IR 05000298/1993006
| ML20035B789 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/30/1993 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20035B790 | List: |
| References | |
| EA-93-030, EA-93-30, NUDOCS 9304050110 | |
| Download: ML20035B789 (8) | |
Text
{{#Wiki_filter:* g aRfCo UNITED STATES K gi . ?g NUCLEAR REGULATORY COMMISSION [[i j
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400 o Y, ' AR LINGTON, TEXAS 76011-8064
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' WR 301993 i r ' Docket 50-298 License DPR-46 EA 93-030 Nebraska Public Power District ATTN: Guy R. Horn, Nuclear Power , Group Manager
P.O. Box 499 Columbus, Nebraska 68602-0499 SUBJECT: NOTICE Of VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES - 5200,000 (NRC INSPECTION REPORT NO. 50-298/93-06) This is in reference to the NRC's February 1-9, 1993, inspection at Cooper Nuclear Station (CNS), which was documented in a report issued on February 26, 1993. This inspection was conducted to review the circumstances surrounding Nebraska Public Power District's (NPPD) January 27, 1993, discovery of temporary strainers in the suction piping for Reactor Equipment Cooling pumps.
The inspection found apparent violations involving: 1) a failure to provide complete and accurate information to the NRC in response to a previous, related Notice of Violation; and 2) a failure of NPPD's corrective action program to identify and resolve this potentially significant safety concern in the Reactor Equipment Cooling and other safety-related systems despite several opportunities. On March 4, 1993, you and other NPPD representatives discussed these apparent violations at an enforcement conference in the NRC's Region IV office in Arlington, Texas.
The circumstances surrounding these violations warrant some discussion.
In August 1992, an NRC inspector found indications of a strainer in,the alternate suction piping for the CNS Core Spray System. Although the system drawings did not indicate the presence of a strainer in this system, NPPD investigated and confirmed the presence of temporary strainers, i.e., strainers used during start-up testing and intended to be removed following such testing, in the alternate suction piping for both Core Spray System lines. This prompted NPPD's preparation of Nonconformance Report (NCR) 92-104 and an investigation to determine the root cause. On November 3, 1992, the NRC issued a Notice of Violation to NPPD, citing the failure of its corrective action program to identify and correct this non-conforming condition.
In a December 1, 1992 response to the Notice of Violation, NPPD cited the root causes of the viclation as: 1) a programmatic weakness in NPPD's actions in response to NRC Information Notice 85-96, entitled " Temporary Strainers left Installed in Pump Suction Piping;" and 2) the failure of the Core Spray System pre-operational CERTIFIED Mall RETURN RECEIPT REQUESTED 3040 g g % $ 9s m - .
. _ ._ __ . . _ ! f ~ . ! ! Nebraska Public Power District-2- } i ,- ! ! i testing procedure to include a specific step regarding the removal of the l temporary strainers. NPPD's December 1,1992, reply also stated that system ~ walkdowns had been conducted to ensure that similar strainers were not located , in other safety systems and that there were no visible indications of ' strainers in the Service Water, Reactor Equipment Cooling, Residual Heat , ' Removal, or High Pressure Coolant Injection systems. With regard to the .! Reactor Core Isolation Cooling System, the reply stated that an unlabeled
spacer plate was discovered in the flange to a spool piece used to install the j original startup (temporary) strainer, but stated "A specific completed sign-j off in the preoperational test procedure... indicates that the strainer had
been removed prior to startup testing." Nonetheless,.the reply stated, this ! conclusion would be physically verified by radiography or removal and i inspection of the spool piece during the 1993 refueling outage.
j i On January 27, 1993, during the replacement of a Reactor Equipment Cooling . ? pump, NPPD personnel discovered a temporary strainer installed in the pump l suction piping.
