ML20082V260
| ML20082V260 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/01/1995 |
| From: | Mueller J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS950106, NUDOCS 9505090142 | |
| Download: ML20082V260 (4) | |
Text
_
4 -
4 e"
COOPER NUCLEAR STATON P.o. 90X 98. BROWNVILLE NEERASKA 68321 Nebraska Public Power District
'" O J" = i NLS950106 May 1, 1995 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Subj ect:
Reply to Notice of Deviation NRC Inspection Report No. 50-298/95-05 Centlemen:
The Nebraska Public Power District (District) submits its response to the Notice of Deviation (NOD) transmitted with NRC Inspection Report No. 50-928/95-05. This inspection report documents the results of the NRC inspection conducted by Mr. John E. Whittemore and an NRC contractor from March 6 through March 10, 1995. on activities authorized at Cooper Nuclear Station (CNS).
The NRC identified two deviations during its inspection of CNS.
An explanation of the deviations and corrective actions taken in response to the deviations is presented below.
Statement of De viation (50-298/9505-01)
NRC Bulletin 90-01, " Loss of Fill-Oli in Transmitters Manufactured by Rost munt,
- March 9,1990, requested, in part, that licensees develop and imp.;aent an enhanced surveillance program to monitor identified affected transmitters for symptoms of loss of fH hoil. Additionally, the discussion section of the bulletin stated that act ans requested by the bulletin were intended to reflect diagnostic procedures recommended in a series of four technical bulletins issued by the vendor.
In a sworn response to the NRC, Letter NLS9000259, dated July 17,1990, the licensee's representative stated that the Cooper Nuclear Station was in compliance with the requested action to implement a trending program to identify sustained transmitter drift.
Contrary to the above, on March 6-10, 1995, an NRC inspector identified that the licensee had not implemented a trending program capable of identifying sustained transmitter drift. Specifically, transmitter calibration data trending had been performed using the upper calibration limit instead of the zero or span drift methodology that had been developed and proven in a laboratory, and recommended by vendor issued technical guidance. The licensee's method would not have idantified a susteined calibration drif t.
Statement of Deviation (50-298/9503-02)
NRC Bulletin 90-01, Supplement I, " Loss of Fill-Oil in Transmitters Manufactured by Rosemount," December 22, 1992, requested, in part, that medium pressure range transmitters in safety-related systems be replaced or monitored by trending on a refueling or 24-month basis.
In a sworn response to the NRC, Letter NSD930924,- dated March 5,1993, the licensee's representative stated that the Cooper Nuclear Station was complying with all requested action of the bulletin supplement by trending calibration data for five transmitters that had not reached the psi-month threshold criterion recommended by the vendor. Further, the transmitters were being trended on an 18-month basis.
9505090142 950501 PDR ADOCK 05
{B G
8 m.
S W
NLS950106 May 1, 1995
.Page 2 Contrary to the above, in February 1995, after the inspectors requested specific documentatie:, the licensee discovered that it was not in compliance with the requested action when calibration data trending was ceased in September 1991, which coincided with the transfer of the responsible engineer to an off-site position.
The affected transmitters were not all replaced until April 1993. As a result, at least one transmitter went 32 months without being evaluated as requested by the bulletin supplement and committed to by the licensee.
Admission or Denial of the Deviations The District admits both of the deviations.
Reason for the Deviations The reason for both of these deviations was inadequate management of commitments to the NRC.
1)
The review of IE Bulletin 90-01 failed to identify that the calibration procedure proposed by Rosemount in its technical bulletins was a part of the requirement for meeting the intent of the IE Bulletin. As a result, in the July 17, 1990, letter to the NRC, the District committed to using the existing CNS procedures rather than the Rosemount proposed procedure to collect calibration data for trending of Rosemount transmitters; however, the District never conveyed to the NRC that the CNS procedures were different from the Rosemount procedure.
2)
The commitment control process which existed was not effective in ensuring continuing trending of affected Rosemount transmitters until replacement as committed in the March 5, 1993, response to IE Bulletin 90-01, Supplement 1.
These are symptomatic of shortcomings in the past method of processing regulatory correspondence and managing the commitments therein.
Corrective Stens Taken and Results Achieved The following corrective actions have been taken to correct such deviations:
1)
The District's Phase I plan has adequately addressed management expectations in regard to regulatory correspondence. Regulatory Correspondence control Procedure 0.42 has been developed and implemented as psrt of the Phase I Plan.
This procedures establishas the method, identifies responsibilities, and sets forth requirements for controlling correspondence issued to or received from the NRC.
CNS Procedure 0.42 contains the following elements that ensure clear identification of embedded commitments and transmittal of accurate and complete information to the NRC:
The statements of fact in NRC submittals are thoroughly verified and appropriately validated prior to their transmittal to the NRC.
Commitments made in NRC submittals are explicitly stated in, and separately entered on, the List of NRC Commitments Form.
This form is transmitted to the NRC along with the submittal, e
Each commitment in NRC correspondence is assigned a commitment number and entered into the Commitment Tracking System.
1
)
__ j
~.
~
NLS950106 May 1, 1995 Page 3 Each commitment made in an NRC submittal is tracked to completion; upon its completion, appropriate closeout documentation is acquired for evidence, reviewed for adequacy, and maintained for future reference.
For ongoing commitments, a program to ensure ongoing maintenance and continuing compliance of such commitments is a requirement for closeout.
- 2) A review of Licensee Event Reports (LERs) issued since 1981 has been performed to verify and validate completed actions. Also, a review of Operating Experience (OE) documents has been conducted to determine if any safety significant degraded and nonconforming conditions existed prior to plant startup.
These reviews which have been performed as a part of the Phase I performance improvement plan, have provided an additional degree of confidence and assurance that CNS has adequately addressed necessary actions committed to in those documents.
Corrective Steos Taken to Avoid Further Deviations f
The District's Nuclear Power Group is continuing to focus on commitment management, monitoring its effectiveness and mak. ing adjustments for improvements if necessary.
Date When Corrective Action Will Be Comoleted CNS has already implemented necessary corrective actions to prevent recurrence of such deviations.
If there are any questions regarding the information presented on these matters, please contact me.
i dA Jhhn H. Mueller Site Manager cc:
Regional Administrator USNRC - Region IV Arlington, Texas NRC Resident Inspector Cooper Nuclear Station NPG Distribution 4
+
I I
1 L
. ~ _ _
l_*
LIST OF NRC COMMITMENTS l ATTACHMENT 3 l
Correspondence No: NLS950106 The following teble identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None I
i PAGE 10 OF 16 l
l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 0 l
1
. - - -