ML20137G699

Responds to NRC Re Violations Noted in Insp Rept 50-298/96-24.Corrective Actions:Dcd Open Items Has Been Revised to Delineate Timeliness Requirement for District Review of Classification of DCD Open Items

ML20137G699
Person / Time
Site:	Cooper
Issue date:	03/27/1997
From:	Graham P NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS970055, NUDOCS 9704010477
Download: ML20137G699 (10)

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i P.O. BOX NEB 68321 Nebraska Public Power District *EL""*A"" j NLS970055 ,

March 27,1997 l U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washir.gton, D.C. 20555 0001 '

Gentlemen:

Subject:

Reply to a Notice of Violation l

NRC Inspection Report No. 50-298/96-24 '

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

Reference:

1. Letter to G. R. Horn (NPPD) from K. E. Brockman (USNRC) dated .

February 25,1997, "NRC Inspection Report 50-298/96-24 and Notice of Violation" By letter dated February 25,1997 (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 Notices of Violation in accordance with 10 CFR 2.201. The District admits to the violations and has completed all corrective actions necessary to return CNS to full compliance. 9 The referenced letter also requested the District to confirm its commitment to complete the  !

existing plan to correct and update site setpoint calculations and associated scaling documents.

Accordingly, all Level 1 and 2 setpoluts (as defined in Procedure 3.26, " Instrument Setpoint and Meter Banking Control"), and their associated calculations, will be reviewed and updated by December 31,1997.  :

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

Sincerely, P. D. Graham Vice President - Nuclear f

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NLS970055 March 27,1997 Page 2 of 2 cc: Regional Administrator  !

USNRC - Region IV Senior Project Manager USNRC - NPR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution l

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Attachment I to NLS970055 t Page 1 of 7 j REPLY TO FEBRUARY 25,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 l 1

During NRC inspection activities conducted from October 7,1996, through February 19,1997, three violations of NRC requirements were cited by letter dated February 25,1997. The particular violations and the District's reply are set forth below:

Violation _4 10 CFR 50, Appendix B, Criterion XI7, " Corrective Action, " requires that measures he established to assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, on or about June 1995, potential conditions adverse to quality identified by a contractor 's review of the licensee 's design criteria documents were not identified as conditions adverse to quality until December 20,1996. For example:  ;

1. Technical Specification 3.9.A. J.h and the associatedsurveillance requirementfor ensuring ,

adequate supply ofemergency dieselgeneratorfuel did not ensure a sufficientfuel oil supply to meet the safety design basis specifiedin USAR Section Vill-5.2.7, " Standby AC Power Source, Safety Design Basis. "

2. 1he si:ing calculationfor the automatic depressuri:ation system accumulators included non-conservative assumptions that did not assure that the accumulators would support the safety famction of the main steam relief valves.

1his is a Severity Levelll' violation (Supplement 1) (50-298/9624-09)

Admission or Denial to Violation The District admits the siolation.

Reason for Violation As documented in Problem Identification Report (PIR) 2-06128 written October 8,1996, it was discovered that 87 design criteria document (DCD) open items identified in 1995 during a comractor's verification and validation effort were " lost" due to a lack of process control by the vendor and the District. Following discovery, these open items were screened, entered into a

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. i Attachment 1 to NLS970055 Page 2 of 7 1

DCD open item data base, and classified as Category 3,4, or 5 As a result of an extensive 8

search of the vendor's DCD working files to bound the scope of this condition, an additional 30 open items were discovered. Of these 30, eleven were originally recommended by the vendor as a Category 1 or 2 classification level. On November 6,1996, these eleven items were entered into the open item data base and an evaluation initiated to validate the classification as provided for in Procedure 3.32.10, "DCD Open Items." On December 19,1996, PIRs 2-07827 and 2-07309 were written to document the two examples cited by this violation.

The " lost" open items were as a result of a breakdown in the administration of the DCD project during the mid-1995 time frame. Some of the subject open items were never fonnally transmitted to the District; others were transmitted but were not recognized as such because an undefmed numbering scheme had been adopted by the vendor without District approval. Once identified, the delay from November 6,1996, to December 19,1996, was a result of weaknesses in Procedure 3.32.10 "DCD Open Items." Specifically, the procedure did not establish expectations for the timely completion of the evaluation to validate the classification proposed by a vendor.

