ML20128F436

Insp Rept 50-298/85-16 on 850501-31.Violation Noted:Licensee Failed to Provide Addl Required Info & Acceptability Status of Radiographic Reader Sheets

ML20128F436
Person / Time
Site:	Cooper
Issue date:	06/28/1985
From:	Dubois D, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20128F421	List: ML20128F417 ML20128F423 ML20128F436
References
50-298-85-16, NUDOCS 8507080237
Download: ML20128F436 (19)

See also: IR 05000298/1985016

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/85-16 License: DPR-4ti

Docket: 50-298

Licensee: Nebraska Public Power District (NPPD)

P. O. Box 499

Columbus, Nebraska 68601

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: Cooper Nuclear Station, Nemaha County, Nebraska

Inspection Conducted: May 1-31, 1985

Inspector: 8

D. L. DuBois, Senior Resident Inspector, (SRI) Date

Other Accompanying Personnel: J. A. Holm

F. N. Carlson

Approved: .

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Jaudo , Chief, Tiefect Section A, Dalb

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Re ctor roject Branch 1

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Inspection Summary

Inspection Conducted May 1-31, 1985 (Report 50-298/85-16)

Areas Inspected: Routine, unannounced inspection of operational safety

verification, monthly surveillance and maintenance observations, licensee

action on previous inspection findings, nondestructive examination activities

associated with recirculation, core spray, and reactor water cleanup systems

piping replacement, and design changes and modifications. The inspection

involved 208 inspector-hours onsite by one NRC inspector and two consultants.

Results: Within the six areas inspected, two violations were identified

(inadequate procedures, paragraph 2; and incomplete test records, paragraph 3).

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DETAILS

1. Persons Contacted

Principal Licensee Personnel

+#P. V. Thomason, Division Manager of Nuclear Operations

+#V. L. Wolstenholm, Quality Assurance Manager

+#D. A. Whitman, Technical Staff Manager

+#C. R. Goings, Regulatory Compliance Specialist

+G. Horn, Construction Manager

+J. M. Meacham, Technical Manager

1. D. Norvell, Acting Maintenance Manager

1. E. M. Mace, Plant Engineering Supervisor

1. L. L. Roder, Administrative Services Manager

1. H. T. Hitch, Senior Staff Engineer

L. Bednar, Senior Staff Engineer

J. Flaherty, Assistant to the Plant Engineering Supervisor

J. T. Scheuerman, Lead Reactor Engineer

The NRC inspectors also interviewed other licensee and contractor

personnel.

+ Denotes presence at exit interview held May 10, 1985

1. Denotes presence at exit interview held May 30, 1985

2. Licensee Action on Previous Inspection Findings

(Closed) 8114-09 (Unresolved). This item identified that plant

procedures did not contain the Technical Specification (TS) review

requirements for special procedures or special test procedures although

the NRC inspector could not identify an instance when the reviews were

not being performed by the licensee. TS Section 6.2.1.A.4.b requires the

Station Operations Review Committee (50RC) to review all proposed tests

and experiments and their results, and the NPPD Safety Review and Audit

Board (SRAB) to review tests that may constitute an unreviewed safety

question. The SRI reviewed the following licensee procedures and

determined that they presently identify the referenced TS requirements:

. CNS Procedure 3.5, "Special Test Procedures /Special Procedures,"

Revision 0, dated September 29, 1984.

. CNS Procedure 0.3, " Station Operations Review Committee," Revi-

sion 0, dated September 28, 1984.

. " Safety Review and Audit Board Instructions and Guidelines," Re-

vision 0, dated August 1, 1984.

This item is closed.

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(Closed) 8420-01 (Unresolved). This item concerned ambiguous TS

requirements for determining operability of the Standby Gas Treatment

(SGT) System. In a letter from Mr. L. G. Kunci (NPPD) to Mr. D. B.

Vassallo (NRR), dated April 26, 1985, the licensee submitted Proposed

Change No. 18 to the TS. The SRI reviewed the proposed TS change and

determined that ambiguous TS statements were removed and replaced by

specific and clear requirements. The proposed TS change affected

Sections 3.7.B.2.a, 3.7.B.2.b, 3.7.B.2.c, and the " BASIS" for those

sections applicable to system flow rates and testing conditions for the

HEPA filters, charcoal absorbers, and fans. CNS Procedures 6.3.19.2 and

6.3.19.3 specify that system flow rate should be established and maintained

during testing and the definition of that flow rate is specifically stated

in the proposed TS change. Also, the licensee has committed to providing

a clear definition of the design function of the SGT system in the CNS

Updated Safety Analysis Report (USAR), Volume II,Section V,

Paragraph 3.3.4, in the next proposed revision to the USAR tentatively

scheduled for July 1985.

