IR 05000298/1996025
| ML20140E604 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/06/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-96-25, EA-97-018, EA-97-18, NUDOCS 9706120156 | |
| Download: ML20140E604 (6) | |
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UNITED ST ATES
SUBJECT:
NRC INSPECTION REPORT 50-298/96-25, EXERCISE OF ENFORCEMENT DISCRETION AND NOTICE OF VIOLATIOlJ
Dear Mr. Horn:
Thank you for your letter of April 17,1997, in response to our letter, Exercise of
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Enforcement Discretion and Notice of Violation dated March 4,1997. We have reviewed l
your reply to Violation A and find it responsive to the concerns raised in our Notice of Violation.
With respect to Violation B, you admitted the violation, but clarified that you believe that
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the actions you took with respect to the significant condition adverse to quality were effective in precluding recurrence. Specifically, you indicated that in followup to Quality Assurance Audit 96-08, you initiated Significant Condition Adverse to Quality 96-0516 to addeess the impact of transient combustible materials on the fire hazards analysis, restore compliance with Procedure 0.7.1, " Control of Combustibles," and initiate weekly
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walkdowns by fire protection personnel to assure compliance with Section 8.2 of Procedure 0.7.1. You appear to conclude that these corrective actions for the significant condition adverse to quality were adequate to preclude recurrence because the walkdowns l
specified in accordance with Section 8.2 of Procedure 0.7.1 were to ensure that significant accumulations of transient combustibles did not exceed the fire hazards analysis. You conclude that these actions were effective because neither your subsequent walkdowns j
nor our inspection identified any examples wherein the combustible loading of the fire hazards analysis were violated. Nevertheless, you acknowledged that housekeeping concerns involving quantities of transient combustibles significantly less than fire hazard
analysis assumptions still remain, in part, because Procedure 0.7.1 has yet to be revised to
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address programmatic weaknesses associated with the control of transient combustibles.
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We acknowledge that neither your quality assurance audit nor our inspection team identified an accumulation of transient combustible materials in excess of the fire rating for
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a fire area. However, your quality assurance audit noted a number of examples where
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transient combustible materials, not in excess of the fire rating for an area, were found in the plant. This audit also indicated that Procedure 0.7.1 did not effectively control I
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combustibles and presented a significant vulnerability for exceeding the fire hazards
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E-Mail report to T. Boyce (THB)
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analysis assumptions for heat loading of fire zones. Our inspection also identified j
additional examples of transient combustible materials in the plant. Even though none of l
the NRC-identified examples exceeded the fire rating of the area in question, we consider j
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this lack of control, in and of itself, to be a significant condition adverse to quality. As
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such, your actions to resolve this issue have not been effective as evidenced by the f act
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i that you acknowledge that " housekeeping concerns" have yet to be addressed and our l
inspection identified further examples of the lack of control of transient combustibles.
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Furthermore, your response to Quality Assurance Audit 96-08 stated that plant personnel
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would be trained on the requirements of this procedure. Specifically, Sections 4.3 and
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8.1.11.1 of Procedure 0.7.1 require that transient combustibles be removed from work
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areas at the end of the work day, thus, preventing the buildup of transient combustible
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l materials. As stated in Section F.8 of our inspection report, we observed that the training j
of plant personnel to meet the requirements of Procedure 0.7.1 had not been completed.
i We considered this lack of training to be a contributor to the less than effective plant l
walkdowns.
i Based on the above, it is not clear from your response to the Notice of Violation whether
you have accepted the cited violation and whether your corrective actione are appropriate for the cl.cumstances. Specifically, after revising Procedure 0.7.1 and conducting i
personnel training on the revision, your inter!m walkdowns were ineffective to identify and correct the transient combustible control problems. As a result, the significant condition adverse to quality, namely uncontrolled transient combustibles continued. Therefore, we request that you provide an additional response within 20 days of receipt of this letter, addressing actions you have taken or plan to take to ensure that your corrective actions are effective in preventing the transient combustible control problems from continuing.
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Sincerely,
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h Arthur T. Howell lil, Director i
Division of Reactor Safety Docket No.: 50-298 License No.: DPR 46 i
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John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 i
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Nebraska Public Power District 3-P. D. Graham, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 B. L. Houston, Nuclear Licensing and Safety Manager Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321
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Dr. William D. Leech MidAmerican Engergy 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303 Mr. Ron Stoddard Lincoln Electric System 11th and O Streets Lincoln, Nebraska 68508 Randolph Wood, Director Nebraska Department of Environmental Quality
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P.O. Box 98922 Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 i
Cheryl Rogers, LLRW Program Manager Environmental Protection Section
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Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 i
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Nebraska Public Power District-4-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 L
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E-Mail report to Document Control Desk (DOCDESK)
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Regional Administrator Resident inspector
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u 9.sy NLS970056
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April 17,1997 N
U.S. Nuclear Regulatory Commission 04.
