IR 05000298/1998022
| ML20204J013 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/19/1999 |
| From: | Marschall C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-98-22, NUDOCS 9903290240 | |
| Download: ML20204J013 (5) | |
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SUBJECT:
RESPONSE TO NRC INSPECTION REPORT 50-298/98-22
Dear Mr. Horn:
Thank you for your letter of Februaly 22,1999, submitting a response to our letter and
l Notice of Violation dated January 7,1999, involving the inadequacies in your implementation of the unauthorized modification review program. We find your reply responsive to the concerns raised in our Notice of Violation. As documented in NRC Inspection Report 60-298/98-22, we have verified that the examples of the v;olation have been entered into your corrective action program. This Severity Level IV violation was issued in a Notice of Violation prior to the
March 11,1999, implementation of the NRC's policy for treatment of Severity Level IV violations (Appendix C of the Enforcement Policy). Because this violation would have been treated as a noncited violation in accordance with Append.x C, it is being closed out in this letter.
Sincerely, b $.
Charles S. Marschali, Chief Project Branch C j
Division of Reactor Projects Docket No.:
50-298 License No.: DPR-46 cc:
John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 9903290240 990319 PDR ADOCK 05000298 G
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J. H. Swailes, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 B. L. Houston, Nuclear Licensing and Safety Manager Nebraska Public Power District P.O. Box 98 l
Brownville, Nebraska 68321 Dr. William D. Leech MidAmerican Energy j
907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303-0657 Mr. Ron Stoddard j
Lincoln Electric System
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1040 O Street P.O. Box 80869 Lincoln, Nebraska 68501-0869 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
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301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007
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Nebraska Public Power District-3-R. A. Kucera, Department Director of intergovernmental Cooperation Department of Natural Resources
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P.O. Box 176
- Jefferson City, Missouri 65102 Jerry Uhlmann, Director State Emergency Management Agency.
P.O. Box 116 Jefferson City, Missouri 65101 Kansas Radiation Control Program Director i
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DOCUMENT NAME: R:\\_.CNS\\CN822AK.DPL To receive copy of document, indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures 'N" - No copy RIV:SPE:DRP/CC)d/d'C:DRP/C D: ACES (b D:DRP
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OFFICIAL RECORD COPY l
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Nebraska Public Power District Nebraska's Energy Leader H
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NLS990011
February 22,1999
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U.S. Nuclear R.egulatory Commission flEGIONIV Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violation j
NRC Inspection Report No. 50-298/98-22 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 Reference:
1. Letter to G. (NPPD) from Ken E. Brockman (USNRC) dated January 7,1999, "NRC Inspection Report 50-298/98-22, Notice of Violation" 2. Letter from J. H. Swailes (NPPD) to Document Control Desk (USNRC) dated July 8,1998,"CNS Strategy for Achieving Engineering Excellence, Revision
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2" 3. Letter from J. H. Swailes (NPPD) to Document Control Desk (USNRC) dated
October 7,1998, " Plans for Monitoring Progress of the CNS Strategy for i
Achieving Engineering Excellence, Revision 2" 4. - Letter from P. D. Graham (NPPD) to Document Control Desk (USNRC) dated April 17,1997, " Reply to Notice of Violation, NRC Inspection Report No. 50-298/96-25" 5. Letter from L. J. Callen (NRC) to G. (NPPD) dated April 17,1996,
" Notice of Violation and Proposed Imposition of Civil Penalty" By letter dated January 7,1997 (Reference 1), the Nuclear Regulatory Commission (NRC) cited Nebraska Public Power District (District) as being in violation of NRC requirements. This response, including Attachment 1, constitutes the District's reply to the referenced Notice of Violation (NOV) in accordance with 10 CFR 2.201. The District's response to the NOV was originally due on February 8,1999, however, more time was required to determine the appropriate corrective actions and a submittal date of February 22,1999 was verbally approved Cooper Nudear Station-O7%
P.O Box 98/ BrownvoIIe, NE 68321-0098 Telephone: (402) 825-3811/ Fax: (402) 825-5211 http//www.nppd tom cgogogrm/4
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i iNLS990011
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February 22,1999 Page 2 of 3 by the NRC's Mr. David Loveless in a telephone conversation with Mr. Daniel Mangan,
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- Licensing Engineer, on February 4,1999.
