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| {{Adams | | {{Adams |
| | number = ML20154D100 | | | number = ML20245D479 |
| | issue date = 05/10/1988 | | | issue date = 06/22/1988 |
| | title = Insp Rept 50-298/88-07 on 880301-0415.Violation Noted.Major Areas Inspected:Operational Safety Verification,Containment Local Leak Rate Test,Monthly Surveillance & Maint Observations,Esf Walkdown,Outage,Refueling & Security | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/88-07 |
| | author name = Bennett W, Holler E, Plettner E | | | author name = Callan L |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| | addressee name = | | | addressee name = Trevors G |
| | addressee affiliation = | | | addressee affiliation = NEBRASKA PUBLIC POWER DISTRICT |
| | docket = 05000298 | | | docket = 05000298 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-298-88-07, 50-298-88-7, NUDOCS 8805190046 | | | document report number = NUDOCS 8806290476 |
| | package number = ML20154D093 | | | title reference date = 06-07-1988 |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | page count = 11 | | | page count = 1 |
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| | ,1N 2 21opM In hply Refer To: |
| . I APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION | | Docket: 50-298/88-07 Nebraska Public' Power District MTN: George A. Tru ors Division'rtanagcr - Nuclear Support ~ |
| | | P.O. Box 499 r i Columbus, NE- 8601 Gantlemen: |
| ==REGION IV==
| | Thank you for-your letter ~ of June 7,1988, in response to our letter |
| NRC Inspection Report: 50-298/ 88-07 License: DPR-46 Docket: 50-298 Licensee: Nebraska Public Power District (NPPD)
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| P. O. Box 499 Columbus, NE 68601 Facility Nanie: Cooper Nuclear Station (CNS) | | ' |
| Inspection At: Cooper Nuclear Statiori, tiemaha County, Nebraska Inspection Conducted: itarch 1-April 15, 1988 Inspectors: . N. / d /suo I//TI /
| | dated May 11, 198L We have reviewed.your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementetion of your corrective cctions during a future inspection to determine that full compliance has been achieved and will be maintaine |
| C A. Plettner, Resident Inspector, (RI)
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| II.~R. Dennett, Senior Resirient inspector, (SRI) Date Approved: * ' '
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| E. . oiler, Chief, Project Section C, Date '
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| Reactor Projects Division 8805190046 880511 PDR O ADOCK 05000298 DCD
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| | Sincerely or:s:r,xt h:sned by L. J Celm |
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| . . | | L. J. Callan, Director Division of Reactor Projects cc: |
| % 0 | | Cooper Nuclear Station ATTN: Guy Horn, Division Manager of Nuclear Operations P.O. Box 98 8rownville, Nebraska 68321 Kansr.3 Radiation Control Program Director Nebraska Radiation Control Program Director bec to DMB (IE-01) |
| | | .. bec distrib, by RIV: |
| Inspection Summary Inspection Conducted March 1 through April 15, 1988 (Report 50-298/88-07)
| | EQ Nfd RRI P. D. % a 's RA |
| Areas Inspected: Routine, unannounced inspection of operational safety verification, containment local leak rate-test, monthly surveillance and maintenance observationt, ESF walkdown, outage, refueling, shutdown, radiological protection, and securit Results: Within the areas inspected, one violation was identified (failure to
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| | RPSB-DRSS r RIV rile o r.,.neer, DRP/C |
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| follow a health physics procedure, paragraph 11).
