IR 05000298/1989011

Insp Rept 50-298/89-11 on 890301-15.No Violations Noted. Major Areas Inspected:Plant Status,Followup of Lers, Operational Safety Verification,Monthly Surveillance & Maint Observations,Balance of Plant Insp & QA Implementation

ML20246Q302
Person / Time
Site:	Cooper
Issue date:	05/09/1989
From:	Bennett W, Constable G, Greg Pick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246Q276	List: IR 05000298/1989011 ML20246Q270
References
50-298-89-11, NUDOCS 8905220439
Download: ML20246Q302 (12)

Text

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l APPENDIX -l

'U.S. NUCLEAR REGULATORY COMMISSION '

REGION IV

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l l, NRC--Inspection Report: ' 50-298/89-11 .

Operating License: DPR-46 i Docket: 50-298

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1 Licensee: Nebraska ,Public Power District (NPPD)

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P.O. Box 499-Columbus, Nebraska , 68602-0499 Facility Name: Cooper Nuclear Station (CNS)

Inspection At: :CNS, Nemaha County, Nebraska

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Inspection Conductsd: Mar'ch 1. April-'15, 1989

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Inspectors: J rUL4pkV G. A. P k, esident Inspector, Project Section C, T( lfN Dge j

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Divis* Reactor Projects

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. R. Bennett, Senior Resident Inspector, Project ~ _Date Section C, Division of Reactor-Projects

'Other Contributing Personnel: P..W. O'Connor, Project Manager, Office of Nuclear Reactor Regulation (NRR)

E. B. Tomlinson, NRP, Project Directorate IV

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Approved: ~ L. Lonstable, Chief, Project Section C, Division Date of Reactor Projects

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-2-Inspection Summary Inspection' Conducted March 1 through April 15, 1989 (Report 50-298/89-11)

Areas Inspected: Routine, unannounced inspection of plant status, followup of LERs, operational safety verification, monthly surveillance and maintenance

- observations, balance of plant inspection, and quality assurance program

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implementatio Results: The NRC inspectors observed that the plant was operated in a safe, conservative manner. The shutdown for the Cycle 13 refueling outage was conducted in accordance with procedures and with excellent operator interaction. The NRC inspectors determined that a preventive maintenance- j prograna is in effect for the diesel generators, however, the licensee does not have an effective predictive maintenance program. An apparent weakness in the corrective actions program was again observe r

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DETAILS . Persons Contacted

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.Pr'incipal Licensee Employees

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• R. Horn, Division Manager of Nuclear Operations J. M. Meacham, Senior Manager, Technical Support

. J. ' R. Flaherty, Engineering Supervisor'

• R. Brungardt, Operations' Manager

• R' L.. Gardner, Maintenance Manager

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• G. E. Smith, Quality Assurance Manager ,

• L. E. Bray, Regulatory Compliance Specialist

• E. M. Mace, Engineering Manager

• Denotes those present during the exit interview conducted on April 18,198 LThe NRC inspectors also' interviewed other licensee employees and '

contractors during the' inspection perio . : Plant Status The plant operated at essentially 100 percent power until= March 14,1989, when coastdown started. The reactor was shut down for the Cycle 13 refueling outage on April 7 and 8, 198 . Licensee Event Reports (LERs) Followup (92700)

(Closed) LER 88-002: This LER documents a reactor scram from an equipment problem when restoring a reactor recirculation pump to servic On January .m., with the reactor at 35 percent power, 28,1988, at 7:12 the IB Reactor Recirculation p(RR) Motor Generator (MG) speed. control system malfunctioned during startup of the IB RR Pump. This caused an increase in core flow ~ and a subsequent increase in reactor power which resulted in an APRM HIGH flux scram. The cause of the flow control system malfunction was a locking screw loosening and vibrating off its shaf Following the event, the licensee verified that no limits had been exceeded during the event, inspected both RRMG's, and performed calibrations of both RRMG control loops. Corrective actions specified by the licensee included upgrading preventive maintenance requirements associated with RRMG . inspection and control loop calibration. The MRC inspector reviewed Surveillance Procedure (SP) 6.4.4.2, "RRMG Hagan Positioner Maintenance and Setting Electrical and Mechanical Stops,"

Revision 6, dated October 21, 1988, and Instrument and Control j Procedure 14.20.5, "RRMG Set GE/MAC Speed Control Loop Check," Revision 0, l

dated January 19, 1989. The NRC inspector verified that the procedures '

covered RRMG inspection and control loop calibration. This LER is considered close _ _ - _ _ - _ _ _ _ - - - _ _ _ _ _ - _ _ _ - _ _ - _ _ _ - _ - _ _ _ -

