ML20058F303
| ML20058F303 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/01/1993 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9312080065 | |
| Download: ML20058F303 (3) | |
See also: IR 05000298/1993008
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License: DPR-46
Nebraska Public Power District
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ATTN:
Guy R. Horn, Vice President - Nuclear
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P.O. Box 98
Brownville, Nebraska 68321
SUBJECT:
NRC INSPECTION REPORT 50-298/93-08
Thank you for your letter of November 8,1993, in response to our letter
and Notice of Violation dated October 8, 1993. We have reviewed your reply
and find it responsive to the concerns raised in our Notice of Violation. We
will review the implementation of your corrective actions during a future
inspection to determine that full compliance has been achieved and will be
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maintained.
Sincerely,
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irector
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ivision of Reactor Safety
cc:
Nebraska Public Power District
ATTN:
G. D. Watson, General Counsel
P.O. Box 499
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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
ATIN: Randolph Wood, Director
P.O. Box 98922
Lincoln, Nebraska 68509-8922
9312090065 931201
ADOCK 05000298
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Nebraska ~ Department of Health
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ATTN: Harold Borchert, Director
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Division of Radiological Health
301 Centennial Mall, South
P.O. Box 95007
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Lincoln, Nebraska 68509-5007
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Department of Natural Resources
ATTN:
Ronald A. Kucera, Department Director
of Intergovernmental Cooperation
P.O. Box 176
Jefferson City, Missouri 65102
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November 8, 1993
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U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
REGION IV
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Washington, D.C.
20555
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Subject:
Reply to a Notice of Violation
NRC Inspection Report No. 50-298/93-08
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Cooper Nuclear Station, NRC Docket 50-298, DPR-46
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Centlemen:
The Nebraska Public Power District (District) hereby submits its response to
the Notice of Violation (NOV) transw.itted with NRC Inspection Report
No. 50-298/93-08. This inspection report documents the results of the NRC
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Phase II inspection of the District's Generic Letter 89-10 MOV Program for
Cooper Nuclear Station (CNS). The NRC identified four violations during its
inspection of the District's HOV Program. An explanation of the violations
and corrective actions taken and planned in response to each violation are
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presented below.
Additionally, as indicated during the October 8,1993, Managernent Meeting held
at the NRC Region IV offices to discuss the District's HOV Program, the
District committed to provide schedules for cornpleting the various corrective
actions discussed during that meeting. All action items related to the MOV
Program and the corresponding schedule for their cornpletion are discussed
below.
Further, the District has completed an assessment of its Quality
Assurance overview of other similar programs, including the Check Valve,
Eronion/ Corrosion, and Snubber programs which were specifically rentioned
during the October 8 meeting.
Consistent with corrective actions speci fied
herein regarding Quality Assurance coverage of the MOV program, all other
sirnilar programs for such coverage have been identified and responsibilities
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assigned pursuant to a new Quality Assurance Guideline, which clearly outlines
management level expectations.
Implementation of the Culdeline will result in
enhancement of Quality Assurance technical capabilities for providing tirnely,
critical overview of these program processes and activities,
Violation
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10 CPR Part 50, Appendix B, Criterion III, states in part that " design control
measures shall provide for verifying or checking the adequacy of design, such
as by the perforinance of design reviews
Design control measures shall be
. .
delineation of acceptance criteria for
applied to items such es the
. . .
inspections and tests."
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Contrary to the above, the licensee failed to provide a documented design
verification of several safety related activities ansociated with the
delineation and evaluation of acceptance criteria for rnot or operated valve
testing.
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November 8, 1993
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Page 2 of 8
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Reason for the Violation
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NRC Inspection Report 93-08, on Page 9, clarifies some of the safety related
activities where no documented design verification was apparent.
