NLS2008068, Reply to a Notice of Violation for Failing to Perform Maintenance Affecting Performance of Safety-related Equipment with Written Procedures or Documented Instructions Appropriate to the Circumstances - NRC IR 05000298-08-002

Reply to a Notice of Violation for Failing to Perform Maintenance Affecting Performance of Safety-related Equipment with Written Procedures or Documented Instructions Appropriate to the Circumstances - NRC IR 05000298-08-002

ML082610225
Person / Time
Site:	Cooper
Issue date:	09/12/2008
From:	Minahan S Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-08-124, NLS2008068
Download: ML082610225 (6)

Text

IN Nebraska Public Power District "Always there when you need us" NLS2008068 10 CFR 2.201 September 12, 2008 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Reply to a Notice of Violation; EA-081724 Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

Letter to Stewart B. Minahan (Nebraska Public Power District) from Roy J.

Caniano (U.S. Nuclear Regulatory Commission) dated August 1, 2008, "Final Significance Determination for a White Finding and Notice of Violation - NRC Integrated Inspection Report 05000298/2008002 - Cooper Nuclear Station"

Dear Sir or Madam:

The purpose of this correspondence is to provide Nebraska Public Power District's (NPPD) reply to a Notice of Violation (NOV) in accordance with 10 CFR 2.201. By letter dated August 1, 2008 (Reference), the Nuclear Regulatory Commission (NRC) cited NPPD for being in violation of NRC requirements.

The violation is concerned with Cooper Nuclear Station (CNS)failing to perform maintenance affectingperformance of safety-relatedequipment with written procedures or documented instructionsappropriateto the circumstances.

The Reference discussed the performance deficiency associated with this violation and concluded the failure of inadequate instructions and procedures resulted in the failure of Diesel Generator 2 during testing on January 15, 2008.

NPPD recognizes the importance of its responsibilities with respect to identifying and correcting significant deficient conditions and accepts the violation. NPPD has taken prompt action to maintain compliance with 10 CFR Part 50, Appendix B, Criterion XVI, and to prevent recurrence of this violation.

COOPER NUCLEAR STATION P 0. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2008068 Page 2 of 2 If you have any questions concerning this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.

Sincerely, Stewart B. Minahan Vice President - Nuclear and Chief Nuclear Officer

/jf Attachment cc: Regional Administrator w/ attachment USNRC - Region IV Cooper Project Manager w/ attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ attachment USNRC-CNS NPG Distribution w/ attachment CNS Records w/ attachment

NLS2008068 Attachment Page 1 of 2 REPLY TO A NOTICE OF VIOLATION; EA-08-124 COOPER NUCLEAR STATION DOCKET NO. 50-298, LICENSE NO. DPR-46 During Nuclear Regulatory Commission (NRC) inspection activities completed on May 6, 2008, a violation of NRC requirements was identified. The violation and Nebraska Public Power District's (NPPD) reply are set forth below:

Restatement of the Violation TS 5.4.1.a requires that writtenprocedures be established,implemented, and maintained, covering the activities specified in Regulatory Guide 1.33, Revision 2, Appendix A, dated February1978. Regulatory Guide 1.33, Appendix A, Section 9(a), requires, in part, that maintenance affecting performance of safety-relatedequipment should be performed in accordancewith written procedures or documented instructions appropriateto the circumstances.

Contraryto the above, the licenseefailed to perform maintenanceaffecting performanceof safety-relatedequipment with written procedures or documented instructions appropriateto the circumstances. Specifically, (1) on December 29, 2000, during reassembly of electrical connections on Diesel Generator2, Work Order 003915 was not appropriateto the circumstances in that it did not include guidance to ensure that thread locking compounds or other measures would be utilized to ensure electricalconnections would not loosen during engine operation. Additionally, (2) since September 30, 1988, the licenseefailed to use procedures appropriateto the circumstancesfor performance ofperiodic electrical inspections to check the tightness of engine-mounted amphenol-type connections. Specifically, Maintenance Procedure 7.3.8.2, "DieselGeneratorElectricalExamination and Maintenance,"

inappropriatelyexcluded engine mounted componentsfrom the scope of electricalconnection tightness checks. The inadequate instructionsand procedure resulted in the failure of Diesel Generator2 during testing on January 15, 2008.