This item is closed.

(Closed) 8421-25 (Unresolved). This item was identified by the NRC

Performance Appraisal Team (PAT) and concerned the apparent failure to

take adequate corrective action to prevent recurrence of nonconforming

conditions and to review identified minor design change (MDC) safety

evaluations.

As a result of an NRC inspection conducted at CNS during the period

October 17-21, 1983, a violation was written concerning the licensee's

failure to approve MDCs prior to implementing those changes. The

violation was documented as item 8326-04 in NRC Report 50-298/83-26 and

is presently being tracked under that item number.

NRC Report 50-298/83-26 also included a violation item 8326-03, con-

cerning a failure of the SRAB to review 17 MDC packages. This item was

closed out in NRC Report 50-298/85-01 following an NRC inspection

s conducted during the period January 7-11, 1985. The SRI subsequently

verified that the SRAB members did review the 17 identified MDCs.

Since one of the PAT findings is being tracked under item No. 8326-04

and the other was closed in a subsequent NRC report, unresolved item

8421-25 is closed for record purposes.

(Closed) 8421-28 (Unresolved). This item was identified by the PAT and

concerned apparent licensee failures: to designate a 50RC member as a

member of SRAB; to correct inconsistencies between the SORC procedure and TS

requirements; and to review items of potential safety significance in

committee.

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The SRI verified that the licensee assigned a SORC member,

Mr. P. V. Thomason, Division Manager of Nuclear Operations, to be a member

of the SRAB. This assignment was documented in an Inter-District

Memorandum from Mr. L. G. Kuncl, Assistant General Manager-Nuclear, to

Mr. P. V. Thomason, dated March 21, 1985. Prior to his formal assignment

to the SRAB, Mr. P. V. Thomason and CNS departmental managers would

attend SRAB meetings only when requested by the SRAB or if plant

management determined that specific plant expertise would be beneficial

during the conduct of a particular SRAB meeting.

The PAT further determined that no SRAB member had ever held an NRC BWR

operators license nor received equivalent training. The SRI's review of

the "SRAB Instructions and Guidelines," Revision 0, dated August 1,1984,

identified a training program requirement that each SRAB member is to

receive a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training each year. The training is to

include regulatory requirements, the CNS Technical Specification and

License, and CNS equipment, systems, and procedures. To date, all but

two SRAB members have received the required training.

The SRI reviewed the inconsistencies between the TS Section 6.2.1 and CNS

Procedure 0.3, " Station Operations Review Committee," Revision 0, dated

September 28, 1984. A synopsis of the SRI's review in this area

includes:

. TS Section 6.2.1.A.1 requires the Division Manager of Nuclear

Operations to appoint in writing, alternate members of the SORC.

The SRI reviewed an Inter-District Memorandum from Mr. P. V.

Thomason to Mr. J. V. Sayer, dated October 5,1984. The memorandum

designated Mr. Sayer as an alternate member of the SORC. Prior to

that date, the SRI was informed by Mr. Thomason that the need had

not arisen to select an alternate 50RC member. Procedure 0.3,

Revision 0, paragraph II.B, did not state the exact words of the TS

requirement for alternate SORC members to be designated in writing

but it did require that, "other members of SORC shall be as described

in the Technical Specifications." Revision 1 of Procedure 0.3, dated

May 13, 1985, states the exact wording of TS Section 6.2.1.A.1.

. TS Section 6.2.1.A.5 requires the 50RC to report specific items,

listed within that section, to the SRAB. Procedure 0.3, Revision 0,

specifically addressed three of the six items listed in the TS. The

remaining three items were indirectly required by Procedure 0.3 to

be reviewed by the 50RC. SORC meeting minutes are reviewed by the

SRAB. The SRI reviewed SORC and SRAB meeting minutes for the years

1984 and 1985 to present and determined that all SORC items were

reviewed by the SRAB as required. Revision 1 of Procedure 0.3

individually addresses all six of tne specific items listed in TS Section 6.2.1.A.5. ,

. TS Section 6.2.1.A.4.b requires the SORC to review proposed tests

and experiments and their results. Procedure 0.3, Revision 0,

required the SORC to review proposed tests and experiments but did

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not state the requirement to review results. The SRI's review of

SORC meeting minutes vcrified that the 50RC was meeting the TS

requirement. Revision 1 of Procedure 0.3 added the words of the

requirement that the 50RC review test and experiment results.

