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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217G7401999-10-14014 October 1999 Forwards MOR for Sept 1999 for Cooper Nuclear Station. Rept Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20216J8061999-09-20020 September 1999 Forwards Rev 37 to Safeguards Plan,Iaw Provisions of 10CFR50.(p).Rev Withheld,Per 10CFR73.21 ML20212C4921999-09-15015 September 1999 Forwards Monthly Operating Rept for Aug 1999 for Cooper Nuclear Station.Rept Includes Operating Data Rept,Unit SD Rept & Documentation of Challenges to Safety/Relief Valves ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211N5271999-09-0202 September 1999 Responds to NRC 990823 RAI Re Y2K Readiness at Cooper Nuclear Station,Per GL 98-01,Suppl 1 05000298/LER-1999-006, Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl1999-08-26026 August 1999 Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl ML20211F1311999-08-24024 August 1999 Forwards Rev 1 to Calculation Nedc 97-044, NPSH Margins for RHR & CS Pumps, in Support of 990615 Proposed Amend to DPR-46 Re Containment Overpressure Contribution to ECCS Pumps NPSH Requirements 05000298/LER-1999-003, Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel1999-08-23023 August 1999 Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20210R0301999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Cooper Nuclear Station,Iaw Guidance Provided by GL 97-02.Rept Also Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6761999-08-10010 August 1999 Requests That Following Changes Be Made to Distribution on NRC Correspondence ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K6071999-08-0202 August 1999 Submits Withdrawal of Proposed License Amend Re Secondary Containment Isolation Description & Refueling Accident Analysis Results ML20210K3811999-08-0202 August 1999 Forwards Listed Info,Which NPPD Believes Demonstrates Ability to Obtain Funds in Amount of $10 Million for Payment of Such Premiums within Specified Three Month Period,Iaw 10CFR140.21 ML20210G5101999-07-28028 July 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 990101-0630,per Provisions of 10CFR26.71(d) ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20209B7851999-07-0101 July 1999 Forwards Corrected Occupational Radiation Exposure Repts, for Cys 1996 & 1997.Util Stated That Repts Did Not Properly Tabulate Number of Personnel Receiving Exposures Less than 100 Mrem by Work & Job Functions in CY96 & CY97 05000298/LER-1999-005, Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl1999-07-0101 July 1999 Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, 05000298/LER-1999-004, Forwards LER 99-004-01.Commitments Made by Util Are Encl1999-06-28028 June 1999 Forwards LER 99-004-01.Commitments Made by Util Are Encl ML20209B5451999-06-28028 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196H0331999-06-24024 June 1999 Informs NRC of Deletion of 1991 Commitment Contained in Ltr Re Feedwater Nozzle Bypass Leakage Monitoring at Plant ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20209A7221999-06-23023 June 1999 Submits Revised Pages to Proposed Change to Plant TS Previously Submitted in ,Per 990615 Telcon with NRC ML20196F5331999-06-22022 June 1999 Forwards Examination Summary Rept for FW Nozzle Examinations Performed During 1998 Fall Refueling Outage at Cooper Nuclear Station.Rept Covers Past Examinations Up to & Including 1998 Fall Refueling Outage ML20196B4681999-06-17017 June 1999 Forwards TS Bases Changes Made at Plant Subsequent to Receipt of License Amend 178,dtd 980731,for Conversion to Its,Through 990610.List of Effective Pages for TS Bases, Encl ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195H8891999-06-14014 June 1999 Forwards Response to NRC 990315 RAI Re GL 95-07, Pressure Locking & Thermal-Binding of SR Power-Operated Gate Valves, 180-day Response Submitted by District on 960213 ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20195E2351999-06-0808 June 1999 Forwards Response to NRC 990517 RAI Re Util Proposed Change to TS Re Calibr Frequency of Reactor Recirculation Flow Transmitters Associated with APRM ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations 1999-09-30
