NLS2011070, Reply to a Notice of Violation
| ML11193A008 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/08/2011 |
| From: | O'Grady B Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-11-024, NLS2011070 | |
| Download: ML11193A008 (7) | |
Text
H Nebraska Public Power District Always there when you need us NLS2011070 10 CFR 2.201 July 8, 2011 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Reply to a Notice of Violation; EA-1 1-024 Cooper Nuclear Station, Docket No. 50-298, DPR-46
References:
- 1. Letter to Brian J. O'Grady (Nebraska Public Power District) from Elmo E.
Collins (U.S. Nuclear Regulatory Commission) dated June 10, 2011, "Final Significance Determination of White Finding and Notice of Violation, NRC Inspection Report 05000298/2011009, Cooper Nuclear Station"
- 2. Letter to Stewart B. Minahan (Nebraska Public Power District) from Roy J.
Caniano (U.S. Nuclear Regulatory Commission) dated June 13, 2008, "Final Significance Determination for a White Finding and Notice of Violation, NRC Inspection Report 05000298/2008008, 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 in accordance with 10 CFR 2.201. By letter dated June 10, 2011 (Reference 1), the Nuclear Regulatory Commission cited NPPD for being in violation of 10 CFR Part 50, Appendix B, Criterion V and Criterion XVI.
The violation is concerned with Cooper Nuclear Station failing to verify that procedure steps required to safely shut down the plant in the event of a fire would actually reposition three motor-operated valves to the required positions, while addressing a previous violation that involved the same procedure steps (Reference 2).
NPPD accepts the violation and recognizes the importance of its responsibilities with respect to maintaining and validating quality-related procedures and correcting conditions adverse to quality. As discussed in the attachment to this letter, NPPD has taken prompt action to return to compliance with 10 CFR Part 50, Appendix B, Criterion V and Criterion XVI, and has actions planned to prevent recurrence of this violation.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2011070 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, Brian J. O'Grady Vice President - Nuclear and Chief Nuclear Officer
/bk 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
NLS2011070 Attachment Page 1 of 4 REPLY TO A NOTICE OF VIOLATION; EA-1 1-024 COOPER NUCLEAR STATION DOCKET NO. 50-298, DPR-46 During Nuclear Regulatory Commission (NRC) inspection activities exited on March 14, 2011, and following a regulatory conference conducted on April 27, 2011, 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 "Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVI, "Corrective Actions," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Emergency Procedure 5.4 POST-FIRE, "Post-Fire Operational Information," Revision 37, and Emergency Procedure 5.4 FIRE-S/D, "Fire Induced Shutdown From Outside the Control Room,"
Revision 38, were designated as quality-related procedures used to implement operator actions to safely shutdown the plant in response to a fire.
Contrary to the above, between July 1997 and November 2010, the licensee failed to establish measures to assure a condition adverse to quality was corrected and ensure the activities affecting quality were prescribed by documented procedures appropriate to the circumstances.
Specifically, Violation 05000298/2008008-1, dated June 13, 2008, identified a condition adverse to quality in that Emergency Procedures 5.4 POST-FIRE and 5.4 FIRE-SD [sic] would not work as written. While correcting that violation, the licensee failed to perform sufficient evaluation of the circuits to identify and correct a problem with three motor-operated valves needed to establish core cooling, RHR-MOV-25A, RHR-MOV-25B and RHR-MOV-53A [sic]. Failure to correct the condition adverse to quality resulted in inadequate procedures in that they contained steps that were inappropriate to the circumstances because they would not work as written to reposition the three motor-operated valves.
This violation is associated with a White significance determination process finding."
NLS2011070 Attachment Page 2 of 4
Background
During the 2007 Triennial Fire Protection Inspection, May 21, 2007, through June 15, 2007, the NRC identified a condition related to the inability of Cooper Nuclear Station (CNS) operators to locally reposition several motor-operated valves (MOV) during or following certain fire scenarios in the reactor building in accordance with station procedures in place at that time.
After a follow-up inspection completed on March 18, 2008, the NRC preliminarily determined the significance to be greater than Green as stated in the NRC Triennial Fire Protection Follow-up Inspection Report letter dated March 19, 2008 (Reference 4).
A regulatory conference was held on May 13, 2008, between the NRC and NPPD to discuss the finding. Subsequently, the NRC determined the final significance for the 2007 Triennial Fire Protection inspection finding was White as stated in Reference 3. In this reference letter, NPPD was cited for violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," in that between 1997 and June 2007, CNS failed to ensure that two emergency operating procedures, which controlled activities affecting quality, were appropriate to the circumstances. Specifically, in 1997, CNS changed Emergency Procedures 5.4POST-FIRE, "Post Fire Operational Information," and 5.4FIRE-S/D, "Fire Induced Shutdown From Outside Control Room," to add steps that were inappropriate for the circumstances because they would not work as written. Additionally, CNS failed to properly verify and validate the procedure steps to ensure that they would work to accomplish the necessary actions.
From October 18, 2010, through November 5, 2010, the NRC conducted the 2010 Triennial Fire Protection Inspection. During this inspection, the NRC identified an apparent violation of 10 CFR Part 50, Appendix B, Criterion V and Criterion XVI, "Corrective Action," for the repeated failure to ensure that some steps contained in the same emergency procedures would work as written. The NRC determined the significance of this finding was preliminarily White as stated in the NRC Triennial Fire Protection Inspection Report letter dated March 17, 2011 (Reference 2). Specifically, steps in Emergency Procedures 5.4POST-FIRE and 5.4FIRE-S/D, intended to reposition MOVs at the motor starter cabinet, would not have worked as written because the steps were not appropriate for the configuration of the motor starters.
