ML20059L284
| ML20059L284 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/08/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NSD931287, NUDOCS 9311160417 | |
| Download: ML20059L284 (8) | |
Text
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NSD931287 November 8, 1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Subj ect: Reply to a Notice of Violation NRC Inspection Report No. 50-298/93-08 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 Gentlemen: The Nebraska Public Power District (District) hereby submits its response to the Notice of Violation (NOV) transmitted with NRC Inspection Report No. 50-298/93-08. This inspection report documents the results of the NRC 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 MOV Program. An explanation of the violations and corrective actions taken and planned in response to each violation are presented below. Additionally, as indicated during the October 8, 1993, Management Meeting held at the NRC Region IV offices to discuss the District's MOV Program, the District committed to provide schedules for completing the various corrective actions discussed during that meeting. All action items related to the MOV Program and the corresponding schedule for their completion'are discussed below. Further, the District has completed an assessment of its Quality Assurance overview of other similar programs, including the Check Valve, Erosion / Corrosion, and Snubber programs which were specifically mentioned during the.0ctober 8 meeting. Consistent.with corrective actions specified herein regarding Quality Assurance coverage of the MOV program, all other similar programs for such coverage have been identified and responsibilities assigned pursuant to a new Quality Assurance Guideline,'which clearly outlines management level expectations. Implementation of the Guideline will result in enhancement of Quality Assurance technical capabilities for providing timely, critical overview of these program processes and activities. Violation 10 CFR 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 performance of design reviews. . Design control measures shall' be applied to items such as the. . delineation of acceptance criteria for inspections and tests." Contrary to the above, the licensee failed to provide a documented design verification of several safety related activities associated with.the delineation and evaluation of acceptance criteria for motor-operated valve testing. / k 9311160417 931108 P M gDR ADOCK 05000298 N PDR gj
t U. S. Nuclear Regulatory Commission November 8, 1993 Page 2 of 8 i Reason for the Violation l NRC Inspection Report 93-08, on Page 9, clarifies some of the safety related-j 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 j criteria checklists (qualitative and quantitative acceptance points), and the direct evaluation of the diagnostic traces themselves (including I placement of software 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. l 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 MOV Program is implemented using a project organization methodology. Under this methodology, a project manager was assigned to j 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 i 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. ) I In addition, the District failed to recognize the need for a dedicated Quality c Assurance Audit Plan for the MOV Program. The District's Generic Letter 89-10 1 I Testing Program was viewed as a continuation of IE Bulletin 85-03 engineering and maintenance activity surveillance. Therefore, the District's Qualit: Assurance Department oversight of MOV Program activities did not provide t.e detailed level of independent review required. Corrective Steps Taken and the Results Achieved i Following the NRC's inspection, the District contracted a third-party review of all MOV testing performed to date under the District's Generic Letter 89-10 i Program. This included all testing performed during the District's Refuel 14, j 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 traces to identify any further significant test anomalies, and verification of engineering judgements made regarding anomalies. The preliminary results of i l
I U. S. Nuclear Regulatory Commission November 8, 1993 Page 3 of 8 this effort indicate that no additional operability concerns exist. Final review and approval of this evaluation by the District is in process and is I expected to be complete by November 15, 1993. The District has incorporated 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. 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 v; ole 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 1 program's requirements. QA will maintain cognizance of and provide [ independent oversight of the MOV Program activities. Included in the specific t 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 I counterparts, to maintain a " program file," to identify needed changes to audit or surveillance criteria, and to perform audits and surveillances of program activities, as necessary. Such auditing and surveillance efforts shall include critical evaluations of program activities, and result in corrective action and resolution of concerns expressed, as appropriate. Corrective Steps That Will Be Taken to Avoid Further Violations 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 performing detailed calculations to document the basis for MOV test target 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 MCV Project personnel, and delineate in the MOV Project instructions personnel qualifications for performing critical MOV Program activities. 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 l require improvements. As indicated during the meeting with the NRC on October 8, the District plans to include a third party in this self-i I assessment. I 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
1 U. S. Nuclear Regulatory Commission November 8, 1993 i Page 4 of 8 Program procedures, including delineation of MOV Project personnel qualifications, by February 1,1994. The District will complete development ) of its 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. Violation 10 CFR Part 50, Appendix B, Criterion V, states in part that " activities 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." 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 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, l l 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 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 necessary procedural controls. Corrective Steps Taken and the Results Achieved l As indicated above in response to the first violation, the District has I documented its acceptance criteria for evaluating MOV test results. In l l addition, a third party review of all MOV testing data was initiated using the I revised acceptance criteria. The preliminary results of this evaluation l indicate that no additional operability concerns exist. The District is in l the process of reviewing the results of this evaluation, and expects to I complete this review by November 15, 1993. Corrective Steps That Will Be Taken to Avoid Further Violations As stated above, the District is reviewing and revising, as required, all 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 extrapolating MOV test 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 level of independent review and/or verification exists for critical program activities. l l l
4 U. S. Nuclear Regulatory Commission November 8, 1993 Page 5 of 8 Date When Full Compliance Will Be Achieved The District expects to complete these revisions to the MOV Program procedures by February 1,1994. Violation 10 CFR Part 50, Appendix B, Criterion XI, 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 i incorporate the requirements and acceptance limits contained in applicable design documents," and the " test results shall be documented and evaluated to assure that test requirements have been satisfied." Contrary to the above, 29 motor-operated valves were returned to service following dynamic testing based on improper acceptance criteria. Each of the differential pressure tests were evaluated to a static test acceptance checklist that had been inadvertently inserted into the dynamic test procedure. Reason for the Violation The underlying cause of this violation is inadequate procedural controls based on critical procedures which were developed under an organizational structure which lacked adequate independent review of critical activities. The lack of independent review resulted in an inadvertent swapping of static and dynamic acceptance criteria in the MOV testing procedures. Additionally, the District had not implemented appropriate Quality Control features into the process / procedures governing the activities. Corrective Steps Taken and the Results Achieved As stated above, the District has completed a reevaluation of and docueented 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 Generic 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 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. Corrective Steps That Will Be Taken to Avoid Purther 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 revisions by February 1,1994.
