ML20059A503
| ML20059A503 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/23/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS935276, NUDOCS 9312300280 | |
| Download: ML20059A503 (4) | |
Text
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CNSS935276 December 23, 1993 U. S. Nuclear Regulatory Commission Attention: Dacument Control Desk Washington, DC 20555 Subj ect:
NPPD Response to Inspection Report 50-298/93-25 (Reply to a Notice of Violation)
Gentleman:
During an NRC inspection conducted August 29 through October 9,1993, violations of NRC requirements were identified in that an alarm response procedure was inadequate and the procedure was not promptly corrected.
Following is a statement of the violation and our response in accordance with 10CFR2.201.
STATEMENT OF VIOLATION Technical Specification 6.3.2 requires.that written procedures and instructions, including applicable check off lists, shall be established, implemented, and maintained for items A through G.
Technical Specification 6.3.2.B requires that actions be taken to correct specific and foreseen potential or actual malfunctions of safety-related systems or components, including responses to alarms, primary system leaks, and abnormal reactivity changes.
Alarm Procedure 2.3.2.22, Revision 16, "HPCI Turbine Inlet Drain Pot HI Level," for Panel / Window Location 9-3-2/C-2, Section 2.0, Operator Observation and Action, specifies the action to be taken as:
(1) verify open High Pressure Coolant Injection (HPCI) Valve HPCI-AO-53, COND DRAIN POT TRAP BYP VLV; (2) check proper operation of steam trap HPCI-TP 57; and (3) if alarm fails to clear, manually drain condensate from line or remove HPCI system from service.
Contrary to the above, a written procedure was not established and maintained for an alarm indicating a malfunction of a safety system in that Alarm Procedure 2.3.2.22, for Panel / Window Location 9-3-2/C-2, Section 2.0, did not appropriately specify the operator actions to be taken when the alarm was received during HPCI system surveillance testing. When the HPCI system is in operation, the condansate drain and steam trap are isolated and cannot be drained or verified to be operating correctly.
This is a Severity Level IV violation (298/93025-01)
(Supplement I).
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S'. Nuclear Regulatory Commission December 23,-1993
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REASON FOR VIOLATION The actions specified in Alarm Procedure 2.3.2.22 were originally intended to address malfunctions which could occur when the HPCI system is in standby 1
status.
When the system is operating, the drain line.from the HPCI turbine i
inlet drain pot is isolated. While there is a possibility that small amounts.
of water could collect in the drain pot causing the alarm to annunciate,-
damage to the turbine would not result because a water slug could not form in the line when steam is flowing through it.
No action was considered necessary j
for that condition; therefore, no steps were included in the procedure to address it.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED -
Temporary Procedure Change Notice (TPCN)93-303 was issued to instruct the operator that, if the HPCI turbine is running, ensure that the alarm clears when the HPCI turbine is secured.
If the alarm doesn't clear after the HPCI turbine-is secured, the operator is then to perform the actions that were i
previously given in the procedure. This procedure change has corrected the identi'fied problem. However, to further evaluate 1this issue, review of other drain pot alarms identified a second one that required procedural clarification.
A TPCN was issued to address this concern on October 4, 1993.
In addition, an engineering evaluation of the HPCI steam supply drain pot level switch has determined that switch application and operation are 1
satisfactory.
t CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID PORTHER VIO1ATIONS The aforementioned TPCNs have been incorporated into a permanent change to Alarm Procedure 2.3.2.22 that is currently being processed.
t DATE WHEN FULL COMELIANCE WILL BE ACHIEVED The alarm procedure has been updated to address action to be taken should the condition recur.
The permanent change to the alarm procedure'will be approved by March 31, 1994.
The' temporary procedure changes will remain in effect until that time.
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' December 23, 1993 Page 3 4
I STATEMENT OF VIOLATION Criterion XVI, to 10 CFR Part 50, Appendix B, requires that measures shall be
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established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material, and equipment and nonconformances, are promptly identified and corrected.
'l Contrary to the above, measures did not assure that a' deficiency was promptly corrected in that the licensee became aware that Alarm Procedure 2.3.2.22, Revision 16, "HPCI Turbine Inlet Drain Pot HI Level," was deficient after surveillance testing on September 1, 1993, and did not promptly correct the deficient procedure.
On September 29, 1993, during surveillance testing, the deficient procedure caused the HPCI turbine to be unnecessarily secured.
This is a Severity Level IV violation (298/93025-2)
(Supplement I).
REASON FOR VIOLATIQH l
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A Deficiency Report was written on September 2, 1993, documenting the' unexpected receipt of the HPCI Turbine Inlet Drain Pot High Level annunciator.
In addition, a work item was generated to investigate switch actuation. Based j
on past experience, annunciation of this alarm during system operation was considered unusual. Therefore, the need for a procedure change to address-
- j alarm annunciation during operation was not. identified at that time.
The.
failure to evaluate the condition and revise the. annunciator response procedure between September 1, 1993, and. September 29, 1993, was due to a lack of thoroughness and timeliness by Operations and Engineering' Department personnel.
'i CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED As noted in the response to the first violation, a TPCN was issued to address receipt of the annunciator during system operation.
CORRECTIVE STEPS WHICH VILL BE TAKEN TO AVOID FURTHER VIOLATIONS e
A new Corrective Action Program is being developed that will aid in addressing potential operational concerns in a prioritized and more thorough fashion.
Operational concerns such as this that occur during surveillance testing will be more highly prioritized.
Problems encountered during surveillance testing and resulting corrective actions will be identified and implemented on a schedule consistent with the,next scheduled system test.
Due to the: priority assignment of these types of deficiencies, investigative and checkout activities and engineering evaluations of the results will be more thoroughly and expeditiously accomplished.
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U.'S". Nuclear Regulatory' Commission
' December 23, 1993 Page 4 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED NPPD.is currently in compliance with the requirements stated in the violation.
The new Corrective Action Program, which will aid in identifying and addressing this type of problem, is expected to be implemented in February 1994.
In response to the concerns expressed in the Inspection Report letter, management is concerned about the repetitive nature of this event.
In anticipation of the new Corrective Action Program, management meetings are; being conducted each morning to review and discuss newly documented deficiencies.
Prioritization for their resolution is being established and corrective action dispositions are being reviewed for adequacy. As noted in our response to the second violation, a new Corrective Action Program is being-developed with implementation expected in February,.1994 As experience is gained.with the new program, the potential for repetitive events such as this will be minimized.
Additionally, the new program is well suited to address the concerns identified with the starter rack and motor control center conditions. Whereas the existing program is primarily directed at material deficiencies, under the new program, human performance concerns such as this will be'better. documented and addressed. This, coupled with the additional management emphasis on personnel accountability, is expected to minimize future occurrences of this nature.
Should you have any questions concerning this matter, please contact me.
Sincerely, A
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R. Horn Nuclear Power Group Manager cc:
Regional Administrator USNRC - Region IV NRC Resident Inspector Cooper Nuclear Station