ML20135C499
| ML20135C499 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/21/1997 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| EA-96-341, NUDOCS 9703040075 | |
| Download: ML20135C499 (8) | |
See also: IR 05000298/1996012
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EA 96-341
G. R. Horn, Senior Vice President
of Energy Supply
Nebraska Public Power District
141415th Street
Columbus, Nebraska 68601
SUBJECT:
NRC INSPECTION REPORT 50-298/96-12 AND NOTICE OF
VIOLATION
Dear Mr. Horn:
Thank you for your letter of November 6,1996,in response to our letter and Notice of
Violation dated October 7,1996. In your response, Nebraska Public Power District denied
Violations A (second and third examples), B, C, and F. For the reasons discussed in
the enclosure to this letter, NRC does not accept your denial of Violations A (second
and third examples), B, and C. In a discussion between Dr. Dale A. Powers and Mr. Brad
Houston of your staff, on January 7,1997, we provided our basis for not accepting
Nebraska Public Power District's positions on the disputed violations. During further
discussions with Mr. R. Wachowiak on February 4,1997, additionalinformation was
obtained that clarified the events related to Violation F. Based on your response and the
additionalinformation, we have determined that no violation occurred. Accordingly, the
violation (50 298/9612-06)is hereby withdrawn,
in accordance with 10 CFR 2.201, you are required to provide an additional response
within 30 days of the date of this letter addressing the corrective actions that have been
taken and the results achieved. The NRC will use this additional response to determine
whether further enforcement action is necessary to ensure compliance with regulatory
requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure (s), and your response will be placed in the NRC Public Document
Room (PDR). To the extent possible, your response should not include any personal
privacy, proprietary, or safeguards ir >rmation so that it can be placed in the PDR without
redaction.
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9703040075 970221
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ADOCK 05000298
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Nebraska Public Power District
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Should you have any questions concerning this matter, contact me at (817) 860-8226 or
Dr. Dale A. Powers at (817) 860-8195.
Sincerely,
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J. E. Dyer
Acting Regional Administrator
Docket No.: 50-298
License No.: DPR-46
Enclosure: As Stated
cc w/ enclosure:
John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, Nebraska 68602-0499
P. D. Graham, Vice President of
Nuclear Energy
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
B. L. Houston, Nuclear Licensing
and Safety Manager
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
R. J. Singer, Manager-Nuclear
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Midwest Power
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907 Walnut Street
P.O. Box 657
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Des Moines, Iowa 50303
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Mr. Ron Stoddard
Lincoln Electric System
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11th and O Streets
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Lincoln, Nebraska 68508
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Nebraska Public Power District
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Randolph Wood, Director
Nebraska Department of Environmental
Quality
P.O. Box 98922
Lincoln, Nebraska 68509-8922
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 Contennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007
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Dr. Mark B. Horton, M.S.P.H.
Director
Nebraska Department of Health
P.O. Box 950070
Lincoln, Nebraska 68509-5007
R. A. Kucera, Department Director
of Intergovernmental Cooperation
Department of Natural Resources
P.O. Box 176
Jefferson City, Missouri 65102
Kansas nadiation Control Program Director
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DOCUMENT NAME: R:\\_CNS\\CN612AK. JEW
To receive copy of document, indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures "N" go, copy
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OFFICIAL RECORD COPY
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ENCLOSURE
Violation A: The licensee admitted the violation except for two of the four examples
concerning the failure to include required functions in the scope of the
With respect to the first and second examples, Nebraska Public Power
District's decision (and subsequent corrective actions) to place the two examples of
Functions RMV-F01 (facility radiation monitors) and RMP-F02 (air ejector off gas
monitor) within the scope of the Maintenance Rule Program adequately addressed
the concerns related to these functions.