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l This violation concerns the corrective action taken in response to a prior violation (Reference 5)
on the Main Steam tunnel blowout panels. The corrective action, committed to in Reference.4, was "to complete the review of the remainder of outstanding maintenance work requests (MWRs) and to disposition identified unauthorized modifications." To complete this corrective
- action, the District initiated an Unauthorized Modification (UM) project which was rpnducted l
between June,1996 and August,1998. The objective of this project was to ident:fy aiose plant l
changes which had been performed using a MWR.
The District accepts the violation and is currently in full compliance regarding the cited violation based on the following:
1. Corrective Actions taken by Cooper Nuclear Station (CNS) should ensure that modifications
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will be installed by the CNS Configuration Control procedures which properly document modifications in accordance with the requirements of 10CFR50.59 and the CNS Quality Assurance program.
2. None of the modifications, discovered and evaluated by the UM project, have been determined to be Unreviewed Safety Questions (USQs) nor deviations from the CNS design and licensing basis.
3. The conditions identified by the NRC during the UM project inspection are in the CNS
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corrective action program which will track them to resolution.
The District has concluded that the violation in Reference I resulted from a lack of project management and oversight and a lack of sufficient allocated resources for the project to achieve the required result. From a broad perspective, the District believes that the Strategy for Achieving Engineering Excellence (References 2 and 3) addresses corrective action as well as past engineering perfonnance issues while providing an integrated plan toward improvement and achieving overall effectiveness of the engineering ft: %n. The District would again like to emphasize its appreciation of and looks fyrward to t'
- ntinued open dialogue with the NRC as
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the Strategy progresses.
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NLS990011 February 22,1999 l
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Should you have any questions concerning this matter, please contact me.
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Sincerely,
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ohn H es Vice Presi t of Nuclear Energy
/dm Attachment cc: Regional Administrator USNRC - B gion IV Senior Project Manager USNRC -NRR Project Directoiate IV-1 Ser:)r Resident Inspector USNRC NPG Distribution
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Attachment I to NLS990011 Page1of5
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REPLY TO JANUARY 7,1999 NOTICE OF VIOLATION
- COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46
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During an Nuclear Regulatory Commission (NRC) inspection conducted on November 16 through December 8,1998, one violation (50-298/9822-01) of NRC requirements was identified.
This violation is a severity Level IV violation (Supplement 1) and requires a response pursuant to the provisions of10 CFR 2.201.
The violation and the District's reply are set forth below:
Violation (Supnlement 1YS0-298/9822-01)
10 CFR Part 50, Appendix B, Criterion XVIstates, " Measures shall be established to assure that conditions adverse to quality, such asfailures, malfunctions, depciencies, deviations, defective material and equipment, and nonconformances are promptly identiped and corrected. "
Contrary to the above, deviationsfrom theplant design basis identiped as a result of
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investigationsfollowing the issuance of Violation 50-298/9604-1013 were notpromptly corrected, in that the unauthorized modipcation reviewprogram, designed to identify and correct additional depciencies caused by an inadequate maintenance work order system, did not identify all unauthorized modipcations norproperly evaluate those identiped as the following two examples illustrate:
Licensee personnel completed the unauthorized modipcation reviewprogram on
August 31,1998. However, during the inspection, seven unauthorized modspcations were identiped by the team had not been identiped by the program.
Additionally, during the inspection, the team determined that seven items
determined by the program to involve unauthorized modifications were not
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properly evaluated and dispositioned.
Adminnion or Denial to Violation The District accepts the violation.
Renenn for Viointion This violation concerns the corrective action taken in response to the violation on the Main j-Steam tunnel blowout panels. The corrective action, committed to in Reference 4, was "to l
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Attachment 1 l
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. complete the review of the remainder of outstanding maintenance work requests (MWRs) and to disposition identified unauthorized modifications." To complete this corrective action, the District initiated an Unauthorized Modification (UM) project which was conducted between June,1996 and August,1998. The objective of this project was to identify those plant modifications which had been performed using only a MWR. The effort involved the review of 95,736 MWRs to determine those which were modifications and to disposition the modifications which resulted from this review. During the time period when the UM project was being conducted, there were a multitude of demands on the Cooper Nuclear Station (CNS) engineering staff and an unusually high turnover ofpersonnel in tu CNS eng incering organization.
