ML20077C403
| ML20077C403 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/25/1994 |
| From: | Mueller J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS940118, NUDOCS 9412010358 | |
| Download: ML20077C403 (6) | |
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NLS940118 November 25, 1994 U.
S.
Nuclear Regulatory Commission Attention:
Document Control Desk washington, D.C.
20555
Subject:
Reply to Notice of Violation / Deviation NRC Inspection Report Po. 50-298/94-27 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 and Notice of Deviation transmitted with NRC Inspection Report No. 50-298/94-27. This inspection report documents the results of the NRC inspection conducted by Mr.
W.
M.
McNeill on September 12-16, 1994.
This inspection included a review of activities authorized at Cooper Nuclear Station (CNS). The NRC identified two violations and one deviation during its inspection of CNS.
An explanation of the violations and deviation and corrective actions taken and planned in response to each one is presented below.
A.
Statement of Violation (298/9427-01)
Cri terion V of Appendix B to 10 CFR Part 50, and the approved quality assurance program description, " Cooper Nuclear Station Quality Assurance Program for Opera tions Policy Document," Revision 10, requires tha t activities which have nuclear safety significance shall be accomplished in accordance wi th procedures.
Administra tive Procedure 1.26, " Routing Procedure for Opera ting Experience Review," Revision 2,
requires that relevant opera ting informa tion from sources such as NRC notices be evaluated as to its applicability and potential effect upon plant operating procedures.
Contrary to the above, NRC Informa tion Notice 84-20, dated March 21, 1984, was not evaluated as to its applicability and potential effect upon the plant preventive maintenance procedure.
Specifically, the design life of energized Agastat relays was not established.
The result of this was the plant being opera ted with certain relays beyond design life.
This is a Severity Level IV violation (Supplement 1} (298/9427-01).
Admission or Denial of the Violation The District admits the violation.
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November 25, 1994 page 2 Reason for'the Violation Administrative Procedure (AP) 1. 26,. Revision 2., " Routing Procedure for Operating-Experience Review," in place at the time that Information Notice 84-20 was issued, provided the method that the District would use for review of information i
notices and other operating information. This procedure provided for routing a copy of the information notice to SORC members and to selected CNS managers, as appropriate. AP 1.26, Rev.2, states that "The CNS manager (s) will assure that the results of the reviews and the resultant actions (if any) taken by their respective department (s) are indicated upon their copy of the material and that a copy documenting that review and actions taken is filed in the appropriate subject file."
A copy of Information Notice 84-20 has-been found in the CNS l
records that shows SORC members and other managers reviewed the notice and that this information notice should be used as input to a supplemental response to IEB 84-02.
At the time of issuance of Information Notice 64-20, the District had already begun to investigate Bulletin (IEB) 84-02 regarding GE HFA relay problems. As part of the response to IEB 84-02, the NRC requested certain information regarding other safety-related relays that were not GE HFA relays. Information Notice 84-20, as indicated on the filed copy, was intended to be used during the l
development of a supplemental response to IEB 84-02 to address non-HFA relays.
The supplemental response, District Letter NLS8400019, dated October 9,
- 1984, from L.
G.
Kuncl to the NRC, stated that research into the failures of relays supplied by other manufacturers throughout the industry, the absence of service i
bulletins or other manuf acturers recommendations, and the existing CNS preventive maintenance program and surveillance procedures at that time indicated the short-
)
term and long-term corrections ac2 ions were adequately addressed to assure continued satisfactory relay performance and no further action was planned.
i Although there is some indication that Information Notice (IN) 84-20 was reviewed l
for input to IED 84-02, this violation was due to a failure to adequately document the' review and action taken.
In August, 1994, as part of a re-review of selected operating experience reports (OERs), the District determined that the past review of IN 84-20 was inadequate.
This condition was documented and evaluated for Agastat relays in a Condition i
Report (CR-94-0709).
The evaluation included reviews of past periormance and f ailure history of this type of relay. The evaluation did not reveal an adverse trend related to the relays and concluded that due to a low failure history at CNS, the aging of installed rel ays has not adversely af fected the operability of affected systems.
i Immediate Corrective Actions and Ret ults Achieved Prior to startup, the District will either replace normally cnergized Agastat model EGP relays greater than 5 years old or evaluate for operability and replacement. The operability evaluation will, in part, determine a replacement date.
In addition, one Agastat series E7000 relay will be changed-out prior to l
startup.
A Preventive Maintenance program will be established to periodically replace the relays addressed by IN 84-20 and IEB 84-02.
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N.LE940118 Nuvember 25, 1994
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Page 3 i
Actions Taken to Prevent Recurrence A comprehensive screening of past OERs and subsequent re-review of selected OERs has been completed.
Additionally, the CNS performance improvement plan will addreas startup, short term, and long term aspects of improving OER reviews.
The Operating Experience Review program has undergone substantial revision since 1984.
The revisions made to the program since 1984 are adequate to prevent recurrence of this specific event.
However, as part of the performance improvement plan, an extensive review of the present Operating Experience Review.
(OER) program has been completed.
An entirely new OER program with new procedures and personnel is being established.
Date When Full Compliance Will be Achieved Relay evaluation or replacement will be completed prior to startup.
The Preventive Maintenance program development for periodic replacement of relays addressed by IN 84-20 and IEB 84-02 will be completed by February 10, 1995.
J B.