With respect to the third example, Nebraska Public Power District's response stated
that a limited review of industry experience, going back 36 months, did not uncover
any instances where a f ailure of Functions AS-F04, F07, F013, and F014 (auxiliary
steam system) resulted in a failure of a safety system. Your review should have
attempted to identify events where failures of the auxiliary steam system at boiling
water reactors challenged the operability or desired functional response of safety
systems or nonsafety systems that support safety systems; also, it should not have
been limited to a 36-month period. (See, for example, Oyster Creek event
discussed in NRC SpecialInspection Report 50-219/88-02.) The violation example
is, thus, sustained, and appropriate corrective action must be developed and
implemented.
With respect to the fourth example, Nebraska Public Power District's decision to
exclude Function IC-F01 (Gaitronics communication system) from the scope of the
Maintenance Rule Program was based on the system not providing a significant
fraction of the total functional ability required to mitigate core damage or radioactive
release. The inspectors noted during the inspection that a survey was conducted
which determined that the fraction of emergency operating procedures
communications which would use the gaitronics communication system was
approximately 20 percent. The response asserted that a 20 percent contribution to
communication function performance was not significant. However, neither the
program nor the response justified what percentage of contribution would be a
significant contribution. Therefore, there was no basis for determining,
quantitatively, whether the system should be included in the scope of the
Maintenance Rule. This violation example is, thus, sustained, and appropriate
corrective action must be developed and implemented.
Violation B: The licensee denied the violation which identified a f ailure to adequately
measure reliability of functions.
Nebraska Public Power District's response concluded that the program method of
measuring reliability by using an absolute maintenance preventable functional f ailure
value for reliability performance could provide trendable information directly linked
to probabilistic risk analysis assumptions. Additionally, the response stated that
this position was similar to the position stated by the Electric Power Research
Institute during the October 16,1996, Nuclear Energy Institute (NEI) Maintenance
Rule Workshop. In a letter to the Senior Vice President and Nuclear Officer for
Nuclear Generation, NEl, dated October 22,1996, the acting director of the Office
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of Nuclear Reactor Regulation provided clarification on this issue. The enclosure to
the letter, a document entitled, "The Reliability Performance Standard," reiterated
the NRC's position on this issue. (A copy of the October 22,1996, letter is
attached to this Enclosure.) As a result of the unchanged NRC position on
measuring reliability for complying with the Maintenance Rule, this violation is, thus,
sustained, and appropriate corrective action must be developed and implemented.
Violation C: The licensee denied the violation which identified inadequate accuracy in
measuring unavailability for functions associated with four safety-related
systems.
Nebraska Public Power District's denial of this violation was accompanied by a
statement that a " revised definition has been applied to these functions and the
unavailability values appropriately adjusted" by considering the position of the
reactor head vent instead of the control rods. This change adequately addressed
our specific concerns about the automatic depressurization and high pressure
coolant injection systems.
However, it is not appropriate to construct availability demand time around the
position of the reactor head vent for functions associated with the emergency diesel
generators and the residual heat removal system. The times when these systems
may be required to function for safety considerations are not necessarily associated
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with the position of the reactor head vent. Additionally, there may be generic
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implications related to other safety functions not identified by the NRC team. This
violation is, thus, sustained, and appropriate corrective action must be developed
and implemented.
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Violation D: The licensee admitted the violation that identified inadequate procedural
guidance to assure risk assessm ut of plant configuration changes.
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Nebraska Public Power District planned and completed corrective action to revise
the guidance procedure was responsive to the concern regarding risk assessment of
changes to plant configuration due to monitoring and preventive maintenance
activities.
Violation E:
The licensee admitted the violation that identified a failure to perform
required assessment of a plant configuration change.
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Nebraska Public Power District completed corrective actions to revise the procedure
and retrain key personnel was responsive to the concern regarding risk assessment
of removing a diesel generator from service for planned maintenance.
Violation F:
The licensee denied the violation that identified the f ailure to properly follow
procedures that implemented Maintenance Rule requirements.