This violation is associatedwith a White SDPfinding.

Background

In December of 1995, the governor magnetic pickup (MPU) was found loose. Loctite 242 was sparingly applied to both MPU connections.

In December of 2000, Diesel Generator (DG) 2 relay tachometer and MPU were replaced.

Although no work was done on the connector, the connector would have to be removed to replace the MPU.

On January 15, 2008, DG2 was started from the Control Room for post maintenance work testing. Normal voltage and frequency levels were achieved and the unit ran for approximately 60 seconds, and then shut down. The shut down was caused by an intermittent connection in the relay tachometer speed sensing circuit.

NLS2008068 Attachment Page 2 of 2 Reason for Violation The root cause of the violation was inadequate controls to assure configuration and functionality on critical components. Additionally, insufficient worker attention was applied to correctly perform reassembly of the DG2 Relay Tachometer speed probe connector and a procedure did not provide specific connector identification to preclude improper disassembly of the wrong connector.

Corrective Steps Taken and Results Achieved Maintenance Procedure 7.3.28.5, "Amphenol-Type Threaded Connector and Assembly Fixture Instruction," was approved on August 8, 2008 and will provide control of the disassembly and reassembly of threaded Amphenol-type connectors.

This action is complete.

Corrective Steps That Will Be Taken to Avoid Further Violations

1. Provide training to appropriate craft personnel who use Procedure 7.3.28.5 and the lessons learned from the causal factors of this root cause.

2. Perform a walkdown to verify that amphenol-type connectors in the following risk significant systems are properly connected: Electrical AC power (essential power),

Electrical 125 and 250 VDC power, Nuclear Boiler Instrumentation, HPCI, RCIC, Service Water and RHR Service Water, RHR, RPS.

3. Develop a procedure(s) that provides direction for configuration control during maintenance for skill of the craft activities on safety related systems.

4. Provide training to appropriate maintenance personnel on the procedure(s) developed that provide direction for configuration control during maintenance for skill of the craft activities on safety related systems.

5. Perform a walkdown of the Diesel Generator Systems using sampling techniques. The walkdown will include a sample of past skill of the craft activities addressed by the procedure(s) developed to verify proper configuration control during maintenance for skill of the craft activities on safety related systems.

6. Revise Procedures 14.17.1, "DG-1 Annual Calibration," and 14.17.2, "DG-2 Annual Calibration," to provide the specific connector identifications.

Date When Full Compliance Will Be Achieved December 31, 2008

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@

Correspondence Number: NLS2008068 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only 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.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE Develop Maintenance Procedure 7.3.28.5, "Amphenol-Type Threaded Connector and Assembly Fixture Instruction" to provide control NLS2008068-01 Complete of the disassembly and reassembly of threaded Amphenol-type connectors.

Provide training to appropriate craft personnel who use Procedure 7.3.28.5 and the lessons learned from the causal factors of this root cause.

Perform a walkdown to verify that amphenol-type connectors in the following risk significant systems are properly connected: Electrical AC power (essential power), Electrical 125 and 250 NLS2008068-03 10/22/08 VDC power, Nuclear Boiler Instrumentation, HPCI, RCIC, Service Water and RHR Service Water, RHR, RPS.

Develop a procedure(s) that provides direction for configuration control during maintenance for NLS2008068-04 10/22/08 skill of the craft activities on safety related systems.

Provide training to appropriate maintenance personnel on the procedure(s) developed that provides direction for configuration control NLS2008068-05 during maintenance for skill of the craft activities on safety related systems.

Perform a walkdown of the Diesel Generator Systems using sampling techniques. The walkdown will include a sample of past skill of the craft activities addressed by the NLS2008068-06 10/31/08 procedure(s) developed to verify proper configuration control during maintenance for skill of the craft activities on safety related systems.

PROCEDURE 0.42 REVISION 22 PAGE 19 OF 27

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@

Revise Procedures 14.17.1, "DG-1 Annual Calibration," and 14.17.2, "DG-2 Annual NLS2008068-07 09/19/08 Calibration," to provide the specific connector identifications.

I PROCEDURE 0.42 REVISION 22 PAGE 20 OF 27