i r j i U. S. Nuclear Regulatory Commission November 8, 1993 i Page 6 of 8 i l .) Violation 10 CFR Part 50, Appendix B, Criterion XVI, states, in part, that " measures shall be 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." Nebraska Public Power District "CNS MOV Program Plan," Revision 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 performance of the CNS MOV Test Program, the conditions will be evaluated and processed in accordance with the following applicable CNS policies and procedures: l CNS Procedure 0.5.1, Nonconformance and Corrective Action 5 CNS Procedure 0.5.2, Deficiency Reporting CNS Procedure 0.27, Operability of Systems, Structures and Components l e CNS Procedure 0.27.1, Operability Evaluations" e 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. Reason for the Violation 1 r During the initial evaluation of test data acquired for CS-MOV-MOSA, the test l trace anomaly was noted, and based'on preliminary evaluation, was incorrectly i 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 MOV test results, including test traces, which again, was due in part to the_ i absence of a cohesive project organizational structure, and inadequate independent oversight. Corrective Steps Taken and the Results Achieved j 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 i CS-MOV-MOSA would close under full Core Spray System flow conditions, although j 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 design basis functions. The District determined during this evaluation, that the Core Spray System injection capability would not be impacted even with CS-MOV-MO5A, a minimum flow bypass valve, fully open. This was determined through an evaluation l performed by the District's Configuration Management Department, which indicated that, with considerable margin, adequate Core Spray System injection - would occur even with the minimum flow valves fully open. This conclusion was verified upon the retrieval of documentation of a Core Spray System injection test performed in 1974 with the minimum flow valves fully open. This information provided reasonable assurance that the Core Spray System was not significantly impacted by the condition of CS-MOV-MOSA, and therefore, was operable. As CS-MOV-MOSA is also designed to provide a remote manual- ] i
U. S. Nuclear Regulatory Commission Novemb'er 8, 1993 Page 7 of 8 1 isolation function from the Control Room, this function was also evaluated. The District determined that if required to isolate, CS-MOV-MOSA would be J required to close against essentially static conditions, and therefore CS-MOV-MOSA was considered operable from this standpoint. As stated above, the District reevaluated its MOV testing acceptance criteria and contracted a third party review of all MOV tests performed under the 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 close under Core Spray full flow conditions. Upon receipt of this information, and questions concerning the scenarios under which CS-MOV-MOSA may be required to isolate, the District ceclared the valve inoperable, secured it in a closed position, and declared Core Spray Subsystem "A" 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 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. 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 Core Spray System flow conditions, but as originally concluded, at near static conditions. The additional diagnostic testing performed on CS-MOV-MOSA showed 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-MOSA was ~ operable. Corrective Steps That Will Be Taken to Avoid Further Violations The District is reviewing procedures related to the MOV Program to ensure that guidance to perform the MOV testing evaluation, including delineated criteria, and appropriate Quality Control features, are provided therein. This guidance 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 resulta falling outside of the acceptance criteria, appropriate 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-MOSA to monitor its condition until the valve is l repaired or replaced. 1 l Date When Full Compliance Will Be Achieved I 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. I i 1 i
U. S. Nuclear Regulatory Commission Nove*mber 8, 1993 Page 8 of 8 The District will complete its review and revision of MOV Program procedures to correct the procedural deficiencies by February 1, 1994. I Should you have any questions or require any additional information, please contact me. Sin 'erely ~ 9-dR. orn .f Vi'ce resident - Nuclear GRH/MJB cc: NRC Regional Administrator Region IV l Arlington, TX t t NRC Resident Inspector Cooper Nuclear Station f I I l 1 l l r i t l l}}