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, (Closed) LER 88-003: This LER documents a ground in "B" Residual Heat Removal (RHR) pump which resulted from worn stator field coil insulatio )

On January 28, 1988, a ground alarm was received on the 1B RHR pump moto After approximately 2 minutes, the pump tripped. About 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> later, an attempt was made to restart the pump, however, the ground alarm was received again and the pump immediately tripped. The pump was then declared inoperabl The licensee performed onsite testing to verify the motor fault, then removed and transported the motor to a General Electric (GE) repair facility to facilitate a detailed inspectio The 1B RHR pump was

. replaced with a qualified pump motor. Diagnostic testing was then performed on the three remaining RHR pump motors and on both core spray pump motors. The licensee, in conjunction with GE, performed a detailed inspection of the failed moto In addition, during the 1988 refueling outage, the RHR C motor was replaced with a newly rewound motor using an improved end-turn bracing system. The licensee and GE performed additional testing to verify that the ground was not a generic proble 'r .

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This LER is considered close >

(Closed) LER 88-007: This LER documents the unplanned actuations of the Reactor Protection System (RPS) and Group 2 and 6 isolations during design change activities. These were due to incorrect design change instruction ,

'f0n March 25, 1988, with the reactor shut down, two RPS actuations occurred. The first actuation was caused by lifting the wrong lead due to

'an error in the work instruction; the second was due to the failure of operations personnel to fully understand the power supply to RPS and effects of their actions on RP The licensee reviewed all work instructions associated with design

' activities for replacement of terminal blocks in an attempt to prevent recurrence. Direction was also provided to verify that terminations were deenergized prior to their being lifte The licensee added this event to their Licensed Operator Requalification Training Program to ensure awareness of the scram discharge volume bypass logic operation. This LER is considered close .

(Closed) LER 88-009: This LER documents setpoint variance and operability concerns associated with safety relief valves (SRVs) and safety valves (SVs).

During the 1988 refueling outage, the licensee sent four of the eight installed SRVs and two of the three installed SVs to Wyle Laboratories for testin One SRV and one SV failed to lift within specifications and one SRV could not be tested due to leakag ._ -_______-- _ ____-__ - -

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4 The licensee contacted GE to evaluate the potential impact upon the most l

severe pressurization transients as a result of the SRV and SV deficiencies. The GE evaluation verified that the setpoint drif t and inoperable SRV would not have impacted any plant safety limits. This LER is considered closed.

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(Closed)LER88-020: This LER documents a surveillance procedure (SP) not being performed within the required surveillance interva The cause of this failure was personnel error due to a large number of surveillance being scheduled utilizing a menual system. The licensee immediately verified that no other SPs had exceeded the allowable test interval . The NRC inspector verified that the licensee has implemented a computerized surveillance scheduling system which appears to be working and should prevent the repetition of this problem. This LER is considered close The licensee took prompt, effective corrective actions to prevent recurrence of the above events. No violations or deviations were identified in this are . Operational Safety Verification (71707)

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The NRC inspectors observed operational activities throughout the inspection period. Proper control room staffing was maintained. Control room activities and conduct were observed to be well controlled and professional. Access to the control room was controlled even after commencement of the outage. The NRC inspectors observed several shift turnover meetings and verified that information concerning plant status was properly communicated to the oncoming operators. During the

. preparations for shutdown for the 1989 refueling outage, the NRC inspector noted that the oncoming and offgoing shift supervisors, during shift turnover, discussed actions which would be required to maintain control after manually scransning the plant. Discussions with operators demonstrated that they understood the importance of, and reason for, each lit annunciator. In addition, the operators were aware of work being performed associated with the outage, and limiting conditions for operation associated with the work-in-progress. Control board walkdowns and tours of accessible areas at the facility were conducted to verify operability of plant equipment. Overall plant cleanliness was observed to be excellent throughout the inspection perio The NRC inspector observed portions of the reactor shutdown performed on April 7 and 8, 1989. The shutdown was accomplished in accordance with General Operating Procedure 2.14, " Normal Shutdown From Power,"

Revision 32, dated January 24, 1989. The NRC inspector observed that, prior to manually scramming the plant, the operators discussed what indications to expect and what to do in case of unexpected occurrence At times during the shutdown, less experienced operators were assisted by senior operators when operating systems which w.e.e in configurations other

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-6-than those used during normal power operations. In those situations, the senior operators discussed system operations and monitored the system operation until the less experienced operators were proficient in that mode of operation. During the shutdown, the operators demonstrated that they were aware of previous problems which had occurred during that type of evolution and were careful to prevent recurrence of similar problem 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 and/or contaminated areas were properly posted and controlled. Health physics personnel were prompt in reposting radiation areas affected by the shutdown. Radiation work permits contained appropriate information to ensure that work could be performed in a safe and controlled manne Health physics personnel were observed to be touring work areas, ensuring proper implementation of ALARA and radiological control requirement Radiation monitors were properly utilized to check for contamination.