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations ML20206Q6171999-05-17017 May 1999 Forwards RAI Re 990301 & 10 Ltrs Re Proposed TS Changes to Calibr Frequency of Recirculation Flow Transmitters from Once Every 184 Days to Once Every 18 Months.Util Responses Should Be Provided within 30 Days of Ltr Date ML20206P0171999-05-12012 May 1999 Discusses GL 96-05 Issued on 960918 & NPPD Responses Submitted on 961118,970317,980504 & 990222 for Cooper Nuclear Station.Forwards Safety Evaluation Concluding That NPPD Adequately Addressed Actions Requested in GL 96-05 IR 05000298/19980091999-05-12012 May 1999 Refers to Insp Rept 50-298/98-09 Conducted Between 981227-990130.During Insp,Apparent Violation of 10CFR50.50 Identified & Being Treated as non-cited ML20206M1791999-05-11011 May 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328. Reorganization Chart Encl ML20206H4191999-05-0707 May 1999 Informs That on 990407,NRC Administered Gfes of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However,Copy of Master Exam with Answer Key,Encl for Info.Without Encl ML20206P8961999-05-0707 May 1999 Refers to Meeting Conducted at Region IV Office on 990506 Re Licensee Upcoming Rev to Strategy for Achieving Engineering Excellence & Plans to Achieve Performance Improvements.List of Attendees & Util Presentation,Encl ML20206H7541999-05-0505 May 1999 Forwards Insp Rept 50-298/99-01 on 990207-0320.Violations Being Treated as non-cited Violations ML20205R5541999-04-16016 April 1999 Submits Summary of 990330 Public Meeting in Brownville,Ne to Discuss Results of PPR Completed on 990211,which Allowed for Exchange on New Assessment Process,Current Performance Review & Upcoming Actions Taken in Response to Y2K Concerns IR 05000298/19980221999-03-19019 March 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/98-22 on 990107.Finds Reply Responsive to Concerns Raised in NOV ML20205E8991999-03-19019 March 1999 Advises of Completion of Plant Performance Review on 990209 to Develop Integrated Understanding of Safety Performance. Overall Performance Was Acceptable.Problems with Communication in CR Resulted in Several Minor Events ML20204D9451999-03-18018 March 1999 Forwards Insp Rept 50-298/98-09 on 981227-990206.Three Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20207M9591999-03-15015 March 1999 Forwards Request for Addl Info Re Licensee Response to GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20204B6771999-03-15015 March 1999 Submits Withdrawal of Amend Request for Operating License DPR-46.Proposed Change Would Have Modified Facility TSs Pertaining to Neutron Monitoring Neutron Detectors ML20207M9811999-03-15015 March 1999 Advises That Which Withdrew 980415 Amend Request, Being Treated as Withdrawal.Proposed Change Would Have Modified Facility TSs Pertaining to Neutron Monitoring,Flow Biased Rod Block Monitor ML20204B3301999-03-11011 March 1999 Forwards SE Accepting Third 10-year Interval Inservice Insp Program Plan Requests for Relief Numbers RI-13,RI-17 & RI-25 for Plant ML20204B7061999-03-11011 March 1999 Requests Approval of Proposed Operability Criteria for Use in Evaluation & Interim Resolution of Degraded & Nonconforming Conditions with Piping & Pipe Supports at Facility ML20205A5811999-03-0909 March 1999 Forwards Exam Rept 50-298/99-301 for Exam Administered on 990212.Exam Included Evaluation of Four Applicants for Reactor Operator License ML20207K3231999-03-0808 March 1999 Discusses 990224 Meeting Re Staff Critique of Refueling & Equipment Outage RE-18 & Implementation Status of Improvement Strategy for Engineering.List of Attendees & Matl Used in Presentation Encl ML20202G1701999-02-0202 February 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam at Util Facility on 990407.Authorized Representative from Facility Must Submit Ltr Listing Names of Candidates ML20202E3121999-01-22022 January 1999 Forwards Insp Rept 50-298/98-08 on 981115-1226 & Notice of Violation.First Violation Re Staff Failure to Follow Procedures (Two in Operations,One in Maint & One in Plant Support) ML20199G6041999-01-19019 January 1999 Informs That Effective 990118,JN Donohew Has Assumed NRC Project Mgt Responsibility for Cooper Nuclear Station ML20199E1521999-01-0707 January 1999 Forwards Insp Rept 50-298/98-22 on 981116-1208 & Notice of Violation Re Lack of Effective Oversight by Plant Mgt 1999-09-30
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Inspection Report - Cooper - 1993008 |
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[g ] NUCLEAR REGULATORY COMMISSION i REGION IV
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Docket: 50-298 License: DPR-46 Nebraska Public Power District ATTH: Guy R. Horn, Vice President - Nuclear .