. TS Section 6.2.1.A.3 specifies the quorum requirements of the 50RC.

Procedure 0.3, Revision 0, did not address the quorum requirements

stated in the TS. The SRI's review of the 50RC meeting minutes did

not find an instance where the quorura requirement was not met during

the conduct of SGRC meetings. Revision 1 of Procedure 0.3,

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paragraph IV.A.1, states the exact wording of the TS quorum

requirement.

. TS Section 6.2.1.A.6 requires that SORC meeting minutes include

identification of all documentary material reviewed and that a copy

of those minutes be forwarded to the Assistant General Manager

(AGM)-Nuclear. CNS Procedure 0.3, Revision 0, paragraph IV.A.3,

required that presentations to the SORC be supported by appropriate

reference material, but the procedure did not specifically require

that the reference material be included in SORC meeting minutes.

The SRI has observed that past SORC minutes have included lists of

reference material.

CNS Procedure 0.3, Revision 0,Section IV.A.7.e, discussed

distribution of SORC minutes but did not specify distribution to the

AGM-Nuclear. In practice, the AGM-Nuclear was regularly receiving

copies of the minutes. Revision 1 of Procedure 0.3,Section IV.D.5,

specifically states the-TS requirement to distribute a copy of the

minutes to the AGM-Nuclear.

. TS Section 5.2.1.A.4 requires the licensee to review changes to

plant equipment and systems for safety significance. Historically,

the licensee has met the intent of this TS requirement; however,

the licensee had not always included all safety significant reviews in

the 50RC minutes because a majority of the preparation, reviews, and

discussions were accomplished outside of formal committee gatherings.

The SRI has held discussions with plant management concerning the

importance of holding committee meetings on all subjects required by

the TS and to provide greater detail and specificity in the committee

minutes. The SRI has observed during his periodic reviews of 1984

and 1985 SORC and SRAB meeting minutes, a continual improvement in

the quality and quantity of information included in those minutes.

To further enhance the overall management controls and administration

of the SORC, CNS Procedure 0.3, Revision 1, provides specific

requirements applicable to safety significant reviews and

documentation of those reviews. Also, during SORC Meeting No. 323,

l conducted May 7, 1985, the Division Manager of Nuclear Operations

! committed the SORC membership to ensuring committee review and

! approval of all items of safety significance and to meet in committee

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on a regularly scheduled weekly basis.

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Based upon the SRI's review of these findings and the licensee's

corrective actions indicated above, unresolved item 8421-28 is closed.

(Closed) 8421-29 (Unresolved.) 'This item was identified by the PAT and

concerned an apparent failure of the SRAB to conduct required reviews and

make necessary recommendations to management; and an apparent failure by

the SORC to review all TS violations. The TS states that the SRAB is

responsible for reviewing certain subjects listed in Subsections a

through k.of Section 6.2.1.B.4. Also, the SRAB must report to and advise

the AGM-Nuclear in those areas of responsibility. The PAT determined

that the following events were not reviewed and reported by the SRAB:

. A violation of TS Section 6.3.4.A which requires that a high

radiation area be barricaded and conspicuously posted. This

violation was identified in licensee QA Audit Report 83-23.

. The cause of the failure of an automatic power transfer that

occurred following a reactor trip on August 8, 1984.

. Drifting in of three control rods from their full power positions.

The SRI reviewed the following documents applicable to the above events:

. Licensee QA Audit Report 83-23. Audit Report 83-23 identified and

discussed the lack of a barrier and conspicuous posting of an area

having a localized high radiation field. The SRI determined that

Audit Report 83-23 was transmitted to the AGM-Nuclear and other

corporate management through normal distribution channels.

. SRAB Meeting No. 80 agenda. The SRI verified that Audit No. 83-23

was attached to the SRAB Meeting No. 80 agenda and was routed to all

SRAB members for their review. The SRAB members acknowledged their

individual reviews by signing and dating a SRAB document review

memorandum from Mr. J. M. Pilant to SRAB, dated October 17, 1983.