| | RSTS Operator - i.iR Project Manager L : .. DRS |
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| | | $@ DRP RIV:DRP/ SRI * t/C* DRP/C* DRPH i $dcs RWBe nett;dp ,?i Madsen;dp LConstable LJCalla D t i |
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| DETAILS
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| ' Persons Contacted Principal'L'icensee Employees | |
| * R. Horn, Olvision Manager of Nuclear Operations
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| * D. Black, Operations Supervisor | |
| *0. M. Norvell, Maintenance Manager
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| *J. V. Sayer, Radiological Manager | |
| *G. E. Smith, Quality Assurance _ Manager
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| *L. E. Bray, Regulatory Compliance Specialist
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| * R. Smith, Licensing Supervisor The NRC inspectors also interviewed other licensee employees during the inspection period.-
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| * Denotes those present during the exit interview conducted on April 15, 198 . Licensee Action on Previous Inspection Findings (Closed) Open Item 298/8709-01: Deficient As-Built Instrument Drawing -
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| This item involved discrepancies between System Operating Procedure (50P) 2.2.20, Revision 23, Appendix A "Valve Checklist Number 2" and Cooper-Bessemer as-built drawing KSV-46-5; and between S0P 2.2.12, Revision 8, Appendix A, "Valve Checklist" and Burns & Roe as-built drawing Nos. 2077 and 2011, Sheet 1. Drawing Change Notice (DCN) 87-1682 was issued to correct labeling deficiencies on KSV-46-5. DCN 88-29 was issued to correct labeling deficiencies on Drawing No. 2011, Sheet 1. DCNs 87-154 and 88-174 were issued to correct labeling defit:iencies on Drawing No. 207 The RI compared 50P 2.2.20, Revision 27, Appendix A, to Drawing KSV-46-5; and S0P 2.2.12, Revision 10, dated October 22, 1987, Appendix A, to Drawings 2011 and 2077, and found no discrepancie This item is close (Closed) Open Item 298/8712-01: 10 CFR 50.59 Conflict with USAR - This item involved conflict between the CNS Updated Safety Analysis Report (USAR) Section 13, paragraph 9.5, and the Safety Review and Audit Board (SRAB) Instructions and Guidelines, Section 1.2. The conflict involved the academic requirements of board members. The USAR required that all members have degrees. The SRAB Instructions and Guidelines stated that they shall have a B.S. degree, or equivalent experienc The
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| licensee submitted to the NRC a change to the USAR which was approved on July 22, 1987, to resolve the conflict. The RI verified agreement between the USAR and the SRAB Instructions and Guideline This item is close (Closed) Violation 298/8728-03: Failure to Maintain Secondary Containment Integrity - This item involved the reactor building railroad airlock doors. With the inner door open while the outer door was closed, air gaps existed between the outer door and the ground. Corrective actions taken by the licensee were to generate two new procedures, which provide detailed instructions to verify integrity of secondary containment penetrations, and to fabricate and mount signs on the airlock doors stating "Prior to shutting either railroad airlock door, insure that the associated railseal plates are installed." The RI reviewed Surveillance Procedure 6.3.10.17, "Secondary Containment Penetration Inspection,"
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| Revision 0, dated March 1, 1988, and Maintenance Procedure 7.0.10,
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| "Railroad Airlock Door Operations," Revision 0, dated March 1, 1988, to verify that corrective actions were complete and adequate. The RI verified that signs were mounted on the railroad airlock door This item is close . Operational 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 maintained. The NRC inspectors observed selected shift turnover meetings and noted that information concerning plant status was communicated to the oncoming operator Tours of accessible areas at the facility were conducted to confirm operability of plant equipment including the fire suppression systems and other emergency equipment. The NRC inspectors performed a walkdown of the Residual Heat Removal (RHR) System. Results of this walkdown are documented in paragraph 7 of this repor Operators were cognizant of maintenance being performed during the outage and how it affected operation of the plan Limiting conditions for operation (LCOs) were properly entered when safety equipment was inoperable for maintenance. Required surveillance testing was properly performed when LCOs were in effec A tagout desk was setup outside the control room (CR) during the outag This allowed qualified personnel to review work packages and initiate tagouts for work performance without having extra personnel in the CR
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| area. This greatly reduced the congestion in the CR and aided the on-watch operators in maintaining plant statu No violations or deviations were identified in this are _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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| 4. Containment Local Leak Rate Test The R1 performed direct observation, record review, and independent calculations associated with the Containment Local Leak Rate Test (LLRT)
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| program conducted by CN The purpose of this inspection was to verify that primary containment local leak rate tests, as required by CNS TS were performed to ensure that leakage through testable containment penetrations and isolation valves would not exceed the allowable leakage specifie The RI observed the performance of Surveillance Procedure (SP) 6.3.1.1,
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| "Primary Containment Local Leak Rate Test," Revision 22, dated February 25, 1988, Attachment 3, for RHR MOV-M021A, M026A, M031A, M0166A, and M0167 Personnel performing the test were cognizant of all precautions associated with the test and performed the test in accordance with applicable procedures. The RI performed independent calculations of LLRT data for the above listed valves and for other valves tested by the procedure. These calculations were in agreement with those performed by licensee personnel during performance of the tes The sum of as-found leakages determined during LLRTs exceeds the requirement of TS. The licensee will evaluate valves for repair and perform applicable LLRTs subsequent to any repairs. The licensee will issue a Licensee Event Report (LER) to document exceeding requirements for allowable leakag No violations or deviations were identified in this are . Monthly Surveillance Observations The NRC inspectors observed and reviewed the performance of Nuclear Performance Procedure (NPP) 10.5, "LPRM Calibration," Surveillance Procedure (SP) 6.3.12.1, "Diesel Generator Operability Test," SP 6.3.5.1,
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| "RHR Test Mode Surveillance Operation," SP 6.2.3.3., "Drywell Air Sampling System Calibration and Functional / Functional Test," and SP 6.3.8.2, "SLC Pump Operability Test."
