IR 05000298/1993008
| ML20059B545 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/21/1993 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9310280287 | |
| Download: ML20059B545 (31) | |
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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2 1 i993 Docket:
50-298 License: DPR-46 Nebraska Public Power District ATTH:
Guy R. Horn, Vice President - Nuclear
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P.O. Box 98 Brownville, Nebraska 68321 Gentlemen:
SUBJECT: MANAGEMENT MEETING ON OCTOBER 8, 1993, IN REGARD TO NRC INSPECTION REPORT 50-298/93-08 This refers to the meeting conducted at your request in the Region IV office on October 8, 1993. This meeting related to initiatives you were taking to improve your motor-operated valve program and was attended by those.on the attached Attendance List.
The subjects discussed at this meeting are described in the enclosed Meeting
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Summary.
It is our opinion that this meeting was beneficial and has provided a good understanding of your plans to address those shortcomings identified by NRC during NRC Inspection 50-298/93-08 conducted in September 1993. Your response and implementation effectiveness will be reviewed and evaluated by NRC during a future inspection.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Should you have any questions concerning this matter, we will be pleased to i
discuss them with you.
Sincerely, GiuM
. Co~TTins, Director Division of Reactor Safety l
l Enclosure:
Meeting Summary w/ attachments cc w/ enclosure:
(see next page)
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Nebraska Public Power District-2-
cc w/ enclosure:
Nebraska Public Power District ATTH:
G. D. Watson, General Counsel P.O. Box 499 Columbus, Nebraska 68602-0499
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Nebraska Public Power District ATTN: Mr. David A. Whitman P.O. Box 499 Columbus, Nebraska 68602-0499 Nebraska Department of Environmental Control
ATTN:
Randolph Wood, Director
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P.O. Box 98922 Lincoln, Nebraska 68509-8922
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Nemaha County Board of Commissioners ATTN: Larry Bohlken, Chairman Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 Nebraska Department of Health ATTN: Harold Borchert, Director Division of Radiological Health 301 Centennial Hall, South P.O. Box 95007 Lir.coln, Nebraska 68509-5007 Kansas Radiation Control Program Director l
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J. L. Milhoan Resident Inspector Section Chief (DRP/C)
Lisa Shea, RM/ALF, MS: MNBB 4503 HIS System DRSS-FIPS Section Chief (DRP/TSS)
Project Engineer (DRP/C)
RIV File Senior Resident Inspector - River Bend Senior Resident Inspector - Fort Calhoun
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M. Runyan T. Westerman
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Section Chief (DRP/TSS)
Project Engineer (DRP/C)
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o MEETING SUMHARY Licensee:
Nebraska Public Power District Facility:
Cooper Nuclear Station License No.: DPR-46 Docket No.:
50-298 Subject:
Motor-operated Valve Program Initiatives
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The licensee presented a summary of actions planned in response to the findings of NRC Inspection Report 298/93-08. The presentation included a summary of general conclusions, discussion of a planned reorganization of the motor-operated valve project, a summary of root causes and corrective actions related to the violations in the subject report, discussion of a planned refocusing of quality assurance in this area, and comments related to the inspection followup items identified during the inspection.
Attachments:
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Attendance List 2.
