IR 05000298/1996013
| ML20129H604 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/30/1996 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9611050298 | |
| Download: ML20129H604 (4) | |
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AR LINGTON, T E XAS 76011 8064 OCT 301996 G. R. Horn, Senior Vice President of Energy Supply Nebraska Public Power District 141415th Street Columbus, Nebraska 68601 SUBJECT:
NRC INSPECTION REPORT 50-298/96-13 Thank you for your letter of October 15,1996,in response to our letter and Notice of Violation dated September 9,1996. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has l
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been achieved and will be maintained.
Sincerely, y/ 'k J. E. D er, Director l
Division of Reactor Projects l
Docket No. 50-298 License No.: DPR-46 cc w/ enclosure:
John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebrat,ka 68602-0499 P. D. Graham, Vice President of l
Nuclear Energy l
Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 9611050298 961030 PDR ADOCK 05000298 G
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Nebraska Public Power District-2-l B. L. Houston, Nuclear Licensing
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and Safety Manager Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 R. J. Singer, Manager-Nuclear Midwest Power 907 Walnut Street i
P.O. Box 657 Des Moines, Iowa 50303 l
Mr. Ron Stoddard Lincoln Electric S', stem 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 l
Nemaha County Courthouse i
1824 N Street Auburn, Nebraska 68305
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Cheryl Rogers, LLRW Program Manager l
Environmental Protection Section i
Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Dr. Mark B. Horton, M.S.P.H.
Director
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Nebraska Department of Health P.O. Box 950070 Lincoln, Nebraska 68509-5007
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R. A. Kucera, Department Director i
of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 I
Jefferson City, Missouri 65102
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Kansas Radiation Control Program Director
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i DOCUMENT NAME: R:\\_CNS\\CN613AK.MHM To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" * Copy with enclosures "N" = No copy RIV:DRP/h C:DfjP/C D:DRP TReis;df%
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i COOPER NUCLEAR STATION i
P.O. BOX 98, BROWNVLLE, NEBRASKA 68321
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Nebraska Publ.ic Power District n'5a"o~o= = >a"
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FAX (402)825-6205 P. D. Graham Vice President, Nuclear (402) 825-5769
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't NLS960187
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October 9,1996
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' ~ j U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-13 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 iteference:
1. Letter to G. R. Horn (NPPD) from J. E. Dyer (USNRC) dated September 9,1996, "NRC Inspection Report 50-298/96-13 and Notice of Violation" By letter dated September 9,1996 (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation of NRC requirements. This letter, including Attachment 1, constitutes the District's reply to the referenced Notice of Violations in accordance with 10 CFR 2.201. The District admits to the violations and has completed all corrective actions necessary to return CNS to full compliance with respect to the identified violations.
Should you have any questions concerning this matter, please contact me.
Sincerely,
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P. D. Graham
Vice President - Nuclear i
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1 NLS960187
October 9,1996 i
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. Page 2 of 2 l
cc:
gional Administrator USNRC - Region IV
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Senior Project Manager
USNRC - NRR Project Directorate IV-1 t
Senior Resident Inspector USNRC
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Attachment I to NLS960187
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Page 1 of 3
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REPLY TO SEPTEMBER 9,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 i
During NRC inspection activities conducted from June 16,1996, through July 27,1996 two violations ofNRC requirements were identified. The particular violations and the District's reply are set forth below-
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A. "10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures.
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Procedure 7.11, ' Reactor Building RoofAccess Hatch Operation and Maintenance,'
Revision 2.1, Step 7.5, requires Shift Supervisor signature and date on an attachment of the procedure prior to accessing the reactor building roof via the reactor building hatch.
Step 9.1 requires that, during hatch restoration, Operations verify that the reactor building hatch was closed, sealed tight, and locked.
l Contrary to the above:
On June 19,1996, a security officer, a radiation protection technician, and two engineers opened the reactor building hatch without the shift supervisor's approval. As of
June 20,1996, the reactor building hatch had not been verified by Operations to be
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restored.
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i B. 10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality
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shall be prescribed by documented instructions orprocedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures. Procedure 2.0.1, ' Plant Operations Policy,' Revision 27, Step 8.4.2, states that approved procedures require step-by-step adherence by allpersonnel.