The cause of the ineffective corrective action cited in this Notice of Violation (NOV) was the lack of effective and consistent project management and oversight of the project and also the insufficient allocation of resources to the UM project. This resulted in inadequate controls on the verification and validation of the project findings, both in the determination of the modifications and the disposition of these modifications once they had been found. In particular, the use of a method of dispositioning of a sizeable portion of the modifications, the " white paper" approach, L
involved the circumvention of existing design controls. This lead to improper dispositioning of I
some of the modifications.
l Corrective Stens Taken and the Reenits Achieved l
The number of engineering personnel at CNS has been substantially increased. The District has l
placed a high priority on hiring experienced engineers, supervisors, and managers.
l The engineering organization has implemented an engineering work management system that
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l allows engineering personnel to schedule activities and resource load their schedules so that the impact of adding emergent work can be evaluated and better control of the work and associated schedules can be maintained.
l The engineering strategy contains formalized project management training for selected i
engineering personnel. This training commenced February 8,1999. The strategy also includes management and supervisory training to improve the capabilities of the engineering management l
team. This action, in conjunction with those items listed in the Corrective Steps That Will Be
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Taken to Avoid Further Violations section below, vill resolve the lack of effective and consistent L
project management and project oversight discussed above.
l The District's evaluation of the NRC inspection team's, and the subsequent CNS audit team's findings, indicate that there are other potential modifications in the MWR population. However, the findings also indicate, in conjunction with the evaluation of the modifications reviewed by j
the UM project, that there is reasonable confidence that: a)there are no Unreviewed Safety j
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Questions (USQs) associated with these modifications, and: b) the safety significance of these j
modifications is low. This confidence is based on the fact that none of the modifications, found i
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Attachment I to NLS990011
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Page 3 of 5
. in the review of the entire MWR population (95,736), represented a USQ and that the safety
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significance of those found is low. Thus, there is a low correlation between the safety
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significance of the initiating problem (modification of the Main Steam (MS) tunnel blowout panels) and the safety significance of the modifications installed under the Maintenance Work
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Control processes between 1973 and 1996.
The violation on the MS blowout panels (Reference 5) stated that the resulting pressure in the steam tunnel during a postulated main steam line break "would have exceeded design and
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licensing safety analysis limits." The results of the MWR review demonstrate with, a reasonable
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confidence level, that none of the other modifications installed by the MWR process involved I
deviations from the CNS design and licensing basis. As implied by the above violation wording, a significant objective of the UM project was to determine if there were deviationr from the plant i
design basis resulting from the improper use of MWRs to install modifications. The results of the UM project and the subsequent NRC and District audits indicate that this particular UM project objective was successful.
Although the earlier CNS work control process had allowed " minor" modifications to be installed withcut the performance of 50.59 evaluations, CNS has validated, with a reasonable level of confidence, that the CNS work control process did not install plant changes which represented a USQ. The work control process had mechanisms in place that ensured that experienced and knowledgeable individuals would assess proposed work items and determine if
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a design change was required.
Criteria did exist on what constituted a modification prior to the revision to the work control procedures in 1996. Previous station procedures clearly defined "a change in the facility as
described in the USAR" but did not provide clear or explicit definitions or examples of what constituted a station modification. By failing to provide a clearer definition of what constituted a station modification CNS personnel had less guidance on what constituted a station modification.
L This resulted in modifications which had an effect on the plant configuration data base but, as
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evidenced by the modifications identified by the project, did not qualitatively affect the plant design basis. One exception to this is the MS blowout panels.
The District has reasonable confidence that no USQs exist in the population of MWRs based on the evaluation of the modifications that were found in the project review of the entire MWR population as discussed above. The substantial UM project effort to evaluate the current plant configuration and with the result that no USQs were found, indicates that further action to identify any remaining modifications in the MWR population would have minimal safety benefit.
The District has revised the Maintenance Work Control process to minimize the possibility of a
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modification being implemented using a MWR and thus not having an associated 10CRF50.59
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evaluation. The NRC UM Inspection Team confirmed that this revision is having the desired
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Attachment 1 to NLS990011 Page 4 of 5 effect in that their audit indicated that no modifications had been inappropriately installed using a MWR since the revision had been implemented.