Statement of Violation (298/9427-02)
Criterion XI of Appendix B to 10 CFR Part 50, and the approved quality assurance program description, " Cooper Nuclear Sta tion Quali ty Assurance Program for Operations Policy Document, " Revision 10, requires that the test program to be defined by written procedures and that these programs include surveillance testing of systems and components to demonstrate their capability to perform satisfactorily as a part of an integrated system.
l Procedure 0.26, " Surveillance Program. " Revision 12, requires surveillance procedures to verify the facility is operated in accordance with Technical Specifications.
Contrary to the above, Procedu re 6.2.1. 5.2, "PCIS Group 2,3, and 6 Isolation Logic Functional Test and Reactor Building Vent Monitor Functional Test, "
Revision 28, did not demonstrats tha t four relays (PCIS-REL-K69, -K70, -K71, and -K72) changed state during testing. Additionally, two relays (PCIS-REL-K67, and -K68) normally energized, did not have power removed in Procedure 6.2.1.5.4,
" Group 1, 7, and Mechanical Vacuum Pump Isolation Functional Test, " Revision 17.
This is a Severity Level IV violation (Supplemen t I) (298/9427-02)
Admission or Denial of the Violation The District denies this violation, l
l 1}LS940118 November 25, 1994 Page 4 Reason for Denial of the Violation The District disagrees with the violation because the function of the identified relays and contacts is tested in a separate Surveillance Procedure (SP), SP 6.3.1.4, "Normally Open Primary Containment Isolation Power Operated Valve Operability and Closure Timing Test."
Although SP 6.3.1.4 does not explicitly describe that the relays in the Statement of Violation are exercised, the District has verified that this SP could not be performed without their proper operation.
In particular, the function of the lockout relays cited in the-Statement of Violation is to prevent the valves from automatically opening after reset of isolation signals.
During the performance of SP 6.3.1.4 each valve is closed using the control switch, which is a three position switch, OPEN-NORM-CLOSE, spring returned to the NORM position. When the switch is turned to CLOSE, power is interrupted to the particular valve solenoid valve and to the lockout relays.
When the switch is returned to the NORM position (spring returned) if the lockout relay did not change state then the solenoid would be re-energized and the valve would reopen.
This event would be a deficiency in performance of the SP and would be reported and investigated as a discrepancy per the requirements of Administrative Procedure 0.26, " Surveillance Program." Therefore, the relays in question are demonstrated through performance of SP 6.3.1.4.
Immediate Corrective Actions and Results Achieved No corrective steps need to be taken as the District is currently in full compliance with the requirements.
Actions Taken to Prevent Recurrence The District has an ongoing program to study and review the testing requirements for each of the CNS systems with Technical Specification criteria. This program is designed to validate the Technical Specification required surveillance program as well as verify that the Technical Specification component / system testing provides assurance the intended design function can be met.
Date When Full Compliance Will be Achieved r
Not applicable.
C.
Statement of Deviation (298/9427-03)
Nebraska Public Power District Letter CNS887255, da ted June 29, 1988, from G.
R.
Horn to the NRC stated, in part, that all normally energized direct curren t safety-related relays at Cooper Nuclear Station would be replaced during the 1989 refueling outage.
contrary to the above, six nonna11y energized direct current safety-related relays at Cooper Nuclear Station were not replaced during the 1989 refueling outage.
The six relays are:
DG-REL -DG1 (4 EBB), DG-RE [si c) -DG2 (4 EBB), MS-
_ _ = _ _. _ _ _ _. _ _ _ _. _ _ _ _
.NLS940118 November 25, 1994 Page 5 REL-K22A, hS-REL-K22B, EE-REL- (2 7X3-1F), and EE-REL- (2 7X3 -1G). The MS-REL-K22A and MS-REL-K22B relays have never been replaced.
This is a deviation (298/9427-03).
l b_d_ mission or Denial of the Deviation r
The District admits a deviation from the commitments in District letter CNS887255, but not as described in the Notice of Deviation.
Peacon for the Deviation The District letter referred to in the Notice of Deviation (CNS887255) was a supplemental response to IEB 84-02 on GE HFA relays. The entire discussion in the letter refers to the HFA relays.
Therefore, the conclusion in the letter that
...the District will initiate a replacement of all normally energized DC safety-related relays at CNS during the 1989 Refueling Outage..." implicitly refers to the HFA relays.
The relays referred to in the Notice of Deviation are Agastat relays that were not a subject of the IEB 84-02 supplemental response in letter CNS887255.
However, on September 2, 1994, the District determined that three HFA relays, EE-REL - ( 2 7X-1FA), - (27X-1GB), and - (2 7X -ETI) were not replaced as specified in letter CNS887255. These relays were not replaced in the time specified in the c
letter because they were misclassified as non-essential until 1993. In addition, a spare relay was identified as an old style HFA relay and has been recommended for replacement.
Two other relays listed in the Equipment Data File, EE-REL-(27X-1FA2) and - (27X8-1F), as old style HFA relays were subsequently verified by a plant walkdown to have been replaced with new style relays and the database is being changed to reflect the correct installed model number.
Corrective Actions Taken and Results Achieved The affected relays, EE-REL- ( 2 7X - 1FA), - (2 7X-1GB), and - (2 7X-ET1), plus the spare, are being replaced.
Actions Taken to Prevent Recurrence
. l Completion of the above corrective action completes the commitment made in District letter CNSB87255.
Date When Full Compliance Will be Achieved Full compliance will be achieved by replacing the above listed relays prior to startup.
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i NLS940118 bovember 25, 1994 Page 6
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If there are any questions about the information presented or on other matters, please call.
Sincerely,
.r /
i f
6 John H. Mueller Site Manager
/nr ce; Regional Administrator USNRC - Region IV Arlington, Texas l
NRC Resident Inspector Office Cooper Nuclear Station NPG Dietribution 1
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