P.O. Box 98 Brownville, Nebraska 68321 Gentlemen:
SUBJECT: MANAGEMENT MEETING ON OCTOBER 8, 1993, IN REGARD TO NRC INSPECTION REPORT 50-298/93-08 This refers to the meeting conducted at your request in the Region IV office on October 8, 1993. This meeting related to initiatives you were taking to improve your motor-operated valve program and was attended by those.on the attached Attendance Lis The subjects discussed at this meeting are described in the enclosed Meeting !
Summar It is our opinion that this meeting was beneficial and has provided a good understanding of your plans to address those shortcomings identified by NRC during NRC Inspection 50-298/93-08 conducted in September 1993. Your response and implementation effectiveness will be reviewed and evaluated by NRC during a future inspectio In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Roo Should you have any questions concerning this matter, we will be pleased to i discuss them with yo l
Sincerely, GiuM
. Co~TTins, Director Division of Reactor Safety ;
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Enclosure:
Meeting Summary w/ attachments cc w/ enclosure: (see next page)
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Nebraska Public Power District -2-cc w/ enclosure:
Nebraska Public Power District ATTH: G. D. Watson, General Counsel P.O. Box 499 Columbus, Nebraska 68602-0499
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Nebraska Public Power District ATTN: Mr. David A. Whitman P.O. Box 499 Columbus, Nebraska 68602-0499 Nebraska Department of Environmental Control *
ATTN: Randolph Wood, Director ,
P.O. Box 98922 Lincoln, Nebraska 68509-8922
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Nemaha County Board of Commissioners ATTN: Larry Bohlken, Chairman Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 Nebraska Department of Health ATTN: Harold Borchert, Director Division of Radiological Health 301 Centennial Hall, South P.O. Box 95007 Lir.coln, Nebraska 68509-5007 Kansas Radiation Control Program Director l
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Nebraska Public Power District -3-l bcc to DMB (IE01)
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J. L. Milhoan Resident Inspector Section Chief (DRP/C) Lisa Shea, RM/ALF, MS: MNBB 4503 HIS System DRSS-FIPS Section Chief (DRP/TSS) Project Engineer (DRP/C)
RIV File Senior Resident Inspector - River Bend Senior Resident Inspector - Fort Calhoun ,
M. Runyan T. Westerman
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Nebraska Public Power District -3-bec to DMB (IE01)
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J. L. Milhoan Resident Inspector Section Chief (DRP/C) Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS <
Section Chief (DRP/TSS) Project Engineer (DRP/C)
RIV File Senior Resident Inspector - River Bend -
Senior Resident Inspector - Fort Calhoun ;
M. Runyan T. Westerman
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o l MEETING SUMHARY Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station License No.: DPR-46 Docket No.: 50-298 Subject: Motor-operated Valve Program Initiatives
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The licensee presented a summary of actions planned in response to the findings of NRC Inspection Report 298/93-08. The presentation included a summary of general conclusions, discussion of a planned reorganization of the motor-operated valve project, a summary of root causes and corrective actions related to the violations in the subject report, discussion of a planned refocusing of quality assurance in this area, and comments related to the inspection followup items identified during the inspectio Attachments: Attendance List Licensee Presentation (NRC distribution only)
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ATTACHMENT 1 l
ATTENDANCE LIST
Attendance at the management meeting between Nebraska Public Power District 1 and NRC on October 8,1993 in NRC Region IV:
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NPPD G. R. Horn, Vice President, Nuclear J. M. Meacham, Site Manager R. E. Wilbur, Division Manager of Nuclear Engineer ing and Construction V. L. Wolstenholm, Division Manager of Quality Assurance K. A. Almquist, MOV Project Manager G. R. Smith, Manager of Nuclear Safety and Licensing ERIN E. Simbles NRC J. L. Milhoun, Regional Administrator S. J. Collins, Director, Division of Reactor Safety (DRS)
A. T. Howell, Acting Deputy Director, Division of Reactor Projects (DRP)
T. F. Westerman, Section Chief, DRS M. F. Runyan, Reactor Inspector, DRS W. B. Jones, Project Engineer, DRP i
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AGENDA Introduction / J. Meacham Summary of Conclusions MOV Project Management R. Wilbur Summary of Violations K. Almquist Root and Contributing Causes Corrective Actions QA Program Oversight V. Wolstenholm Discussion of Other Inspection Issues K. Almquist Closing Remarks J. Meacham