Radiography of the remaining three Reactor Equipment Cooling
pumps confirmed that temporary strainers were present in the suction piping ! for each. This finding indicated that the system walkdowns relied upon in ! responding to the November 3,1992, Notice of Violation may not have been i , adequate to determine the presence of temporary strainers. Thus, NPPD-l radiographed the suction piping to the Reactor Core _ Isolation Cooling pump and i confirmed the presence of a temporary strainer in it, a finding which drew
' into question the statements made in response to the previous violation and discussed above. The facts that have emerged from the NRC's follow-up
inspection and from discussions with NPPD personnel during the enforcement
l conference indicate: 1) that NPPD's December 1, 1992, reply was inaccurate l t and incomplete in several material respects; and 2) that NPPD had multiple ! opportunities to act on information that indicated the possibility of i temporary strainers left in plant safety systems and failed to do so.
NRC regulations require licensees to ensure that information provided to the NRC is complete and accurate in all material respects. With regard to NPPD's
December 1,1992, letter, the NRC's inspection did not find a " specific completed sign-off in the preoperational test procedure" indicating that the
Reactor Core Isolation Cooling pump strainer had been removed.
In fact, the ! only document which would have indicated that the strainers had been removed [ was Startup Test Instruction (STI) 14.
On the only available copy of this-l document, there was no signature in the block adjacent to Step 6.2.9, which l said " Remove suction strainers at a convenient time after completion of all- ! RCIC related. tests." Although the individual who prepared NPPD's reply was j aware of this documentation at_ the time the inaccurate reply was submitted, he_ ? stated _ttat he relied on an interview with an engineer who had been involved in start-up testing and who assured him that a signed document' existed , verifying the removal of the temporary strainer. During the enforcement
conference, NPPD indicated that the engineer may have been confused by his ! recollection of a signature on a Reactor Core Isolation Cooling preoperational j' test document, which_ indicated only that " Notation has been made to remove
these strainers when appropriate." Had the information NPPD provided been ll
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! ' Nebraska Public Power District - 3- . ! ! ! E accurate, this information would have caused the NRC to conduct additional
inspections or request NPPD to pursue further the question of whether l temporary strainers were left in this system.
{ The NRC must be able to rely on information provided by licensees to make ! sound regulatory judgements about the safety of licensed activities. Although l the submission of inaccurate information in this case appears not to have been willful, the circumstances surrounding it indicate a. failure on the part of.
the Plant Engineering Department supervisor who prepared NPPD's response to i the Notice of Violation and carelessness on the part of others who reviewed , this information to ensure its accuracy before submission to the NRC.
Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, ! Violation A in the enclosed Notice of Violation and Proposed Imposition of i Civil Penalty (Notice) has been categorized at Severity Level III.
l In addition to the inaccurate statement in NPPD's reply to the Notice of Violation, the reply provided no information regarding other evidence that NPPD had obtained indicating that the possibility of temporary strainers having been left in safety systems could not be ruled out. This information, ' which was available to NPPD during the preparation of Nonconformance t Report 92-104 and prior to the issuance of its December ~1, 1992, letter, l included: 1) the fact that temporary strainers had been found in the Residual l Heat Removal system in 1986, a finding which apparently invalidated NPPD's , confidence in its response to NRC Information Notice 85-96 but.which resulted i in no further efforts to check for the presence of strainers in other systems; . ! 2) the fact that spacer rings were discovered during NPPD's September 1992 walkdown of the Reactor Equipment Cooling system, a finding which, according I
to the NRC's 1985 information notice, could indicate the presence of temporary
' strainers; and 3) the fact that NPPD's 1986 evaluation in response to the same ! information notice had recommended further evaluation of the possibility of I temporary strainers in the Reactor Equipment Cooling system and'that no .! further evaluation was done. The NRC believes that this information should-have been provided in NPPD's December 1, 1992,. response.. However, NPPD's ! failure to provide this information is closely related to the failure'of . i NPPD's corrective action program to evaluate the same information and question ! whether temporary strainers had been removed from all safety systems. Thus, > the NRC has elected to exclude from Violation' A in the Notice any reference to 'I the-incompleteness of NPPD's response.