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| NPP 10.5, "LPRM Calibration," Revision 19, dated February 1,1988, At'=chment 1, "Tip System Operation": This test was performed on Marci,1, 1988, to verify that Local Power Range Monitors were within calibrotion. The RI observed that the test was performed by qualified personnel who were cognizant of all precautions associated with the test. The test was performed in accordance with all applicable procedure SP 6.3.12.1, "Diesel Generator Operability Test," Revision 22, dated November 19, 1987: This test was performed on March 29, 1988, to verify operability of No. 2 Diesel Generator (DG) after performance of the annual inspection. The SRI observed that the test was performed by qualified operators who were cognizant of all surveillance requirements. Maintenance identified a potential problem with one cylinder during the test. A broken ring and scored
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| liner were discovered on one cylinder, and the ring and liner were replaced. SP 6.3.12.1 was repeated on April 5, 1988, and subsequently, DG No. 2 was declared operabl '
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| SP 6.3.5.1, "RHR Test Mode Surveillance Operation," Revision 27, dated February 25, 1988: This test was performed on April 6, 1988, to verify RHR Loop B (Pumps B and D) operability subsequent to maintenance performed on loop B. The SRI reviewed the surveillance and determined that all data was properly verified to be acceptable per the procedure and T The test was properly reviewed by all required personne SP 6.2.3.3, "Drywell Air Sampling System and Functional / Functional Test," Revision 21, dated August 7,1986. This test was performed on April 7, 1988, as acceptance testing for maintenance performed on the drywell particulate monitor per Work Item (WI) 88-1618. This test was performed by a qualified technician in accordance with approved procedures. The SRI noted that the procedure was written in such a manner that, at times, it was difficult to follo Discussions with licensee personnel determined that the procedure was being rewritten and the revision was in the review and approval proces SP 6.3.8.2, "SLC Pump Operability Test," Revision 27, dated March 3, 1988: This test was performed on April 11, 1988, to verify operability per TS 3/4.4 and to meet requirements for inservice testing. The test was performed by qualified personnel who were cognizant of procedure requirements. The SRI verified that all test equipment used during the procedure was in calibration. The SRI observed that independent verification was properly performed and that seals were properly reinstalled on appropriate valve 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 codes or standards, and in conformance with T On March 16, 1988, the RI observed the performance of Preventive Maintenance (PM) No. 03728, "Inlet and Outlet Cooler Tubes Inspection,"
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| and associated Equipment Clearance and Release Order 88-378, RRLO-HX A and -HX B, dated March 15, 1988. The RI observed maintenance personnel performing the PM and noted that it was performed in a professional manner and that the personnel were cognizant of all procedural requirements. All clearance order tags were appropriately identified and hung in accordance with the equipment clearance and release orde The NRC inspectors observed maintenance personnel perform Surveillance Procedure (SP) 6.3.12.6, "Diesel Generator Annual Inspection,"
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| Revision 20, dated June 12, 1986, and associated Maintenance Work
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| Request (MWR) 88-0866 for DG No. This procedure was performed to meet TS requirements that the diesel generator be inspected in accordance with instructions based on the manufacturer's recommendations. The NRC inspectors observed that maintenance personnel were aware of the requirements of the inspection, and performed the inspection in accordance with the procedure. DG No. 2 was declared operable on April 5, 1988, af ter appropriate acceptance testing was performe On March 31, 1988, the SRI observed the performance of hydrostatic testing on "B" RHR heat exchangers per WI 88-1009. The hydro was performed as acceptance testing following maintenance. The SRI observed that the test was properly performed in accordance with Maintenance Procedure (MP) 7.0.8, "Pressure Testing," Revision 4, dated November 5, 198 The SRI noted that quality control hold points were properly observed and that the proper test pressure was maintained throughout the tes No violations or deviations were identified in this are . Engineered Safety (ESF) Feature Walkdown The NRC inspectors performed an independent walkdown of Loop B of the RHR syste 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 This system was chosen because Loop B had just been declared operable following maintenance performed during the outag ) In preparation for performing the walkdown of the RHR system, the NRC inspectors conducted a review and comparison of the following licensee system checklist and applicable as-built drawings:
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| 50P 2.2.69A, "Residual Heat Removal Valve Checklist," Revision 1, dated March 3, 1988 As-Built Drawing - Burns & Roe 2040 "RHR System" i
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| General Electric Diagram 729E211BB "RHR System" During the walkdown minor discrepancies involving missing labels were noted which did not affect system operability. The licensee was notified of these discrepancies and initiated actions to correct them.