Corrective Steps Taken and the Results Achieved i

As noted above, as a result of the initial discovery, an extensive search of the vendor's DCD l working files was done to bound the scope of this condition. An additional 30 open items were l discovered. These open items have been processed in accordance with Procedure 3 32.10,"DCD Open Items," and operability issues addressed as required. Currently, of the 117 open items  ;

identified,35 have been formally closed with the remaining 82 in various stages of closure. The l remaining open items will be closed by June 30,1997.

The organizational weaknesses discussed above were corrected by the eng' m eering reorganization which was also initiated during the 1995 time frame. As a result of the reorganization, the temporary DCD pioject team was replaced by permanent staff within the Configuration Management Engineering Group. Additionally, the DCD project guidelines were replaced with l formally approved and controlled station procedures.

Finally, Procedure 3.32.10, "DCD Open Items," has been revised to delineate the timeliness requirements for District review of the classification of DCD open items proposed by a vendor.

i Procedure 3.32.10, "DCD Open Items," provides for the screening of DCD open items, their classification according to safety significance, and tracking. Upon confirmation that an actual discrepancy does exist, items classified as Category 1 or 2 are also entered into the corrective action program via the PIR 1rocess. Open items assigned a Category 3,4, or 5 classification have no safety significance and aie tracked to closure via the DCD open item data base. Once a PIR is initiated on an open item, the corresponding open item data base entry is closed.

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4 4 Attachment I to NLS970055 Page 3 of 7 Corrective Steps That Will Be Taken to Avoid Further Violations No additional corrective actions are planned at this time.

Date When Full Compliance Will Be Achieved The District is in full compliance with respect to the cited violation.

Violation Il TechnicalSpecification 6.3.2 requires, inpart, that writtenprocedures be establishedand implementedfor emergency conditions involvingpossible releases ofradioactive materials.

Contrary to the above:

1. As ofNovember 1,1996, Emergency Operating Procedure 5.8.8, " Alternate Baron injection and Preparation, " Revision 3, had been establishedfor emergency conditions involving possible releases ofradioactive materials. However, the procedure was inadequate because itfailed to provide appropriate instructions to ensure that adequate space was available in the reactor vessel when the reactor core isolation cooling system was utili:edfor alternate ,

boron injection, i

2. As ofNovember 1,1996, [ Station] Operating Procedure 2.2.69.2, "RHR lresidualheat removal] System Shutdown Operations, " Revision 19, was being usedfor emergency conditions involvingpossible releases ofradioactive materials. However, the procedure failed to provide appropriate instructions to ensure that design basis baron concentrations would not be compromised during an anticipated Imnsient without scram event.

3. As ofNovember 1,1996, [ Station] Operating Procedure 2.2.69.2, "RHR [ residual heat removal] System Shutdown Operations, " Revision 19, was being usedfor emergency conditions involvingpossible releases ofradioactive materials. However, the procedure

failed to provide appropriate instructions to ensure that the containment of radioactive l materials would not be compromised during an anticipated transient without scram event ir a l design basis accident.

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1his is a Severity LevelIV violation (Supplement Vill) (50-298/9624-07)

Admission or Denial to Violation The District admits the violation.

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Ittachment I to NLS970055 l Page 4 of 7 ILeason for Violation l

The reason for this violation is focused in two areas. The first element involves the initial review I and implementation of Design Change (DC)90-001, "RCIC Alternate Baron Injection." A '

retrospective review of this modification determined that the safety analysis and design basis sections failed to accurately present the operating strategy used for alternate baron injection with l RCIC under failure-to-scram conditions. Specifically, the DC describes a worst case scenario  ;

where reactor pressure vessel (RPV) level is lowered and controlled at or near the top of active i fuel (TAF) to accommodate boron injection via RCIC. This is not totally correct; in actuality, RPV level is lowered to reduce power and protect primary containment integrity per the Level  ;

Power Control strategy presented in Revision 4 of the Boiling Water Reactor Owners' Group '

