions were complet This item is close (Closed) Unresolved Item (298/8512-01): Need to establish a formal method of incorporating changes to the inservice test progra _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

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-3-The NRC inspector verified that the licenaee revised design change procedure EP 3.4 to require that changes be reviewed in light of their impact on the inservice inspection and inservice test programs. The NRC inspector noted that changes internal to the program were to be handled as if they were procedure changes. At the time of the inspection, it was also found that the formal methods of handling these latter type changes was being reviewed by the licensee because of a licensee nonconfonaance repor ,

This item is close (Closed) Unresolved Item (298/8512-02): Preinservice inspection of a questionable wel This item concerned whether or not coverage from both sides of the weld was possible (as required by the ASME Code,Section XI, Article III - 4420 and4430). The weld in question (RL-A-15 (SW-1)) was ultrasonically tested by the inservice inspection vendor, General Electric, and this was documented in General Electric reports to the licensee, which the NRC inspector reviewed. The weld in question is a 6 inch, branch type connection to the reactor water clean up system, on a 90 elbow of the 20 inch residual heat removal supply piping. The NRC inspector verified the ASME Code and the procedure requirements are for one side coverage, as a mininum, when it is not possible to cover both side This item is close (Closed) Violation (298/8512-03): Failure to identify a linear indicatio The licensee subsecuently repaired this weld. The NRC inspector reviewed the post repair radiographs and determined that the repairs were satisfactor Licensee preventive action included the requirement that all radiographs asiociated with the pipe replacement project were to be reviewed by a CBI JNT-TC-1A level III inspector. The NRC inspector reviewed and evaluated five radiograph packages in order to verify that they were reviewed by the level III inspector. The NRC inspector verified that a non-qualified CNS individual also reviewed all radiographs. The individual did have some qualifications. As a result of the CNS review, some additional rework did occu This item is close (Closed)UnresolvedItem(298/8512-04): Concerns with the vendor's radiographic progra The specific welas identified in the NRC Report were 'reradiographed and, with one exception, indications were verified to be film artifacts. The exception, field weld N1A, was repaired. Audits by outside consultants, i.e., Lambert and Hartford Steam Boiler Inspection & Insurance were performed to upgrade and improve the CBI radiographic program. A review i

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-4-of later CBI radiographs by the NRC inspector found double film loading, clearer interpreter recording and documentation of indications, and greater film sensitivit This item is close (Closed) Violation (298/8520-03): Failure to impose 10 CFR Part 21 in procurement document The licensee has established procedures which require that 10 CFR Part 21 be incorporated into purchase orders (P0s) for components identified as

" essential." The NRC inspector reviewed 15 current P0s and verified that all " essential" component P0s had Part 21 incorporated. However, he noted that some P0s associated with design change DC 86-21 (the alternate shutdown modification) were not identified as essential and, therefore, Part 21 was not incorporated into there P0s. The P0s in question included instrumentation such as high pressure coolant injection turbine steam inlet pressure (HPCI-PI-1111), torus level (PC-LI-110), residual heat removal flow indication (RHR-FI-11338), reactor vessel level instrumentation (NBI-LI-191B), and level instrument (NBI-LI-1858). The licensee stopped further processing of the aforementioned P0s until the instruments are correctly classified as " essential" or " nonessential."

The NRC inspector reviewed the licensee's equipment classification procedure, EP 3.13 " Equipment Classification." He noted that fire protection equipment could be classified as " essential" or " nonessential" because of ambiguous procedure wordin This item is unresolved pending: (1) correct classification of the identified instruments, and (2) review and revision of procedure EP 3.13 to rid it of ambiguities in the area of fire protection equipment (298/8607-01).

The preventive action designed to be taken by the licensee in this area was to increase training of engineering personnel involved with procurement of safety-related equipment. The training records were reviewed by the NRC inspector, and it was noted that a new employee and some senior general office (corporate level) employees were not trained on this subject. This finding was similar to an observation that was documented in NRC report (50-298/86-06). This was identified as a deviation (298/8607-02).

This item is close (Closed) Unresolved Item (298/8520-04): Apparent misuse of a heat treatment test bloc The NRC inspector found that the licensee established that one of the certified material test reports (CMTR) in question was in error. The error was made by a subvendor's representative. A corrected CMTR has been received. The NRC inspector verified that the corrected CMTR was in the Purchase Order (PO) file : . . .

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.- (Closed) Open Item (298/8204-04): Revision of procedures on establishing quality classification Licensee Administrative Procedure No.1.11 was replaced by new procedures AP 1.4, 1.5, 1.7, and 1.8. Additionally, procedure EP 3.13 was issued. This procedure is more specific in the classifing components than was procedure QAI-9 and CNS Instruction Letter No. 75-1, which classified only systems. Essential and equipment ' qualification classifica-

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tions are defined in the Itcensee's procedure as requiring 10 CFR Part 21, 10 CFR Part 50, Appendix B and ANSI N45.2 on P0s. The licensee's procedure identifies essential-commerical grade as requiring Appendi_x B and N4 All essential, equipment qualification and essential-commerical grade procurement are required by procedure to be given receipt inspectio This item is close (Closed) Open Item (298/8309-03): Completion of component classificatio This item is similar to the unresolved item opened in this report, and is addressed with that unresolved ite .- This item is close " (Closed) Open Item (298/8520-01): Review of design change: record The NRC inspector found that the design change file (DC 85-41) was 3; completed and reviewed by the licensee. He found that the 10 CFR 50.59 review was, completed July 11, 1985, by the licensee and that General

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Electric had performed the same analysis on May 8,1985. The completion report was dated August 16, 198 This item is close (Closed)OpenItem(298/8520.02): A change to the inservice inspection program to include replacement jet pump beam >

Revisian 3 of the inservice inspection program addresses in part 7.3, the augmented inservice. inspection. The NRC inspector found that the replace-ment jet pump besns are to be irspected at a frequency of once during the second 10-year interval . At the time of this inspection, it was noted that the inservice inspection program did not list or otherwise identify each individual jet pump beam reouired to be inspected, nor was the

., ultrasonic test procedure listed that would be used to perform the inspection of those components.

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This item is closed.

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-6-3. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether or not the items are acceptable, violations, or deviations. The following unresolved item was discussed in this report:

Paragraph Item Subject 2 8607-01 Classification of the Alternate Shutdown System 4. Exit Meeting The NRC inspector conducted an exit meeting on February 28, 1986, with the licensee personnel denoted in paragraph 1. The NRC senior resident inspector also attended. At this meeting, the scope and findings of the inspection were summarized.

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