ML20137D249
| ML20137D249 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/19/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS970051, NUDOCS 9703260104 | |
| Download: ML20137D249 (7) | |
Text
{{#Wiki_filter:__ '5 p.a.BoxTa%E"ttis n'c'a*E se2zi h -{ Nebraska Public Power District i "%"sP=i NLS970051 March 19,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 0001 Gentlemen:
Subject:
Additional Response to a Notice of Violation NRC Inspection Report No. 50-298/96-12 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from K. E. Brockman (USNRC) dated October 7,1996, "NRC Inspection Report 50-298/96-12 and Notice of Violation"
- 2. Letter to USNRC from P. D. Graham (NPPD) dated November 6,1996,
" Reply to a Notice of Violation, NRC Inspection Report No. 50-298/96-12, Cooper Nuclear Station, NRC Docket 50-298, DPR-46"
- 3. Letter to G. R. Horn (NPPD) from J. E. Dyer (USNRC) dated February 21, 1997, "NRC Inspection Report 50-298/96-12 and Notice of Violation" By letter dated October 7,1996 (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation of NRC requirements. In the reply dated November 6,1996 (Reference 2), the District denied Violations 9612-01 (third and fourth examples),9612-02,9612-03, and 9612-06. Following review of the District's reply, the NRC withdrew Violation 9612-06 but did not concur with the District's basis for denying the remaining violations in dispute.
Accordingly, by letter dated February 21,1997, the NRC requested the District provide an additional response detailing the corrective actions taken and the results achieved. This letter, including Attachment 1. constitutes the District's response to the remaining violations in accordance with 10 CFR 2.201. Should you have any questions concerning this matter, please contact me. Sincerely, PML 260008 g', P. D. Graham Vice President - Nuclear 9703260104 970319 ll[ll$ll[l*ll]l[lll*l[llll'[l-l PDR ADOCK 05000298 G PDR & $ $'$ $$ bI $ $b kl ? $ h w== = x3yg= s= = _ :
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_ ~ ' NLS970051 March 19,1997 Page 2 of 2 l i /crm Attachment -i l 'cc: Regional Administrator j USNRC - Region IV i Senior Project Manager I USNRC - NRR Project Directorate IV-1 I Senior Resident Inspector USNRC l j l NPG Distribution i i L l l I ) 1 i l i 1 I i i l-l J f 1 i
' Attacliment I to NLS970051 Page1 of4 ADDITIONAL RESPONSE TO OCTOBER 7,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from August 12,1996, through August 16,1996, six { violations of NRC requirements were identified. In the reply dated November 6,1996, the j District admitted to Violations 9612-01 (first and second examples),9612-04, and 9612-05 and denied Violations 9612-01 (third and fourth examples),9612-02,9612-03, and 9612-06. Following NRC review, Violation 9612-06 was withdrawn. However, the NRC did not concur I with the District's basis for denying the remaining violations in dispute and, by letter dated February 21,1997, requested the District provide an additional response detailing corrective actions taken and results achieved. The NRC's evaluation and the District's additional response to the remaining violations are set forth below: Violation A (9612-01) The licensee admitted the violation exceptfor two of thefour examples concerning thefailure to include requiredftmetions in the scope of the Maintenance Rule Program. IVith respect to thefirst and second examples, Nebraska Public Power District 's decision (andsubsequent corrective actions) to place the two examples ofFunctions RMV-F01 (facility radiation monitors) and RMP-F02 (air ejector offgas monitor) within the scope of the Maintenance Rule Program adequately addressed the concerns related to thesefunctions. IVith respect to the third example, Nebraska Public Power District 's response stated that a limited review ofindustry experience, going back 36 months, did not uncover any instances where afailure ofFtmetions AS-F04, F07, F013 and F014 (auxiliary steam system) residted in afailure ofa 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 desiredfunctional response ofsafety systems or nonsafety.pstems that support safety systems; also, it should not have been limited to a 36-month period. (See, for example, Oyster Creek event discussedin NRC SpecialInspection Report 50-219/88-02.) 1he violation example is, thus, sustained, and appropriate corrective action must be developed andimplemented. With respect to thefourth 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 sigmficantfraction 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 thefraction ofemergency operatingprocedures communications which would use the gaitronics
' Attac15 ment I to NLS970051 Page 2 of 4 communication system was approximately 20 percent. The response asserted that a 20 percent contribution to communicationftmetionperformance was not sigmpcant. However, neither the program nor the responsejustiped whatpercentage ofcontribution would be a sigmpcant contribution. 7herefore, there was no basisfor determining, quantitatively, whether the system should be includedin the scope of the Maintenance Rule. 7he violation example is, thus, sustained, and appropriate corrective action must be developed and implemented. i Corrective Actions Taken and Results Achieved
- 1. Case 3 (Functions AS-F04. AS-F07. AS-F13. AS-F14)
The Auxiliary Steam functions AS-F04, AS-F07, AS-F13 and AS-F14 have been included in the scope of the CNS Maintenance Rule Program (Program) under NUMARC 93-01 screening criteria four which includes nonsafety-related SSCs whose failure prevents safety-related SSCs from fulfilling their functions. These functions are monitored at the plant level with their performance criteria being defined as: "No failure of an in-scope function attributable to failure of the Auxiliary Steam system to maintain area temperature."