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The NRC inspectors observed security personnel perform their duties of vehicle, personnel, and package search. Vehicles were properly authorized and controlled or escorted within the protected area. The NRC inspectors conducted site tours to ensure that compensatory measures were properly implemented as required. The licensee continued implementation of the security equipment upgrade. Personnel access was observed to be controlled in accordance with established procedures. Interviews with security personnel demonstrated that they were cognizant of their responsibilities. The PA barrier had adequate illumination and the isolation zones were free of transient material The licensee operated the plant in a safe, controlled manner during this inspection period. The plant shutdown fer the planned refueling outage was conducted in a controlled, conservative manner. During the shutdown, operations personnel demonstrated very good preparation and excellent interactions. No violations or deviations were identified in this are . Monthly Surveillance Observations (61726)

The NRC inspectors observed and/or reviewed the performance of the following surveillance procedures (SPs):

SP 6.3.12.1, " Diesel Generator Operability Test," Revision 27, dated February 9,1989: This surveillance was performed on fiarch 20, 1989, to meet Technical Specification (TS) operability requirements for Emergency Diesel Generator (EDG) 1 and EDG Approximately 1 1/2 hours into the EDG 1 operability test, the diesel engine was shut down due to a leaking fuel line. After the fuel line was repaired, the test was reinitiated. Both EDG surveillance were then completed satisfactorily. Review of the completed procedures indicated that all required data was recorded and within specifications. All procedures had been properly signed off and approvals had been obtaine ____ _________ ____-_-__ - _ _ .-

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Functional / Functional-Test," Revision 26, dat'ed April. 14, 1989: A-quarterly. calibration was performed'on March 21, 1989, as required by TS. The procedure required testing'of two instruments in separate channels. The SP was performed by a qualified individual in'

accordance with applicable procedures. The NRC inspector' verified that approvals had been obtained and that test instruments were within calibration.- The technician performing the surveillance:

demonstrated good knowledge concerning the operation of the test

. equipment.' One instrument was found,to be out of calibration and was

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subsequently recalibrates in~accordance with the procedure. When

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restoring the instrument to operational status, the licensee used the qualified grease and replacement 0-ring required for this environmen SP 6.2.2.2.1, " ADS Water Level Calibration and Functional / Functional Test," Revision 22, dated May 26, 1988: This functional-test was performed on March.29, 1989, to verify operation of the automatic

'depressurization system (ADS). level indicating. switches and permissive circuit response as required by TS. ;This level instrument shares a common sensing line with several other' level instrument These instruments electrically input into both reactor protection Lsystem (RPS) logic circuits. Both RPS' logic circuits receive inputs from' instruments located on the same sensing line. Since isolating and unisolating instruments causes indicated level swings, caution must be taken to prevent an inadvertent reactor scram on low leve The NRC inspector observed the technician using slow deliberate-motions when' returning the instrument t'o service. The technician was aware of the consequence of not using caution when returning the instrument to operation. -The NRC inspector observed that good radiological practices were utilized and;that all test instruments I were'within' calibratio *-

SP;6'.3.6.1, "RCIC' Test Mode Surveillance Operation," Revision 21, dated January (5,1989: This surveillance was performed on March 29, 1989, to determine operability of the reactor core isolation cooling (RCIC) system'as required by TS. The NRC inspector verified that the" licensed operaton reviewed and/or performed'all precautions and limitations as required. The NRC inspector observed conversations between the control room supervisor and -the 1.icensed-operator performing the test whenever there were questions concerning the test. The surveillance.was performed in accordance with applicable procedures..t roper P reviews and approvals were obtaine The test'was; completed ~successfully with the equipment performing a , require No'v oiations or. deviations were identified in this are __ -__

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6 .' Monthly Maintenance Observation (62703)

On' March 21, 1989, the NRC inspector observed the performance of TS required hydraulic- snubber visual inspections in accordan::e with Maintenance Procedure (MP).7.2.34.1, " Snubber Inspection," Revision 1,

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Ldated February 9,- 1989.: f This _ inspection activity.is conducted each-refueling outage as required by-SP 6.3.10.9.1, " Snubber Operability,"