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l Contrary to the above, the following procedures were not adhered to step by step:
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On June 15,1996, Section 8.2 ofProcedure 4.15, ' Elevated Release Point and Building Radiation Monitoring Systems,' Revision 14, was performed without performingSection 8.1 where the step to open the suction valve was located.
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Procedure 4.15 does not state that each section can be performed independently.
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On April 10,1996, Step 8.10.2.4, to open the pump suction valve, ofProcedure i
6.4.6.4.1, ' Turbine Building Kaman Monitor Calibration,' Revision 5, was not performed, resulting in the turbine building radiation monitor being returned
l to operable status with the pump suction valve closed.
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On July 14,1996, maintenance technicians, while performing
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Procedre 7.2.55.1, ' Replacement ofHCU Accumulator,' Revision 2, removed the cart before directed by Step 8.5 and before the fasteners were torqued.
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l Attachment I to NLS960187 Page 2 of 3 4.
On July 11,1996, while performing Procedure 6.1EE.302, '41600 Bus 1F Undervoltage Relay and Relay Timer Functional Test,' Revision 0, the operator logged the allowed outage stop time at Step 8.187 instead ofStep 8.189."
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Admission or Denial to Violations The District admits the violations.
Reason for Violation A.
This violation resulted from personnel failing to implement Procedure 7.11 due to an unawareness of procedural control of the secondary containment hatch, lack of signage indicating requirements for access and egress, and the lack of a questioning attitude by the personnel involved.
l Corrective Steps Taken and the Results Achieved - Violation A.
l Operations immediately declared Secondary Containment inoperable and entered the
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Technical Specification 3.7.C action statement. Within three hours Operations performed l
Surveillance Procedure 6.SC.502 to verify the integrity of the reactor building hatch prior to l
declaring secondary containment operable. The unescorted badges or the two engineering l
contractors were withheld pending a review of the event, The badges have since been l
reactivated. Placards were placed on the ladder leading to the hatch and on the hatch indicating that the hatch is a secondary containment boundary and that the requirements of l
Procedure 7.11 must be met before opening the hatch. Security Procedure 2.8 was revised l
to require Security Shift Supervisor approval ofissuing the reactor building roof hatch key
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after coordination with the Station Shift Supervisor.
Corrective Steps That Will Be Taken to Avoid Future Violations - Violation A.
No further corrective actions are required.
Reason for Violation B.
Collectively, the four examples resulted from personnel failing to follow procedure.
Corrective Stens Taken and the Results Achieved - Violation B.
i On July 25,1996, CNS stopped plant work and training activities so that departmental meetings could be held to focus attention on current problems regarding procedural compliance. Several issues were identified during this meeting and are being resolved through the corrective action process. The stand down continued until departmental managers were confident that expectations regarding procedural compliance were clearly communicated and understood.
The specific procedural violations are being discussed with personnel from the applicable department.
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Attachment I to NLS960187 Page 3 of 3 Corrective Steps That Will Be Taken to Avoid Future Violations - Violation B.
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Procedure 4.15 will be revised by November 19,1996, to creato independent
sections for placing either the normal or high range monitors in service.
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Kaman calibration procedures will be revised by December 3,1996, to include
specific check offs or initials when component manipulations are performed.
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3.
The crew leader was counseled regarding this event and no further corrective steps are required.
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Allowed Outage Time implementation guidance will be reviewed for
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appropriate application by December 11,1996.
Date When Full Compliance Will Be Achieved
The District has completed all corrective actions necessary to return CNS to full compliance
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with respect to the identified violations.
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS Correspondence No: NLS960187 i
The following table identifies those actions comndtted 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 Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE l
COMMITMENT OR OUTAGE Procedure 4.15 will be revised to create independent sections for November 19,1996 placing either the normal or high range momtors m service, i
Kaman calibration procedures will be revised to include specific December 3,1996 check offs or initials when component manipulations are performed.
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Allowed Outage Time implementation guidance will be reviewed for December 11,1996 appropriate application.
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l PROCEDURE NUMBER 0.42 l REVISION NUMBER 1.2 l PAGE 8 OF 10 l
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