ML20210F232

Responds to NRC Re Violations Noted in Insp Rept 50-298/86-27.Corrective Actions:Method of Cleaning Bolts Immediately Halted Due to Residue Deposits Found on Pump & Overall Good Housekeeping & Maint Practices Reviewed

ML20210F232
Person / Time
Site:	Cooper
Issue date:	01/27/1987
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20210F208	List: ML20210F202 ML20210F232
References
CNSS870060, NUDOCS 8702110034
Download: ML20210F232 (6)

Text

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CNSS870060 January 27, 1987

(* R@R MR W JAN 3 01987 I

Mr. J. E. Gagliardo, Chief U Reactor Projects Branch

~ ~ - ~

U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to IE Inspection Report 50-298/86-27

Dear Mr. Gagliardo:

This letter is written in response to your letter dated December 30, 1986 transmitting Inspection Report No. 50-298/86-27. Therein you indicated that certain of our activities were in violation of NRC requirements.

The following includes statements of the violations and our response in accordance with 10 CFR 2.201.

A. Statement of Violation Failure to llave an Adequate Refueling Procedure Appendix B, Criterion V, of 10 CFR Part 50, and the licensee's Quality Assurance Plan require that activities affecting quality shall be pre-scribed by documented instructions and procedures. These instructions and procedures shall include appropriate qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, Nuclear Performance Procedure 10.25, " Refueling",

Revision 6, dated August 7, 1986, was inadequate, in that the procedure failed to specify the need to ensure that the refueling mast was fully retracted before moving the refueling bridge from the fuel pool to the reactor cavity.

This is a Severity Level IV Violation. (Supplement I.D.)(298/8627-02) 8702110034 070 (

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m___.,_ _ _ _ . _ _ _ _ y e-;s s Mr. J. E. Cagliardo January 27, 1987 Page 2 Reason for the Violation

} On October 16, 1986, at approximately 1430, the refueling mast was damaged during movement of the refueling bridge from the fuel pool to the reactor vessel. There was no fuel on the grapple at the time of this incident. A contributing factor to the incident was the mast not being fully retracted prior to bridge movement from the fuel pool to the reactor cavity, thus allowing the mast to engage the side of the shielding chute and become damaged. The extended mast apparently created additional water resistance causing the operator to misjudge the actual position of the lower part of the mast during movement through the shielding chute.

The NRC Resident Inspector performed a review of Nuclear Performance Procedure 10.25 " Refueling", Revision 6, dated August 7, 1986. The NRC l Resident Inspector's review of the procedure revealed that the procedure failed to identify the need to ensure that the refueling mast was fully retracted before moving the refueling bridge from the fuel pool to the reactor cavity. Based on his review of the event and applicable procedure, i the NRC Resident Inspector concluded that had the mast been fully retracted, damage would have been avoided because no contact between the mast and the shielding chute would have occurred. Based on his conclusion, an

. apparent violation had occurred.

) Corrective Steps Which Have Been Taken and the Results Achieved

, The Operations Supervisor issued a Standing Night Order which contained a caution to all Operations personnel in regard to refuel activities and a directive stating that movement between the fuel pool and the reactor cavity be accomplished with the fuel grapple in the full up position. No further incidents of this nature occurred for the remainier of the 1986 i outage.

l Corrective Steps Which Will Be Taken to Avoid Further Violations

In addition to the corrective steps which were taken, a revision to t Nuclear Performance Procedure 10.25, " Refueling", was submitted. The

! revision added a new administrative limit and a note prior to the appli-l cable step which stated that ". . . when traversing the refueling bridge between the fuel pool and the reactor cavity, the refuel mast shall be fully retracted."

Date When Full Compliance Will Be Achieved 4

l Cooper Nuclear Station will achieve full compliance by March 2, 1987

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B. Statement of Violation

! Inadequate Cleanliness Controls l

Appendix B, Criterion II, of 10 CFR Part 50, and the licensee's Quality Assurance Program establish the requirements that activities affecting quality shall be accomplished under suitably controlled conditions.

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awwm;ren mmm,wwmanwwnuwwumsmwesmwwww=nw newn wmmm Mr. J. E. G:glicrdo January 27, 1987 Page 3 Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance that all prerequisites for the given activity have been satisfied.

Contrary to the above, suitable cleanliness controls were not maintained in the high pressure coolant injection (HPCI) pump room during pneumatic wire brush cleaning operations. As a result, the area immediately adjacent to the cleaning activity, which included components such as the HPCI turbine and auxiliary lube oil pump and motor, were covered with particulate material and residual aged lubricant.

This is a Severity Level V Violation. (Supplement I.E)(298/8627-05)

Reason for the Violation During performance of Maintenance Procedure 7.2.28, adequate cleanliness controls were not maintained in the High Pressure Coolant Injection (HPCI) Pump Room. A pneumatic wire brush was used to clean the threaded portion of bolts removed during disassembly of the HPCI turbine without taking the proper precautions to contain the residue materials.

The described activity resulted in residue (lubricant) from the cleaning operation being deposited on the auxiliary lube oil pump motor and nearby turbine components.

Corrective Steps Which Have Been Taken and the Results Achieved The described method of cleaning bolts, upon notification of the Senior Resident Inspector, was immediately halted.

Although the HPCI auxiliary lube oil pump motor is a totally enclosed type motor, a Maintenance Work Request was issued to inspect the motor internals for cleanliness. This inspection was performed and the motor internals were found to be extremely clean, with no bolt cleaning residue present.