Corrective Steps That Will Be Taken to Achieve Full Compliance The District is currently in full compliance regarding the cited violation based on the following:
1. Corrective Actions taken by CNS should ensure that modifications will be installed by the
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CNS Configuration Control procedures which properly document modifications in accordance with the requirements of 10CFR50.59 and the CNS Quality Assurance program.-
2. None of the modifications, discovered and evaluated by the UM project, have been determined to be USQs nor deviations from the CNS design and licensing basis.
3. The conditions identified by the NRC during the UM project inspection are in the CNS corrective action program which will track them to resolution.
Future Corrective Actions 1. The District performed additional sampling of MWRs to confirm the NRC's sampling results. Seven (7) additional MWRs were determined to be modifications and these items will be resolved in accordance with the CNS Corrective Action and Configuration Change Control Programs.
2. Seven (7) Problem Identification Reports (PIRs) have been issued for those MWRs determined by the NRC Inspection team to be modifications which had been overlooked by the UM project. These items will be resolved in accordance with the CNS Corrective Action and Configuration Change Control Programs.
3. Seven (7) PIRs have been issued for those modifications which the NRC Inspection team determined were not appropriately dispositioned by the UM project. These items will be resolved in accordance with the CNS Corrective Action and Configuration Change Control
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Programs.
4. The MWRs that are not presently in the electronic database will be entered into the system.
Design control procedures will be revised to require a review of the applicable MWRs to aid in detecting potential configuration discrepancies prior to installation of future design changes.
5. The Configuration Control process will be revised to require a field walkdown of those issues identified by the above MWR review for future proposed modifications. This will ensure that
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Attachment 1 to NLS990011 Page 5 of 5
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drawing errors that may exist due to improperly documented prior modifications will be corrected.
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6. Previously identified configuration discrepances identified by the UM project will be reviewed to ensure that the configuration discrepance has been properly resolved i
Correc*ive Steps That Will Be Taken to Avoid Further Viointions 1. Lessons learned from this project will be reviewed with CNS Senior Managers, Engineering Department engineers, supervisors and managers.
2. Major engineering projects will be reviewed to ensure that project management oversight and guidance provides for sufficient resources to complete the project and ensure that quality is-preserved.
3. A CNS procedure will be developed for the preparation of detailed project plans which will include provisions for project quality management.
Date When Full Compliance Will Be Achieved The District is currently in full compliance regarding this violation.
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
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Correspondence No: NLS990011 The following table identifies those actions committed to by the District in this 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 information and are not regulatory. commitments.
Please notify the NL&S Manager at Cooper Nuclear Station of
./ questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE Seven (7) Problem Identification Reports (PIRs) have been issued for those MWRs determined by the NRC Inspection team to be modifications which had been overlooked by the UM project. These items will be resolved in accordance NA with the CNS Corrective Action and Configuration Change Control Programs.
The District performed additional sampling of MWRs to confirm the NRC's sampling results. Seven (7) additional MWRs were determined to be modifications and these items NA will be resolved in accordance with the CNS Corrective Action and Configuration Change Control Programs.
Seven (7) Problem Identification Reports (PIRs) have been issued for those modifications which the NRC Inspection team determined were not approp Lately dispositioned by NA the UM project. These items will be resolved in accordance with the CNS Corrective Action and Configuration Change Control Programs.
The Configuration Control process will be revised to require a field walkdown of those issues identified by the MWR review for future proposed modifications. This NA will ensure that drawing errors that may exist due to improperly documented prior modifications will be corrected.
Lessons learned from the UM project will be reviewed with NA CNS Senior Managers, Engineering Department engineers, supervisors and managers.
Major engineering projects will be reviewed to ensure that project management oversight and guidance provides for sufficient resources to complete the project and NA ensure that quality is preserved.
A CNS guideline will be developed for the preparation of detailed project plans which will include provisions for project quality management.
The MWRs that are not presently in the electronic database will be entered into the system. Design control procedures will be revised to require a review of the applicable MWRs to aid in detecting potentially NA configuration discrepancies prior to installation of l
future design changes.
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 6 l
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l-l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
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Previously identified configuration discrepances identified by the.UM project will be reviewed to ensure A
that the configuration discrepance has been properly i
resolved
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 6 l
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