(BWROG) Emergency Procedure Guideline (EPG) document. As a result of this inaccuracy, an 1 inconristency was introduced between Emergency Operating Procedure (EOP) 5.8.8, " Alternate Boron Injection and Preparation," and the design basis strategy documented in the DC. I l

The second element of this violation is reflected in the second and third examples cited and is considered to be a programmatic weakness which may be common to the non-emergency  ;

procedures used to implement EOP strategies. In general, these procedures existed prior to  !

development of the EOPs. When adapted to implement or augment an EOP strategy, they were validated using a symptom - action philosophy which did not focus on the EOP goal or factors that should be considered (i.e., the non-emergency procedures used to support the EOPs were not  !

revised to reflect the EOP strategy beir.g implemented or the EOP related factors to be considered). Instead, these considerations were communicated and reinforced during EOP l classroom and simulator training. This is considered a weakness in that the operators executing an EOP strategy using non-emergency procedures during emergency conditions may focus on the steps to be performed and neglect underlying considerations such as boron inventory control or the release of radioactive materials. This element is considered extremely important given the fact that these procedures may not address every contingency during an emergency and that certain steps or actions may be altered by the Emergency Response Organization (ERO) during recovery operations.

Corrective Steps Taken and the Results Achipyed EOP Procedure 5.8.8, " Alternate Boron Injection and Preparation," and Station Operating Procedure (SOP) 2.2.69.2, "RHR System Shutdown Operations," have been revised to address the specific concerns of this violation.

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Attachment 1 to NLS970055 Page 5 of 7 Corrective Steps That Will Be Taken to Avoid Further Violations Design Criteria Document (DCD) 18,"RCIC System," will be revised or augmented as required to reflect the correct EOP strategy as established by Revision 4 of the BWROG EPG. This action will be completed by June 27,1997.

The design change process was revised in 1991 to formally include an EOP review in the checklist used for the development of modification packages. Had this review been in place at the time DC 90-001 was reviewed and approved, the inconsistency introduced by its approval would have been detected.

To address the programmatic weakness common to the second and third cited examples, non-emergency procedures used within the EOPs will be reviewed and revised as required to reflect EOP considerations such as boron inventory control or the release of radioactive materials.

Resulting procedure revisions will be implemented by July 25,1997.

Date When Full Compliance Will Be Achieved The District is in full compliance with respect to the cited violation.

Violation C Technical Specification 6.3.1, " Introduction, " requires that station personnel shall be provided ,

detailed written procedures to be usedfor maintenance ofsystem components and systems that could have an effect on nuclear safet)

Ik chnical Specification 6.3.3.C, " Maintenance and 11st Procedures, " states that procedures l will be providedforpreventive or corrective maintenance ofplant equipment and syster:s that 1 cordd have an a[fect on nuclear safety.

Maintenance Procedure 7.2.55.2, "HCUSCRAM l'alve Operator Diaphragm Replacement, "

Revision 2, requires that scram valve mounting assembly capscrews be torqued to 240 in-lbs.

Contrary to the above, licensee personnel did notfidly use Maintenance Procedure 7.2.55.2, in that, on or about November 21,1996, one capscrew on each of the mounting bracketsfor Inlet Scram Valve CRD-AO-CV126 and Oudet Scram Valve CRD-AO-CV127 on Hydraulic Control Unit 3h'-23 were not torqued to 240 in-lbs.

1his is a Severity Level IV violatwn (Siqqdement I) (50-29W9624-06) l

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dttachment I to NLS970055 Page 6 of 7 Admission or Denial to Violation  ;

The District admits the violation as clarified below.

