IR 05000298/1996012

Ack Receipt of 961106 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/96-12

ML20140D306
Person / Time
Site:	Cooper
Issue date:	04/16/1997
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 9704230130
Download: ML20140D306 (5)

Text

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NUCLEAR REGULATORY COMMISSION (

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~D * 611 RYAN PLAZA oRIVE, SulTE 400 b'

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G. R. Horn, Senior Vice President of Energy Supply Nebraska Public Power District ,

141415th Street Columbus, Nebraska 68601  !

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SUBJECT: NRC INSPECTION REPORT 50-298/96-12 AND NOTICE OF VIOLATION Thank you for your letters of November 6,1996, and March 19,1997, in response 7 to our letters and Notice of Violation dated October 7,1996, and February 21,1997. We

have reviewed your reply and find it responsive to the concerns raised in our Nutice of Violation. We will review the implementation of your corrective actions during a future  ;

inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, l

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pg Arthur T. Howell 111, Director j e Division of Reactor Safety Docket No.: 50-298 License No.: DPR-46  !

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cc:

John R. McPhail, General Counsel Nebraska Public Power District l

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P.O. Box 499 Columbus,' Nebraska 68602-0499  !

P. D. Graham, Vice President of j Nuclear Energy Nebraska Public Power District P.O. Box 98 k{

Brownville, Nebraska 68321

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Nebraska Public Power District -2-l B. L. Houston, Nuclear Licensing and Safety Manager  !

Nebraska Public Power District l l P.O. Box 98 I Brownville, Nebraska 68321 )

R. J. Singer, Manager-Nuclear l Midwest Power l 907 Walnut Street P.O. Box 657  ;

Des Moines, Iowa 50303 l

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Mr. Ron Stoddard Lincoln Electric System 11th and O Streets Lincoln, Nebraska 68508 Randolph Wood, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 Cheryl Rogers, LLRW Program Manager Environmental Protection Section Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Dr. Mark B. Horton, M.S. Director j Nebraska Department of Health '

P.O. Box 950070 j Lincoln, Nebraska 68509-5007 i

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Nebraska Public Power District -3-R. A. Kucera, Department Director of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 i Kansas Radiation Control Program Director i l

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Nebraska Public Power District -4-E-Mail report to T. Boyce (THB)

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Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/C) MIS System Branch Chief (DRP/TSS) RIV File Project Engineer (DRP/C)

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I DOCUMENT NAME: r:\_CNS\CN612ak2. JEW To receive copy of document, Indicate in box: "C" = Copy wrtho@ enclosures "E" = Copy with enclosures "N" = No copy

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DOCUMENT NAME: r:\_CNS\CN612ak2. JEW To receive copy, of document, indicate in box: "C" = Copy witho@ enclosures "E" = Copy with enclosures "N" = No copy

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\ Nebraska Public Power District " W h"" NLS970051 hr - -

March 19,1997 nb U

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U.S. Nuclear Regulatory Commission -_ , , , M 2 41997 L Attention: Document Control Desk j Washington, D.C. 20555-0001

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L cREGIONIV . T Gentlemen:

Subject: Additional Response to a Notice of Violation

NRC Inspection Report No. 50-298/96-12 Cooper Nuclear Station, NRC Docket 50-298, DPR-46

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Reference: 1. Letter to G. R. Horn (NPPD) from K. E. Brockman (USNRC) dated

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October 7,1996, "NRC Inspection Report 50-298/96-12 and Notice of

. Violation"

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2. Letter to USNRC from P. D. Graham (NPPD) dated November 6,1996,  ;

i " Reply to a Notice of Violation, NRC Inspection Report No. 50-298/96-12, I

Cooper Nuclear Station, NRC Docket 50-298, DPR-46"

3. Letter to G. R. Horn (NPPD) from J. E. Dyer (USNRC) dated February 21, 1997,"NRC Inspection Report 50-298/96-12 and Notice of Violation"

By letter dated October 7,1996 (Reference 1), the NRC cited Nebraska Public Power District

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(District) as being in violation of NRC requirements. In the reply dated November 6,1996 (Reference 2), the District denied Violations 9612-01 (third and fourth examples),9612-02,9612-

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03, and 9612-06. Following review of the District's reply, the NRC withdrew Violation 9612-06 but did not concur with the District's basis for denying the remaining violations in disput Accordingly, by letter dated February 21,1997, the NRC requested the District provide an

additional response detailing the corrective actions taken and the results achieved. This letter,

including Attachment 1, constitutes the District's response to the remaining violations in

accordance with 10 CFR 2.201.