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| During the inspection, the NRC inspectors verified proper positioning and I
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| tagging of valves associated with the A Loop of the RHR system which was inoperable due to maintenance being performed on the syste No violations or deviations were identified in this are l I
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| 8. Outage The licensee commenced a refueling outage on March 5, 1988. In addition to refueling, numerous maintenance items and modifications are being performed including diesel generation inspection, replacement of 125V batteries, detailed control room design review human factors modifications, motor control center upgrades, and Standby Liquid Control System modification The licensee performed maintenance on all "Loop B" safety systems simultaneously while maintaining all "Loop A" systems operable. Upon completion of "Loop B" maintenance, the NRC inspectors monitored and reviewed acceptance testing of "Loop B" safety systems as they were declared operable. The switchover from "Loop A to "Loop B" was performed in a controlled, conservative manner. The NRC inspectors observed that acceptance testing and system lineups were properly performed. Limiting conditions for operations were properly observed at all times, and TS were properly reviewed whenever a system or systems was inoperabl The NRC inspectors observed the implementation of Design Change 87-029B
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| "MCC Qualification Upgrade," approved on February 25, 1988, and associated Maintenance Work Request, MWR 88-1081. The purpose of the upgrade was to refurbish breakers located within the Motor Control Centers (MCC) to meet environmental qualification standards. The NRC inspectors observed the electrical craft personnel performing their duties in a professional manner, and in accordance with procedures. Quality control hold points were observed. Quality control personnel performed their duties in a professional manner. The assigned system engineers were also observed during the implementation of the design change and during performance of acceptance testin On March 16, 1988, the RI observed the performance of Design Change 87-043, "Replacement of NBI Pressure Switches," approved on March 4, 1988, and associated MWR 88-1057. The purpose of the design change was to upgrade current pressure switches with environmentally qualified pressure switches. The RI observed the instrumentation and control personnel perform their duties in a professional manner and in accordance with the design change procedur The assigned system engineer was also present at various times to observe the performance of the wor The NRC inspectors observed the replacement of 125V battery 1B in accordance with Design Change 87-073. The design change was implemented in accordance with the ap Surveillance Procedure (SP)6.3.15.7,glicableprocedure V Batteries 1A and 18 Service Test,"
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| Revision 0, was approved on March 31, 1988, to perform the acceptance test for the new battery. The procedure was based on manufacturer's recommendations and was performed in addition to testing previously 4 observed by licensee personnel at the battery manufacturers. SP 6.3.1 was completed on April 4, 198 No violations or deviations were identified in this area.
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| 9 Refueling The NRC inspectors held discussions with fuel handling and control room personnel, observed fuel movement, verified fuel assemblies locations in the spent fuel pool and the reactor, accountability records, and status board updates during this inspection period. The NRC inspectors also .