Licensee Presentation (NRC distribution only)
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-2-ATTACHMENT 1 ATTENDANCE LIST
Attendance at the management meeting between Nebraska Public Power District
and NRC on October 8,1993 in NRC Region IV:
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NPPD G. R. Horn, Vice President, Nuclear J. M. Meacham, Site Manager R. E. Wilbur, Division Manager of Nuclear Engineer ing and Construction V. L. Wolstenholm, Division Manager of Quality Assurance K. A. Almquist, MOV Project Manager G. R. Smith, Manager of Nuclear Safety and Licensing ERIN E. Simbles NRC J. L. Milhoun, Regional Administrator S. J. Collins, Director, Division of Reactor Safety (DRS)
A. T. Howell, Acting Deputy Director, Division of Reactor Projects (DRP)
T. F. Westerman, Section Chief, DRS M. F. Runyan, Reactor Inspector, DRS W. B. Jones, Project Engineer, DRP i
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AGENDA Introduction /
J. Meacham Summary of Conclusions MOV Project Management R. Wilbur Summary of Violations K. Almquist Root and Contributing Causes Corrective Actions QA Program Oversight V. Wolstenholm Discussion of Other Inspection Issues K. Almquist Closing Remarks J. Meacham
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BTRODUCTION The purpose of this meeting is to:
Address Issues Raised During the Recent Generic Letter 89-10 Inspection e
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Focus on root cause(s) of deficiencies
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Provide a summary of actions taken and to be taken
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Demonstrate the overall adequacy of Cooper ~MOV Program H
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NRC INSPECTION RESULTS e
Four Strengths
Four Potential Violations e
One Unresolved Item Ten Inspection Follow-Up Items
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SUMMARY OF CONCLUSIONS The MOV Project effort has been responsive to GL 89-10 concerns
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Strengths include assumption conservatism, design basis review calculations, aggressive test program, and torque and thrust measurement during diagnostic testing
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Procedure deficiencies are unacceptable to manageme.ut, however, GL 89-10 efforts have been effective, as will be demonstrated during the presentation Oversight of MOV activities by the project organization must be improved to ensure
that issues are appropriately addressed Engineering judgements for the MOV Project have been generally correct -
documentation of bases forjudgments must be auditable Quality Assurance oversight must be improved to better provide a " safety net"
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MOV PROJECT MANAGEMENT HISTORY Significant MOV work as a result of IE Bulletin (IEB) 85-03
Generic Letter 89-10 expanded scope of IEB 85-03 work
Plan developed to use existing CNS organi7ation
NRC Phase I inspection results indicated that CNS was on the right track
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MOV Project Functional Organization m oi" *
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Site Osganisation NPCD Hanages
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Larry Kohles CNS Maintenance Manager
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Hlho Unruh
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Een Almquist
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Progree $1te (Remaining Program Activities)
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Supa rvisor
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Cost and Supervisor.
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CNS Operations Scheduling Speel li st s
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Support
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Psoject Enstneer Project Seceetasy CNS Maintenance
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Support
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Electalcal Program Development
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Nuclear 1. l c e n s i ns Haintenance Engineering
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Support
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Engineer Support
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Planner / Scheduler
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Enstneering Support
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Project Support System Engineer Servlees
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Palmary Consultant utganisatiou
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HudtlicatLons Deslan Enstneers Construction Hanagement ERIN Project Hausger
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Support (As tequired)
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Assoclated Contract
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Hodification EitIN Psoject Modifications Suppest Installation
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Orgenlaatton Support
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hullJ aeporting !!aes indicate funettonal Intesteces, 2.
Dasbe,I reporting lines indfeste communleation and coosdinatten luterisces.
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Revised MOV Project Organization
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NPCD Manager Site Organization CNS Maintenance Manager
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Project Manager Ken Almquist
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Cost and
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Scheduling Specialists Supervisors
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ltthe Tumicht J. Steiner/K. Wemhoff Consultant
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Program Site Project Secretary Quality Assurance ji Supe rviso r Nora Dingman Electrical Engineering
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Val Rathke
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Support D. McManaman/J. Hackney /D. Buman
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CNS OperatLons Program Development Nuclear Licensing
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Supporr Mechanical Enstneering
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Support Using Outside Assistance (M. Bennett)
B. Kochanovier (Full Time)
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Project Support Services
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5. Harsh (Part Time)
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Civ11 Enstneering I
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LCAs and Speelal Tasks
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Design Engineers Construction Management ERIN Program Manager
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Art Ulese C. Bean Craig Sellers
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I Diagnostic Testing & Analysts Contract ERIN Froject
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Supervisor Modification Organisation L. Briley - Consultant Installation Support
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Solid reporting lines indicate functional interfaces.
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Dashed reporting lines indicate consuunleation and coordination interfaces.
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MOV PROJECT IMPROVEMENTS Centralized project management
Improved project overview (better coordination of efforts)
Improved auditability
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SUDIARY OF POTENTIAL VIOLATIONS 10 C.F.R. Part 50. Appendix B Criterion III - Design Control Inadequate formulation of target windows and acceptance criteria, and trace evaluation Criterion V - Procedures Inadequate procedures for controlling extrapolation, errors outside of calibration range, and evaluation of trace point 010 extrapolation; undefined acceptance criteria in the open direction.
