IR 05000298/1996015
| ML20128G044 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/04/1996 |
| From: | Brockman K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9610080319 | |
| Download: ML20128G044 (4) | |
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SUBJECT:
NRC INSPECTION REPORT 50-298/96-15 and Notice of Violation
Dear Mr. Horn:
l Thank you for your letter dated September 23,1996,in response to our letter and Notice of Violation dated August 22,1996. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the
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implementation of your corrective actions during a future inspection to determine that full l
compliance has been achieved and will be maintained.
Sincerely, w &
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Kenneth E. Brockman, Acting Director Division of Reactor Safety Docket No.: 50-298 j
License No.: DPR-46 Enclosure: Letter dated September 23,1996 cc w/o enclosure:
John R. McPhail, General Counsel Nebraska Public Power District
P.O. Box 499 Columbus, Nebraska 68602-0499
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9610080319 961004 ADOCK0500g8 PDR G
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Nebraska Public Power District-2-
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John Mueller, Site Manager
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Nebraska Public Power District J
j P.O. Box 98 Brownville, Nebraska 68321
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Robert C. Godley, Nuclear Licensing
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& Safety Manager
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Nebraska Public Power District q.
P.O. Box 98
Brownville, Nebraska 68321 I
R. J. Singer, Manager-Nuclear Midwest Power
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907 Walnut Street
. P.O. Box 657 Des Moines, Iowa 50303 Mr. Ron Stoddard Lincoln Electric System
11th and O Streets
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Lincoln, Nebraska 68508
' Randolph Wood, Director Nebraska Department of Environmental j
- Quality P.O. Box 98922 j
Lincoln, Nebraska 68509-8922 i
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
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e Nebraska Public Power District-3-Dr. Mark B. Horton, M.S.P.H.
Director Nebraska Department of Health P.O. Box 950070 Lincoln, Nebraska 68509-5007 R. A. Kucera, Department Director of intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 Kansas Radiation Control Program Director
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Nebraska Public Power District-4-E-Mail report to D. Nelson (DJN E-Mail report to NRR Event Tracking System (IPAS)
<bcc. to DMB (lE01) -
bec w/ enclosure distrib. by RIV:
L. J. Callan Resident inspector DRP Director DRS-PSB Branch Chief (DRP/C)
MIS System Branch Chief (DRP/TSS)
RIV File I
Project Engineer (DRP/C)
Leah Tremper (OC/LFDCB, MS: TNFN 9E10)
DRS Al 96-G-0099 l
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DOCUMENT NAME: R:\\_CN\\CN615AK.GLG To receive copy of document, indicate in box: "C" = Copy wnhout enclosures "E" = Copy with enclosures "N" = No copy RS:PSB E
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OFFICIAL RECORD COPY 080007 i
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Nebraska Public Power District-4-
l E-Mail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System (IPAS)
bec to DMB (IE01)
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l bec w/ enclosure distrib. by RIV-L. J. Callan Resident inspector DRP Director DRS-PSB l
Branch Chief (DRP/C)
MIS System
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Branch Chief (DRP/TSS)
RI V Fife i
Project Engineer (DRP/C)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
DRS Al 96-G-0099
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DOCUMENT NAME: R:\\_CN\\CN615AK.GLG I
To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RS:PSB E
RS:PSB
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AD:DRS N[
l GLGuerra:cg (,hb MPShanndfT% BMurray 6 KEBrockmargQ
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OFFICIAL F ECORD COPY
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P.O. BOX B ILLE NEB 68321 Nebraska Public Power District 5L%""
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NL,S960183
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September 23,1996 SEP 2 1 ; g U.S. Nuclear Regulatory Commission f
Attention: Document Control Desk
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Washington, D.C. 20555-0001
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Gentlemen:
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Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-15 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 Reference:
1. Letter to G. (NPPD) from K. E. Brockman (USNRC) dated August 22,1996, "NRC Inspection Report 50-298/96-15 and Notice of j
Violation" By letter dated August 22,1996 (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation ofNRC requirements. This letter, including Attachment 1, constitutes the District's reply to the referenced Notice of Violatibiis in accordance with 10 CFR 2.201. The District admits to the violations and has completed all corrective actions necessary to retum CNS to full compliance with respect to the identified violations.
Should you have any questions concerning this matter, please contact me.
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Sincerely, k
P D. Graham Vice President - Nuclear
/cet Attachment 0i lnn t n I dr
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ff l &O U Powerful Pride in Nebraska 1-
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NLS960183 September 23,1996
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Page 2 of 2 cc: Regional Administrator
USNRC -Region IV....
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Senior Project Manager USNRC-NRR Project Directorate IV-1 Senior ResidentInspector USNRC NPG Distribution
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Attachment I to NLS960183 Page1of3 REPLY TO AUGUST 22,1996, NOTICE OF VIOLATION gOOPER NUCLEAR STATION l
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NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from July 29,1996, through August 2,1996, two i
violations of NRC requirements were identified. The particular violations and the District's reply are set forth below:
A. " Criterion VofAppendix B to 10 CFR Part 50 states, in part, that activities affecting quality shall be prescribed by documentedprocedures, ofa type appropriate to the circumstances, and shall be accomplished in accordance with these procedures.