Revision 15,Tdated March 9, 1989. The snubbers inspected,. located in the service water. pump house, were not ensily accessible. The technicia perfonning,the inspection was carefel not to climb or step on small bore piping. . . One~ of the snubbers had a fluid-leak from a fitting as indicated by;a low level in the reservoir and a greasy stain on the floor. The

' technician refilled the reservoir and reported the leak as a discrepanc T  : The snubber engineer evaluated the discrepancy and determined the. snubber to be operable but needing repair. . The licensee is evaluating whether to

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repair or replace the snubbe On. March 20, 1989, while. performing.SP 6.3.12.1, " Diesel Generator-Operability Test," a pinhole . leak developed in a fuel line. The licensee initiated a shutdown of the' diesel generator in order to replace the fuel

.line. The replacement fuel line was procured from.the warehouse as essential equipment and installed in accordance with Work Item 89-128 The NRC inspectors performed an analysis of the licensee's maintenance program relative.to.the EDGs... The NRC inspectors determined that the licensee conducts periodic overhauls of selected components as a ,

. preventive maintenance measure, and reacts on an as-needed basis to other maintenance requirements. The EDG's are subjected to a comprehensive inspection in accordance with vendor recommendations on a regular basi This. inspection includes major engine components wherein signs of engine degradation and/or iminent failure would be noted. The licensee's preventive maintenance program includes regular use of an engine analyzer and regular engine lube oil analysis. -These'both provide an excellent means for early detection of engine degradation. The program appears to be implemented by knowledgeable personne The licensee does not have an effective predictive maintenance program wherein engine operating parameters are monitored and trended over time as a means of predicting end-of-service life. The NRC inspectors noted that retrieval of what maintenance data is available is difficult. There does not appear to be an established methodology for correlating Licensee Event Reports (LERs) Nonconformance Reports, and Maintenance Work Requests / Work Items (WI). -In addition, there does not appear to be a single individual with responsibility for data correlation and revie An. example of this is that the EDG system engineer had not been formally

trained in reading the engine analyzer data. This prevents the' licensee from utilizing available data to the fullest extent possible. For example, the July 6,1988, data for EDG 13L & 4R cylinders shows an abnonnal amount of indication on the ultrasonic trace from shortly after top dead center (TDC) on the firing stroke and continuing almost until

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-9-exhaust valve opening. Data for 3R cylinder on the same EDG also taken on July 6,1988, shows abnormal indications on the ultrasonic trace subsequent to intake valve closure. None of these anomalies have been analyzed for their cause and potential impact on EDG operatio Consequently, the usefulness of the beta analyzer as a diagnostic tool is seriously compromised. The apparent cause of inccmplete data analysis is a lack of adequate time / personnel to conduct the analysi The licensee is attempting to develop a comprehensive predictive maintenance program as evidenced by their plan to implement a pilot Plant Performance Monitoring Program for the RHR system. This pilot program is detailed in a proposal from General Energy Systems Corporation to NPPD dated March 1, 1989. It is based on Alternative 2 as detailed in a report from GE to NPPD entitled " Plant Performance Monitoring Pro Nuclear Station Final Report" (EAS 82-1188, November 1988) gram for Cooper .

The NRC inspectors also noted a weakness in the licensee's root cause analysis of failures / maintenance requirements on the EDGs. WI 88-1461 documents that the diesel driven air compressor associated with EDG 2 failed to start following maintenance. The cause of the problem was determined to be air in the fuel system. This was the same reason that the EDG 2 diesel driven air compressor had failed to start at some earlier time. It is apparent that an inadequacy exists in procedures, training, or implementation of a preventive maintenance requirement associated with the compressors; however, this had not been identified as a root cause and contributed to the repeated failure of the compressor. WI 88-3164 is an example of a good root cause analysis. The control air tubing failure was investigated in detail, the root cause determined and documented, and corrective actions implemented based on the root cause determinatio However, there is no evidence that the same corrective action was implemented on the second EDG, therefore, value of a good root cause determination appears to have been minimize The NRC inspectors observed that water and oil were leaking out from under engine cylinder heads. The licensee was aware of the leakage and had determined that the leakage was occurring at soft rubber gaskets that seal oil and water passage between the cylinder head and the engine bloc This is less serious than leakage at the head gasket that seals the firing