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Nebraska Public Power District's response argued against a violation of the
Maintenance Rule; however, they did admit that, with respect to one of the
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corrective action documents referenced in the violation, its corrective action system
requirements were not met. Additionally, the licensee's program for implementing
the Maintenance Rule fully incorporated NUMARC 93-01, and Section 9.4.5
requires a cause determination to determine a maintenance preventable functional
f ailure had occurred. A subsequent exchange of information indicated that for the
two events in question:
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.The equipment function was continuously maintained.
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A failure evaluation was performed by the component vendor.
As a result of this additionalinformation, the NRC learned that there was no failure
to cunduct a cause determination for the two separate events. Therefore, this
violatioa is withdrawn.
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ATTACHMENT
LETTER OF OCTOBER 22,1996
TO: Ralph E. Beedle
FROM: Frank J Miraglia
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UNITED STATES
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October 22 1996
Mr. Ralph E. Beedle
Senior Vice President
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and Chief Nuclear Officer
Nuclear Generation
Nuclear Energy instrtute (NEI)
1776 Eye Street, N.W., Suite 300
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Washington, D.C. 20006-3706
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Dear Mr. Beedle:
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I am responding to your letter of September 30,1996, regarding your concem that the
maintenance rule baseline inspections have identified a generic industry issue Your letter
desenbed the NRC's posrtion en the use of reliability as a performance " indicator." discussed
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the industry's choice of reliability performanca indicators, and imphed the NRC has
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established "new interpretations of compliance expectations through inspection and
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enforcement."
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I, too, am concemed that the industry and regulatory guidance developed over the last
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several years may not be completely understood by the licensees, even though the nine site
pilot visits did not reveal such a problem. My concem is based on the fact that, in four out of
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the five maintenance rule baseline inspections (MRBis) completed by the NRC through
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October 4,1996, potential violations of 10 CFR 50.65 (the Maintenance Rule) have been
found in the area of goals and performance cnteria that the licensees have established for
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rehability of systems, structures, trains, and components (SSCs). (A more detailed
explanation of my concem is contained in the enclosure.)
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Paragraph (a)(1) of the maintenance rule requires that " goals shall be established
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commensurate with safety . " Although not a requirement, quantitative methods - wrth
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individual plant examinations (IPEs) or plant-specific probabilistic risk assessments (PRAs),
for example, as the basis - have been used to establish this required link with safety. Your
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guidance document, NUMARC 93-01, ties the requirements for goals (10 CFR 50.65 (a)(1))
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to similar requirements for performance enteria (10 CFR 50 65 (a)(2)). NUMARC 93-01,
Paragraph 9.3.2," Performance Cntena for Evaluating SSCs" states," Performance enteria for
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nsk significant SSCs should be estabhshed to assure that raliability and availability
assumptions used in the plant-specific PRA, IPE, IPEEE, or other risk determining analysis
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are maintained or adjusted when determined necessary by the utility." It is the lack of a clear
link to PRA/IPE/IPEEE or other rehabikty assumptions that is at the root of the NRC's
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concems
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October 22, 1996
Maintaining the link between rehabihty assumptions in the plant-specific nsk-determining
analysts and the performance standards under the maintenance rule has been a longstanding
position of the agency. For example, the meeting summary regarding the April 22,1992,
NRC/NUMARC public meeting for developing maintenance rule implementation guidance
noted.
"The Industry Guidehne allows but does not recommend or require the use of
IPE/PRA results for performance criteria or goal setting. The NRC believes the
maintenance (monitoring) results should be used to confirm performance and
conditions (including component and train availability and reliabihty) in
available iPE/PRA and other safety analysis results.