These
included:
"... calculations detailing MOV diagnostic test target windows (thrust
limits associated with test acceptance), open and close stroke
evaluations (comparisons between target and measured values), acceptance
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criteria checklists (qualitative and quantitative acceptance points),
and the direct evaluation of the diagnostic traces themselves (including
placement of sof tware marks and extraction of quantitative data from the
traces)."
The District has determined that this violation occurred primarily as a result
of an ineffective program organizational structure.
The original MOV Project
Organization necessarily segregated various responsibilities important to the
success of the program under different District functions, but without
providing for uniform oversight of all activities in the program.
Additionally, the District had not implemented proper independent reviews or
other appropriate Quality Control features into the process / procedures
governing the activities.
The District's HOV Program is implemented using a project organization
methodology. Under this methodology, a project manager was assigned to
provide overall coordination of various matrixed resources, project cost and
schedule control, and execution of required contracts and service agreements.
Within this structure, a number of District organizations perform various
functions to support the requirements of the program, with some personnel
dedicated full time, and others dedicated part time to the MOV Program.
Under
this structure, the MOV testing and analysis function, including the
performance of the activities identified by the NRC and restated above, fell
under the cognizance of the CNS Maintenance organization, but without adequate
accountability and control by the MOV Project Manager. Therefore, some of
these activities were not provided the same level of independent review and
approval as the balance of the District's MOV Program activities.
In addition, the District failed to recognize the need for a dedicated Quality
Assurance Audit Plan for the MOV Program.
The District's Generic Letter 89-10
Testing Program was viewed as a continuation of IE Bulletin 85-03 engineering
and maintenance activity surveillance.
Therefore, the District's Quality
Assurance Department oversight of MOV Program activities did not provide the
detailed level of independent review required.
Corrective Steps Taken and the Results Achieved
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Following the NRC's inspection, the District contracted a third-party review
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of all MOV testing performed to date under the District's Generic Letter 89-10
Program.
This included all testing performed during the District's Refuel 14,
Cycle 15 Refueling Outage and the Refuel 15, Cycle 16 Refueling Outage.
The
third party review included preparation of detailed acceptance criteria to use
in the evaluation of the test data, including extrapolation of test results
and evaluation of significant anomalies.
The scope of the test data review
included a quantitative evaluation of test data acquired, review of the test
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traces to identify any further significant test anomalies, and verification of
engineering judgements made regarding anomalics.
The preliminary results of
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Page 3 of 8
this effort indicate that no additional operability concerns exist.
Final
review and approval nf this evaluation by the District is in process and is
expected to be complete by November 15, 1993.
The District has incorporated
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the revised acceptance criteria into its MOV project instructions, and will
incorporate this criteria as appropriate into the MOV testing procedures, as
discussed further below.
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The District has also reorganized its MOV Project team.
This reorganization
places all critical project functions, including MOV testing and analysis, and,
development and maintenance of procedures which control these activities under
the cognizance of a single project manager.
This reorganization will ensure
that a consistent level of independent review and approval will be performed
on all safety related MOV Program activities.
The District has also re-evaluated the role of the Quality Assurance (QA)
Division in the Generic Letter 89-10 MOV program. A QA staff member has been
assigned to follow the MOV Program and to become knowledgeable of the
program's requirements. QA will maintain cognizance of and provide
independent oversight of the MOV Program activities.
Included in the specific
responsibilities outlined in the new Quality Assurance Guideline 5.14
"QA
Coverage of Programs," are criteria to maintain continuous cognizance of
program procedures and processes, to routinely interface with program
counterparts, to maintain a " program file," to identify needed changes to
audit or surveillance criteria, and to perform audits and surveillances of
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program scrivities, as necessary.
Such auditing and surveillance efforts
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shall include critical evaluations of program activities, and result in
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corrective action and resolution of concerns expressed, as appropriate,
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Corrective Steps That Will Be Taken to Avoid Further Violations
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As indicated above, the District has documented in the MOV Project
instructions the criteria to be used in developing MOV test target windows,
performing MOV test evaluations, and evaluating traces. The District is
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performing detailed calculations to document the basis for MOV test target
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windows and MOV settings.
