ML20132B713

Responds to NRC Re Violations Noted in Insp Rept 50-298/96-23.Corrective Actions:Procedure 0.27, Maint Rule Program, Will Be Revised

ML20132B713
Person / Time
Site:	Cooper
Issue date:	12/12/1996
From:	Graham P NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS960236, NUDOCS 9612170356
Download: ML20132B713 (5)

Text

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COOPER NUCLEAR STATON P.O. BOX 96, BROWNVILLE, NE8RASKA 68321 Nebraska Public Power District m;gg;'g a" s

NLS960236 December 12,1996 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-23.

Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

1. Letter to G. R. Horn (NPPD) from J. E. Dyer (USNRC) dated November 12, 1996,"NRC Inspection Report 50/298/96-23 and Notice of Violation" By letter dated November 12,1996, (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation of NRC requirements. This letter, including, constitutes the District's reply to the referenced Notice of Violation in accordance with 10 CFR 2.201. The District admits to the violation and has completed all corrective actions necessary to return CNS to full compliance.

Should you have any questions concerning this matter please contact me.

Since k{

P. D. Graham Vice President - Nuclear

/cnn Attachment gD cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1

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Senior Resident Inspector j

USNRC NPG Distribution 9612170356 961212 PDR ADOCK 05000298 G

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. Attachment I to NLS960236 Page1of3 REPLY TO NOVEMBER 12,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from September 8,1996, through October 19,1996, i

one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:

Violation 10 CFR Part 50.65, "Requirementsfor Monitoring the Effectiveness ofAfaintenance at

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Nuclear Power Plants, " as described in 10 CFR 50.65(a)(2) states, in part, that monitoring under (a)(1) is not required where it has been demonstrated that the performance or condition ofa structure, system or component has been efectively controlled through the performance ofappropriate preventive maintenance ofthe structure, system, or component and that the structure, system or component remains capable ofperforming its intended fimetion.

Regulatory Guide 1.160, "Afonitoring the Efectiveness ofAlaintenance at Nuclear Power Plants, " Revision 1, January 1995, endorses NUAfARC 93-01, " Industry Guidelinesfor Ahmitoring the Efectiveness ofAlaintenance at Nuclear Power Plants, " as an acceptable methodfor implementing the requirements of10 CFR 50.65. Regulatory Guide 1.160 states that the methods described in the guide will be used in the evaluation ofthe efectiveness of maintenance activities by licensees who are required to comply with 10 CFR 50.65 unless a licensee hasproposed an acceptable alternative methodfor compliance. The licensee subscribed to the NUAfARC 93-01 methodology in Administrative Procedure 0.27, "Alaintenance Rul. Program, " Revision 1, Section 2.2, which stated, inpart, thisprocedure l

provides guideline methodologv to ensure compliance with 10 CFR 50.65 criteria by l

incorporating NUAIARC 93-01.

l NUA1 ARC 93-01, Section 9.3.2, states, in part, that performance criteriafor risk sigmficant structures, systems, and components should be established to assure reliability and availability assumptions used in the plant-specificprobabilistic risk assessment, individual l

plant examination, or other risk determining analysis are maintained or adjusted when necessary.

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Procedure 0.27, Step 4.11, states, inpart, that the Operations department is responsiblefor

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recogni:ing the impact on the Alaintenance Rule Program with regard to risk sigmficance i

and unavailability when taking equipment out ofservice, recording out-of-service time, and i

recording return-to-service time.

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to NLS960236 j

Page 2 of 3 Contrary to the above:

l On October 2,1996, while performing Surveillance Procedure 6. LADS 303, " ADS Logic 1

Functional Test (Div 1), " Revision 1, the control room crewplaced both Trains A and B of i-the automatic depressuri:ation system in the inhibitpositions but recorded only Train A out-l of-service andreturn-to-service timesfor unavailability evaluation with respect to the i

Maintenance Rule.

This is a Severity LevelIV violation (Supplement 1) (298/96023-01).

l Admission or Denial to Violation The District admits the violation.

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Reason for Violation

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As detailed below, this violation is a result of a weakness associated with the application of Allowed Out-of-Service Times (AOTs) for accumulating unavailability for risk significant functions under the CNS Maintenance Rule Program.

Allowed Out-of-Service Times are used within the CNS Surveillance Testing Program to address

. operability of equipment required by the CNS Technical Specifications during testing. They are based on reasonable out-of-service times required to perform the testing and focus on the out-of service time of the affected system as opposed to individual components or steps within the procedure. Accordingly, the AOT logs do not require documentation of all components made unavailable within an existing AOT window. While this approach is adequate to satisfy the requirements of the Surveillance Testing Program, it does not fully satisfy the requirements for accumulating unavailability under the Maintenance Rule Program.

A contributing factor to this violation is the ambiguity of Procedure 0.27," Maintenance Rule Program," relative to the program requirements for accumulating unavailability for risk significant functions.

Corrective Steps Taken and the Results Achieved Each surveillance procedure that affects the operability of equipment controlled by the CNS Technical Specifications has an associated AOT tracking sheet (or log)J Accordingly, the AOT tracking sheets for both Surveillance Procedures 6.l ADS.303," ADS Logic Functional Test (Div 1)," and 6.2 ADS.303," ADS Logic Functional Test (Div 2)," have been modified to reflect the fact that both Train A and Train B of the automatic depressurization system (ADS) are rendered unavailable during performance of these procedures.

to NLS960236 Page 3 of 3 In addition, the unavailability accumulated for ADS Trains A and B have been adjusted to account for the error. (While the second train was inhibited only 6 seconds per surveillance on the average, the full unavailability recorded since January 1996 for Train A as a result of Procedure 6.1 ADS.303 has been conservatively added to the unavailability accumulated for Train B and vice versa for Procedure 6.2 ADS.303.) This did not result in either of the trains approaching their unavailability performance criteria limits.

Corrective Steps That Will Be Taken to Avoid Further Violations Other surveillance procedures monitored under the AOT program will be reviewed to ensure that the requirements of the Maintenance Rule Program are being met with respect to the accumulation of unavailability for risk significant ftmetions. This review will be completed by January 24,1997. To minimize the potential for a repeat violation prior to the completion of this review, appropriate operations personnel have been sensitized to this issue. Further, Procedure 0.27, " Maintenance Rule Program," will be revised to clarify the program requirements for accumulating unavailability for risk significant functions. This revision will be implemented by February 7,1997.

Date When Full Comnliance Will Be Achieved The District has completed all corrective actions necessary to return CNS to full compliance with i

respect to the identified violation.

' ATTACHMENT 3 LIST OF NRC COMMITMENTS Correspondence No: MLS960236 The following table identifies those actions committed to by the District in this

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document. Any other actions discussed in the submittal represent intended or i

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 Other surveillance procedures monitored under the AOT I

program will be reviewed to ensure that the requirements January 24, 1997 of the Maintenance Rule Program are being met with respect to the accumulation of unavailability for risk i

significant functions.

Procedure 0.27, " Maintenance Rule Program," will be revised to clarify the program requirements for February 7, 1997 accumulating unavailability for risk significant functions.

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PROCEDURE NUMBER 0.42 l

REVISION NUMBER 1.2 l

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