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s Attention: Document Control Desk
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Washington, D.C. 20555-0001 J
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Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-25
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Cooper Nuclear Station, NRC Docket 50-298, DPR-46 1. Letter to G. R. Hom (NPPD) from K. E. Brockman (USNRC) dated Reference:
March 4,1997,"NRC Inspection Report 50-298/96-25, Exercise of Enforcement Discretion and Notice of Violation" By letter dated March 4,1997, (Reference 1), the NRC cited Nebraska Public Power (District) as being in violation ofNRC requirements. This letter, including Attachment 1, the District's reply to the referenced Notices of Violation in accordance with 10 CFR 2.201.
District admits to the violations and has completed all corrective actions necessary to return Co Nucic~ar Station (CNS) to full compliance.
The referenced inspection report also noted that the District had verbally committed to comp review of the remainder of outstanding maintenance work requests (MWRs) and to dispos The District confirms this conunitment to review the identified unauthorized modifications.
remainder of MWRs by December 31,1997, and disposition identified unauthorized modifi by June 30,1998.
Should you have any questions conceming this matter, please contact me.
Sincerely, f
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P. D. Graham Vice President of Nuclear Energy
/nr Attachment N
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NLS970056 April 17,1997 Page 2 of 2 cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC -NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution
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Attachment I to NLS970056 PageIof4 REPLY TO MARCH 4,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted on November 18-22 and December 9-13,1996, two violations of NRC requirements were identified. The particular violations and the District's reply are set forth below:
Violation Technical Specification 6.2.1.A.4.e, requires a review of station operation by the Station Operations Review Committee so that potential nuclear safety hazards could be detected.
I Contrary to the above, during the period ofJuly 2 through November 25,1996, the Station
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Operations Review Committee did not review station operations to detect potential nuclear safety hazards.
This is a Severity LevelIV violation (Supplement 1) (50-298/9625-01).
Admission or Denial to Violation The District admits the violation.
Reason for Violation This violation is attributed to poorly defined procedural requirements. Station Procedure 0.3, Station Operations Review Committee (SORC), did not clearly define station operations review requirements, creating the potential for an operational or safety hazard issue to be missed. While SORC reviewed potential nuclear safety hazards in their review of procedure changes, design modifications, safety evaluations; etc., this aspect of their review was not specifically documented in SORC meeting minutes.
Corrective Steps Taken and the Results Achieved
As of December 1996, the review of plant operational issues to detect potential nuclear safety hazards has been identified in the SORC meetings / minutes as a separate presentation category. The Plant Operations Manager periodically presents to SORC current plant operational issues and safety concerns which could potentially affect the continued safe operation of the station. Items are presented for review and awareness as to the individual and cumulative effects of safety and operations implications. In addition, effective in March 1997, at the beginning of each SORC meeting, the membership is asked if they have any immediate safety concems with plant operations / conditions or the material being presented. In order to ensure continued compliance with the Technical Specification requirement to review station operation to detect potential nuclear safety hazards, Procedure 0.3," Station Operations Review Committee," was revised to add appropriate
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Attachment 1 l
to NLS970056 l
Page 2 of 4 clarification. A procedure revision was approved on March 20,1997, which clarifies that SORC l
review to meet the subject Technical Specification requirement will include a standard opening l
review for any immediate opemtional safety concems or any safety concem with the material being l
presented to SORC for review, as well as a routine advisement by Operations regarding current plant operational issues.
l A review was performed to determine if SORC was properly implementing other Tecimical Specification review requirements. This review concluded that other specific areas of SORC responsibility delineated in the Technical Specifications are being appropriately implemented.
Corrective Steps That Will Be Taken to Avoid Further Violati.on:i
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No additional actions beyond those discussed above are required.
Date When Full Compliance Will Be Achieved The District is currently in full compliance.
Violation 10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures be established to assure that conditions adverse to quality, such asfailures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case ofsigmficant conditions adverse to quality, the measures shall ensure that the cause ofthe condition is determined and corrective action taken to preclude repetition.
Contrary to the above, on November 20, 1996, one of the corrective actions for Quality Assurance Audit 96-08, which includedrevising Procedure 0.7.1, " Control ofCombustibles, "
personnel training on this revision, andinterimplant walkdowns to identify and correct transient combustible controlproblems, was inadequate. Specifically, the plant walkdownsfailed to identify and correct three transient combustible controlproblems.