. SRAB document review memorandums from Mr. L. R. Berry to SRAB dated

August 13, 1984 (two memorandums); August 14, 1984, September 10,

1984, and September 20, 1984. These memorandums combined, required

the SRABs review of SORC meetings 298, 299, and 300; Licensee Event

Report (LER)84-010; and formal SRAB' Meeting 88. The referenced

SORC meeting minutes documented discussions concerning failure of an

automatic power transfer including special testing and test results,

safety-related maintenance and surveillance testing that occurred

during the brief outage, Scram Report 84-05, and restart criteria

that the SORC required to be satisfied prior to starting up the

plant. LER 84-010 concerned the reactor trip and circumstances

surrounding that event. SRAB Meeting No. 88 minutes indicated

discussions of various topics including the automatic power transfer

failure. The SRI reviewed the SRAB memorandums discussed in this

paragraph and verified that each SRAB member acknowledged their

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individual reviews and discussions by signing and dating each

memorandum.

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SRAB document review memorandum from C. M. Kuta to SRAB dated

February 20, 1984. This memorandum required the SRAB to review SORC

Meeting No. 272 minutes that contained a discussion of control rod

drift problems. The SRAB members acknowledged their individual

reviews by signing and dating the document review memorandum.

. SRAB Meeting No. 83 minutes dated April 13, 1984. These minutes

identified the SRABs review of 50RC Meeting No. 275 minutes that

contained a discussion of control rod drift problems.

The PAT determined that the following TS violations were not reviewed by

the SORC:

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The violation of TS Section 6.3.4.A identified above.

. A violation of TS Section 6.2.1.B.6 which requires that SRAB meeting

minutes be issued within 1 month of the meeting. This violation

was identified in licensee QA Audit Report 84-02.

. A violation of TS Section 6.2.1.8.4 which requires the SRAB to

review 10 CFR Part 50.59 safety evaluations to verify that they do

not constitute an unresolved safety question. This violation was

identified in licensee QA Audit Report 83-01.

Concerning the 50RC's failure to properly review a violation of TS Section 6.3.4.A; the SRI confirmed that the 50RC had not reviewed this violation.

The SRIs review of the following documents identified procedural

deficiencies which contributed to the lack of SORC review:

. CNS Procedure 0.5, "Nonconformance and Corrective Action," Revision 0,

dated September 28, 1984, implements the requirement of TS Section 6.3.4.A concerning nonconformances and Nonconformance

Reports (NCRs). This procedure delegates the responsibility to any

individual who believes a nonconformance condition exists, to

implement the procedure including the initiation of Attachment "A,"

"Nonconformance Report." Attachment "C" provides a distribution

list for NCRs which includes the 50RC. Paragraph III.A.7 implies

exception to the distribution list in Attachment "C," when it states

that NCRs originated by the QA staff shall be sent to the department

supervisor responsible for the area in which the nonconformance is

identified. Also, the following procedures will indicate that the

QA department does not use Attachment "A" for reporting

nonconformances but instead uses a "QA Audit / Surveillance Report."

. CNS Quality Assurance Instruction (QAI)-5, " General Guidelines-

Quality Assurance Audits," Revision 18, dated June 18, 1984,

paragraph 3.3.j.2, defines QA " Findings" and " Observations." The

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implied definition of a QA " Finding" is synonomous with a "non-

conformance" as described in CNS Procedure 0.5. Paragraph 3.2

states that internal QA audit' findings, disposition, and followup

corrective actions will be identified on Attachment 7.2, "QA

Audit / Surveillance Report." Paragraph 6.0 provides a distribution

list for audit reports that differs from Attachment "C" of

Procedure 0.5 and does not include the SORC.

. CNS QAI-4, " Quality Assurance Surveillance," Revision 12, dated

January 30, 1984, paragraph 4.0 requires that QA findings be

identified on Attachment 5.3, "QA Audit / Surveillance Report."

Paragraph 4.0 also provides a distribution list for Attachment 5.3

which differs from the distribution lists noted in the preceeding

two paragraphs.

. CNS QAI-10, "Nonconformance Reporting, Issuance, Control and

Corrective Action," Revision 10, dated June 1, 1984, paragraph 3.1,

states that QA audits are to be documented on the " Quality Assurance

Audit / Surveillance Report" found in QAI-4. QAI-5 contains the same

form but it is not referenced in paragraph 3.1. Paragraph 3.2 of

QAI-10 states, in part, "CNS personnel will follow the guidelines

established in Administrative Procedure 1.10 (Nonconformance and

Corrective Action) whenever a nonconformity is identified . ..