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BTRODUCTION The purpose of this meeting is to:
e Address Issues Raised During the Recent Generic Letter 89-10 Inspection
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Focus on root cause(s) of deficiencies
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Provide a summary of actions taken and to be taken
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Demonstrate the overall adequacy of Cooper ~MOV Program H
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NRC INSPECTION RESULTS e Four Strengths
- Four Potential Violations e One Unresolved Item
- Ten Inspection Follow-Up Items l
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SUMMARY OF CONCLUSIONS
- The MOV Project effort has been responsive to GL 89-10 concerns
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Strengths include assumption conservatism, design basis review calculations, aggressive test program, and torque and thrust measurement during diagnostic testing
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Procedure deficiencies are unacceptable to manageme.ut, however, GL 89-10 efforts have been effective, as will be demonstrated during the presentation
- Oversight of MOV activities by the project organization must be improved to ensure that issues are appropriately addressed
- Engineering judgements for the MOV Project have been generally correct -
documentation of bases forjudgments must be auditable
- Quality Assurance oversight must be improved to better provide a " safety net" M .
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MOV PROJECT MANAGEMENT HISTORY
- Significant MOV work as a result of IE Bulletin (IEB) 85-03
- Plan developed to use existing CNS organi7ation
- NRC Phase I inspection results indicated that CNS was on the right track H
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MOV Project Functional Organization m oi" *
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Site Osganisation NPCD Hanages
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Larry Kohles
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.(HOV Testins Project Manager
. Activltles) Een Almquist
'. Progree $1te (Remaining Program Activities)
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Supa rvisor _ _ _ , . _ _ _ _ _ . _ .
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Cost and Superviso Scheduling Speel li st s
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Program Development
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Electalcal Support Nuclear 1. l c e n s i ns Haintenance Engineering -
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Project Support
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Servlees Palmary Consultant utganisatiou
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Construction Hanagement ERIN Project Hausger HudtlicatLons Deslan Enstneers
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Hodification EitIN Psoject Modifications Suppest Installation . Orgenlaatton Support
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Not e s s hullJ aeporting !!aes indicate funettonal Intesteces, Dasbe,I reporting lines indfeste communleation and coosdinatten luterisce _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ .
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Revised MOV Project Organization
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Site Organization NPCD Manager CNS Maintenance Manager 1 (Mthe Unruh) .
Project Manager Ken Almquist ;
i I Cost and . NED Managers &
Scheduling Specialists Supervisors Project Enstneer -
-- ltthe Tumicht J. Steiner/K. Wemhoff Consultant
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Program Site Project Secretary Quality Assurance ji Supe rviso r '
Nora Dingman Electrical Engineering - Val Rathke I
- Support D. McManaman/J. Hackney /D. Buman
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CNS OperatLons Nuclear Licensing Program Development !
Supporr Support & Safety I'
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- Support Using Outside Assistance (M. Bennett)
B. Kochanovier (Full Time) .
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Project Support Services 5. Harsh (Part Time)
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Civ11 Enstneering I
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Design Engineers Construction Management ERIN Program Manager
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Art Ulese C. Bean Craig Sellers Special Assignment i I Diagnostic Testing & Analysts Contract ERIN Froject
- Supervisor Modification Organisation L. Briley - Consultant Installation Support
. NOTES: Solid reporting lines indicate functional interface . Dashed reporting lines indicate consuunleation and coordination interface , - - . . .. .