Criterion XI - Test Control Inadequate evaluation and documentation of acceptance criteria related to dynamic testing prior to returning valve to service Criterion XVI - Corrective Action Inadequate corrective action taken to address CS-M05A H
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ROOT AND CONTRIBUTING CAUSES All of the potential violations were caused by one or more of the following deficiencies:
Inadequate oversight of MOV project by personnel in charge of the effort
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Unclear definition of responsibilities
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Inadequate documentation of basis for technical conclusions
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Failure to ensure through independent assessments that procedures contained appropriate criteria and that engineering judgement assessments were properly documented
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Inadequate QA oversight -- failure to:
confirm that proper acceptance criteria was contained in procedures
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ensure that independent technical assessments were performed on technical
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conclusions
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ensure that engineering judgement decisions were properly documented M
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COS RECTIVE ACTIONS -- SHORT-TERM l
Efforts initiated to develop consistent, documented guidelines for MOV assessment-
(minimize use of undocumented, unchecked engineering judgement):
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documented criteria for target windows, acceptance criteria, and extrapolation
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documented guidelines ~or evaluating significant abnormalities / anomalies Actions were taken to obtain third-party verification of engineering judgments made e
regarding anomalies, target windows, trace evaluations, etc.
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An assessment is currently being performed of tested valves in the GL 89-10 program to determine if similar deficiencies existed M
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CORRECTIVE ACTIONS -- SHORT TERM (CONT.)
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Immediately upon identification of the CS-MO5A issue, an operability determination
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Deficiency Report issued regarding CS-MO5A The QA organization began reassessing its involvement in the GL 89-10 MOV
Project The MOV Project organization was reviewed to determine whether it was
performing its intended functions and modified appropriately Began review of all procedures related to MOV program
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_ CORRECTIVE ACTIONS - LONG TERM Complete window and setting engineering calculations
Revise procedures to more clearly require:
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documented acceptance criteria
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engineering review and approval of testing results prior to operability declaration
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trace evaluation and extrapolation methodology Periodically assess effectiveness of new MOV Project organization through existing
(but improved) mechanisms such as the QA organization and self-assessment program Additional training of personnel and clearer definition of personnel qualifications
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QUALITY ASSURANCE OVERSIGHT
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Several NRC findings should have been identified by the QA organization e
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Several are indicative of basic QA expectations a
confirmation of existence of acceptance criteria confirmation of adequate procedural controls a
a documentation of bases for conclusions Similar to the continuation of efforts approach taken by the MOV Project regarding e
IEB 85-03 and GL 89-10, the QA organization viewed its efforts as a continuation of IEB 85-03 engineering and maintenance activity surveillance
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QA continued to monitor MOV work by surveillances that had been incorporated into the functional area audits
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GL 89-10 greatly expanded the IEB 85-03 focus BG
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QUALITY ASSURANCE OVERSIGHT CORRECTIVE ACTIONS Due to unique nature of GL 89-10 efforts, unique QA audit plan is being developed
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Ensure adequate technical self-assessments
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QA inspectors will not become technical experts, but will be familiar with test equipment capabilities, bases for acceptance criteria, results expectations
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Will have characteristics of performance-based and compliance-based QA audits BG
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QUALITY ASSURANCE OVERSIGHT CORIMCTIVE ACTIONS (CONT.)
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QA deficiencies are not indicative of current overall QA performance
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QA has learned many lessons as a result of recent events and is involved in an extensive transformation
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Recent QA improvements would have prevented similar mistakes if similar project initiated today Other similar ongoing programs have been reviewed and QA involvement will be e
improved based on lessons learned from this event
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Check Valve Program
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QUALITY ASSURANCE OVERSIGHT CORRECTIVE ACTIONS (CONT.)