As indicated above, this concem was resolved pnor to the NRC's endorsenient of
The maintenance rule is a risk-informed, performance based regulation that requires
heensees to provide reasonable assurance that SSCs remain capable of performing their
intended functions. The NRC does not expect licensees to perform highly sophisticated,
ngorous analyses to demonstrate that rehability performance entena are mathematicahy
equivalent to the values used in PRAs. Rather. our expectation is that heensees provide a
reasonable and appropriate technical basis for selecting performance entena to meet the
regulat on. However, it is expected that such approaches would incorporate some
consideration of demands for standby systems and service time for normaHy operating
systems
Acceptable approaches exist for fir %ng performance levels to safety (nsk). Dunng the nine
pilot site visits performed to review early implementation of the maintenance rule, reviews of
the hcensees' goal- and performance critena-setting processes were performed. As stated
above, the inspectors found that hcensees did understand the issues related to developing
performance standards for reliability that were linked to safety. Several of those hcensee
programs described in significant detad the link to safety (nsk) and justified the use of
functional failures in the measure of SSC rehabihty. Therefore, the issue was not raised in
the inp reportr or meetings with NEl, since none existed.
In short, the NRC's posrtion has been, and is, that performance standctds - goals and
performance entena - must be demonstrably linked to safety, and our enforcement decisions
will continue to be made based on licensee comphance with 10 CFR 50.65.
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October 22, 1996
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As requested by your letter, a public meeting between the industry and the NRC was
arranged and held on Tuesday, October 15,1996, to discuss this issue. During that meeting.
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the staff and NEl agreed that additional guidance to the industry is warranted. On
October 16,1996, at an NEl workshop, discussions took place among industry participants to
propose approaches to solution of the issue for further consideration. I anticipate that
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guidance on this issue will be promulgated by NEl at the earliest possible time so as to give
those licensecs that may not currently have acceptable reliability performance criteria the
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basis for making the necessary adjustments in their programs.
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Sincerely,
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or181 mal signed by
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Trank J. Miraglia
Frank J. Miraglia
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Acting Director
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Office of Nuclear Reactor Regulation
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Enclosure: As statec
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cc:
Thomas E. Tipton
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Vice President. O&E Dept.
Nuclear Energy Institute (NEI)
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1776 Eye Street, N.W., Surte 300
Washington, D.C. 20006-370S
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THE REllABILITY PERFORMANCE STANDARD
NUMARC 93-01 defines reliability as "(a) measure of the expectation (assuming that the SSC
is availabic) that the SSC will perform its function upon demand at any future instant in time."
Numencally, for normally operating SSCs, reliabilrty is the complement of the ratio of the
expected number of failures to a given time of required performance. The ratio of functional
fa:!ures to a specified number of operating hours could be shown to describe a reliability level
that could be related to the plant-specific PRA/IPE/IPEEE or other nsk-determining analysrs.
Likewise, for standby SSCs, reliability is the complement of the ratio of the expected number
of failures to a given number of start demands and, once started, run demands. The ratio of
functional failures to a specified number of attempted starts and attempted runs could be
shown to desenbe a reliability level that could be related to the plant-spec:fic PRA/IPE/IPEEE
or other nsk-determining analysis
in four of the five maintenance rule baseline inspections conducted thus far, the licensees
used maintenance preventable functional failures (MPFFs) over time as their reliability
performance standard. For normally operating SSCs, that performance standard could be
acceptable if it desenbed a satisfactory relationship to plant-specific PRA/IPE/IPEEE or other
nsk-determining analysis. The onus is upon the licensee to demonstrate the satisfactory
nature of that relationship, and those four licensees had not done so
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More of a problem however, was their use of MPFFs over time as a performance standard
for standby SSCs. As desenbed above, the reliability calculation for ? e,tandby SSC must
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incorporate both failures and demands. All four licensees failed to incorporate demands in
their calculations and, therefore, used unacceptable performance standards, clearly not
demonstrating a relationship to plant specific PRA/IPEllPEEE or other nsk-determining
analysis.
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Enclosure
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E-Mail response to Richard Correia (RPC)
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L. J. Callan
Resident inspector
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Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
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G. F. Sanborn, EO
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DOCUMENT NAME: R:\\_CNS\\CN612AK. JEW
To receive copy of document, indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures ,"N" go,, copy
.
RIV:Rl:MB
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11/14/96
11/20/96
01/07/97
02/ L/97
02/q/97 ? 02/F97
02&I/ {
OFFICIAL RECORD COPY
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