ML20138Q223
| ML20138Q223 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/20/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| Shared Package | |
| ML20138Q184 | List: |
| References | |
| NLS970010, NUDOCS 9703060215 | |
| Download: ML20138Q223 (7) | |
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P.O. BOX ROWNVLLE.
68321 Nebraska Public Power District "Tg=a" 1
NLS970010 January 20,1997 JM 2 4 m Director, Office of Enforcement U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Reply to a Notice of Violation; NRC Inspection Report No. 50-298/96-30; Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
Letter from Mr. J. E. Dyer (USNRC) to Mr. G. R. Ilorn (NPPD), dated December 20,1996, NRC Inspection Report 50-298/96-30 and Notice of Violation.
This letter, including Attachment 1, constitutes Nebraska Public Power District's (the District) reply to the referenced Notice of Violation in accordance with 10CFR2.201. Inspection Report 50-298/96-30 documented the results of an NRC inspection conducted between November 4-8, 1996, and December 4,1996, which focused on the regulatory and safety significance of a self-identified design flaw in the Reactor Core Isolation Cooling System and the practice of perf ming full core offloads during refueling operations at Cooper Nuclear Station (CNS).
The District admits to Violation A and feels that adequate documentation exists on the docket.
The District also admits to Violations B and C, alth=gh tbe un6ying issue of Violation B would have been better characterized as a failure to properly update the CNS Final Safety Analysis Report (FSAR) pursuant to the requirements of 10CFR50.71(e)(3). From this perspective, the District requests that the information contained in this submittal be considered as responsive to the concerns raised in the remaining aspects of URI 298/95-14-01. All corrective actions have been completed which were necessary to return CNS to full compliance with 10CFR50.59 and 10CFR50 P;>pendix B, Criterion III with regard to these two violations.
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- Should you have any questions concerning this matter, please contact my office.
i Sincerely, hh P. D. Graham j.
Vice President-Nuclear Energy i
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USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC - Cooper Nuclear Station i
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REPLY TO DECEMBER 20,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 i
During NRC inspection activities conducted from November 4-8,1996, and December 4,1996 i
three violations of NRC requirements were identified. Violation A did not require a response per the instructions in the referenced inspection report. Violations B and C are set forth below along 1
with the District's reply:
VIOLATION B J
"10 CFR 50.59(a)(1) states, in part, that a licensee may make changes in thefacility as described in the safety analysis report withoutprior Commission Approval unless the change
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involves a change in the TechnicalSpecifications incorporate in the license or an unreviewed i
safety question. 10 CFR 50.59(b)(1) states, in part, that the licensee shall maintain records of changes in thefacility, to the extent that these changes constitute changes in thefacility as described in the safety analysis, and that these records must include a written safety evaluation which provides the basisfor the determination that the change did not involve an unreviewed safety question.
"On October 20,1995, the licensee's FSAR. Section 8.5.6, stated, in part, that 'the residual heat remm'al (RHR) system can be intertied with the Fuel Pool cooling system sfrequired.
This capability increases the spentfuelpool cooling capacity in the event that such additional i
capacity is necessitated by removalfrom the core of an unusually large number offuel j
elements. The RHR system -fuelpool cooling system intertie is sized to remove an emergency heat load...from thefuelpool which corresponds tofull core off-loadingplus the batch of spentfuel discharged at the previous refueling outage. '
4 "In the NRC's safety evaluation supporting License Amendment 52 dated September 29,1978, j
it was indicated in Section 2.2 that the RHR cooling would be available when performingfull
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core offloads.
Toniary to the above, on October 20,1995, the licensee changed thefacility as described in i
L te safety enalysis report in that thefacility was not operated as described in the FSAR and a written safe 4 evaluation of the changefrom the FSAR had not been performed to determine whether thii change involved an unreviewed safety question. Specifically, the licensee was in the process qfperforming afull core of]Ioad, and the RHR system was not available to assist thefuelpool cooling system in removing what the FSAR characterized as an emergency 1
offload."
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Admission or Denial to Violation j
The District admits the violation.
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to NLS970010 Page 2 of 4 Reasons for Violation The Inspection Report discusses the chain of events during Reload 16 (RE-16). The fundamental chronology is as follows:
10/14/95 Reactor shutdown achieved.
i 10/19/95 Full core offload commences.
10/20/95 Core offload discontinued after 160 bundles (i.e., the " normal" heat load) were transferred.
10/22/95 Station Operations Review Committee approves the 10CFR50.59 Safety Evaluation associated with the Updated Safety Analysis Report (USAR) text changes for the Fuel Pooling Cooling and RHR Systems. The revised text clarified what the " normal" and " worst case" heat loads were at CNS, and specified that the RIIR Fuel Pool Cooling Assist lineup is placed in service to prevent the Spent Fuel Pool temperature from exceeding 150"F.
10/23/95 Based on the clarified USAR wording approved for incorporation in that USAR update cycle, full core offload recommenced.
10/27/95 Full core offload completed.