. chamber, however, there was no evidence that the licensee had actively investigated the potential for EDG degradation due to this leakage or had pursued a permanent fix with the EDG vendor. Another example of incomplete followup concerned LER 82-020 dated October 22, 1983. The vendor responded, in a letter dated July 14, 1983, to the licensee's request fm' analysis of failed parts reported in the LER. Included in the letter was a recommendation that the 1icensee review the EDG water treatment program because there was indication of corrosion on the parts sent for analysis. The only documented response to this recommendation observed by the NRC inspectors was a notation on the vendor's letter that the NPPD water treatment program was in accordance with vendor recommendations. There was no evidence that the licensee attempted to reconcile the obvious difference between the NPPD program and the vendor's observation .-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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related to the EDGs revealed that there is no basis to doubt the capability of the EDGs to respond to a design basis event. A preventive maintenance program is in place; however, the licensee does not have an

- effective predictive maintenance program. The licensee is making efforts to develop a predictive maintenance program utilizing a pilot program to be implemented on the RHR system. The licensee does not-have a single person who oversees EDG maintenance and histor The maintenance technicians performed their maintenance activities in accordance with procedures. Corrective maintenance work items were initiated as required by procedures for conditions identified as deficien No violations or deviations were. identified in this are , Balance of Plant (BOP) Inspection (71500)

This inspection was conducted to evaluate the effectiveness of licensee activities regarding preventive maintenance (PM) and corrective maintenance program The NRC inspector selected the condensate system for review and evaluatio Documents reviewed included: nonconformance report. summaries, open and closed maintenance work request (MWR)

summaries, design modification listings, and information contained in the Nuclear Plant Reliability Data System (NPRDS) data bas Review of the MWRs indicated that equipment failures were corrected promptly with proper prioritization, Necessity of the repair and radiological concerns were considered in the determination of when the repair would be accomplishe The NRC inspector identified 25 open MWRs related tu the condensate syste Fourteen of the MWRs were PMs planned for the refueling outag Eleven of the 14 PM activities had a procedure specifie The 11 remaining MWRs concerned corrective maintenance activitie The NRC inspector determined from discussions with the licensee that the PM types and frequency of maintenance on secondary equipment were based on recommendations contained in the vendor manual Failures of components were evaluated by the maintenance department to determine whether a PM should be generated to correct the problem prior to failures occurring in the futur The NRC inspector selected two

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components which had failed previously and verified that they had subsequently been added to the PM schedule. The establishment of PMs for

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B0P components based on vendor recommendations and evaluation of failures were not defined by. procedure Updating of vendor manuals and establishment of PMs based upon vendor manuals related to nonessential equipment was not required nor did a procedure exist. Skill-of-the-craf t is used of ten during minor corrective maintenance activities on nonessential component Procedures were used for complicated maintenance activities involving both essential and

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, nonessential component A .. field walkdown of the condensate system was conducted by- the NRC

. inspector to identify deficiencies in structures or component No problems were identified during the walkdow _____-__ _ - - - - _ - _ -

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O i' :L Review of the data reported to NPRDS by the licensee, related to the condensate 1 system,. indicated that 28 records had been reported during a m .4 year perio Over a 13-month period, three records involved faulty

instrument readings.due to air in the sensing lines and one record

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involved. poor prior'. installation. This indicated a weakness in that procedures may not exist'or were not followed while. placing the components

, in servic The programs and activities related to the condensate systems did not receive the same degree of attention and details as essential system However,-the level of attention applied to B0P systems assure reliability and availabilit No violations or deviations were identified in this are . Evaluation of Licensee Quality Assurance Program Implementation (35502)

On March 2,1989, NRC ' met- to evaluate the overall. quality assurance -

program implementation at CNS. This evaluation included a review of NRC inspection results, systematic assessment of licensee performance history,.

licensee corrective action on NRC inspection findings, licensee event reports, and other performance indicator On the basis'offthis evaluation, regional management determined that there

'was no need to change the emphasis of the NRC inspection program at CN . Exit Interviews- (30703)

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An exit interview was conducted on April 18, 1989, with licensee representatives (identified in paragraph 1). During this interview, the NRC inspectors reviewed the scope and findings of the inspectio Other meetings between the NRC inspectors and licensee management were held periodically.during the inspection period to discuss identified concern The licensee did not identify as proprietary any information provided to, or reviewed by, the NRC inspector .

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MO DAY VR MO- DAY VR ? - PE51 DENT INSPECTOR ._REGON 03 VISION BRANCH Cl3 O ll 9M Olq gly yR 3 - PERFORMANCE APPRAISAL TEAM l { L 20 - 25 26 31 32 33 34 35 RfGiONAL ACTION TYPE OF ACTivlTV CONDUCTEDIChech One boa ontvl

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