ML11255A192

Reply to Notice of Violation 05000298-11-006-05

ML11255A192
Person / Time
Site:	Cooper
Issue date:	09/07/2011
From:	O'Grady B Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-11-176, NLS2011091 IR-11-006
Download: ML11255A192 (6)

See also: IR 05000298/2011006

Text

N Nebraska Public Power District Always there when you need us NLS2011091

2.201 September

7, 2011 U.S. Nuclear Regulatory

Commission

Attention:

Document Control Desk Washington, D.C. 20555-0001

Subject: Reply to Notice of Violation 05000298/2011006-05;

EA-2011-176

Cooper Nuclear Station, Docket No. 50-298, DPR-46 References:

1. Letter to Brian J. O'Grady (Nebraska

Public Power District)

from Dr. Dale A.Powers (U.S. Nuclear Regulatory

Commission)

dated August 8, 2011,"Cooper Nuclear Station -NRC Problem Identification

and Resolution

Inspection

Report 05000298/2011006

and Notice of Violation" 2. 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 a Notice of Violation

in accordance

with 10 CFR 2.201. By letter dated August 8, 2011 (Reference

1), the Nuclear Regulatory

Commission

cited NPPD for being in violation

of 10 CFR Part 50, Appendix B, Criterion

III, Design Control.The violation

is concerned

with Cooper Nuclear Station failing to assure that applicable

regulatory

requirements

and the design basis were correctly

translated

into specifications, drawings, procedures

and instructions

within a reasonable

amount of time after a previous noncited violation (Reference

2) documented

the same issue.NPPD accepts the violation

and recognizes

the importance

of its responsibilities

with respect to design basis control. 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

III, and 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

NLS2011091

Page 2 of 2 If you have any questions

concerning

this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.Sinc rely, Brian J.O'Gra y 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

NLS2011091

Attachment

Page 1 of3 REPLY TO NOTICE OF VIOLATION 05000298/2011006-05;

EA-2011-176

COOPER NUCLEAR STATION, DOCKET NO. 50-298, DPR-46 During Nuclear Regulatory

Commission (NRC) inspection

activities

conducted

June 6 through June 24, 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 CFR 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, since December 3, 2010, the licensee failed to assure that applicable

regulatory

requirements

and the design basis were correctly

translated

into specifications, drawings, procedures, and instructions.

Specificallv, the licensee failed to correctly

translate regulatory

and design basis requirements, associated

with tornado and high wind generated missiles, into design information

necessary

to protect the emergency

diesel generator

fuel oil day tank vent line components.

This violation

is associated

with a Green Significance

Determination

Process finding." Background

During the 2010 Component

Design Bases (CDB) Inspection, conducted

July 21, 2010, to October 20, 2010, at Cooper Nuclear Station (CNS), NRC personnel

questioned

whether analysis existed for a postulated

tornado-induced

missile strike on the number one emergency

diesel generator's (EDG) fuel oil day tank vent line. The EDG fuel oil day tank vent lines at CNS are made of six-inch diameter, schedule 40 thick steel pipe. The vent lines run from each EDG's fuel oil day tank to outside of the EDG rooms, and extend upward along the exterior wall of the turbine building and terminate

at a vent cap. CNS determined

the current configuration

of the EDG fuel oil day tank lines acceptable

based on an original Bums and Roe civil design specification

which documented

the worst case for the tornado-induced

missile scenario;

i.e., impact of a wooden utility pole traveling

at 200 miles per hour. CNS did not have a formal design basis calculation

on record to support this conclusion

and initiated

a corrective

action to develop one.In the CDB Inspection

Report dated December 3, 2010 (Reference

2), the NRC documented

seven examples as a green noncited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for failure to establish

measures to ensure that applicable

regulatory

requirements

and the design bases were correctly

translated

into specifications, drawings, procedures, and instructions.

Reference

2 specified

that this finding applied to the tornado and high wind impact on the EDG fuel oil storage facilities.

