ML20116F350
| ML20116F350 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/31/1996 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CAL-4-94-08, CAL-4-94-8, NLS960135, NUDOCS 9608060322 | |
| Download: ML20116F350 (5) | |
Text
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COOPER NUCLEAR STATION P.O. EM 96. BROWNVILLE. NEBRASKA 88321 Nebraska Public Power District "EET" s
a NLS960135 July 31,1996 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Revision of Commitment Regarding Review of Operating Experience Documents Cooper Nuclear Station, NRC Docket 50-298, DPR-46
References:
- 1. Letter from G. R. Horn (NPPD) to L. J. Callan (NRC) dated August 8,1994,
" Response to Request for AdditionalInformation."
- 2. Letter from L. J. Callan (NRC) to G. R. Horn (NPPD) dated August 2,1994,
" Confirmatory Action Letter,"(CAL 4-94-08).
- 3. Letter from T. P. Gwynn (NRC) to G. R. Horn (NPPD) dated March 17,1995, "NRC Inspection Report 50-298/95-01 and Notice of Violation."
- 4. Letter from T. P. Gwynn (NRC) to G. R. Horn (NPPD) dated April 11,1996, "NRC Inspection Report 50-298/96-05 and Notice of Violation."
The purpose of this letter is to notify the NRC of the Nebraska Public Power District's (Eistrict's) intention to revise an earlier commitment made to the NRC. By letter dated August 8,1994 (Reference 1) the District committed to perform a full review of Cooper Nuclear Station's (CNS's) industry operating experience review (OER) database responses, with an estimated completion time of two years. The District has completed a screening evaluation of the complete population to determine potential safety significance, and performed a full review of the adequacy of the responses which met the screening criteria. As discussed in further detail below, these reviews provide reasonable assurance that all safety significant issues identified in these documents have been addressed. Therefore, the District does not intend to expend further resources to perform full reviews of the balance of the OER database responses.
By letter dated August 2,1994, the NRC issued Confirmatory Action Letter (CAL) 4-94-08 (Reference 2). That letter requested the District to describe the basis for its assurance that an adequate review of Cooper's own operating experience, industry experience, and NRC information has been conducted to support plant restart. Reference 1 provided, in part, the 9608066322 960731
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l U. S. Nuclear Regulatory Commission i
July 31,1996 Page 2 0f 3 l
District's response to that request. The District indicated that it would perform the following review of OER responses prior to plant restart:
All closed OER responses for the years 1992,1993, and 1994; All closed pre-1987 responses; and 25% of the 1987-1991 responses.
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The intent of this review was to provide a reasonable basis for concluding that the District's OER program had not overlooked issues that could have a significant impact on safety. The review consisted of an initial screening of all responses against the following criteria:
The item could adversely affect nuclear safety; The item is needed to comply with the CNS Technical Specifications; The consequences of not completing the OER action could affect the ability of a safety system to satisfy its design function; The consequences of not completing the OER action could result in reduced safety system availability.
Those OER documents which met any of the above criteria were reviewed for adequacy. If the basis for closure did not appear adequate, the item was to be reviewed in detail. The District committed to complete this effort prior to restart. The District further committed to complete a full review of Cooper's OER database responses, with an estimated completion time of two years.
As committed, the District completed, prior to restart, the OER response screening and review effort described above. Ilowever,in lieu of a 25% sampling of the 1987-1991 OER responses, the District performed a 100% screening and review of the information for that period in accordance with the methodology outlined above. Prior to restart, the NRC reviewed this effort and documented its results in NRC Inspection Report 50-298/95-01 (Reference 3).
The District's screening and review effort resulted in an additional detailed review of approximately 7.5% of all the OER responses. Approximately 0.6% of the total population of these responses required additional actions. Therefore, while the District did identify further actions as a result of this review, the percentage of the total population of OER responses was small.
The District has implemented a number ofimprovements in its OER program. These improvements included incorporating the screening and review methodology described above, dedicating an experienced staff to the review and disposition of OER issues, and ensuring that a 1
more timely review of OER issues is performed. These improvements provide continued assurance that future safety significant issues will be adequately addressed in a timely manner.
The NRC reviewed these OER program improvements and documented their review in NRC Inspection Report 50-298/96-05 (Reference 4). The NRC recognized the improvements made to
i U. S. Nuclear Regulatory Commission July 31,1996 Page 3 of 3
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the District's OER program, acknowledging the adoption of the methodology used to review the historical OER database information as a means for ensuring consistency and thoroughness of review. The NRC also noted that the existing OER program procedures appeared to be adequate to ensure program requirements continue to be met.
Upon further evaluation, the District does not believe further review of the historical OER database information and responses would be an effective use ofits resources. The reviews of the historical OER information used the same screening methodology that has since been 4
i incorporated into, and made a part of Cooper's improved OER program. The District does not 1
believe that further review of the historical responses would provide a safety benefit commensurate with the cost of performing the review.
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In summary, the District believes that the screening and review of the historical OER information performed, the results of that effort, and improvements made to Cooper's OER program, provide sufficient assurance that both past and future safety concerns have and will continue to be adequately addressed. Therefore, the District does not intend to expenffurther resources bn this i
issue.
l Please contact me if you have any questions concerning this matter, or if you require any additional information.
Sincerely, hh W P. D. Graham Site Manager cc:
Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident inspector USNRC - Cooper Nuclear Station Regional Administrator USNRC - Region IV NPG Distribution
l LIST OF NRC COMMITMENTS l ATTACHMENT 3 l
1-Correspondence No:
NLS960135 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.
COMMITTED DATE COMMITMENT OR OUTAGE Nonc e
.)
l i
l PROCEDURE NUMBBR 0.42 l
REVISION NUMBER 1.1 l
PAGE 9 OF 11 l
LIST OF NRC COMMITMENTS l ATTACHMENT 3 l
Correspondence No:
NLS960135 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.
COMMITTED DATE COMMITMENT OR OUTAGE None l
PROCEDURE NUMBER 0.42 l
REVISION NUMBER 1.1 l
PAGE 9 OF 11 l
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