In addition, the District will review all
procedures related to its MOV Program and include the above criteria in future
revisions to the District's MOV testing procedures. The District will also
include in these procedures detailed instructions with checklists, as
appropriate, to ensure the consistent application of the criteria. As
committed during the October 8, 1993, meeting with the NRC, the District will
also provide additional training for the MOV Project personnel, and delineate
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in the MOV Project Instructions personnel qualifications for performing
critical MOV Program activities.
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In addition, the District's Quality Assurance Division is developing a unique
audit plan to provide and document the guidance to be used in administering
their independent oversight function. The District will also conduct a self-
assessment of its MOV Program to identify any other program elements which may
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require improvements. As indicated during the meeting with the NRC on
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October 8, the District plans to include a third party in this self-
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assessment.
Date When Full Compliance Will Be Achieved
The District expects to complete the MOV thrust and torque window setting
calculations by January 1, 1994, and make all necessary revisions to its MOV
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November 8, 1993
Page 4 of 8
Program procedures, including delineation of MOV Project personnel
qualifications, by February 1,1994
The District will complete development
of ita Quality Assurance Audit Plan for the MOV Program and implement its
initial audit in 1994.
Specific scheduling of this audit will take into
consideration the schedules for upgrading the MOV Program as specified herein,
and the results of the MOV self assessment, with the intent that such auditing
will assess the effectiveness of program upgrading.
The District expects to
complete the self-assessment of its MOV Program and complete the additional
training of MOV Project personnel by April 1,1994.
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Violation
10 CFR Part $0, Appendix B, Criterion V,
otates in part that " activities
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affecting quality shall be prescribed by documented instructions, procedures,
or drawings, of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures or drawings."
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Contrary to the above, the licensee failed to prescribe by procedure two
safety related activities essential for the proper evaluation of motor-
operated valve testing. These activities were adjustment of measurement
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uncertainties when measured thrust is outside of the calibration range and the
comparison of extrapolated opening thrust to motor-operated valve limits for
test acceptance.
As a result of this deficiency, these activities were not
performed.
Reason for the Violation
As stated above in the response to the first violation, the primary reason for
this violation was the development of critical procedural controls under an
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organizational structure that did not foster the appropriate level of
independent review and approval. Therefore, these processes, including
appropriate Quality Control features, were inappropriately omitted from the
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necessary procedural controls.
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Corrective Steps Taken and the Results Achieved
As indicated above in response to the first violation, the District has
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documented its acceptance criteria for evaluating MOV test results.
In
addition, a third party review of all MOV testing data was initiated using the
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revised acceptance criteria. The preliminary results of this evaluation
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indicate that no additional operability concerns exist.
The District is in
the process of reviewing the results of this evaluation, and expects to
complete this review by November 15, 1993.
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Corrective Steps That Will Be Taken to Avoid Further Violations
As stated above, the District is reviewing and revising, as required, all
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procedures related to the MOV Program to ensure all necessary criteria,
activities, and appropriate checklists are included.
This effort will include
instructions for adjusting test accuracy when the tests fall outside of
equipment calibration range, and will include instructions for extrapointing
MOV t es t results and comparing these results to MOV limiting values.
The
District will also include in these procedures, where appropriate, Quality
Control features to ensure an adequate 1cvel of independent review and/or
verification exists for critical program activities.
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Date When Full Compliance Will Be Achieved
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The District expects to complete these revisions to the MOV Program procedures
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by February 1, 1994
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Violation
10 CFR Part 50, Appendix B, Criterion X1, states in part that "a test program
shall be established to assure that all testing required to demonstrate that
structures, systems, and components will perform satisfactorily in service is
identified and performed in accordance with written test procedures which
incorporate the requirements and acceptance limits contained in applicable
design documents " and the " test results shall be documented and evaluated to
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assure that test requirements have been satisfied."