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Should you have any questions concerning this matter, please contact me.

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Sincerely, PD A j P. D. Graham Vice President - Nuclear V

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NLS970051 }

March 19,1997  ;

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cc: Regional Administrator

- USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution l

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Attachment I to NLS970051 Page1 of4 ADDITIONAL RESPONSE TO OCTOBER 7,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from August 12,1996, through August 16,1996, six violations of NRC requirements were identified. In the reply dated November 6,1996, the District admitted to Violations 9612-01 (first and second examples),9612-04, and 9612-05 and denied Violations 9612-01 (third and fourth examples),9612-02,9612-03, and 9612-0 Following NRC review, Violation 9612-06 was withdrawn. However, the NRC did not concur with the District's basis for denying the remaining violations in dispute and, by letter dated February 21,1997, requested the District provide an additional response detailing corrective actions taken and results achieved. The NRC's evaluation and the District's additional response to the remaining violations are set forth below:

Violation A (9612-01)

The licensee admitted the violation exceptfor two of thefour examples concerning thefailure to include requiredfunctions in the scope of the Maintenance Rule Progra * With respect to thefirst andsecond examples, Nebraska Public Power District 's decision (and subsequent corrective actions) toplace the two examples ofFunctions RMV-F01 (facility radiation monitors) and RMP-F02 (air ejector offgas monitor) within the scope of the Maimenance Rule Program adequately addressed the concerns related to thesefunction * With respect to the third example, Nebraska Public Power District 's response stated that a limited review ofindustry experience, going back 36 months, did not uncover any instances where afailure ofFunctions AS-F04, F07, F013 andF014 (auxiliary steam system) resulted in afailure of a safety system. Your review should have attempted to identify events where failures of the auxiliary steam system at boiling water reactors challenged the operability or desiredfunctional response ofsafety systems or nonsafety systems that support safety systems; also, it should not have been limited to a 36-month period. (See, for example, Oyster Creek event discussed in NRC SpecialInspection Report 50-219/88-02.) The violation example is, thus, sustained, and appropriate corrective action must be developed andimplemente * With respect to thefourth example, Nebraska Public Power District 's decision to exchide Function IC-F01 (Gaitronics communication system)from the scope of the Meintenance Rule Program was based on the system not providing a sigmpcantfraction of the total functional ability required to mitigate core damage or radioactive release. The inspectors noted during the inspection that a survey was conducted which determined that thefraction of emergency operating procedures communications which would use the gaitronics

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Attachment I to NLS97005l Page 2 of 4 communication system was approximately 20 percent. The response asserted that a 20 l percent contribution to communicationfimction performance was not sigmficant. However, neither the program nor the responsejustified what percentage ofcontribution would be a sigmficant contribution. 1herefore, there was no basisfor determining, quantitatively, l whether the system should be included in the scope of the Maintenance Rule. The violation 1 example is, thus, sustained, and appropriate corrective action must be developed and implemente Corrective Actions Taken and Results Achieved 1. Case 3 (Functions AS-F04. AS-F07. AS-F13. AS-F14)

The Auxiliary Steam functions AS-F04, AS-F07, AS-F13 and AS-F14 have been included in l the scope of the CNS Maintenance Rule Program (Program) under NUMARC 93-01 ,

screening criteria four which includes nonsafety-related SSCs whose failure prevents safety- l

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related SSCs from fulfilling their functions. These functions are monitored at the plant level with their performance criteria being defined as: "No failure of an in-scope function attributable to failure of the Auxiliary Steam system to maintain area temperature."

2. Case 4 (Function IC-F01)

Function IC-F01 has been redefined and divided into two new functions. The first is IC-F01 (Gaitronics system components servicing plant operations) which is in scope of the Program under NUMARC 93-01 screening criteria three which includes nonsafety-related SSCs that are used in Emergency Operating Procedures. The second function is IC-F05 (Gaitronics system components not servicing plant operations) which is not in scope of the Progra Function IC-F01 is monitored at the plant level with its performance criteria being defined as:

"No failure of an in-scope function attributable to failure of the Gaitronics system."