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Note: Procedure 1.10 should be numbered 0.5.

The SRI determined from the above reviews that the QA department does not

follow the guidelines of Administrative Procedure 0.5 when they identify

nonconformances during QA surveillances and audits as follows: ,

. QAIs-4, 5, and 10 do not require the use of Procedure 0.5, ,

Attachment "A," "Nonconformance Report," for documenting,

dispositioning, and following up QA identified " Findings." As a

result, QA findings did not receive the same level of management

review as nonconformances identified by other CNS personnel.

. The QA Audit / Surveillance Report. identified in QAIs-4, 5, and 10

does not receive the same distribution as the "Nonconformance

Report" and neither QAI distribution list includes the 50RC.

The licensee's failure to-follow the procedure for activities affecting l

quality constitutes an apparent violation of 10 CFR Part 50, Appendix B,

Criterion V. (298/8516-01)

Concerning the 50RC's failure to properly review a violation of TS Section 6.2.1.B.6, the SRI determined that the SORC failed to review this

audit finding.for the same reasons stated above; e.g., insufficient level

of management review and inadequate distribution of the QA Audit /Sur-

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veillance Report. Subsequent to the finding identified in Audit 84-02,

the liceasee issued change 1 to Attachment 1, paragraph 7, of the "NPPD

Safety Review and Audit Board Instructions and Guidelines," effective

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September 24, 1984. The revision states, "SRAB meeting minutes should be

distributed to all SRAB members, the Assistant General Manager-Nuclear,

the Division Manager of Nuclear Operations, and others designated by the

SRAB Chairman within one week of each meeting. In no case will the SRAB

meeting minutes be issued later than one month from the date of the given

meeting as prescribed in CNS Technical Specifications, Item 6.2.1.B.6."

Concerning the 50RC's failure to properly review a violation of TS Section 6.2.1.B.4.a, the SRI reviewed the licensee's Audit of SRAB Activities

(G83-01) and determined that the findings were properly documented as TS

violations in an attachment to the QA Audit / Surveillance Report. The

SORC failed to review this audit finding for the same reasons stated

above; e.g. insufficient level of management review and inadequate

distribution of the QA Audit / Surveillance Report.

Based upon the licensee's corrective steps and the NRC regulatory action

stated above, unresolved item 8421-29 is closed.

(Closed) 8422-01 (Violation). This item concerned the licensee's

failure to cover materials stored outside with flame resistant covering.

Licensee corrective actions included removal of all nonflame resistant

tarpaulins from the site that could be used as weatherproof covering for

material stored outdoors. The NRC inspector reviewed the licensee's

response and verified satisfactory completion of corrective actions.

This item is closed.

(Closed) 8423-01 (Violation). This item concerned degradation of four

sets of fire doors due to the lack of maintenance of door knobs and

hinges, and extensive welding of exterior surfaces. Licensee corrective

actions included immediate adjustment and/or replacement of affected door

hinges and latches, ventilation system adjustments which enabled door

H305-3 to close and latch properly, and subsequent purchase of three sets

of doors to replace doors 8100-1, B101-1, and D301-1. Doors B101-1 and

D301-1 are included in Purchase Order (PO) No. 234767, whereas door

B100-1 has been already installed. The NRC inspector reviewed the

licensee's response to this violation and verified implementation of

corrective actions.

This item is closed.

(Closed) 8423-02 (Unresolved). This item concerned procedural

deficiencies, inadequate testing interval, and unsatisfactory test

results applicable to station emergency lighting units. The licensee

performed the following corrective actions:

. Repaired /or replaced lighting units that failed testing.

. Reduced the testing interval from 12 to 6 nonths on older model

nickel cadmium (NICAD) battery units.

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. Approved and implemented Maintenance Procedure 7.3.30, " Emergency

Lighting Units Inspection (NICAD) Battery Units," Revision 0, dated

March 1,.1985.

. Committed to replace the old NICAD battery units with " maintenance-

free" Exide units as the old units fail, or by December 1,1965,

whichever occurs first.

. Maintain sufficient supply of spare new units.

