IR 05000298/1989009
| ML20244C977 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/02/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| EA-89-056, EA-89-56, NUDOCS 8906160010 | |
| Download: ML20244C977 (1) | |
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?JUN -.21989
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' In Reply Refer To:
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Docket: 50-298/89-09 EA No; 89-56:
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Nebraska Public Power District-ATTN: ~ George A. Trevers
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t Division Manager - Nuclear Support l'
P.O. Box 499
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Columbus, NE 68602-0499'
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Gentlenu.
Thank you for your letter:of May'.17,1989, in response to ourTletter.and
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' Notice ~of Violation dated April. 20,'1989.. We have' reviewed your reply,and findfiti f.
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responsive to the concerns raised ~1n'our Notice of Violation. We will review
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the implementation of your corrective actions during a' future inspection:to '
determine.that full compliance has been achieved and will.be maintained.
Sincerely,
. ORIGINAL SIGNED BY:
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'1. J. Callan Director
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' Division of. Reactor Projects
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Cooper Nuclear Station i
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ATTN: Guy Horn, Division Manager
of Nuclear Operations -
P.O. Box 98
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Brownville, Nebraska 68321
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Kansas Radiation Control Program Director Nebraska Radiation Control Program Director
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bectoDMB-(IE01)
bec distrib. by RIV:
RRI R.;D. Martin, RA i
SectionChief(DRP/C)
Lisa Shea, RM/ALF l
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RPB-DRSS MIS System RIV File Project Engineer (DRP/C).
RSTS Operator DRP
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P. O'Connor, NRR Project Managerf (MS:.13-D-DRS
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nnett GL stable GFSan orn LJCallan
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COOPER NUCLEAR STA~loN j
Ibd. Neb aska Public Power District
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CNES897239 l
May 17, 1989-i'(9[Op]~lj 3, ll f
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U.S. Nuclear Regulatory Commission J L L_... - ---
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Attention: Document Control Desk Washington, DC 20555 j
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Subject: NPPD Response to Notice of Violation - NRC Inspection Report j
No. 89-09 i
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Gentlemen:
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This letter is written in response to your letter dated April 25, 1989, I
transmitting Inspection Report 50-298/89-09.
Therein you indicated 'that i
lj certain of our activities were in violation of NRC requirements.
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Following is a statement of the violations and our. response in accordance with l
Statement of Violation 10CFR Part 50, Appendix B, Criterion XVI, requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and
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equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall l
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assure that the cause of the condition is determined and corrective i
action taken to preclude repetition.
Contrary to the above, Emergency Diesel Generator (EDG) No. I at Cooper l
Nuclear Station failed on January 17, 1989, due to a cracked fitting in
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the control air system, and the licensee did not take adequate corrective
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action to preclude repetition. EDG No. I failed again on February 13. 1989 I
when the replacement' fitting, a thinner walled component than that which
had been replaced, was found cracked during an operational' test of the diesel.
l Reason For The Violation The reason for the violation was an inadequate root cause evaluation'of the January 17 failure in that vibration resistance was not recognized as a critical characteristic of the replacement control air system fitting.
The January 17 failure was attributed to interferences between the tubing attached to the failed fitting which had eventually caused it to become overstressed..
J The interferences were removed, the fitting was replaced, and the' EDG was returned to an operable status.
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The original installation.of the failed fitting, and its function related_ to l
vibrcthn recictance, were.the subject of_a Nonconformance Report (NCR) issued,
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However, the event associated with the 1974 NCR was not discovered during, the root. cause analysis performed as ~ a. result of the January 17 failure.
Since the selection of the replace..:nt fitting overlooked vibration resistance as a critien1 characteristic, the second failure occurred.
Ccrrective, Steps Which Have Been Taken And The Results Achieved 1.
Subsequent to the. February 13, 1989, fitting failure, immediate
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corrective actions included modifying the tubing configuration ' to
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eliminate the need for the fitting, change out ' of tubing in the critical
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air header, and implementing other modifications' to increase the vibration resistance of the control air system tubing on both EDGs.
These modifications provided for reliable EDG operation for the remainder
of the operating cycle.
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During the period of March 15 through March 17, 1989, station engineering.
and management personne1' attended training on technical root cause and
failure analysis.
The training was presented on' site by Failure l
Prevention, Inc.
This training discussed, depth of root cause analyses, l
common failure mechanisms, and failures which have recently. been of primary cencern at nuclear power generating facilities.
For the short term, the EDG failure and the training provided have increased the awareness of station engineering personnel as to the information required j
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to adequately identify failure mechanisms and to better evaluate failure l
modes.
Corrective Steps Which Will Be Taken To Avoid Further Violation i
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As a planned part of the current (1989) refueling outage, the following
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EDG tubing and control component modifications are currently in progress:
1) Critical components and instrumentation for EDG support systems are
being moved from the EDGs to seismically qualified floor-mounted panels, 2) All critical stainless steel, copper, ot carbon steel tubing is being replaced with stainless steel tubing, 3) Tubing supports are -being replaced with supports which are more resistant to fretting interaction with the tubes, and 4) The new tubing spans will be verified to be within pre-determined specifications for required seismic and engine vibration constraints. These modifications will be completed on both EDGs prior to
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plant startup from the 1989 Outage, e
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Contract engineering services have been obtained to reformat and enhance
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the computerized NCR database. This effort includes a detailed review of
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the data for all NCR records to ensure that it accurately reflects the l
system or component which was affected, as well as the required failure and root cause information.
In' addition, the information will be i
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revised, as required, to conform to a set of standard guidelines. This will allow station engineers to manipulate the data more efficiently _and effectively during future root cause analyses. The scheduled completion
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date for this task is September, 1989.
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May 17, 1989
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Parallel to the NCR database upgrade' effort, an= Engineering Department
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Instruction for document research will be issued.
This instruction will
'l provide general search methods and guidelines for the review of industry'
l experience databases and station - computer files.. ' The NCR database document research methodology will-be incorporated into the instruction I
by September, 1989.
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The root cause analysis program will be revised to include requirements
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for evidence preservation, guidelines for failure mode. identification, instructions for root cause' determination, and additional' training for engineering and. management personnel.
'In ' addition, Cooper - Nuclear l
Station Engineering wi11' purchase and maintain investigative tools to support these activities. The scheduled completion date for-this task is October, 1989.
Date'When Full Compliance Will Be Achieved The corrective steps noted will be implemented on the' dates specified herein, with full compliance achieved by October, 1989.
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.i If you have any questions regarding this response, please contact me or
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G. R. Horn at the site.
Sincerely, j
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_-G. A. Trevors Division Manager Nuclear Support GAT kg j
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Ld S. Nuclear Regulatory Commission
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Region IV Arlington, TX NRC Resident Inspector i
Cooper Nuclear Station
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