This is a Severity Level IV violation (Supplement 1) (50-298/9625-07).
Admission or Denial to Violation j
The District admits the violation as further clarified below.
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Attaciunent I to NLS970056 Page 3 of 4 Reason for Violation The District believes actions taken in response to the Significant Condition Adverse the Quality (SCAQ) wcre effective in precluding recurrence. The scope of the SCAQ was to address the concems of Quality Assurance (QA) Audit 96-08 identified a number of examples where transient combustible materials were located in areas containing safety related equipment. Specifically, the audit finding stated:
" Procedure 0.7.1 [ Control of Combustibles) does not effectively control combustibles and presents significant vulnerabilities for exceeding the heat loading of fire zones as analyzed in the Fire Hazards Analysis [ FHA]."
"It has been concluded that the listings of combustible loadings for Fire zones may potentially have fire loadings greater than the total loading allowed in the FHA without additional compensatory actions (e.g., fire watch)."
In follow up to the QA audit, SCAQ 96-0516 was initiated and immediate corrective actions were taken to:
Assess impact to the FHA. This assessment demonstrated that the FHA assumptions had not
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been violated.
Restore compliance with Procedure 0.7.1. This was done by removing or issuing Transient
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l Combustible Permits for the identified combustibles.
Initiate weekly plant walk downs by Fire Protection personnel to check for compliance with
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Section 8.2 of Procedure 0.7.1 (i.e., significant accumulations of transient combustibles that had the potential to violate FHA assumptions).
In addition, actions were taken to heighten the stafi's awareness via memorandum and various news
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l letters. Rese actions have been adefuate to preclude repetition of the originally identified condition.
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Hosie~v~er, the District acknowledges that housekeeping concerns involving quantities of transient l
combustibles significantly less than FHA assumptions (typified by the examples discussed in this l
violation) still remain. These remaining concems are a result of:
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Programmatic weaknesses in the fire protection program. The purpose of Procedure 0.7.1,
" Control of Combustibles," is to control transient combustibles such that the fire loading assumptions of the FHA are not violated. While the procedure includes some housekeeping expectations, it relies on other programs and procedures to control transient combustibles of minimal significance (i.e., quantities more accurately described as housekeeping issues), there is no recognition of thir fact nor are there formalized ties to these programs and procedures.
Weaknesses in the implementation of the housekeeping program. Directive 11, " Site
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I Housekeeping and Inspection Program," was significantly revised in April 1995 and, while
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' Attachment I to NLS970056 Page 4 of 4 achieving imprc%d overall housekeeping practices, has yet to be assessed for effectiveness in meeting management's expectations. 'Ihe housekeeping program was further enhanced in June 1996 with the issuance of Procedure 0.44," Housekeeping Cleanliness Controls." Although this procedure provided better integration with other station procedures, it has introduced an element of program fragmentation.
Corrective Steps Taken and the Results Achieved As noted above, an initial assessment of operability verified that the fire loading assumptions of the FHA have not been challenged. Further, the specific examples identified by this violation were resolved. The weekly plant walk downs by Fire Protection personnel are continuing. These walk downs will continue until the corrective actions relative to Procedure 0.7.1 described,below are completed.
Corrective Steps That Will Be Taken to Avoid Further Violations 1. Procedure 0.7.1 will be revised to address the programmatic weaknesses described above.
Further, performance indicator (s) for transient combustible material control will be developed and reported to station management. This will provide a means of communicating the results of performance monitoring, thereby providing a basis for consistent reinforcement of transient combustible material control standards.
2. A self assessment of the housekeeping program and implementing procedures will be performed to ensure program results are meeting management expectations.
Date When Full Compliance Will Be Achieved The District is in full compliance, as clarified above, with respect to the cited violation. Procedure 0.7.1 will be revised to address the programmatic weakne::ses described above by July 31,1997.
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
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Correspondence No: NLS970056 The following table identifies those actions committed to by the District in this
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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 COMMITMENT OR' OUTAGE The District will review the remainder of MWRs.
December 31, 1997.
The District will disposition identified unauthorized June 30, 1998.
modifications from the above review.
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Procedure 0.7.1 will be revised to address programmatic July 31, 1997.
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Performance indicator (s) for transient combustible N/A material control will be developed and reported to station management.
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A self assessment of the housekeeping program and N/A implementing procedures will be performed.
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PROCEDURE NUMBER 0.42 l
REVISION NUMBER 4 l
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