The NRC inspector verified that the licensee implemented the above

corrective actions.

This item is closed.

(Closed) 8423-04 (0 pen Item). This item addressed the existence of

excessive trash in the areas of the radwaste and turbine buildings. The

NRC inspector toured the affected areas on May 29, 1985, and observed

that the areas were properly maintained and free of accumulated trash.

This item is closed.

(Closed) 8423-05 (0 pen Item). This item concerned an inadequate .

number of barrier posts at six locations in the fire protection system.

The NRC inspector reviewed Maintenance Work Request (MWR) 84-0581 which

documented the installation of additional barrier posts, and visually

inspected those installations. Five of the six locations appeared

adequate, however, the fire flushing pump area requires another post or

relocation of the present posts in order to close the excessive gap

between posts located on the south side. The licensee committed to make

the necessary changes to provide the required equipment protection.

This item is closed.

(Closed) 8423-06 (0 pen Item). This item concerned a shortage of

equipment in fire locker No. 3. The NRC inspector reviewed CNS

Surveillance Procedure 6.4.5.2, Attachment (G)(fire locker evaluation)

that was completed by the licensee during May 1985, and determined that

all fire lockers contained the required inventory of equipment.

This item is closed.

(Closed) 8423-07 (0 pen Item). An NRC inspector identified that CNS

Surveillance Procedure 6.4.5.17, " Fire Fighting Equipment Monthly

Inspection," Attachment B, stated that outside hose cabinets were to

contain playpipes having a length of 50 inches. The actual length of the

playpipes were observed to be 30 inches. The licensee corrected the

typographical error of 50 inches to indicate the required length of 30

inches in a subsequent revision to Procedure 6.4.5.17. The NRC inspector

verified that the procedure was revised and that the new equipment

inventory checklists were in use.

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This item is closed.

(Closed) 8423-08 (0 pen Item). During a previous inspection, an NRC

inspector observed that a fire protection sprinkler located above the

primary containment maintenance entrance was sprung out of position and

was found to have several power cables strapped to it. The NRC inspector

toured the affected area on May 29, 1985, and observed that the

discrepancies had been corrected.

This item is closed.

(Closed) 8423-09 (0 pen Item). During the week of November 26-30, 1984,

an NRC inspector observed that housekeeping practices associated with the

firehouse were poor resulting in limited accessibility to fire fighting

equipment located inside. The SRI performed a followup inspection of the

area on December 4, 1984, and determined that licensee corrective actions

restored the firehouse to an acceptable level of cleanliness and

equipment was found to be properly stored and readily accessible. The

SRI has performed several inspections of the firehouse during 1985 and

has observed continued good housekeeping practices by the licensee.

Also, access doors to the firehouse are maintained in a closed condition

and accessibility to the area is limited to only those personnel having a

need to enter it.

This item is closed.

3. BWR Pipe Replacement Nondestructive Examination

An inspection was conducted by a DOE contractor from the Idaho National

Engineering Laboratory at the request of the NRC. The purpose of the

inspection was to evaluate nondestructive examination test records

associated with the BWR pipe replacement at the CNS. The inspector

reviewed 25 Chicago Bridge and Iron (CBI) work travelers including

approximately 900 sets of double loaded radiographic films, radiographic

reader sheets, and liquid penetrant / visual examination test reports. The

following work travelers and corresponding weld numbers were reviewed:

Travelers Weld Numbers

46801 2N-60 degrees

98A05 RWC-5

84A05 H2A

85A07 R1A and RSA

90A04 D1B and D2B

39F01 2N-210 degrees

49A02 NSB

89A04 S1B and S28

82A03 S7A and S8A

84A08 H1A

81A15 RR27A

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Travelers Weld Numbers (con't)

85A15 R6A and R2A

, 96A06 CSB Joint C

91A08 H2B

91A05 hlb

91A14 H38

92A11 R1B and R5B

91A11 H4B

96A0A CSA Joint G

96A05 CSA Joint G

51A01 Delta P

83A12 05A and D6A

83A04 DIA and D2A

81A08 S3A

98A07 RWC-3

It was concluded that there was an excellant defect correlation between the

radiographic reports and the ultrasonic reports. However, it was found

there were the following types and numbers of discrepancies:

. Radiographic reader sheets located in the travelers needed to be

updated to indicate acceptance or rejection status. (23 cases)

. The required copies of the radiographic reader sheets were not found

in the travelers. (9 cases)