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MOV PROJECT IMPROVEMENTS
- Centralized project management
- Improved project overview (better coordination of efforts)
- Improved auditability M-A.-__---+ _ _ - - -- . _ _ _ _ _ _---__-_- - - _ _ - _ _ _ - _ - _ . - _ _ _ _
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SUDIARY OF POTENTIAL VIOLATIONS 10 C.F.R. Part 50. Appendix B Criterion III - Design Control Inadequate formulation of target windows and acceptance criteria, and trace evaluation Criterion V - Procedures Inadequate procedures for controlling extrapolation, errors outside of calibration range, and evaluation of trace point 010 extrapolation; undefined acceptance criteria in the open directio Criterion XI - Test Control Inadequate evaluation and documentation of acceptance criteria related to dynamic testing prior to returning valve to service Criterion XVI - Corrective Action Inadequate corrective action taken to address CS-M05A H
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ROOT AND CONTRIBUTING CAUSES All of the potential violations were caused by one or more of the following deficiencies:
- Inadequate oversight of MOV project by personnel in charge of the effort
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Unclear definition of responsibilities
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Inadequate documentation of basis for technical conclusions
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Failure to ensure through independent assessments that procedures contained appropriate criteria and that engineering judgement assessments were properly documented
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- Inadequate QA oversight -- failure to:
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confirm that proper acceptance criteria was contained in procedures
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ensure that independent technical assessments were performed on technical conclusions
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ensure that engineering judgement decisions were properly documented
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l COS RECTIVE ACTIONS -- SHORT-TERM
- Efforts initiated to develop consistent, documented guidelines for MOV assessment-(minimize use of undocumented, unchecked engineering judgement):
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documented criteria for target windows, acceptance criteria, and extrapolation
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documented guidelines ~or evaluating significant abnormalities / anomalies e Actions were taken to obtain third-party verification of engineering judgments made regarding anomalies, target windows, trace evaluations, et An assessment is currently being performed of tested valves in the GL 89-10 program to determine if similar deficiencies existed M
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(v1 CORRECTIVE ACTIONS -- SHORT TERM (CONT.) . .
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Deficiency Report issued regarding CS-MO5A
- The QA organization began reassessing its involvement in the GL 89-10 MOV Project
- The MOV Project organization was reviewed to determine whether it was performing its intended functions and modified appropriately
- Began review of all procedures related to MOV program H
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_ CORRECTIVE ACTIONS - LONG TERM
- Complete window and setting engineering calculations
- Revise procedures to more clearly require:
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documented acceptance criteria
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engineering review and approval of testing results prior to operability declaration
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trace evaluation and extrapolation methodology
- Periodically assess effectiveness of new MOV Project organization through existing (but improved) mechanisms such as the QA organization and self-assessment program
- Additional training of personnel and clearer definition of personnel qualifications H
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QUALITY ASSURANCE OVERSIGHT
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e Several NRC findings should have been identified by the QA organization
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Several are indicative of basic QA expectations a confirmation of existence of acceptance criteria a confirmation of adequate procedural controls a documentation of bases for conclusions e Similar to the continuation of efforts approach taken by the MOV Project regarding IEB 85-03 and GL 89-10, the QA organization viewed its efforts as a continuation of IEB 85-03 engineering and maintenance activity surveillance
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QA continued to monitor MOV work by surveillances that had been incorporated into the functional area audits
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GL 89-10 greatly expanded the IEB 85-03 focus
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QUALITY ASSURANCE OVERSIGHT CORRECTIVE ACTIONS
- Due to unique nature of GL 89-10 efforts, unique QA audit plan is being developed
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Ensure adequate technical self-assessments
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QA inspectors will not become technical experts, but will be familiar with test equipment capabilities, bases for acceptance criteria, results expectations
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Will have characteristics of performance-based and compliance-based QA audits BG
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QUALITY ASSURANCE OVERSIGHT CORIMCTIVE ACTIONS (CONT.) . .
- QA deficiencies are not indicative of current overall QA performance
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QA has learned many lessons as a result of recent events and is involved in an extensive transformation
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Recent QA improvements would have prevented similar mistakes if similar project initiated today e Other similar ongoing programs have been reviewed and QA involvement will be improved based on lessons learned from this event
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Check Valve Program
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Erosion / Corrosion Program .
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Snubber Program H
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QUALITY ASSURANCE OVERSIGHT CORRECTIVE ACTIONS (CONT.)
