ML20128D288

Responds to NRC Re Violations Noted in Insp Rept 50-298/92-19.Corrective Actions:Walkdown Conducted to Ensure That Similar Strainers Not Located in Main & Alternate Pump Suction Lines for Other Safety Sys & Programs Upgraded

ML20128D288
Person / Time
Site:	Cooper
Issue date:	12/01/1992
From:	Horn G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212070209
Download: ML20128D288 (3)

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December 1, 1992 Document Control Desk U. S. fluclear Fogulat> r Crwnl o o lon Washington, DC 20555 Gentlemen

Subject:

PEPLY TO A IJOTICE or VIOLATIotl (!!RC IllSPECTION REPORT NO. 50-298/92-19)

This 'etter is written in response to your letter dated IJovember 3, 1992, which tranumitted the Notice of Violation (NRC Inspection Deport flo . 50-298/92-19).

Therein you identified one violation.

l'ollowing is the otatement of violation and our reuponnen in accordance with 10 CYR 2.201.

fMLCMDi_of V1Ohtd2D 10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measurea shall be outablished to aaoure that conditiona adverue to quality are promptly identified and corrected.

Contrary to the above, from 1974 until September 1992, the licensee failed to identify and correct the praucnce of temporary start-up strainers in the condennate storage tank suction line for the core spray pumps, which was not in accordanco with the core spray eyotem design.

Operation of the core spray system with the temporary start-up strainers installed in the condensate otorage tank suction was not in accordance with core spray ayatem design, ao indicated on Drawing DR 2045 and, thus, was a condition adverse to quality. 10 CFR Part 50, Appendix B, criterion XVI, requires that the licensee identify and correct conditions adverse to quality. The licensee operated the core opray system from 1974 until September 1992 and did not identify and correct this condition adverse to quality when notified of a potential generic issue in Information tiotice 85-96, until prompted by the NRC in 1992. This condition is a violation of 10 CFR Part 50, Appendix B (298/9219-03).

This 10 a Severity Level IV violation (298/9219-03) (supplement I).

BE ASON JM_V,101A110_i(

On August 21, 1992, it was discovered that the temporary plant start-up strainers located in the core Spray (CS) pumps A and B alternate (shutdown or emergency) suctic" supply lines from the Condenaate Storage Tank (CST) were potentially still installed. Radiography performed on August 22, 1992, verified that the otrainers were still in place. An operability evaluation of the CS System was 7-9212070209 921201 PDR ADOCK 05000298 i mmmp , y rwwrn-mm pnaawwa9,t .S1 w ww n?m:mwww v --

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Document Cors;rol Desk y Page 2, Docomber b 1992 performed which concluded that both CS loops woro still operable with the strainers installed and the core spray system in its normal lineup to take ra tion from the torus. Nonconformance Report (NCR)92-104 was generated on August 24, 1992, to evaluate the root cause of this occurrence.

1 In December 1985, the NRC issued IE Information Notice 85-96 entitled, " Temporary  !

Strainers Lef t Installed in Pump suction piping". The purpose of the Inf ormation Notice was to alert licensees about a potentially significant problem pertaining to temporary construction strainers left installed in the auction piping of safety-related pumps. As a result of IE Information Notico 85-96, system- t engineers were instructed to confirm that pump suction strainers shown on system Pf, ids woro either removed or continued to be part of the permanent plant design.

This instruction did not result in detection of strainers in tho CS System-attornato suction: supply line apparently because they were not shown on plant P& ids. Had a detailed system walkdown been conducted, the temporary strainers would most likely have boon detected. As such, one root cause of this violation is a- programmatic weakness in that corrective action taken to address IE Information Notice 85-96 was less than adequate.

Review of pro-operational test documentation indicated that the strainers were designed to be removed during pre-operational testing. Howevor, the test procedure for the CS System did not contain specific steps for strainer removal.

Had the procedure used specific sign-off steps to document temporary strainer removal, these strainers probably would not have remained in place.

Consequently, another root cause of this violation is a procedural deficiency with the CS System pre-operational test procedure.

@RRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Immediate correctivo action consisted of a walkdown to ensuro similar strainers are not located in the main and alternate pump suction lines for other safety systems including the Reactor Core Isolation Cooling (RCIC), liigh Pressure Coolant Injection (llPCI), Residual Heat Removal (RHR), Service Water-(SW), and Reactor Equipment Cooling (REC)-systems. As a result of the walkdown, there are no externally visiblo indications that temporary strainers are present in the SW, REC, RHR, or HPCI suction piping. Additionally, the CS Strainers were-removed in September 1992. q When walking down the RCIC system, an unlabeled spacer plet9 was discovered in the flange on the inlet to the spool piece used to install the original startup strainer. A specific completed sign-off in the preoperational test procedure (unlike the CS System pro-operational test) indicatos that tho strainer had been removed prior to startup -testing. As such, it is concluded that adequate evidence exists to indicate that a strainer is not installed in the RCIC suction piping and that the unlabeled plate was left installed as a spacer. However,-

during the 1993 Outage, this conclusion will be physically verified by removal and inspection of the spool piece or by radiograph.-

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@PECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIOfig There- is no. preventive action associated with- the original- inadequate preoperational test procedure since it will not be used again and the affected strainers have been-removed.

, s Document Control Desh

,.. Page 3-D,ecember 3, 1992 Preventive action to address programmatic concerns has been implemented in the form of various program upgrades since occurrence of this oversight in 1986.

Specifically, extensive system engineering training and corrective action program upgrades have been implemented. This event will also be incorporated into industry event training for system engineers. The District believen that these upgrades will prevent similar events from recurring.

DATE WHEN FULL COMELIAt!.QE WILL BE ACHIEVED rull compliance with the requirements of the subject violation will be completed upon inspection of the RCIC spool piece which will occur prior to startup from the spring, 1993 Refueling Outage.

This in-house event will be incorporated into industry event training for system  :

engineers by May 1993. l should you have any questions concerning this matter, please contact my office.  ;

Sinefrel ,

kV bO G .[ R Hor 7 '

Nuc1 ar Power Group Hanager GRH/DSDscml-53D i

ces Regional Administrator USNRC - Region IV NRC Resident Inspector Cooper Nuclear Station i

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