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! The circumstances surrounding the. failure of NPPD's corrective action program l to identify and resolve the potential for temporary ' strainers left in safety - r systems are 'similar and equally significant. Although Violation B'in the ' ' i enclosed Notice refers only to the failure of NPPD's corrective action program i' subsequent to the discovery of temporary-strainers in the Core Spray system and the issuance of-the Notice of Violation in November 1992, the fact is that NPPD has had multiple indicators of the potential for this problem and ! multiple. opportunities over an extended period of time to identify and. resolve ! this issue.
Beginning with the issuance of the NRC's information notice ~in l ! I ' , , , -- r ' v ...-.. ------ .------ - - ---- -- -- - A .-- -- - --
, .-. .. .. . - . i . l Nebraska Public Power District-4- . i .i 1985, these included: 1) NPPD's response to the information notice, which identified the possibility of strainers in the Reactor Equipment Cooling system but which resulted in no further evaluation; 2) NPPD's. discovery in i 1986 of temporary strainers in the Residual Heat Removal System, which also
prompted no further evaluation; 3) NPPD's discovery in 1989 of what appeared ! to be temporary strainers which had affected flow in a fan coil unit; 4) the j NRC's discovery in 1992 of temporary strainers in the Core Spray system; and i 5) NPPD's awareness that it had no documented evidence of having removed the i temporary strainer; from the Reactor Core Isolation Cooling system.
Despite all of these indications, and information to the contrary, NPPD took.
! no effective steps to positively ensure that the intended removal of temporary l strainers from plant safety systems had been effected.
NRC regulations in ! ' 10 CFR Part 50 require licensees to have measures in place to assure that " conditions adverse to quality," including deviations and nonconformances, are
- promptly identified and corrected.
In this case, NPPD's program for ! identifying and resolving such nonconformances failed on multiple occasions.
! The NRC's 1985 information notice informed NPPD that there are several i' mechanisms by which temporary construction strainers could cause safety systems to be made inoperable.
Although the temporary strainers found in CNS safety systems do not appear to have impacted system operability during normal plant operations, the potential problems discussed in Information Notice 85-96 still existed.
Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR ! Part 2, Appendix C, Violation B has been deemed a failure to identity and l resolve a potentially significant condition adverse to quality and has been ! categorized at Severity Level III.
l i As described at the enforcement conference, NPPD's short-term corrective i actions amounted to an evaluation of the existence of additional strainers by.
! reviewing system drawings, conducting system walkdowns, performing radiography ! of safety systems, and reviewing existing design basis documentation.
NPPD's ! - long-term corrective actions include: 1) plans to evaluate, and. remove if {' necessary, all safety and support system strainers; 2) plans to update affected plant drawings; 3) plans to provide management's expectations to all personnel with respect to NRC submittals; 4) plans to include 10 CFR 50.9 requirements in continuing training programs; 5) plans to include the strainer -; -issue in industry. event training; and 6) plans to develop instructions for-l disposition of broad, multi-system issues.
l At the enforcement conference, NPPD identified the root cause of both of these ! violations as a failure to assign ownership or responsibility for resolving.
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broad, multi-system issues. With respect to the accuracy of information, NPPD ' identified a secondary root cause as a lack of' sensitivity to'the' requirements of 10 CFR 50.9.
NPPD's corrective actions are directed toward these two , factors. While the NRC agrees that these factors played a role in these . , issues, individual performance and commitment to quality performance, may be a ll contributing root cause.
The NRC recommends that NPPD examine these factors ! - and supplement its corrective action as appropriate.
In addition, with ! l i .h
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! Nebraska Public Power District-5-t > respect to the failure of NPPD's corrective action program, the NRC recommends that NPPD focus more attention on the program itself to determine whether a j more fundamental weakness exists with regard to the identification and
resolution of potential problems. As you know, the NRC has been critical of various aspects of NPPD's corrective action program in the past.
In the most
recent Systematic Assessment of Licensee Performance report, dated March 16, 1992, we stated that "... the threshold for issuance of nonconformance ! reports was too high to ensure that all potential deficient conditions were , identified." Other reports issued in the last year have cited untimely root > cause analyses for identified problems, ineffective corrective actions to address copper contamination of station batteries' the failure to document , annunciator problems in a nonconformance report, the failure to correct i deficiencies in Emergency Operating Procedures and the failure to correct
emergency preparedness deficiencies.