- Ongoing QA improvement efforts involve:
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Development of a QA assessment group
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Reduction in the frequency of certain audits depending on need
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Re-scoping audits and re-focusing surveillances to be more effective
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Development of a QA Guideline a Evaluates NRC inspection reports, QA inspection reports, NRC generic documents, industry initiatives, etc., to determine applicability to QA activities
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DISCUSSION OF OTIIER INSPECTION FINDIN'GS CS-MO5A
- During evaluation of test data, anomaly noted
- Based on an undocumented evaluation the anomaly was not an operability concern e During Phase II inspection, anomaly questioned by inspectors e Documented evaluation and O.D. performed - valve and CS train determined to remain operable H
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DISCUSSION OF OTHER INSPECTION FIXDINGS (CONT.'D)
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CS-MO5A
- Third party review, as part of inspection short term corrective actions, utilized additional conservatisms and resulted in a negative torque margi * Valve declared Inoperable on October 7,1993
- Maintenance activities being considered to render valve operable l
- Request for Enforcement Discretion being considered in order to conduct additional testing or operate in the present condition
- Part of D.R. short term corrective action is to obtain diagnostic test signatures during quarterly surveillance to monitor condition
- Repair / replace valve during next available cold shutdown H
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DISCUSSION OF OTWR INSPECTION FINDINGS INSPECTOR FOLLOW-UP ITEMS Use of uncertainties in generic DC motor curves in calculations regarding degraded voltage capabilitie The District will Monitor industry initiatives and adjust the MOV Project accordingly. Use of maintenance history reliance for thermal binding / pressure locking evaluatio The District will monitor industry action related to this issue and will initiate any additional corrective actions prior to completion of the RE-16 outage. Exclusion of pressure instrumentation uncertainty in initial acceptanc The District is evaluating this item for possible inclusion in the initial acceptance of
' MOVs. These uncertainties are presently accounted for in the CNS validation calculations and component level review calculation H
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U L O INSPECTOR FOLLOW-UP ITEMS (CONT.) Schedule showing extension will be require The present CNS commitment is to complete GL 89-10 MOV testing during the presently scheduled 1994 (RE-16) outage. Due to the extended 1993 outage, the next CNS refueling outage may be rescheduled for the first quarter of 1995. If necessary, NPPD will submit a formal request for a GL-89-10 schedule extension. Failure of CS-MO7B to ope The required investigation, documentation and corrective actions will be complete All information related to the corrective actions for CS-MO7B are being provided to the CNS Resident Inspectors RHR-920MV - Actions taken to demonstrate capability as a result of a bad sensor during the DP tes The District will demonstrate the capability of the valve by retest during the next scheduled outag H
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INSPECTOR FOLLOW-UP ITEMS (CONT.) QA & QC involvement in program including self- or third-party assessment An immediate third party review of all current testing data and traces for all valves tested to date is in progress. Any valves identified as not meeting the specified criteria will be evaluated in accordance with CNS corrective action procedure The District will conduct a self-assessment of the MOV Program and its output during the first quarter of 1994. An outside firm will be considered as a third party participant in the audi Involvement by the QA organization has been addressed by V. Wolstenholm's presentation.
- 8. Validate the use of linear extrapolation.
l The District will continue to monitor industry actions related to this issue and will l consider the use of multipoint testing to validate the extrapolation should industry l actions not provide an acceptable justificatio (q J
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DISCUSSION OF OTHER INSPECTION FINDINGS INSPECTOR FOLLOW-UP ITEMS (CONT.) DP tests with no discernable DP effects on test traces (seems to be a significant number of test The District will investigate the lack of discernable effects. It should be noted that four (4) of the seven (7) valves reviewed during the inspection had orifice type restrictions downstream of the valves. One (1) valve was tested using its Design Basis Scenario which only closes it to a 10% open positio . Accuracy of placing software marks on VOTES traces (errors on C5, Cl1, and 010).
Procedural requirements will be established to require an engineering review of the trace markings, trace marking guidance enhancement, and additional training of personnel. In addition, a thorough third party review, to ensure that all traces are marked correctly, will be performe BE
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CLOSING REMARKS
- All of the individual issues have been, and are being addressed
- Project management & QA oversight weaknesses are being corrected
- The lessons learned from this situation are being applied to other similar project-related efforts
- Self-assessment improvement efforts will be continued
- The District is committed to a comprehensive and effective GL 89-10 program and will continue to work to that end i BG