During the NRC's walkthrough of the procedures, the team expressed concern with the use of safety gloves worn by the station operators performing the required actions to reposition the MOVs in that they might not allow access to the recessed starter contactors. To address the NRC's concern, CNS personnel fabricated a non-conductive tool to allow station operators to manually actuate the motor starters using the tool to depress the contactor versus directly manipulating the contactor. CNS training personnel subsequently discovered, when developing a tailgate training session in support of the tool, that manual manipulation of one of the four types of starter contactors (Size 2 DC Siemens Model 3TC4817) would not result in electrical closure of the contact. Three MOVs with the Size 2 DC Siemens model contactor were affected; RHR-MOV-25A and RHR-MOV-25B, residual heat removal (RHR) loop 'A' and 'B' injection inboard isolation valves, and RR-MOV-53A, reactor recirculation (RR) 'A' pump discharge valve.
NLS2011070 Attachment Page 3 of 4 To demonstrate the ability to perform manual positioning of MOVs with motor starters other than the Size 2 DC Siemens model (three other types), CNS personnel fabricated a training mock-up. The mock-up utilized a power source connected to the supply side of each starter.
CNS personnel used the mock-up to perform multiple actuations of each starter. The starters operated as expected.
On April 27, 2011, a regulatory conference was held between the NRC and NPPD to discuss information related to the 2010 Triennial Fire Protection apparent violation. NPPD presented the station's risk assessment of the significance of the finding, the root cause, and corrective actions taken. The NRC subsequently concluded that the inspection finding was appropriately characterized as White as stated in Reference 1. In this reference letter, the NRC discussed the final results of the significance determination for the finding.
Reason for Violation NPPD accepts the cited violation.
CNS performed two evaluations utilizing root cause analysis and determined the causes to be:
" Insufficient guidance for identification and validation that design features for CNS Fire Protection Program credited manual actions have not been unintentionally altered.
" No developed protocol to physically validate assumptions embedded within Emergency Procedures 5.4POST-FIRE and 5.4FIRE-S/D.
Corrective Steps Taken and Results Achieved NPPD has taken the following actions:
" Revised Emergency Procedures 5.4POST-FIRE and 5.4FIRE-S/D to direct manual operation of the valves whose starters utilize Size 2 DC Siemens Model 3TC4817 starter contactors. These procedure changes are implemented.
" Revised applicable engineering procedures to include prompts to consider potential impact of the change on the functionality of design features associated with CNS Fire Protection Program manual actions. These procedure changes are implemented.
- Revised the station procedure for the procedure change process to include a protocol to verify that emergency or abnormal procedures, which do not have regular surveillances or tests, will work as described when called upon and that assumptions embedded within the procedures are valid. This procedure change is implemented.
These actions are complete.
NLS2011070 Attachment Page 4 of 4 Corrective Steps That Will Be Taken to Avoid Further Violations The corrective actions already taken discussed in the previous section and the corrective actions planned below will prevent recurrence of the violation:
" Execute validation protocol for Emergency Procedures 5.4FIRE-S/D and 5.4POST-FIRE to demonstrate that they work as described.
NPPD will complete this action by September 1, 2011.
" Develop and implement a modification for MOVs which are operated manually in support of safe and alternate shutdown to eliminate the need for station operators to depress contractor buttons and to provide direct feedback indicating that the contactor was successfully engaged.
NPPD will complete this action prior to startup from Refueling Outage 27.
Date When Full Compliance Will Be Achieved NPPD is currently in full compliance with 10 CFR Part 50, Appendix B, Criterion V and Criterion XVI.
References
- 1. Letter to Brian J. O'Grady (Nebraska Public Power District) from Elmo E. Collins (U.S.
Nuclear Regulatory Commission) dated June 10, 2011, "Final Significance Determination of White Finding and Notice of Violation, NRC Inspection Report 05000298/2011009, Cooper Nuclear Station"
- 2. Letter to Brian J. O'Grady (Nebraska Public Power District) from Anton Vegel (U.S. Nuclear Regulatory Commission) dated March 17, 2011, "Cooper Nuclear Station - NRC Triennial Fire Protection Inspection Report 05000298/2010006; Preliminary White Finding"
- 3. Letter to Stewart B. Minahan (Nebraska Public Power District) from Roy J. Caniano (U.S.
Nuclear Regulatory Commission) dated June 13, 2008, "Final Significance Determination for a White Finding and Notice of Violation, NRC Inspection Report 05000298/2008008, Cooper Nuclear Station"
- 4. Letter to Stewart B. Minahan (Nebraska Public Power District) from Roy J. Caniano (U.S.
Nuclear Regulatory Commission) dated March 19, 2008, "Cooper Nuclear Station - NRC Triennial Fire Protection Followup Inspection Report 05000298/2008007; Preliminary Greater Than Green Finding"
4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©4 Correspondence Number: NLS2011070 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 NPPD will execute validation protocol for Emergency Procedures 5.4FIRE-S/D and NLS2011070-01 September 1,2011 5.4POST-FIRE to demonstrate that they work as described.
NPPD will develop and implement a modification for MOVs which are operated manually in support of safe and alternate shutdown to Prior to startup from eliminate the need for station operators to NLS2011070-02 Refueling Outage 27 depress contactor buttons and to provide direct feedback indicating that the contactor was successfully engaged.
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