NLS2011091

Attachment

Page 2 of 3 On December 14, 2010, CNS design engineering

completed

a calculation, and associated

engineering

evaluation, to evaluate a postulated

tornado-induced

missile impact on the EDG fuel oil day tank vent lines. The evaluation

concluded

that the existing EDG day tank vent lines were adequate after a postulated

tornado strike and able to provide venting.From June 6, 2011, to June 24, 2011, the NRC conducted

a Problem Identification

and Resolution

inspection

at CNS. During this inspection, the NRC noted that the design basis calculation

performed

in December 2010, and subsequent

revisions, contained

non-conservative

assumptions

related to net positive suction head and head loss, that could affect the outcome of the calculation.

CNS reviewed the calculation

and determined

additional

clarifying

engineering

analysis would be required to resolve the NRC's concern.In Reference

1 the NRC discussed

its review of the December 2010 calculation

and corrective

actions taken in response to the CDB Inspection

NCV, and concluded

that CNS had failed to restore compliance

within a reasonable

time after the NCV was identified

on December 3, 2010.Specifically, CNS failed to correctly

translate

regulatory

and design basis requirements, associated

with tornado and high wind generated

missiles, into design information

necessary

to protect the EDG fuel oil day tank vent line components.

Reason for Violation NPPD accepts the cited violation.

CNS performed

an evaluation

utilizing

root cause analysis.

The root cause team reviewed the December 2010 calculation, associated

engineering

evaluation, and subsequent

revisions.

The team identified

that the calculation

was inadequate.

When the December 2010 calculation

was being prepared, a decision was made by CNS engineering

supervision

to pursue the worst case approach;

i.e., assuming the EDG fuel oil day tank steel vent line would be flattened

and pinched off. The engineer assigned to prepare the calculation

was provided with this presumed result and was not tasked with determining

the result of the impact based upon the original design basis scenario.

Rather, the evaluation

attempted

to demonstrate

no adverse effect to EDG operation.

The root cause for the condition, cited in Reference

1, is underestimation

of the scope and task to address an NCV. In summary, CNS failed to resolve a design basis issue in a timely manner because an initial decision had been made by CNS engineering

supervision

to develop an operability

type evaluation.

This decision resulted in a calculation

that focused on addressing

the operability

of the vent pipe after impact, rather than generation

of the missing design basis analysis of the impact.Corrective

Steps Taken and Results Achieved CNS has performed

a new calculation

to evaluate the design basis tornado-induced

missile impact on the EDG fuel oil day tank vent lines. This calculation

is approved and implemented, and supersedes

the December 2010 calculation

and associated

engineering

evaluation.

NLS2011091

Attaclunent

Page 3 of 3 Corrective

Steps That Will Be Taken to Avoid Further Violations

The action described

above will prevent further violations

related to translating

regulatory

and design basis requirements

for tornado and high wind generated

missiles into design information

necessary

to protect the EDG fuel oil day tank vent line components.

Additional

Corrective

Actions CNS will deliver a case study of the decision making aspects of this issue to design engineering

supervisors.

CNS will also review calculation

assignments

in the civil engineering

department

made in the past 18 months to determine

if any were directed towards establishing

operability

rather than addressing

design basis.Date When Full Compliance

Will Be Achieved NPPD has restored compliance

with 10 CFR Part 50, Appendix B, Criterion

III.References

1. Letter to Brian J. O'Grady (Nebraska

Public Power District)

from Dr. Dale A. Powers (U.S.Nuclear Regulatory

Commission)

dated August 8, 2011, "Cooper Nuclear Station -NRC Problem Identification

and Resolution

Inspection

Report 05000298/2011006

and Notice of Violation" 2. 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"

ATTACHMENT

3 LIST OF REGULATORY

COMMITMENTSC

4 ATTACHMENT3

LIST OF REGULATORY

COMMITMENTSN4

Correspondence

Number: NLS2011091

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

NUMBER OR OUTAGE None-4- 4 PROCEDURE

0.42 REVISION 27 PAGE 18 OF 25