Ongoing QA improvement efforts involve:
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Development of a QA assessment group
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Reduction in the frequency of certain audits depending on need
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Re-scoping audits and re-focusing surveillances to be more effective
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Development of a QA Guideline Evaluates NRC inspection reports, QA inspection reports, NRC generic a
documents, industry initiatives, etc., to determine applicability to QA activities
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DISCUSSION OF OTIIER INSPECTION FINDIN'GS CS-MO5A During evaluation of test data, anomaly noted
Based on an undocumented evaluation the anomaly was not an operability concern
During Phase II inspection, anomaly questioned by inspectors e
Documented evaluation and O.D. performed - valve and CS train determined to e
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v DISCUSSION OF OTHER INSPECTION FIXDINGS (CONT.'D)
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CS-MO5A Third party review, as part of inspection short term corrective actions, utilized
additional conservatisms and resulted in a negative torque margin.
- Valve declared Inoperable on October 7,1993 Maintenance activities being considered to render valve operable
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Request for Enforcement Discretion being considered in order to conduct additional testing or operate in the present condition Part of D.R. short term corrective action is to obtain diagnostic test signatures
during quarterly surveillance to monitor condition
Repair / replace valve during next available cold shutdown H
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DISCUSSION OF OTWR INSPECTION FINDINGS INSPECTOR FOLLOW-UP ITEMS 1.
Use of uncertainties in generic DC motor curves in calculations regarding degraded voltage capabilities.
The District will Monitor industry initiatives and adjust the MOV Project accordingly.
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Use of maintenance history reliance for thermal binding / pressure locking evaluation.
The District will monitor industry action related to this issue and will initiate any additional corrective actions prior to completion of the RE-16 outage.
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Exclusion of pressure instrumentation uncertainty in initial acceptance.
The District is evaluating this item for possible inclusion in the initial acceptance of
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These uncertainties are presently accounted for in the CNS validation calculations and component level review calculations.
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L INSPECTOR FOLLOW-UP ITEMS (CONT.)
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Schedule showing extension will be required.
The present CNS commitment is to complete GL 89-10 MOV testing during the presently scheduled 1994 (RE-16) outage.
Due to the extended 1993 outage, the next CNS refueling outage may be rescheduled for the first quarter of 1995.
If necessary, NPPD will submit a formal request for a GL-89-10 schedule extension.
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Failure of CS-MO7B to open.
The required investigation, documentation and corrective actions will be completed.
All information related to the corrective actions for CS-MO7B are being provided to the CNS Resident Inspectors 6.
RHR-920MV - Actions taken to demonstrate capability as a result of a bad sensor during the DP test.
The District will demonstrate the capability of the valve by retest during the next scheduled outage.
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INSPECTOR FOLLOW-UP ITEMS (CONT.)
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QA & QC involvement in program including self-or third-party assessments.
An immediate third party review of all current testing data and traces for all valves tested to date is in progress.
Any valves identified as not meeting the specified criteria will be evaluated in accordance with CNS corrective action procedures.
The District will conduct a self-assessment of the MOV Program and its output during the first quarter of 1994.
An outside firm will be considered as a third party participant in the audit.
Involvement by the QA organization has been addressed by V. Wolstenholm's presentation.
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Validate the use of linear extrapolation.
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consider the use of multipoint testing to validate the extrapolation should industry l
actions not provide an acceptable justification.
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DISCUSSION OF OTHER INSPECTION FINDINGS INSPECTOR FOLLOW-UP ITEMS (CONT.)
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DP tests with no discernable DP effects on test traces (seems to be a significant number of tests.
The District will investigate the lack of discernable effects. It should be noted that four (4) of the seven (7) valves reviewed during the inspection had orifice type restrictions downstream of the valves.
One (1) valve was tested using its Design Basis Scenario which only closes it to a 10% open position.
10. Accuracy of placing software marks on VOTES traces (errors on C5, Cl1, and 010).
Procedural requirements will be established to require an engineering review of the trace markings, trace marking guidance enhancement, and additional training of personnel. In addition, a thorough third party review, to ensure that all traces are marked correctly, will be performed.
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CLOSING REMARKS All of the individual issues have been, and are being addressed
Project management & QA oversight weaknesses are being corrected
The lessons learned from this situation are being applied to other similar
project-related efforts Self-assessment improvement efforts will be continued
The District is committed to a comprehensive and effective GL 89-10 program and
will continue to work to that end i
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