Procedure 9.1.1.3, ' Personnel Dosimeter Program, ' Revision 38, Section
8.1.1.4.a states inpart, 'DRD 's shall be available to allpersonnel entering the RCA. DRD 's are to be usedin addition to thermoluminescant dosimeters (TLD)
i and not in lieu ofTLD 's..
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Procedure 9.1.5, ' Respiratory Protection Program, ' Revision 31, Section 8.9.2,
states in part, 'This examination shall include [that]: Sorbent canisters are se ded and within their 3 year shelf hfe. '
j Contrary to the above,
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Between Nyvember 1995 and May 1996 workers cr.*ered the radiological
controlled area during six separate occurrences without the proper dosimetry.
On July 31,1996, the inspectors identified that the monthly examination of
respiratory equipment did not identify that sorbent canisters exceeded the
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proceduralshelfhfe requirement.
B. 10 CFR 20.1501 states, in part, (a) Each licensee shall make or cause to be made surveys that - (1) May be necessaryfor the licensee to comply with the regulations in thispart; and i
~(2) Are reasonable under the circumstances to evaluate - (i) The extent ofthe radiation levels; and (ii) Concentrations or quantities ofradioactive material; and (iii) The potential
radiological ha:ard that could be present.
Coritrary to the above, on June 8,1996 andJune 18,1996, u ork wasperformed in the dryer /separatorpit and refuelingpool area ofthe reactor building, withoutperforming surveys to evaluate the radiological ha:ardspresen:. "
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Attacl.rnent 1 -
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to NLS960183 Page 2 0f 3
Admission or Denial to Violations j
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L The District admits the violations.
i Reason forViolation A.
The first example resulted from personnel failing to follow procedure. The identified six entries without direct reading dosimeters were from a population of approximately 175,000 RCA entries
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during this time period. All personnel were wearing TLDs to record their radiation dose.
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The second example resulted from an inadequate initial evaluation of a corrective action from a
~ self-assessment. It was n' t recognized at the time of the self-assessment that the discrepancy o
between the procedure and form was a compliance issue.
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i Conective Steos Taken and the Results Achieved - Violation A.
j Present RCA access controls were evaluated and it was determined that the present process provides excellent tracking of personnel dose. Management expectations regarding dosimetry l
l requiremems for RCA entry were re-emphasized to station ~ personnel to increase their sensitivity
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to the issue.
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The procedure identified in the second example was revised to refTect manufacturer recommendations regarding the shelflife of the sorbent caniners and the inspection form'now accurately reflects procedural requirements.
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Corrective Stens That Will Be Taken to Avoid Future Violations - Violation A.
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Subsequent to the inspection, three additional RCA entries without DRDs were identified. The i
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District will evaluate the human performance aspects of this issue and implement additional i
L corrective measures if warranted based on that evaluation. CNS will continue to evaluate similar
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circumstances through the Corrective Action Program and take actions for any future adverse
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tre_nds identified regarding the first example. The District will also review present personnel dosimetry requirements.
Reason for Violation B.
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' Both events occurred due to a complacency with respect to procedural requirements for
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radiological protection (RP) personnel involved. RP personnel had not adequately scoped the current conditions of the two jobs which resulted in erroneous assumptions and the failure to
- recognize potential radiological hazards.
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i Attachment 1
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Page 3 of 3 Corrective Stens Taken and the Results Achieved - Violation B.
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Subsequent to the second even't', the project supervisor suspended work on the fuel pool cleanup
project until the initial investigation could be conducted and a restart plan developed. A briefing on the event and the results of the investigation was held with the contract work force and RP personnel. This briefimg included the actions necessary for work restart.
Corrective Stens That Will Be Taken to Avoid Future Violations - Violation B.
Training on procedures, basic survey techniques, basic job coverage techniques, and management expectations rela:r i to this violation will be provided to the appropriate personnel by December 31,1996. r Date When Full Comnliance Will Be Achieved
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The District has completed all corrective actions necessary to return CNS to full compliance with respect to the identified violations.
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ATTACHMENT 3
. LIST OF NRC COMMITMENTS
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l Correspondence No: NLS960183 L
The following table identifies those actions committed to by the District in this document. Any
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. otlwr actions discussed in the suhmittal represent intended orplanned actions by the District.
They are described to the NRC for the NRC's information and are not regu'atory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this
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document or any associated regulatory commitments.
l COMMflTED DATE COMMITMENT OR OUTAGE The District will evaluate the human performance aspects of RCA entries without DRDs and implement additional corrective measures if
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warranted based on that evaluation.
The District will review present personnel dosimetry requirements.
Training on procedures; basic survey techniques, basic job coverage techniques, and management expectations related to this violation will December 31,1996
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be provided to the appropriate personnel.
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l PROCEDURE NUMBER 0.42 l REVISION NUMBER 1.2 l PAGE 8 OF 10 l
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