Corrective Steps That Will Be Taken to Avoid Further Violations No further corrective actions are planned at this tim Date When Full Compliance Will Be Achieved The District has completed all corrective actions necessary to return CNS to full compliance with respect to the identified violatio . . -

Attachment I to NLS970051 Page 3 of 4 Yiolation B (9612-02)

1he licensee denied the violation which identifiedafailure to adequately measure reliability of function * Nebraska Public Power District 's response concluded that the program method ofmeasuring reliability by using an absolute maintenance preventablefunctionalfailure mluefor reliabilityperformance couldprovide trendable information directly linked to probabilistic risk analysis assumptions. Additionally, the response stated that the position was similar to the position stated by the Electric Power Research Institute during the October 16,1996, Nuclear EnergyInstitute (NEI) Maintenance Rule Workshop. In a letter to the Senior Vice President andNuclear Officerfor Nuclear Generation, NEI, dated October 22,1996, the acting director of the Office ofNuclear Reactor Regulationprovided clarification on this issue. 7he enclosure to the letter, a document entitled, "The Reliability Performance Standard, " reiterated the NRC'sposition on this issue. As a result of the unchangedNRC position on measuring reliabilityfor complying with the Maintenance Rule, this violation is, thus, sustained, and appropriate corrective action must be developed and implemente Corrective Actions Taken and Rnu_lts Achieved The District has adopted a methodology in keeping with that described in EPRI Technical Bulletin 96-11-01, " Monitoring Reliability for the Maintenance Rule," by which a quantitative relationship can be established between performance criteria and the Probabilistic Safety Assessment (PS A)

data without requiring that the specific number of demands experienced by structures, systems and components (SSCs) be tracked. Accordingly, as part of the Maintenance Rule Program Periodic Assessment (currently under way and scheduled to be completed by June 30,1997), the District is establishing performance criteria based on this methodology which compares the observed number of failures in an operating cycle to the probability of failure on demand used in the PSA analysi Date When Full Compliance Will Be Achieved Reliability performance criteria using the above described methodology will be developed for all risk significant functions by June 30,199 I.

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Attachment I to NLS970051 Page 4 of 4 ,

l Violation C (9612-03)

1he licensee denied the violation which identified inadequate accuracy in measuring unavailabilityforfunctions associated withfour safety-related system *

Nebraska Public Power District 's denial of this violation was accompanied by a statement that a " revised definition has been applied to thesefunctions and the unavailability values cypropriate!y adjusted" by considering the position of the reactor head vent instead of the control rods. This change adequately addressed our specific concerns about the automatic depressuri:ation and high pressure coolant injection system However, it is not appropriate to construct availability demand time around the position of the reactor head ventforftmetions associated with the emergency diesel generators and the residual heat removalsystein. The times when these systems may be required tofimctionfor safety considerations are not necessarily associated with the position of the reactor head vent. Additionally, there may be generic implications related to other safetyfunctions not identified by the NRC team. This violation is, thus, sustained, andappropriate corrective action must be developedandimplemente Corrective Actions Taken and Results Achieved Procedure 0.27, " Maintenance Rule Program," has been revised to utilize data from the Outage Risk Assessment and Management (ORAM) program to determine when to accumulate unavailability during shutdown conditions. ORAM is used to monitor key outage safety functions (i.e., decay heat removal, inventory control, power availability, reactivity control and containment) utilizing the concept of defense in depth to assure that outage planning and scheduling activities are conducted to optimize safety system availability. It is further used to assure that these key safety functions are provided using redundant, alternate or diverse method As a result of this revision, all risk significant systems mydeled by ORAM, including functions associated with the emergency diesel generators and the residual heat removal system, are monitored for unavailability during shutdown condition Date When Full Compliance Will Be Achieved The District has completed all corrective actions necessary to return CNS to full compliance with respect to the identified violatio , . _ - - _

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/ l ATTACHMENT 3 LIST OF NRC COMMITMENTS l ,

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Correspondence No: NLS970051_ )

The following table identii .4 those actions committed to by the District in this l document. Any other actions discussed in the submittal represent intended or  !

planned actions by the District. They are described to the NRC for the NRC's I information and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitment COMMITTED DATE COMMITMENT OR OUTAGE Reliability performance criteria using a methodology in keeping with that described in EPRI Technical Bulletin June 30, 1997 96-11-01 will be developed for all risk significant function I i

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i l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l