ML20132H269
| ML20132H269 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/24/1996 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9612300034 | |
| Download: ML20132H269 (5) | |
See also: IR 05000298/1996023
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DEC 2 41996
G. R. Horn, Senior Vice President
of Energy Supply
Nebraska Public Power District
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141415th Street
Columbus, Nebraska 68601
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SUBJECT: NRC INSPECTION REPORT 50-298/96-23
Dear Mr. Horn:
Thank you for your letter of December 16,1996,in response to our letter and Notice
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of Violation dated November 12,1996. We have reviewed your reply and find it responsive
to the concerns raised in our Notice of Violation. We will review the implementation of your
corrective actions during a future inspection to detr uiine that full compliance has been
achieved and will be maintained.
Sincerely,
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J. E. Dyer, Director
Division of Reactor Projects
Docket No.: 50-298
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License No.: DPR-46
cc:
John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, Nebraska 68602-0499
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P. D. Graham, Vice President of
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Nuclear Energy
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Nebraska Public Power District
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P.O. Box 98
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Brownville, Nebraska 68321
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9612300034 961224
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ADOCK 05000298
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Nebraska Public Power District
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B. L. Houston, Nuclear Licensing
and Safety Manager
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
R. J. Singer, Manager-Nuclear
Midwest Power
907 Walnut Street
P.O. Box 657
Des Moines, Iowa 50303
Mr. Ron Stoddard
Lincoln Electric System
11th and O Streets
Lincoln, Nebraska 68508
Randolph Wood, Director
Nebraska Department of Environmental
Quality
P.O. Box 98922
Linccin, Nebraska 68509-8922
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Chairman
Nemaha County Board of Commissioners
Nemaha County Courthouse
1824 N Street
Auburn, Nebraska 68305
Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
Nebraska Department of Health
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007
Dr. Mark B. Horton, M.S.P.H.
Director
Nebraska Department of Health
P.O. Box 950070
Lincoln, Nebraska 68509 5007
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Nebraska Public Power District
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R. A. Kucera, Department Director
of intergovernmental Cooperation
Department of Natural Resources
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P.O. Box 176
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Jefferson City, Missouri 65102
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Kansas Radiation Control Program Director
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DEC 2 41996
bec to DMB (IE01)
bec distrib. by RIV:
L. J. Callan
Resident inspector
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DRP Director
DRS-PSB
Branch Chief (DRP/C)
MIS System
Branch Chief (DRP/TSS)
RIV File
Project Engineer (DRP/C)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
DOCUMENT NAME: R:\\_CNS\\CN623AK.MHM
To receive copy of document, irdcate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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OFFICIAL RECORD COPY
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Nebraska Public Power District
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DEC 2 41996
bec to DMB (IE01)
bec distrib. by RIV:
L. J. Callan
Resident inspector
DRP Director
DRS-PSB
Branch Chief (DRP/C)
MIS System
Branch Chief (DRP/TSS)
RIV File
Project Engineer (DRP/C)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
DOCUMENT NAME: R:\\_CNS\\CN623AK.MHM
To receive copy of document, indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures "N" = No copy
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OFFICIAL RECORD COPY
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P.O. GOX 98. BROWNVILLE. NE BRASKA 68321
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NLS960236
December 12,1996
U.S. Nuclear Regulatory Commission
DEC16
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
Attachment 1, 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
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P. D. Graham
Vice President - Nuclear
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Attachment
cc: Regional Administrator
USNRC - Region IV
Senior Project Manager
USNRC - NRR Project Directorate IV-1
Senior Resident inspector
NPG l)istribution
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Attaclunent I
to NLS960236
Page1 of3
IEPLY 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,
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 Afonitoring the Effectiveness ofAlaintenance at
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 pe-formance or
condition ofa structure, system or component has been effectively controlled through the
performance ofappropriate preventive maintenance ofthe structure, system, or component
and that the structure, system or component remains capable ofperforming its intended
function.
Regulatory Guide 1,160, "Afonitoring the Effectiveness ofAfaintenance at Nuclear Power
Plants, " Revision 1, January 1995, endorses NUMARC 93-01, " Industry Guidelinesfor
Afonitoring the Effectiveness 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 effectiveness 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,
"Afaintenance Rule Program, " Revision 1, Section 2.2, which stated, in part, thisprocedure
provides guideline methodology to ensure compliance with 10 CFR 50.65 criteria by
incorporating NUAfARC 93-01.
NUAfARC 93-01, Section 9.3.2, states, inpart, that performance criteriafor risk sigmficant
structures, systems, and components should be established to assure reliability and
availability assumptions used in the plant-specific probabilistic risk assessment, individual
plant examination, or other risk determining analysis are maintained or adjusted when
necessary.
Procedure 0.27, Step 4.11, states, in part, that the Operations department is responsiblefor
reco',ni:mg the impact on the Afaintenance Rule Program with regard to risk sigmficance
and unavailability when taking equipment out ofservice, recording out-of; service time, and
recording return-to-service time.
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Attachment I
to NLS960236
Page 2 of 3
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Contrary to the above:
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On October 2,1996, whileperforming Surveillance Procedure 6.1 ADS 303, "ADSLogic
Functional Test (Div 1), " Revision 1, the control room crewplaced both Trains A and B of
the automatic depressurization system in the inhibitpositions but recorded only Train A out-
of-service and return-to-service timesfor unavailability evaluation with respect to the
klaintenance Rule.
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This is a Severity Level IV violation (Supplement 1) (298/96023-01).
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Adaliscion or Denial to Violation
The District admits the violation.
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Reason for Violation
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 withm 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
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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). 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.
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Attaclunent 1
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Page 3 of 3
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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
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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 ensurelhat
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the requirements of the Maintenance Rule Program are being met with respect to the
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accumulation of unavailability for risk significant functions. 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
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February 7,1997.
Date When Full Comnliance Will Be Achieved
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The District has completed all corrective actions necessary to return CNS to full compliance with
respect to the identified violation.
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ATTACHMENT 3
LIST OF NRC COMMITMENTS
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Correspondence No: NLS960236
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
COMMITTED DATE
COMMITMENT
OR OUTAGE
Other surveillance procedures monitored under the AOT
program will be reviewed to ensure that the requirements
January 24, 1997
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of the Maintenance Rule Program are being met with
respect to the accumulation of unavailability for risk
significant functions.
Procedure 0.27, " Maintenance Rule Program," will be
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revised to clarify the program requirements for
February 7,
1997
accumulating unavailability for risk significant
functions.
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PROCEDURE NUMBER 0.42
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REVISION NUMBER 1.2
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PAGE 8 OF 10
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