I Reason for Violation l The pneumatically operated inlet and outlet scram valves are mounted to the hydraulic control unit (HCU) assembly via an "L" shaped bracket. The bracket is attached to the HCU assembly via two horizontal capscrews. The valve is attached to the bracket by two vertical capscrews that also serve as part of the closure bolting for the diaphragm case and actuator assembly. I Specifically, the diaphragm case is attached to the actuator assembly by 24 capscrews, of which l two are longer to facilitate mounting to the bracket. These 24 capscrews (which includes the two f

longer mounting capscrews) are secured with nuts that are torqued to 240 in-lbs, prior to l mounting the valve assembly to the bracket. (Steps 8.1.8.10 through 8.1.8.12 of Procedure 7.2.55.2, Revision 2, detail the above described assembly and torquing actions following diaphragm replacement.) Once the diaphragm case is reassembled, the two longer capscrews are placed through the bracket and secured with a flat washer, locking washer, and nut. Per the vendor manual, the bracket nuts are to be torqued to 225 in-lbs. (Procedure 7.2.55.2, Revision 2, is silent on torquing or tightening the bracket nuts.)

Since the nuts found to be loose were the bracket nuts (i.e., those not detailed by Procedure 7.2.55.2), the cited violation is not correct in stating that licensee personnel did not fully use Maintenance Procedure 7.2.55.2. As documented in Maintenance Work Request (MWR) 95-2241, the 24 diaphragm nuts were torqued to the required 240 in-lbs. Ilowever, the District l acknowledges that Procedure 7.2.55.2, Revision 2, did not provide for the installation of the i bracket nuts as further discussed below.

Upon investigation, it was determined that, in some cases, misalignment exists such that the i bolting faces of the valve diaphragm case, actuator assembly and mounting bracket are not parallel I (i.e., there is little or no gap at one of the mounting capscrews while a significant gap may exist at the other capscrew location). Consequently, if the capscrew having the least amount of gap is torqued or tightened first, the preload achieved is diminished when the capscrew having the larger gap is torqued or tightened. That is, if the misalignment is of suflicient magnitude, the torque i applied to the capscrew having the smaller gap will not produce enough force to draw the bolting faces parallel and a gap of smaller proportion will still exist. Then, when the second capscrew is tightened and the bolting faces are drawn parallel, the gap remaining from the first capscrew will be closed, thus reducing the preload originally applied. Depending upon the magnitude of misalignment, this reduction in preload will result in one nut being tight and one being loose as observed and documented in the cited violation.

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Corrective Steps Taken and the Results Achieved

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l Immediate corrective actions were taken to visually inspect the remaining scram valves for loose bracket nuts. One loose bracket nut was found on the Outlet Scram Valve on HCU 42-27 and addressed via PIR 2-10538.

l To prevent recurrence, Procedure 7.2.55.2,"HCU SCRAM Valve Operator Diaphragm l Replacement," has been revised to require the horizontal mounting bracket capscrews be loosened l

prior to torquing the bracket nuts described above. (This action will ensure any misalignment that j

, may exist is eliminated prior to torquing the bracket nuts.) Additionally, while the installed lock l washers will maintain preload if fully compressed, the procedure has also been revised to specify a l bracket nut torquing value. I l

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! Corrective Steps That Will Be Taken to Avoid Further Violations The bracket nuts on all scram valves will be verified and/or retorqued as required to meet the vendor specified 225 in-lb value prior to restart from the 1997 Refueling Outage.

1 I Date When Full Compliance Will Be Achieved The District is in full compliance with respect to the cited violation.

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,, l ATTACHMENT 3 LIST OF NRC COMMITMENTS l Oorrespondence No: NLS970055 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 tr, 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 Level 1 and 2 setpoints (as defined in Procedure 3.26,

" Instrument setpoint and Meter Banking Control"), and December 31, 1997 their associated calculations, will be reviewed and updated.

The remaining 82 DCD open items currently in various June 30, 1997 stages of closure will be closed by June 30, 1997.

Design Criteria Document (DCD) 18, "RCIC System," will be revised or augmented as required to reflect the correct June 27, 1997 EOP strategy as established by Revision 4 of the BWROG EPG.

Tt address the programmatic weakness common to the second and third cited examples of Violation 9624-07, non-emergency procedures used within the EOPs will be reviewed and revised as required to reflect EOP July 25, 1997 considerations such as boron inventory control or the release of radioactive materials.

The bracket nuts on all scram valves will be verified Prior to restart from and/or retorqued as required to meet the vendor specified the 1997 Refueling 225 in-lb value. Outage i

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l l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l J