NLS2013061, Reply to Notice of Violation EA- 13-075

Reply to Notice of Violation EA- 13-075

ML13162A400
Person / Time
Site:	Cooper
Issue date:	06/06/2013
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk, NRC Region 4
References
EA-13-075, NLS2013061
Download: ML13162A400 (6)

Text

H Nebraska Public Power District Always there when you need us NLS2013061 10 CFR 2.201 June 6, 2013 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Reply to Notice of Violation EA- 13-075 Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

Letter to Oscar A. Limpias, (Nebraska Public Power District) from Ray L. Kellar (U.S. Nuclear Regulatory Commission) dated May 9, 2013, "Cooper Nuclear Station - NRC Problem Identification and Resolution Inspection Report 05000298/2013009 and Notice of Violation"

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 May 9, 2013, (Reference), the Nuclear Regulatory Commission cited NPPD for being in violation of 10 CFR Part 50, Appendix B, Criterion III.

The violation is concerned with Cooper Nuclear Station failing to assure that the applicable design basis requirements associated with the Standby Liquid Control (SLC) system test tank were correctly translated into plant procedures to ensure that the SLC system would be available following a design basis seismic event.

NPPD accepts the violation and recognizes the importance of its responsibilities with respect to correctly translating design basis requirements into plant procedures. As discussed in Attachment I to this letter, NPPD has taken prompt action to return to compliance with 10 CFR Part 50, Appendix B, Criterion III, and has actions planned to avoid further violations.

This letter contains one regulatory commitment, which is identified in Attachment 2.

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

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NLS2013061 Page 2 of 2 If you have any questions concerning this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.

ly, WSince Oscar A. Linas Vice President - Nuclear and Chief Nuclear Officer Jo Attachments: 1. Reply to Notice of Violation EA-13-075

2. List of Regulatory Commitments cc: Regional Administrator w/ attachments USNRC - Region IV Mr. Ray L. Kellar w/ attachments NRC - PE, Chief, Technical Support Branch Division of Reactor Safety Cooper Project Manager w/ attachments USNRC - NRR Project Directorate IV- I Senior Resident Inspector w/ attachments USNRC - CNS NPG Distribution w/ attachments CNS Records w/ attachments

NLS2013061 Page 1 of 3 REPLY TO NOTICE OF VIOLATION EA-13-075 COOPER NUCLEAR STATION DOCKET NO. 50-298, DPR-46 During Nuclear Regulatory Commission (NRC) inspection activities exited on March 28, 2013, 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 CFR Part50, Appendix B, CriterionIII, "DesignControl," requires,in part, that measures shall be establishedto assure that applicable regulatory requirementsand 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 translatedinto specifications, drawings,procedures, and instructions.

Contrary to the above,from May 10, 2012 through March 13, 2013, the licensee failed to establish measures to assure that applicable regulatory requirements and design basis, as defined in 10 CFR 50.2 and as specified in the license application,for components to which 10 CFR 50 Appendix B applies, were correctly translatedinto specifications, drawings,procedures, and instructions. Specifically, the licenseefailed to assure that the applicable design basis requirements associatedwith the standby liquid control system test tank were correctly translatedinto plantproceduresto ensure that the standby liquid control system would be availablefollowing design basis seismic event.

This violation is associatedwith a Green Significance DeterminationProcessfinding.'"

Background

NRC Information Notice (IN) 12-01 was issued on January 26, 2012. In response to IN 12-01, Cooper Nuclear Station (CNS) initiated a condition report and generated a prompt operability evaluation (Status 5 calculation) of the Standby Liquid Control (SLC) system, as stated in Reference 1, which determined that reasonable assurance of the SLC system operability existed.

Further evaluation of the condition report via the Corrective Action Program determined a design basis evaluation (Status I calculation) was needed to fully qualify the SLC tanks and establish a seismic design basis for these tanks.

The design basis evaluation, which was approved on February 28, 2013, concluded that the SLC test tank met seismic design requirements when empty.

During the 2013 Problem Identification and Resolution Inspection, the NRC walked down the SLC system to verify corrective actions taken to address the 2012 non-cited violation. During this walk down, the SLC test tank was discovered to be full. Following this observation, the test

NLS2013061 Page 2 of 3 tank was immediately drained, and a Standing Order to maintain the test tank drained and to declare the SLC system inoperable when the tank is filled for testing, was implemented.

CNS failed to implement procedures changes or compensatory actions to ensure the test tank was empty after approval of the design basis evaluation, thus failing to maintain seismic qualification of the SLC system, as cited in Reference 2.

Reasons for Violation NPPD accepts the cited violation.

It was identified on March 13, 2013, that CNS failed to implement procedure changes or compensatory measures after adoption of a new design basis calculation to ensure the SLC test tank was maintained empty.

This violation is cited because CNS failed to restore compliance of the seismic qualification of the SLC system within a reasonable amount of time after the violation was identified.

Corrective Steps Taken and Results Achieved NPPD has taken the following actions:

• Drained the test tank, thus immediately bringing CNS into regulatory compliance.

• Issued a Standing Order for Operations to maintain the tank empty; or if the tank is full to declare the SLC system inoperable. This Standing Order will ensure the test tank is maintained empty.

Corrective Steps That Will Be Taken to Avoid Further Violations The corrective action already taken discussed in the previous section and the corrective action planned below will be taken to avoid further violations:

1. Revise NEDC 13-010 to evaluate the SLC test and mixing tanks for seismic II/I.

NPPD will complete this action by October 10, 2013.

Date When Full Compliance Will Be Achieved NPPD is currently in compliance with 10 CFR Part 50, Appendix B, Criterion III, "Design Control" thru implementation of interim measures. Full compliance will be restored upon revision and implementation of NEDC 13-010.

NLS2013061 Attachment I Page 3 of 3 References

1. Letter to Brian J. O'Grady (Nebraska Public Power District) from Vince Gaddy (U.S. Nuclear Regulatory Commission) dated May 10, 2012, "Cooper Nuclear Station - NRC Integrated Inspection Report 05000298/2012002"

2. Letter to Oscar A. Limpias (Nebraska Public Power District) from Ray L. Kellar (U.S.

Nuclear Regulatory Commission) dated May 9, 2013, "Cooper Nuclear Station - NRC Problem Identification and Resolution Inspection Report 05000298/2013009 and Notice of Violation"

NLS2013061 Page 1 of I LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Nebraska Public Power District in this document. Any other actions discussed in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE COMMITMENT (Check one) SCHEDULED COMMITMENT N ONE- COMPLETION COMMITMENT NO. TIE CONTINUING DT TIME COMPLIANCE DT ACTION (If Required)

Revise NEDC 13-010 to evaluate the Standby Liquid Control test and mixing tanks for seismic II/I. X 10/10/13 NLS2013061-01