IR 05000298/1997003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/97-03

ML20148P550
Person / Time
Site:	Cooper
Issue date:	06/26/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
50-298-97-03, 50-298-97-3, NUDOCS 9707020364
Download: ML20148P550 (5)

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I l . 14 E'IO UNITED STATES y- *g NUCLEAR REGULATORY COMMISSION g R EoloN IV

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g 611 RYAN PLAZA DRIVE, SUITE 400 l g+,7*****# ' AR LINoToN, TEXAS 76011-8064 1 JUN 2 61997 I G. R. Horn, Senior Vice President of Energy Supply Nebraska Public Power District 141415th Street Columbus, Nebraska 68601

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SUBJECT: NRC INSPECTION REPORT 50-298/97-03

Dear Mr. Horn:

Thank you for your letter of June 11,1997, in response to our letter and Notice of Violation dated May 16,1997, involving an inadequate fire watch observation of hot work and a lack of protection for combustible material during hot work. We have reviewed your reply I and find it responsive to the concerns raised in our Notice of Violation. We will review the i i implementation of your corrective actions during a future inspection to determine that full I compliance has been achieved and will be maintained.

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Sincerely, r omas G y , Director Division of Reactor Projects Docket No.: 50 298 i License No.: DPR-46

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cc: i John R. McPhail, General Counsel  !

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Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 i P. D. Graham, Vice President of i Nuclear Energy i Nebraska Public Power District P.O. Box 98 I Brownville, Nebraska 68321 )i 9707020364 970626 PDR

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0 ADOCK 05000298 PDR l

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Nebraska Public Power District -2-8. L. Houston, Nuclear Licensing and Safety Manager

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Nebraska Public Power District ' P.O. Box 98 Brownville, Nebraska 68321 Dr. William D. Leech . MidAmerican Energy 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303-0657 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.P.H.

Director Nebraska Department of Health P.O. Box 950070 Lincoln, Nebraska 68509-5007 ) ._.

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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 Kansas Radiation Control Program Director , i I

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Nebraska Public Power District -4-3 JUN 2 61997 a bcc to DCD (IE01) bec distrib. by RIV: 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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i e . DOCUMENT NAME: R:\_CNS\CN703AK.MHM To receive copy of document, indicate in box: "C" = Copy wdhout enclospres "E" = Copy with enclosures "N" = No copy RIV:DRP/C , C:DRP/C , _ D:DRP g ATGody;dfM EECollingg TPGwynn /,//g 6/J/97 6/off97 @97 /V OFFIClAL RECORD COPY

l l . o Nebraska Public Power District -4-JUN 2 61997 (bc'clo DCD;(IE01);" bec distrib. by RIV: Regional Administrator Resident inspector j DRP Director DRS-PSB l Branch Chief (DRP/C) MIS System Branch Chief (DRP/TSS) RI V File . Project Engineer (DRP/C) I I l l l

DOCUMENT NAME: R:\_CNS\CN703AK.MHM To receive copy of document. Indicate in box: "C" = Copy without enclospires "E" = Copy with enclosures "N" = No copy RIV:DRP/C , C:DRP/C , l D:DRP g ATGody;df;4( EECollingg TPGwynn /,/g) , 6/J/97 6/of.#97 64fp/97 /C _f OFFIClAL RECOFlD COPY

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Nebraska Public Power District * N t"" _ __

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NLS970119 [j ,[@ [[ Q 7/ E June 11,1997 4

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dE I IE U.S. Nuclear Regulatory Commission I '

Attention: Document Control Desk REClON IV Washington, D.C. 20555-0001 Gentlemen: i

Subject: Reply to a Notice of Violation j NRC Inspection Report No. 50-298/97-03 ' - Cooper Nuclear Station, NRC Docket 50-298, DPR-46 i

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Reference: 1. Letter to G. (NPPD) from T. P. Gwynn (USNRC) dated May 16, 1997, "NRC Inspection Report 50-298/97-03 and Notice of Violation" By letter dated May 16,1997 (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 Violation in accordance with 10 CFR 2.201. The District admits to the violation and has completed all corrective actions necessary to return CNS to full compliance.

