ML20116B500
| ML20116B500 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/22/1996 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS960136, NUDOCS 9607300075 | |
| Download: ML20116B500 (6) | |
Text
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3 P.O. BOX BROMV B
M2 Nebraska Public Power District T M ""
NLS960136 July 22,1996 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-07 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
Letter from Mr. J. E. Dyer (USNRC) to Mr. G. R. Horn (NPPD), dated June 21,1996, "NRC Inspection Report 50-298/96-07 and Notice of Violation" This letter, including Attachment 1, constitutes the Nebraska Public Power District's (District's) reply to the referenced Notice of Violation in accordance with 10 CFR 2.201.
Inspection Report 50-298/96-07 docmnented the results of an NRC inspection conducted from j
March 17 through May 4,1996, at the Cooper Nuclear Station (CNS) facility. The District j
admits to the violation and has completed all corrective actions that are necessary to return CNS to full compliance with 10 CFR Part 50, Appendix B, Criterion V with respect to the identified violation.
Should you have any questions concerning this matter, please contact my office.
Sincerely, P D. Graham Site Manager Cooper Nuclear Station 9607300075 960722
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i to NLS960136
, Page I of 3 REPLY TO JUNE 21,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from March 17 through May 4,1996, one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
"10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these i
instnictions orprocedures.
Procedure 3.4.10, Revision 4.2, ' Station Modification Changes, ' controls design changes to safety-related equipment. Step 2.1.1.1 states that any change to a station modification package which results in a change to the design basis or design criteria is considered a change ofintent and cannot be implemented using an on-the-spot change.
Contrary to the above, on March 15, 1996, Design Modification 93-024 changed by On-The-Spot Change 61 specified, in part, to modify the muffler bypass valve by enlarging air tubing and changing the valve orientation and to allow the control room staff to declare the emergency diesel generator operable with the muffler bypass valve removed. These modifications changed the design criteria of the equipment and should not have been implemented using an on-the-spot change."
Admission or Denial to Violation The District admits the violation.
Reason for Violation
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Design Change (DC)93-024 was implemented during the last refueling outage to install several diesel generator (DG) upgrades. Among the modifications implemented was changing the failure position of the muffler bypass valves on a loss of instrument air.
Subsequent to the outage, it was identified that the muffler bypass valve was mounted horizontally as opposed to the vendor recommended orientation of vertical. This had resulted in moisture accumulation and corrosion of the valve stem inhibiting free inovement of the valve for DG 2.
To reorient the valve in accordance with the vendor's recommendation, an On the Spot Change (OSC 61) to DC 93-024 was written since the DC had not been administratively closed. The Instrument and Control Design Engineering supervisor reviewed the existing
l to NLS960136 Page 2 of 3 safety evaluation for DC 93-024 and determined that the safety evaluation was not changed by the OSC premised on the diesel being declared inoperable during the activity.
Originally, the OSC specified the DG inoperable during the modification work with the muffler bypass vn.ves removed but due to a mis-communication between the design engineer and Operations manager, the OSC was revised to provide guidance to the Shift Supervisor to exit the DG LCO with the muffler bypass valve removed. However, the OSC did not specify testing nor did it document an evaluation of this configuration prior to exiting the LCO.
This violation occurred due to a violation of procedure in the inappropriate use of the design modification change process. The design engineer misinterpreted procedure 3.4.10 to allow use of the OSC process to conect an installation error (mis-orientation of the valve) that could not have been identified prior to DC approval. The design engineer and subsequent reviewers incorrectly considered the OSC within the scope of the DC. The DC Amendment process, which requires Station Operating Review Committee approval, should have been used in this situation.
A second reann for this violation was a lack of guardianship of operability determinations.
The Shift Supervisor inappropriately ceded to what he assumed to be an approved document with proper reviews regarding Emergency Diesel Generator operability. Incorrect guidance was supplied to the Shift Supervisor due to the lack of controls and guidance for design engineers on when Technical Specification requirements or LCO action statements are to be included in station modification work instructions. Additionally, specific guidance for returning SSCs to an operable status was i ot available to the Shift Supervisor.
Corrective Stens Taken and the Results Achieved Post-modification testing was completed on the Emergency Diesel Generator to demonstrate operability.
Management expectations regarding the appropriate use of the OSC process have been communicated to personnel responsible for design change development and implementation.
Operational guidance for returning SSCs to an operable status has been incorporated into an Operations Instruction and the information reviewed with all Shift Supervisors.
Corrective Stens That Will Be Taken to Avoid Further Violations 1.
Engineering procedure 3.4.10 will be revised by September 22,1996, to enhance guidance and provide clearer documentation for OSC applicability screening to indicate what changes constitute a change of scope and what changes require an additional safety evaluation.
to NLS960136 Page 3 of 3 2.
Appropriate procedures will be revised by August 27,1996, to provide guidance and controls to ensure that station modification documents that specify Technical Specification requirements are at a consistent level of detail and accuracy.
Date When Full Compliance Will Be Achieved The District is in full compliance with the requirements of 10 CFR Part 50, Appendix B, Criterion V with respect to the identified violation.
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LIST OF NRC COMMITMENTS ATTACI1 MENT 3 Correspondence No: N1 S960136 j
The following table 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.
COMMITMENT COMMITfED DATE OR OUTAGE Engineering procedure 3.4.10 will be revised to enhance guidance and provide September 22,1996
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clearer documentation for OSC applicability screening to indicate what changes constitute a change of scope and what changes require an additional safety evaluation.
Cuidance and controls will be developed to ensure that station modification August 27,1996 documents that specify Technical Specification requirements are at a consistent level of detail and accuracy.
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PROCEDURE NUMBER 0.42 REVISION NUMBER 0 PAGE 12 OF 16
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