To emphasize NPPD's need to improve its problem identification and resolution programs, as well as its need to assure that information-provided to the NRC ' is complete and accurate in all material respects, I have been authorized, , after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regicnal Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of ! Civil Penalties (Notice) in the amount of $200,000 for the Severity Level III violations described above and in the Notice.
' t . The base value of a civil penalty for a Severity Level III violation is i 550,000. The civil penalty adjustment factors in the Enforcement Policy were i considered for each violation and resulted in penalties twice the base value j for each.
For the violation of 10 CFR 50.9, the penalty was increased because
it was identified through the pursuit of the NRC's inspectors and.because NPPD ' had information available to it (prior opportunities to identify) that, if acted upon, could have prevented the violation from occurring. These ! increases were balanced against.a decrease based on NPPD having no recent
history of violations of this type. The adjusted civil penalty for. this j violation is $100,000.
For the violation of-10 CFR Part 50, Appendix B,
Criterion XVI, the penalty was decreased because NPPD identified the strainers i that led to the recognition of this violation, but was increased because NPPD ' had information available to it that, if acted upon, could have prevented this . violation from occurring, and because this violation appears to be another i indication of generally poor performance in identifying and resolving problems. The adjusted penalty for this violation is $100,000. -The remaining ! adjustment factors were considered for each violation but no additional
adjustments were deemed to be warranted.
~ r NPPD is required to respond to Ethis letter and should follow the instructions ' ! specified in the enclosed Notice when preparing its response.
In your + response, you should document the. specific actions taken and any additional-l actions you plan to prevent recurrence.
In addition, you should include-in j your response, (1) the measures NPPD has taken, or plans'to take, to ensure
that NPPD employees involved in communicating with the NRC, and in particular l . p , $ .~ -
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. _ _ _ _ _ - -= _. - i ' f Nebraska Public Power District-6-I i I ! ! the aforementioned Plant Engineering Department supervisor, understand the l importance of and will comply with the requirements of 10 CFR 50.9 in ' preparing information for submittal to the NRC and (2) the measures NPPD has j taken or plans to take to address possible additional root causes of these i I violations including individual performance and attitudes, and weaknesses in i the identification and resolution of potential deficiencies. After reviewing l your response to this Notice, including your proposed corrective actions and , l the results of future inspections, the NRC will determine whether further NRC
enforcement action is necessary to ensure compliance with NRC regulatory ! requirements.
l ! In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of l this letter and its enclosure will be placed in the NRC Public Document Room.
! The responses directed by this letter and the enclosed Notice are not subject j to the clearance procedures of the Office of Management and Budget as required i by the Paperwork Reduction Act of 1980, Pub. L. No. 96-511.
Sincerely, , n L /l b
i J ames L. Milhoan I egional Administrator Enclosure: ! Notice of Violation and Proposed Imposition
of Civil Penalties
CC: ' Nebraska Public Power District ATTN: G. D. Watson, General Counsel ! . P.O. Box 499 i Columbus, Nebraska 68602-0499
Cooper Nuclear Station ATTN: John M. Meacham, Site Manager , l P.O. Box 98
Brownville, Nebraska 68321 i Nebraska Department of Environmental Control ! ATTN: Randolph Wood. Director P.O. Box 98922 Lincoln, Nebraska 68509-8922 ! ? ! ! i .
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-* j ..- . i ' Nebraska Public Power District- -7-i l i . I Hemaha County Board of Commissioners I ATTN:: Richard Moody, Chairman ! Nemaha County Courthouse
1824 N Street.
i Auburn, Nebraska '68305 Nebraska Department of Health , ATTN: Harold Borchert, Director ! Division of Radiological _ Health ! 301 Centennial Mall, South P.O. Box 95007 ! Lincoln, Nebraska 68509-5007 j Kansas Radiation Control Program Director i-i
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