Should you have any questions concerning this matter, please contact me.

Sincerely, PB&L~ P. D. Graham Vice President of Nuclear Energy

/nr Attachment cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution  . *tT-IBIB (3 m ( 6 c 4 ', ? LM
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Attachment' I to NLS970119 l Page 1 of 2 REPLY TO MAY 16,1997, NOTICE OF VIOLATION l COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from February 23,1997, through April 5,1997, one !' violation of NRC requirements was identified. The particular violation and the District's reply are set forth below: . Violation Technical Specification 6.3.2, states, in part, written procedures and instructions shall be established implemented, andmaintainedfor thefireprotectionprogram. l Procedure 0.39, " Fire Watches, " Revision 12, Step 8.4.1, states inpart, that allfire watch personnelshall be diligent in their observance of the affected area and alertfor signs offire andsmoke. Fire watchpersonnelshallmaintain continuous observation of the affectedarea.

Procedure 0.39, Step 8.1.4, states, in part, that immediatelyprior to the start of the hot work, thepre watch shall ensure combustible materialshall be protectedfrom hot work. j Protection is requiredfor a radius of 35feetfrom the hot work.  ! Contrary to the above, on March 6,1997, during installation ofModification 94-072, fire watch personnel did not maintain continuous observation of the affectedarea in that sparks from welding andgrinding extended beyond the range of the view of the camera usedforfire watch observation. Also, fire watchpersonneldidnot ensure that combustible material, l which was located within 35 feet ofhot work in progress, wasprotected Admincion or Denial to Violation The District admits the violation.

Reason for Violation Interviews conducted with the fire watches associated with this work indicated that Procedure 0.39, " Fire Watches," contained the appropriate requirements with respect to control and protection of combustible material in the vicinity of hotwork; however, strict compliance with the : l procedure was not enforced by supervision. The fire watches' tolerance of an inadequate field of i

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view was also evidence of procedure adherence problems. A contributing cause to these procedural adherence problems was that a weakness existed in the procedure in that it did not provide specific guidance on the use of cameras and the authority to stop work if conditions were l not in accordance with procedure requirements.

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Attachment 1 l , to NLS970119 l ' Page 2 of 3

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Corrective Steps Taken and the Results Achieved

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The conditions in the room were corrected by removing or protecting combustible materials and the addition of a third camera to increase the field of view.-

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A site-wide moratorium on hotwork was implemented until briefings with fire protection l personnel could be held for each job and work group to outline expectations for fire watch performance and to emphasize fire watch stop work authority if fire safe conditions do not exist.  :

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A site wide stand down on work for procedure adherence was held the following day.  ! Included in this stand down was training and testing to procedure adherence expectations and  :

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Procedure 0.39 was revised to clearly delineate the requirements for control and protection of combustible material in the vicinity of hotwork to aid procedural adherence. ) i As a result of these actions, no hotwork related fires occurred during the recently completed refueling outage. In addition, the following actions have been taken:

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Ongoing corrective actions to address the site wide issue of procedural adherence have been I made a station alignment issue and incorporated into the business plan.

- Administrative Procedure 0.39 was revised to specify the conditions under which and how cameras may be utilized for fire watch activities and to include a discussion on fire watch authority in addition to responsibilities.

Corrective Steps That Will Be Taken to Avoid Further Violations ,

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No further corrective actions beyond those discussed above are required.

Date When Full Comoliance Will Be Achieved The District is in full compliance with respect to the cited violation.

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 ATTACHMENT 3 l*  LIST OF NRC COMMITMENTS   j l

Correspondence No: NLS970119 The following table identifies those actions committed 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

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information and are not regulatory commitments. Please notify the Licensing Manager ! at Cooper Nuclear Station of any questions regarding this document or any associated J regulatory commitments.

I COMMITTED DATE ; COMMITMENT OR OUTAGE I None _ __ l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l }}