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contrary to the above, 29 motor-operated valves were returned to service
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following dynamic testing based on improper acceptance criteria.
Each of the
differential pressure tests were evaluated to a static test acceptance
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checklist that had been inadvertently inserted into the dynamic test
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procedure.
Reason for the Violation
The underlying cause of this violation is inadequate procedural controls based
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on critical procedures which were developed under an organizational structure
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which lacked adequate independent review of critical activities.
The lack of
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independent review resulted in an inadvertent swapping of static and dynamic
acceptance criteria in the MOV testing procedures. Additionally, the District
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had not implemented appropriate Quality Control features into the
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process / procedures governing the activities.
Corrective Steps Taken and the Results Achieved
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As stated above, the District has completed a reevaluation of and documented
its MOV test acceptance criteria. The District also contracted a third party
review to evaluate the results of all testing performed to date under the
District's Ceneric Letter 89-10 MOV Testing Program.
The preliminary results
of this review indicate that no additional operability concerns exist.
Final
review and approval of this evaluation by the District is in process and is
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expected to be complete by November 15, 1993.
The District has also
reorganized its MOV Project team to provide uniform parallel review of all
critical MOV Program activities.
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Corrective Steps That Will Be Taken to Avoid Further Violations
The District is performing a review of all MOV Program procedures to ensure
all necessary guidance, criteria, and checklists, and Quality Control features
are provided and documented. This review will also identify and correct, if
necessary, any further procedural deficiencies which may exist.
Date When Full Compliance Will Be Achieved
The District expects to complete this procedural review and make necessary
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revisions by February 1,1994.
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November 8, 1993
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Page 6 of 8
Violation
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10 CFR Part 50, Appendix B, Criterion XVI, states, in part, that " measures
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shall be established to assure that conditions adverse to quality, such as
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failures malfunctions, deficiencies, deviations, defective material and
equipment, and nonconformances are promptly identified and corrected."
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Nebraska Public Power District "CNS MOV Program Plan," Revisian 6. Section
5.0, " Test Program." states, in part, that "if any MOVs are found to be
malfunctioning or not capable of functioning at design basis conditions during
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performance of the CNS MOV Test Program, the conditions will be evaluated and
processed in accordance with the following applicable CNS policies and
procedures:
CNS Procedure 0.5.1, Nonconformance and Corrective Action
CNS Procedure 0.5.2
Deficiency Reporting
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CNS Procedure 0.27, Operability of Systems, Structures and Components
CNS Procedure 0.27.1, Operability Evaluations"
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Contrary to the above, during a Spring 1993 outage, valve CS-MOV-MOSA-
determined to be potentially malfunctioning by the presence of a significant
thrust trace anomaly, was not evaluated as a nonconformance, not screened for
operability, and not considered for any corrective actions.
Feason for the Violation
During the initial evaluation of test data acquired for CS-MOV-MO5A, the test
trace anomaly was noted, and based on preliminary evaluation, was incorrectly
determined not to be significant, although it was noted that its performance
should be monitored in the future. This violation occurred due to the absence
of clear procedural guidance.and detailed acceptance criteria for evaluating
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MOV test results, including test traces, which again, was due in part to the
absence of a cohesive project organizational structure, and inadequate
independent oversight.
Corrective Steps Taken and the Results Achieved
Following NRC identification of the CS-MOV-MOSA operability issue, and during
the inspection, the District re-evaluated the test data acquired during
testing of CS-MOV-MOSA.
The results of this initial evaluation indicated that
CS-MOV-MO5A would close under full Core Spray System flow conditions, although
little margin was available.
In parallel with this effort, the District
performed an evaluation of CS-MOV-MOSA operability based on each of its safety
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design basis functions.
The District determined during this evaluation, that the Core Spray System
injection capability would not be impacted even with CS-MOV MOSA, a minimum
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flow bypass valve, fully open.