- 2. Case 4 (Function IC-F01)
Function IC-F01 has been redefmed and divided into two new functions. The first is IC-F01 (Gaitronics system components servicing plant operations) which is in scope of the Program under NUM ARC 93-01 screening criteria three which includes nonsafety-related SSCs that are used in Emergency Operating Procedures. The second function is IC-F05 (Gaitronics system components nm servicing plant operations) which is not in scope of the Program. Function IC-F01 is monitored at the plant level with its performance criteria being defined as: "No failure of an in-scope function attributable to failure of the Gaitronics system." Corrective Steps That Will Be Taken to Avoid Funber Violations No funher corrective actions are planned at this time. Date When Full Compliance Will Be Achieved The District has completed all corrective actions necessary to return CNS to full compliance with respect to the identified siolation.
\\ l ' Attachment 1 l to NLS970051 Page 3 of 4 Violation B (9612-02) The licensee denied the violation which identified afailure to adequately measure reliability of l functions. Nebraska Public Power District 's response concluded that the program method of measuring l reliability by using an absolute maintenance preventablefunctionalfailure valuefor i reliabilityperformance couldprovide trendable information directly linked to probabilistic l risk analysis assumptions. Additionally, the response stated that the position was similar to \\ the position stated by the Electric Power Research Institute during the October 16,1996, Nuclear Energy Instnute (NEI) Maintenance Rule Workshop. In a letter to the Senior Vice President and Nuclear Offcerfor Nuclear Generation, NEI, dated October 22,1996, the acting director of the Office ofNuclear Reactor Regulationprovided clarification on this issue. The enclosure to the letter, a document entided, "The Reliability Performance Standard, " reiterated the NRC'sposition on this issue. As a restdt of the unchanged NRC position on measuring reliabilityfor complying with the Maintenance Rule, this violation is, thus, sustained, and appropriate corrective action must be developed andimplemented. Corrective Actions Taken and Results Achieved The District has adopted a methodology in keeping with that described in EPRI Technical Bulletin J 96-11-01, " Monitoring Reliability for the Maintenance Rule," by which a quantitative relationship can be established between performance criteria and the Probabilistic Safety Assessment (PSA) data without requiring that the specific number of demands experienced by structures, systems and components (SSCs) be tracked. Accordingly, as part of the Maintenance Rule Program i Periodic Assessment (currently under way and scheduled to be completed by June 30,1997), the District is establishing performance criteria based on this methodology which compares the observed number of failures in an operating cycle to the probability of failure on demand used m j the PSA analysis. Date When Full Compliance Will Be Achieved Reliability performance criteria using the above described methodology will be developed for all risk significant functions by June 30,1997. l
l l to NLS970051 Page 4 of 4 Violation C (9612-03) I The licensee denied the violation which identified inadequate accuracy in measuring unavailabilityforfunctions associated withfcmr safety-related systems. Nebraska Public Power District 's denial of this violation was accompanied by a statement that a "reviseddefinition has been applied to thesefunctions and the unavailability values appropriately adjusted" by considering the position of the reactor head vent instead of the control rods. 1his change adequately addressed our specific concerns about the automatic depressuri:ation and high pressure coolant injection systems. However, it is not appropriate to construct availability demand time around the position of the reactor head ventforfamctions associated with the emergency dieselgenerators and the residual heat removal system. The times when these systems may be required tofunctionfor safety considerations are not necessarily associated with the position of the reactor head vent. Additionally, there may be generic implications related to other safetyfunctions not identified by the NRC team. This violation is, thus, sustained, and appropriate corrective action must be developed and implemented. Corrective Actions Taken and Results Achieved Procedure 0.27, " Maintenance Rule Program," has been revised to utilize data from the Outage Risk Assessment and Management (ORAM) program to determine when to accumulate unavailability during shutdown conditions. ORAM is used to monitor key outage safety functions (i.e., decay heat removal, inventory control, power availability, reactivity control and containment) utilizing the concept of defense in depth to assure that outage planning and scheduling activities are conducted to optimize safety system availability. It is further used to assure that these key safety functions are provided using redundant, alternate or diverse methods. As a result of this revision, all risk significant systems modeled by ORAM, including functions associated with the emergency diesel generators and the residual heat removal system, are monitored for unavailability during shutdown conditions. Date When Full Com_oliance Will Be Achieved The District has completed all corrective actions necessary to return CNS to full compliance with respect to the identifica violation. l
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- l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
+ e Correspondence No: NLS970051 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 Reliability performance criteria using a methoJology in keeping with that described in EPRI Technical Bulletin June 30, 1997 96-11-01 will be developed for all risk significant functions. i l 1 l 1 l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l}}