This violation was caused by the failure to accurately and unambiguously document the Current Licensing Basis for the Spent Fuel Pool Cooling System in the CNS USAR as provided for in 10CFR50.71(e). Specifically, the results of analyses submitted pursuant to Amendment 52 were not properly reflected during implemention of the FSAR update rule in 1982. While the USAR wording (as periodically updated) reiterated the assumptions and results of the rerack amendment analyses, it was ambiguous as to when RHR Fuel Pool Cooling Assist should be available when a greater decay heat removal capability existed than credited by the bounding analyses.
Accordingly, the requirements of 10CFR50.59 had not been carefully considered with respect to defueling practices.
Corrective Steps Taken and the Results Achieved A 10CFR50.59 Safety Evaluation was expedited which supported a change to the wording in the USAR. This USAR change more clearly articulated the Current Licensing Basis for the Fuel Pool Cooling System and the conditions under which RHR Fuel Pool Cooling Assist must be available. 'Ihis USAR change was transmitted to the NRC as part of the 1996 USAR update.
Corrective Steps That Will Be Taken to Avoid Further Violations No further corrective actions are needed to preclude future violations of 10CFR50.59 with regard to Spent Fuel Pool cooling issues. However, the District will be communicating its plans for ensuring the accuracy of USAR information in response to the NRC's Request For information of October 9,1996, pursuant to 10CFR50.54(f).
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I to NLS970010 Page 3 of 4 Date When Full Compliance Will Be Achieved The District is in full compliance with the requirements of 10CFR50.59 with respect to this Violation.
VIOLATION C
" Criterion III ofAppendit B to 10 CFR Part 50 requires that regulatory requirements and the design basis, as defined in 10 CFR 50.2 and as specified in the license application,for those structures systems and components to which the appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
"In the safety evaluation report which accompaniedAmendment 52 to thefacility operating license, the NRC staff acknowledged that the licensee's spentfuelpool and cooling systems were capable ofhandling the heat load associated with afull core discharge. However, this acknowledgment was based on certain design assumptions. In the Safety Evaluation Report, the staffstated that the maximumfuelpool heatload was associated with an offload that would occur 13 days after shutdown.
" Contrary to the above, the design basis assumption that the maximum heat load was associated withfull core discharge which was completed in 13 days was not translated into procedures. Procedure 2.3.2, ' Fuel Pool Cooling and Demineralizer System,' contained no administrative controls to ensure thatfuel was not loaded at a rate that would exceed the 13-day assumption. In October 1995, the licensee did exceed this offload rate. "
Admission or Denial to Violation The District admits the violation.
Reasons for Violation Violation B discusses the sequence of events during the beginning of RE-16. Based on the District's records, the 13-day offload criteria of Amendment 52 (time from reactor shutdown until completion oflast bundle transfer) was not exceeded as indicated in the text of the Violation and on page 7 of Enclosure 2 of the Inspection Report. Nevertheless, the District acknowledges that plant procedures did not specifically implement the analytical limitations associated with decay heat removal as submitted in Amendment 52.
This Violation was caused by the failure to clearly document the acceptability of the Station's operating practices for Spent Fuel Pool cooling with respect to the limitations of the 13-day defueling period. At CNS, the Spent Fuel Pool heat balance is monitored by a temperature recorder in the Control Room. Spent Fuel Pool temperature is logged by the Control Room staff every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If temperature would reach 125*F, Abnormal Procedure 2.4.8.6 would be entered which provides guidance for restoring or augmenting the existing Spent Fuel Pool cooling capability. Documentation did not exist that clearly justified this approwh relative to the bounding analytical values of the Amendment 52 correspondence.
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Corrective Steps Taken and the Results Achieved A 10CFR50.59 Safety Evaluation was performed which supported a change to the wording in the USAR. This USAR change reconciled the deterministically restrictive language of the 1
Amendment 52 submittals with the actual licensing basis of the Fuel Pool Cooling System. This USAR change was transmitted to the NRC as part of the 1996 USAR update. Procedure 2.2.32
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was revised to incorporate the operational controls needed to implement the revised USAR wording.
Corrective Steos That Will Be Taken to Avoid Further Violations i
l No further actions are required to prevent recurrence of this Violation.
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Date When Full Comoliance Will Be Achieved l
The District is in full compliance with the requirements of 10CFR50 Appendix B, Criterion III with respect to this violation.
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L LIST OF NRC COMMITMENTS ATTACHMENT 3 f
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Correspondence No:NLS970010 d-4 The following table identifies those actions committed to by the District in i
f this document. Any other actions discussed in the submittal represent l
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 j
this document or any associated regulatory commitments.
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i COMMITMENT COMMITTED DATE i
OR OUTAGE The District will be communicating its plans for ensuring 2/11/97 j
the accuracy of USAR information in response to the NRC's l
Request For Information of October 9, 1996, pursuant to j
l 10CFR50. 54 (f).
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l PROCEDURE NUMBER 0.42 REVISION NUMBER 2 PAGE 12 OF 16 1
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