This was determined through an evaluation
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periouwd by the District's Configuration Management Department, which
indicated that, with considerable margin, adequate Core Spray System injection
would occur even with thc minimum flow valves fully open.
This conclusion was
verified upon the retrieval oi uocumentation of a Core Spray System injection
test performed in 1974 with the minimum tive valves fully open.
This
informc. tion provided reasonable assurance that the Cu;r Snray System was not
significantly impacted by the condition of CS-MOV-MOSA, and theicfore, was
operable. As CS-MOV-MOSA is also designed to provide a remote manual
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U. S. Nuclear Regulatory Commission
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November 8, 1993
Page 7 of 8
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isolation function from the Control Room, this function was also evaluated.
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The District determined that if required to isolate, CS MOV-h05A would be
required to close against essentially static conditions, and therefore
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CS-MOV-MO5A was considered operable from this standpoint.
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As stated above, the District reevaluated its MOV testing acceptance criteria
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and contracted a third party review of all MOV tests performed under the
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Ceneric letter 89-10 program.
Based on this review, and the use of more
conservative acceptance criteria, it was determined that CS-MOV-MOSA might not
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close under Core Spray full flow conditions. Upon receipt of this,
information, and questions concerning the scenarios under which CS-MOV-MO5A
may be required to isolate, the District declared the valve inoperable,
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secured it in a closed position, and declared Core Spray Subsystem "A"
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inoperable, entering a seven-day Limiting Condition for Operation in
accordance with the CNS Technical Specifications.
Following these events, the District re-evaluated the design functions of the
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valve, performed additional diagnostic testing of CS-MOV-MOSA, and performed a
flow test of Core Spray Subsystem
"A" with CS-MOV-MOSA fully open to verify
the earlier conclusions reached regarding Core Spray System operability.
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Further review of the design basis functions of the Core Spray. System minimum
flow valves determined that they would not be required to isolate against full
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Core Spray System flow conditions, but as originally concluded, at near static
conditions. The additional diagnostic testing performed on CS MOV-MO5A showed
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no evidence of anomalous behavior. The test results, including the test
traces, were promptly evaluated and independently reviewed.
The results of-
this testing indicated that CS-MOV-MOSA was capable of closing under full Core
Spray System flow conditions.
In addition, the results of the special Core
Spray System flow test verified that adequate core Spray injection exists with
CS MOV-MOSA open.
Therefore, the District determined that CS-MOV-MO5A was
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Corrective Steps That Will Be Taken to Avoid Further Violations
The District is reviewing procedures related to the MOV Progrsm to ensure that
guidance to perform the MOV testing evaluation, including delineated criteria,
and appropriate Quality Control features, are provided therein.
This guidance
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will include detailed instructions for performing data analysis, extrapolation
of test results, comparison to MOV limits, and test trace analysis.
In
addition, the District will ensure through procedures, that an adequate level
of independent review of MOV testing data and analysis is performed, and that
for testing results falling outside of the acceptance criteria, appropriate
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corrective action program measures are initiated to ensure expedient
resolution of the concern identified, including its potential applicability to
other valves in the program. The District will also conduct quarterly
diagnostic testing of CS-MOV-MO5A to monitor its condition until the valve is
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repaired or replaced.
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Date When Full Compliance Will Be Achieved
The District will repair or replace both Core Spray System minimum flow valves
during the March 1994 mini-outage to perform various maintenance activities.
The Core Spray System minimum flow valves will be refurbished or replaced
during that outage.
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November 8, 1993
Page 8 of 8
The District will complete its review and revision of HOV Program procedures
to correct the procedural deficiencies by February 1, 1994.
Should you have any questions or require any additional information, please
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contact me.
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Sin erely
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Vi'c a resident - Nuclear
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cc:
NRC Regional Administrator
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Region IV
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/irlington, TX
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NRC Resident Inspector
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Cooper Nuclear Station
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