View source for NLS2012127, Reply to Notice of Violation IR 05000298-12-004-02; EA-12-206

{{Adams
| number = ML12354A104
| issue date = 12/10/2012
| title = Reply to Notice of Violation IR 05000298-12-004-02; EA-12-206
| author name = O'Grady B
| author affiliation = Nebraska Public Power District (NPPD)
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/RGN-IV
| docket = 05000298
| license number = DPR-046
| contact person = 
| case reference number = EA-12-206, IR-12-004, NLS2012127
| document type = Letter type:NLS, Licensee Response to Notice of Violation
| page count = 7
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Nebraska Public Power District"Always there when you need us" NLS2012127 10 CFR 2.201 December 10, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

==Subject:==
Reply to Notice of Violation 2012004-02; EA-12-206 Cooper Nuclear Station, Docket No. 50-298, DPR-46 

==References:==
: 1. Letter to Brian J. O'Grady (Nebraska Public Power District) from Robert C.Hagar (U.S. Nuclear Regulatory Commission) dated November 9, 2012,"Cooper Nuclear Station -NRC Integrated Inspection Report 05000298/2012004 and Notice of Violation" 2. Letter to Brian J. O'Grady (Nebraska Public Power District) from Vince Gaddy (U.S. Nuclear Regulatory Commission) dated August 2, 2012, "Cooper Nuclear Station -NRC Integrated Inspection Report 05000298/2012003" 3. Letter to Brian J. O'Grady (Nebraska Public Power District) from Thomas R.Farnholtz (U.S. Nuclear Regulatory Commission) dated December 3, 2010,"Cooper Nuclear Station -NRC Component Design Bases Inspection Report 05000298/2010007" 