. Welder information was not transferred properly from one reader

sheet to another. (5 cases)

. No acceptance or rejection of a radiographic station was on the

reader sheets. (5 cases)

. Addition of welders' names to the reader sheets between reshots and

final acceptance of the welds indicates a repair was made. The weld

of concern was not repaired or rejected. (1 case)

. Radiographic film was not properly marked to indicate status,

reshots, or repairs. (7 cases)

. The reader sheet indicated four films were used in the final

acceptance radiography. Only two films were found in the film

package. (1 case)

. The reader sheets did not indicate the number of the reshots or

repairs. (3 cases)

. A majority of the visual and liquid penetrant inspection reports

were not signed off by the customers' inspection department.

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All of the above discrepancies, excluding the last item, were corrected by

the licensee prior to the conclusion of the inspection. However, the

discrepancies indicated an apparent violation of 10 CFR Part 50, Appendix B,

Criterion XVII, which requires that inspection and test records identify

the inspector, the acceptability of test results, and the corrective actions

taken to correct deficiencies (8516-02).

4. Design Changes and Modifications

The NRC inspector selected work / procedure packages for review that were

implemented during the outage that commenced September 15, 1984, and is

still in progress. The outage has consisted of major work activities

such as replacement of reactor recirculation system piping, environmental

qualification of electrical equipment, 10 CFR Part 50, Appendix R fire

protection system upgrade, refueling operations, and other equipment

preventive maintenance, overhaul, replacement, or modification. A total

of 20 packages were selected and these included 16 MDCs, 2 surveillance

test procedures (STPs), and 2 special procedures (SPs). The selected

packages provided a broad cross section of work performed on plant

equipment and systems, the planning and coordination effort required

by all affected technical and work groups, and management review and

oversite of the outage as a whole. Special procedures and surveillance

test procedures were included in this review because they related to or

were a part of the MDC program performed during this outage. The following

work / procedure packages were reviewed:

. MDC-84-216, Amendment 1, Bronze Guides for Rockwell MSIVs

. MDC 83-066, HFA Relay Replacement

. MDC 84-0105/DC 84-001, ADS Logic Modification

. MDC 83-079, Replace D/P Transmitters-Steamline

. MDC 80-084, High Range Effluent Monitor

. MDC 84-224, Removal of Rec, PC & SW Valve Unqualified Local Control

Switches

. MDC 83-023, HPCI Exhaust Line Vacuum Breakers

. MDC 84-147, DG Instrument Tubing Upgrade

. MDC 84-150, IGSCC Piping Replacement

. MDC 84-150A, Removal of Interferences for IGSCC

. MDC 84-1508, Reactor Building Interior Wall Penetrations

. MDC 84-150C, Jet Pump Instrument Small Bore Piping-Reroute

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. MDC 84-150, Amendment 1, Reinstallation of Interference for IGSCC

Pipe Replacement

. MDC 84-259, Installation of CF-V-588

. MDC 85-005, Replace 24 VDC Battery

. MDC 85-022, Reroute ADS Valve Cables

. SP 84-009, Installation of RPV-Annulous Level

. SP 84-010, Installation of RPV Shroud Level Indicator

. STP 6.3.12.6, Diesel Generator No. 1 Annual Inspection .

. STP 6.3.12.6, Diesel Generator No. 2 Annual Inspection

In addition to the documents listed above, the NRC inspector performed

the following reviews:

. Master field copies for 16 of the above MDCs.

. Governing station Procedures 3.3, " Station Safety Evaluations"; 3.4,

" Station Design Changes"; and 3.5, "Special Test Procedures."

. Applicable 50RC and SRAB meeting minutes.

. Trend of MDCs implementation and closure over the past 3 years.

The NRC inspector's review verified that:

. Test results met established acceptance criteria.

. When circumstances prevented normal continuance of a procedure,

appropriate changes were made to that procedure prior to

recommencing the activity.

. Procedure controls were established and maintained as required by

the appropriate governing procedure.

. Inservice leak testing, if required, was appropriately addressed in

the work package and the applicable ANSI standard was readily

available and referenced.

. If questions were raised by personnel performing a particular

procedure, the cognizant design engineer responded to the question

and attached his reply to the package.

. The packages contained required signature review sheets.

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. SORC and SRAB approvals were documented.

. 10 CFR Part 50.59 reportable analysis reviews were performed.