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| reviewed the licensee's procedures and records concerning the movement of fuel and storage of fuel assemblies. Included as part of those reviews were SP 6.1.2.7, "Refueling Platform Interlocks and System Functional Tests," Revision 23, dated November 12, 1997, with attachments to the procedure, NPP 10.21, "Special Nuclear Materials Control and Accountability Instructions," Revision 1, dated May 14, 1987, NPP 10.25,
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| "Fueling," Revision 8, dated February 12, 1987, and NPP 10.26, "Working Over or In Reactor Vessel Requirements," Revision 1, dated March 10, 198 Three different operating shifts were observed during this inspection period. Each operating shift was cognizant of the requirements of the various procedures, and performed their duties in a controlled and professional manner. All required surveillances were performed including daily surveillances of "A" Standby Gas Treatment and "A" Standby Liquid Control when the "B" trains of those systems were inoperative for maintenanc On March 7, 1988, the SRI questioned the licensee's intent to lift the reactor vessel head prior to demonstrating the ability of secondary containment to maintain 1/4-inch of water vacuum under calm wind conditions, as stated in TS 4.7 C.1.c. Paragraph 4.7.C of TS Bases implies that this test should be done prior to the time that primary containment is opened for refueling. Discussions were held among the licensee, SRI, NRR project manager, and NRC Region IV management. It was agreed that the test to demonstrate secondary containment need only be performed prior to fuel movement. The licensee committed to reviewing TS to determine if a change to TS 4.7.C Bases was required. The test (SP 6.3.10.8, "Secondary Containment Leak Test, Revision 9, dated December 17, 1987) was completed satisfactorily on March 9, 1988, prior to commencing fuel handling operation No violations or deviations were identified in this are . Shutdown The NRC inspectors held discussions with operations shift personnel and reviewed control room records including log entries, record traces, and computer printouts associated with the scheduled shutdown. The shutdown started at 4:30 a.m., on March 6, 1988. The shutdown was required in order to perform the refueling of the reactor, preventive maintenance activity on selected equipment, and install approved plant design change The RI reviewed General Operating Procedure (GOP) 2.1.4, "Normal Shutdown
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| ; from Power," Revision 27, dated December 10, 1987. Other procedures which were revcewed in whole or in part were GOP 2.1.10, "Station Power
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| Changes," Revision 15, dated December 10, 1987, and GOP 2.1.20, "RPB Refueling Preparation," Revision 12, dated February 18, 1988. During the shutdown, two safety system challenges occurred:
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| A Group II, III, and VI Isolation was received at 4:31 a.m. on March 5, 1988, because of a reactor vessel low-water setpoint (+12.5 inches) being reached. The event was attributed to a reactor vessel water level "shrink" which occurs on a reactor scram. The manual scram was initiated at 25 percent power as part of the normal shutdown procedur A Group III Isolation was received at 2:40 p.m. on March 5, 1988, because of an indicated reactor water cleanup (RWCU) system high-flow condition. The incorrect indication was the result of pump cavitation due to the loss of net positive suction head to the pum Notification of each event was made to the NRC headquarters operation central duty officer as required. In addition, the SRI was notified when the events occurre No violations or deviations were identified in this are . 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. Radiation and/or contaminated areas were properly posted and controlled. Radiation monitors were utilized to check for contaminatio During a routine plant tour on March 28, 1988, the RI observed an individual inside a posted radiation area in the heater bay room with shoe covers and gloves, which is normal attire for a tour and inspection of the area. However, in this case, Special Work Permit (SWP) 88-3-46, issued on March 21, 1988, for the area, did not allow for tour and inspection, and required additional protective clothing. No other SWP was assigned to the area. The RI questioned the individual to ascertain whether permission had been received from health physics personnel to be in the area with only shoe covers and gloves. The individual responded that no permission had been received. Failure to comply with Health Physics Procedure (HPP) 9.1.1.4, "Special Work Permit," Revision 16, dated April 15, 1987, and SWP 88-3-46, titled, "Bypass Valves," is an apparent violation. (298/8807-01)
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| The licensee took immediate corrective actions when notified of the proble No other violations or deviations were identified in this are .- - U
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| 12. Security The NRC inspectors observed security personnel perform their duties of vehicle, personnel, and package search. Vehicles were properly authorized and escorted or controlled within the protected area (PA). The PA barrier had adequate illumination and the isolation zones were free of transient material. Compensatory measures were implemented in a timely manner when equipment failed or when security doors were required to be open for work being performed during the outage. These observations verified that the physical security plan was being implemented in accordance with the requirements established in the CNS Operating Licens No violations or deviations were identified in this are . Exit Interview An exit interview was conducted on April 15, 1988, with licensee representatives (identified in paragraph 1). During this interview, the SRI reviewed the scope and findings of the inspectio . - _ .
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