==Dear Sir or Madam:==
The purpose of this correspondence is to provide Nebraska Public Power District's (NPPD) reply to Notice of Violation (NOV) 2012004-02 (EA-12-206) in accordance with 10 CFR 2.201. By letter dated November 9, 2012, (Reference 1), the Nuclear Regulatory Commission (NRC) cited NPPD for being in violation of NRC requirements.
The NOV is concerned with Cooper Nuclear Station (CNS) failing to restore compliance within a reasonable time after non-cited violations were identified in previous inspection reports (References 2 and 3).NPPD recognizes the importance of its responsibilities with respect to timely identification and correction of significant deficient conditions and accepts the violation.
As discussed in the attachment to this letter, NPPD has developed corrective actions to restore compliance with 10 CFR Part 50, Appendix B, Criterion III, "Design Control." COOPER NUCLEAR STATION P.O. Box 98 /Brownville, NE 68301-0098 Telephone:
(402) 825-3811/
Fax: (402) 825-5211 http://www.nppd.com NLS2012127 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. r'dy Vice President 
-Nuclear and Chief Nuclear Officer/em 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 NLS2012127 Attachment Page 1 of 4 REPLY TO NOTICE OF VIOLATION 2012004-02; EA-12-206 COOPER NUCLEAR STATION DOCKET NO. 50-298, DPR-46 During Nuclear Regulatory Commission (NRC) inspection activities conducted June 26, 2012, through September 25, 2012, 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"10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2 and as specified in the license application, for those components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, from December 3, 2010, until August 30, 2012, measures established by the licensee failed to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2 and as specified in the licensee application, for those components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
Specifically, the licensee failed to assure that the emergency diesel generator starting air receiver was capable of providing sufficient air to perform multiple starts of the'emergency diesel generator without immediate replenishment, as described in USAR section 5.3.3.This violation is associated with a Green Significance Determination Process finding." Background NRC Component Design Bases Inspection Report 2010007 documented non-cited violation 2010007-04, "Inadequate Design Control," for the Cooper Nuclear Station's (CNS) failure to perform suitable pre-operational testing to ensure each starting air receiver was capable of multiple starts of the emergency diesel generator as required by the system design. CNS entered this deficiency into the corrective action program as Condition Report CR-CNS-2010-05294.
The following corrective actions were developed and implemented:
(1) CNS generated station calculation NEDC 11-072, Revision 0, "DGSA Accumulator Sizing Basis," to document that multiple starts were available from a single air accumulator in the starting air subsystem, and (2)CNS updated the Updated Safety Analysis Report and Technical Specification Basis based on the results from NEDC 11-072 to reflect that a single air accumulator was capable of providing sufficient air to perform multiple starts without immediate replenishment with pressure at least 200 psig in a starting air accumulator.
On April 30, 2012, inspectors reviewed NEDC 11-072 and the corrective actions documented in Condition Report CR-CNS-2010-05294.
During their review the inspectors noted that the calculation had been based on pre-operational testing data that had been performed with both NLS2012127 Attachment Page 2 of 4 accumulators in service at an average starting pressure of 239.5 psig, and the number of air starts performed was divided by two to determine the number of multiple starts with a single accumulator in service. The inspectors determined that this calculation was not adequate to demonstrate the station's design basis. Specifically, the calculation failed to demonstrate the ability of a single air receiver to perform multiple diesel generator starts from the required pressure.The inspectors informed CNS of their concerns and CNS initiated Condition Report CR-CNS-2012-03039 to capture this concern in the corrective action program. CNS subsequently performed an operability review and apparent cause evaluation.
Based on results of the operability review, CNS took an action to keep diesel generator starting air accumulators cross tied, which was already controlled by procedures, and to resolve the issue by either changes in NEDC 11-072 or the Updated Safety Analysis Report and Technical Specification Bases. The apparent cause evaluation initiated the following corrective actions: (1) revise NEDC 11-072 to establish the design basis for two diesel generator air accumulators based on the pre-operational test data multiple starts without replenishment and (2) revise the Updated Safety Analysis Report and Technical Specification Bases to reflect the requirements of two diesel generator starting air accumulators.
The inspectors had reasonable expectations that the emergency diesel generators could perform multiple starts on a single air accumulator.
CNS' failure to prepare an adequate design calculation demonstrating that a single diesel generator starting air accumulator was capable of performing multiple starts of an emergency diesel generator was a performance deficiency.
The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated objective to ensure availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences, and was therefore a finding. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, "Phase I-Initial Screening and Characterization of Findings." The inspectors determined that the finding was of very low safety significance (Green) because the finding: (1)was not a design or qualification issue confirmed not to result in a loss of operability or functionality, (2) did not represent an actual loss of safety function of system or train, (3) did not result in the loss of one or more trains of nontechnical specification equipment and (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event.The finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision making component because CNS failed to use conservative assumptions and conduct effectiveness reviews to validate the underlying assumptions when determining the number of multiple starts on one diesel generator starting air accumulator
[H. 1 (b)].10 CFR 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 nonconformance's are promptly identified and corrected." Contrary to the above, from July 2:3, 2010, to May 31, 2012, measures established by CNS failed to assure that an identified condition adverse to quality was corrected.
NLS2012127 Attachment Page 3 of 4 Specifically, CNS failed to prepare an adequate design calculation demonstrating that a single diesel generator starting air accumulator was capable of performing multiple starts of an emergency diesel generator.
Because the finding was of very low safety significance (Green)and had been entered into the CNS corrective action program as Condition Report CR-CNS-2012-03039, the violation was being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000298/2012003-13, "Fail to Correct a Condition Adverse to Quality for Determining the Number of Multiple Starts for a Single Diesel Generator Starting Air Accumulator." Reason for Violation NPPD accepts the cited violation.
It was identified on July 23, 2010 that CNS failed to perform adequate testing to ensure each starting air receiver was capable of multiple starts as required by the system design. On April 30, 2012, it was determined that the calculation performed to correct the identified condition failed to demonstrate the ability of a single air receiver to perform the required multiple starts.NPPD did not establish measures to assure the identified condition was promptly corrected.
This violation is cited because CNS failed to restore compliance in a reasonable time following documentation of the issue as a non-cited violation in NRC Inspection Report 05000298/2010007, issued December 3, 2010.Corrective Steps Taken and Results Achieved NPPD has taken the following actions: 1. Special Procedure SP 12-003, Diesel Generator Air Receiver Capacity Test, was performed on November 19, 2012. The results of this procedure demonstrate that a single Diesel Generator (DG)2 air receiver is capable of five (5) starts with the pressure initially at 200 psig. Two (2) successful starts were accomplished with the accumulator pressure below 125 psig. The Procedure results bound CNS Technical Specification Bases B 3.8.3.E. 1 requirements of a minimum of two (2) starts from 200 psig and at least one (1) start attempt from 125 psig.Upon completion of this testing, NPPD has a reasonable expectation that the Emergency Diesel Generators can perform multiple starts from a single air receiver.This action is complete.
NLS2012127 Attachment Page 4 of 4 Additional Corrective Steps That Will Be Taken 1. NPPD will complete a Special Procedure air start test on DG1 to demonstrate DG1 air receiver performance similar to Special Procedure SP 12-003 that was completed for DG2 on November 19, 2012 during RE27 and complete NEDC 11-072 Revision 1.NPPD will complete this action by May 31, 2013 in conjunction with the next scheduled DG1 maintenance outage.Date When Full Compliance Will Be Achieved Completion of the Additional Corrective Steps, by May 31, 2013, will establish NPPD's compliance.
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 (Check one) SCHEDULED COMMITMENT/COMMITMENT NO. ONE-TIME CONTINUING COMPLETION ACTION COMPLIANCE DATE NPPD will complete a Special Procedure X May 31, 2013 air start test on DG1 to demonstrate DG1 air receiver performance similar to Special Procedure SP12-003 that was completed for DG2 on November 19, 2012 during RE27 and complete NEDC 11-072 Revision 1.[NLS2012127-01]
EN-LI-106, Rev. 9C0, Attachment 9.3}}