. MDCs that were orginated under the superceded CNS Engineering

Procedure 1.13, contained appropriate attachments from the present

Engineering Procedure 3.4, which supplemented the original

information and ensured that the packages conformed with current

requirements and guidelines.

. The licensee was making a conscientious effort to complete and reduce

the total number of open MDCs.

The NRC inspector noted that only one of the MDC packages he reviewed was

officially closed out; i.e., the " Design Change Completion Report," which

is Attachment D to CNS Engineering Procedure 3.4, was completely filled

out, reviewed, and approved. This item is open pending review of the

remaining MDC completion reports identified during this inspection will

be subject to an NRC inspection prior to startup frva the present outage

(298/8516-03).

These reviews were conducted to verify that facility design changes were

prepared, reviewed, implemented, and closed in accordance with the

requirements established in CNS procedures.

No violations or deviations were identified in this area.

5. Operational Safety Verification

The SRI observed control room operations, instrumentation, controls,

reviewed plant logs and records, conducted discussions with control room

operators, and conducted system walk-downs to verify that:

. Minimum shift manning requirements were met.

. Technical Specification requirements were observed.

. Plant operations were conducted using approved procedures.

. Plant logs and records were complete, accurate, and indicative of

actual system conditions and configurations.

. System pumps, valves, control switches, and power supply breakers

were properly aligned.

. Licensee systems lineup procedures / checklists, plant drawings, and

as-built configurations were in agreement.

. Instrumentation was accurately displaying process variables and

protection system status to be within permissible operational limits

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for operation.

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. Plant equipment that was discovered to be inoperable or was removed

from service for maintenance was properly identified, redundant

equipment-was verified to be operabic, applicable limiting ,

conditions for operation were identified and maintained. ,

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. Equipment safety clearance records were complete and indicated that

affected components were removed from and returned to service in a

correct and approved manner.

. Maintenance work requests were initiated for equipment discovered to

require repair or routine preventive upkeep, appropriate priority

was assigned, and work commenced in a timely manner.

. Plant equipment conditions, such as cleanliness, leakage,

lubrication, and cooling water were controlled and adequately

maintained.

. Areas of the plant were clean, unobstructed, and free of fire

hazards. Fire suppression systems and emergency equipment were

maintained in a condition of readiness.

. Security measures and radiological controls were adequate.

The SRI performed lineup verifications of the following systems:

. Standby Liquid Control System

. 4160 VAC Electrical Distribution System

. Number 2 Diesel Generator

The tours, reviews, and observations were conducted to verify that

facility operations were performed in accordance with the requirements

established in the CNS Operating License and Technical Specification.

No violations or deviations were identified in this area.

6. Monthly Surveillance Observations

The SRI observed Technical Specifications-required surveillance tests.

These observations verified that:

. Tests were accomplished by qualified personnel in accordance with

approved procedures.

. Procedures conformed to Technical Specifications requirements.

. Test prerequisites were completed including conformance with

applicable limiting conditions for operation, required

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administrative approval, and availability of calibrated test

equipment.

. Test data was reviewed for completeness, accuracy, and conformance

with established criteria and Technical Specifications requirements.

. Deficiencies were corrected in a timely manner.

. The system was returned to service.

The reviews and observations were conducted to verify that facility

surveillance operations were performed in accordance with the

requirements established in the CNS Operating License and Technical

Specifications.

No violations or deviations were identified in this area.

7. -Monthly Maintenance Observation

The SRI observed preventive and corrective maintenance activities. These

observations verified that:

. Limiting conditions for operation were met.

. Redundant equipment was operable.

. Equipment was adequately isolated and safety tagged.

. Appropriate administrative approvals were obtained prior to

commencement of work activities.

. Work was performed by qualified personnel in accordance with

approved procedures.

. Radiological controls, cleanliness practices, and appropriate fire

prevention precautions were implemented and maintained.

. Quality control checks and postmaintenance surveillance testing were

performed as required.

. Equipment was properly returned to service.

These reviews and observations were conducted to verify that facility

maintenance operations were performed in accordance with the requirements

established in the CNS Operating License and Technical Specifications.

No violations or deviations were identified in this area.

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8. Exit Meetings

Exit meetings were conducted at the conclusion of each portion ~of the

inspection. Then NRC inspector summarized the scope and findings of

'each inspection segment at those meetings.

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