Additionally, Maintenance Procedure 7.2.28 contains steps to seal and tape lube oil piping when it is disconnected. Also, there are require-ments to make sure all parts are absolutely clean and undamaged in the reassembly portion of the procedure. Therefore, any bolt cleaning residue that may have been present was removed on all other turbine components.

Corrective Steps Which Will Be Taken to Avoid Further Violations Housekeeping and good maintenance practices will be reviewed with all Maintenance Department Mechanical personnel. The review of housekeeping and good maintenance practices will be completed by March 2, 1987.

Supervisors will monitor job site activities in the future to ensure these practices are being carried out.

r Mr. J. E. C:glizrds January 27, 1987 Page 4 Date When Full Compliance Will Be Achieved Cooper Nuclear Station will achieve full compliance by March 2, 1987.

C. Statement of Violation Failure to Provide Adequate Controls in a Special Test Procedure Appendix B, Criterion V, of 10 CFR Part 50, and the licensee's Quality Assurance Plan require activities affecting quality shall be prescribed by documented instructions and procedures. These instructions and procedures shall include appropriate qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, Special Test Procedure 86-08, " Inspect IE Floor Mounted Switchgear", dated October 18, 1986, was inadequate, in that it failed to identify the removal of an insulating device called a boot from a set of relay contacts on an under voltage relay. The boot, when installed, would have prevented the automatic starting of emergency diesel generator No. I upon a loss of Emergency Transformer Voltage.

This is a Severity Level IV violation. (Supplement II.D)(298/8627-06)

Reason for the Violation On October 27, 1986, when performing Special Test Procedure 86-08,

" Inspect IE Floor Mounted Switchgear", an insulating device called a boot was placed over a set of contacts on an undervoltage relay. The boot would have prevented the automatic starting of Emergency Diesel Generator No. 1 on a loss of Emergency Transformer Voltage. On November 1, 1986, plant personnel discovered that the boot had not been removed after completion of the procedure on October 27, 1986. The NRC Resident Inspector issued the violation for failing to have an adequate procedure which required the removal of the boot from the relay contacts.

However, upon further examination it was revealed that this incident was attributable to procedural deficiencies in Station Procedure 2.2.17,

" Emergency Station Service Transformer", which outlined the booting process and was being followed at the time. This created the misunder-standing by Operations Department personnel that the contact booting was necessary to prevent an auto-start of Emergency Diesel Generator No. 1.

The licensee agrees to the violation of Appendix B, Criterion V, of 10 CFR Part 50 and the Quality Assurance Plan only as it applies to the procedural inadequacies that existed within Station Procedure 2.2.17.

Corrective Steps Which Have Been Taken and the Results Achieved Station Procedure 2.2.17. " Emergency Station Service Transformer", was subsequently revised and approved on December 29, 1986 to include specific information regarding contact booting of the emergency service auxiliary undervoltage relays to prevent a spurious auto-start of the Emergency Diesel Generator. In addition, the revision calls for the issuance of a Plant Temporary Modification which provides the necessary documentation for the installation and removal of the electrical boots.

, ,e .- o Mr. J. E. C:glicrds January 27, 1987 Page 5 Corrective Steps Which Will Be Taken to Avoid Further Violations All Operations personnel will be informed of this event and made aware of Ststion Procedure 2.2.17 revision during the weekly crew meetings with the Operations Supervisor.

Date When Full Compliance Will Be Achieved Cooper Nuclear Station will achieve full compliance by March 2, 1987.

D. Statement of Violation Failure to llave a Procedure for Controlling Maintenance Activities CNS Technical Specifications 6.3.1 requires that station personnel shall be provided detailed written procedures to be used for operation and maintenance of system components and systems that could have an effect on nuclear safety.

Contrary to the above, maintenance was performed on the refueling bridge on October 16, 1986, without a procedure while the bridge was located above the spent fuel pool, which at the time contained both spent and new fuel.

This is a Severity Level IV violation. (Supplement I.D.)(298/8627-07)

Reason for the Violation on October 16, 1986, at approximately 2:30 p.m., the telescoping mast on the refueling bridge was damaged during refueling operations. A Maintenance Work Request (MWR) was subsequently issued to repair the damage which required replacing a damaged mast section. The Maintenance Supervisor, when reviewing the MWR to perform this work, filled in the Special Instruction portion of the MWR with what was thought adequate instruction for performance of a simple mast replacement activity.

It should be noted, that in order to remove and reinstall the damaged mast section, it must be first extended downward in a vertical position in the fuel pool. Following removal of the attachment bolts for the mast section, the mast can then be raised and the remaining work performed over the refueling floor (1001 ft. elevation). The apparent violation is then a result of not providing adequate instruction for placing the fuel handling machine in an appropriate location for performance of the maintenance activity.

Corrective Steps Which Have Been Taken and the Results Achieved Cooper Nuclear Station personnel are in the process of developing a specific maintenance procedure for replacement of the refueling bridge mast. This procedure will include the necessary instructions to ensure the refueling bridge is correctly placed in the fuel pool prior to the performance of maintenance activities. By providing station maintenance personnel with this specific procedure guidance, similar events of this type will be precluded.

• **

• e Mr. J. E. GIgliardo January 27, 1987 Page 6 Corrective Steps Which Will Be Taken to Avoid Further Violations It is felt the additional criteria and controls that will be contained in the maintenance procedure for working on the refueling machine mast will prevent the recurrence of a similar event and avoid further violations in this area. The expected SORC approval date of this procedure is April 1, 1987.

Date When Full Compliance Will Be Achieved Cooper Nuclear Station will achieve full compliance by April 1, 1987.

If you have any questions regarding the above responses, please contact me.

Sincerely, G. A. revors Division Manager of Nuclear Support GAT:1b