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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 - 1996012 |
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NUCLEAR REGULATORY COMMISSION (
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G. R. Horn, Senior Vice President of Energy Supply Nebraska Public Power District ,
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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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John R. McPhail, General Counsel Nebraska Public Power District l
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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 !
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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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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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\ 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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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