IR 05000298/1997006
| ML20216E696 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/08/1997 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-97-06, 50-298-97-6, NUDOCS 9709110051 | |
| Download: ML20216E696 (5) | |
Text
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SUBJECT:
NRC INSPECTION REPORT 50 298/97-06
Dear Mr. Horn:
Thank you for your letter of August 25,1997, in response to our letter and Notice of Violation dated July 25,1997, involving inadequate procedures for use of the 24-inch containment vont valves and for verification of jet pump operability. We have reviewed , your reply and find it responsive to the concerns raised in our Notice of Violation. We will ! f review the implenientation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, /' fl c fr.wd /su T oma P.
yn ' irector j ivision 'Rea or Projects Docket No.: 50-298 License No.: DPR 46 cc: John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Colurnbus, Nebraska 68602-0499 }k P. D. Graham, Vice President of I ' Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 lI!,!!ll!,kk!,!!! fi, , 9709110051 970900 PDR ADOCK 05000290
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. , , Nebraska Public Power District- -2-5. L. Houston, Nuclear Licensing and Safety Manager 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 l Ouality i P.O. Box 98922 { Lincoln, Nebraska 68509 8922
Chairman t 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 _ __ _ _ - _ _.
-_ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ - __ . . Nebraska Public Power District-4-SEP - 81997 bec to DCD (IE01) bec distrib. by RIV: Regional Administrator Resident inspector DRP Directer DRS-PSB Branch Chief (DRP/C) MIS System Branch Chief (DRP/TSS) RIV File Project Engineer (DRP/C) l i DOCUMENT NAME: R:\\_CNS\\CN706AK.MHM To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/C C:D 3P/Q l D:DRP l_ CSMarschall;df (' jar EEQoltfils TPGwynn /,/fy 9/ Li /97 9/ J /97 9/ 7/97 / ' ' DFFICIAL RECORD COPY I
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x4 Nebraska Public Power District _ "it"JKn"" % __ _ [[]j [h }] [, ' ' NLS970159 t 3> - August 25,1997 9 - 2 1997 U.S. Nuclear Regulatory Commission -- J --- Attention: Document Control Desk
REGION IV
Washington, D.C. 20555-0001 Gentlemen: Subject: Reply to a Notice of Violation l NRC Inspection Report No. 50 298/97-06 l Cooper Nuclear Station, NRC Docket 50-298, DPR-46 i Rcrerence: 1. Letter to G. R. Ilom (NPPD) from T. P. Gwynn (USNRC) dated July 25,1997, "NRC Inspection Report 50-298/97-06, Notice of Violation" By letter dated July 25,1997 (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 Notices of Violation in accordance with 10 CFR 2.201. The District admits to the violation and has completed all of the corrective actions necessary to return Cooper Nuclear Station (CNS) to full compliance with respect to the cited violation.
Should you have any questions concerning this matter, please contact me.
Sincere , - - P. D. Graham Vice President of Nuclear Energy /dm Attachment ec: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector & l da 6 6 NPG Distribution 44%gp
' . . . Attachment I to NLS970159 Page 1 of 2 REPLY TO JULY 25,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO,50-298, LICENSE DPR-46 During NRC inspection activities conducted May 18 through June 28,1997, a violation of NRC requirements was identified. The particular violation and the District's reply are set forth below: Violation 10CFR Part 50, Appendix B, Criterion V, requires, in part, that activities afecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
, Contrary to the above, on June 14,1997, the licensee 'sproceduresfor inerting containment were not appropriate to the circumstances in that they did not allow the use ofinstalled 24-inch valves; and, on May 19,1997, the licensee impicmenteda change to Procedure 2.1.1, "Startup Procedure, " which was not appropriate to the circumstances in that it would have allowed verification ofjet pump op:rability afterplacing the reactor mode switch to the "startup" position, conflicting with TechnicalSpecifications.
This is a Severity LevelIV violation (Supplement 1) (298/97006-01, EA 97-322).
Admission or Denial to Violation The District admits the violation.
Reason for Violation The cause for these procedural deficiencies are as follows: 1) With regard to the verification of the jet pump operability, this is attributed to a lack of understanding and application of procedural requirements to assure that all Technical Specifications are fulfilled and documented prior to changes in the mode switch.
2) With regard to the procedure for inerting the containment, this is attributed to an inadequate review of a procedure prior to performing an evolution involving the procedure. Procedure 2.2.60 was conservatively written to prohibit use of the 24-inch valves during containment inerting. Technical Specification 3.7.A.2.b restricts the use of the 24-inch valves to no more than 90 hours per calender year when the coolant temperature is over 212 degrees Fahrenheit. The fact that the procedure was unduly restrictive was not discovered by station personnel during the procedure review prior to the down power evolution. Therefore the cause for the procedural inadequacy was a less than adequate review by personnel who should have recognized the _
_ . . .. .. . . . .. . . ....
. . . . . Attachment I to NLS970159 Page 2 ef 2 prohibitive restriction in the procedure and initiated a procedure change to remove the barrier prior to the down power.
Corrective Steps Taken and the Results Achieved The following immediate actions have been taken: 1) Procedure 2.1.1 was revised on May 30,1997 to require that ajet pump operability check be performed fo;R.ving establishment of reactor recirculation flow but prior to a reactor mode switch change to the startup and hot standby mode.
2) Procedure 2.2.60 was revised on June 14,1997, to provide guidance to allow use of the 24-inch valves during the inerting process.
, l h addition, the following corrective actions have also been taken: ! ! 3) Emphe. size to the Shift Supervisors the requirements of Technical Specification 1.0.J to ensure safety equipment operability a required for a given mode, prior to placing the plant in that mode.
This action has been completed.
4) Prepare a Trainink Work Request (TWR) to include the lessons teamed from this condition and other similar events at other Nuclear Facilities into the License Operator Training. This action has been completed.
Corrective Steps That Will Be Taken to Avoid Further Violations The following actions will be taken to avoid the situaticas described above, or similar conditions, in the future: 1) Perform a review of the Technical Specifications to identify all operability verifications required prior to a mode change to the stactup and hot standby or the run modes, consistent with Tecimical Specification 1.0.J. The expected completion date is September 2.1997.
2) Revise, as necessary, procedure 2.1.1.2 to incorporate all of the operability verifications identified by the above Technical Specification review. The expected completion date is October 15,1997.
3) Evaluate TWR and perform License Operator Retraining to emphasize both the current requirements per Technical Specification defimition 1.0.J and related industry events. The expected completion date is January 31,1998.
. Date When Full Comnliance Will Be Achieved The District is currently in full compliance with respect to the cited violation.
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, e l ATTACHMENT 3 LIST OF NRC COMMITMENTS l Correspondence No NLS970159 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 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 Revise procedure 2.1.1 to require that a jet pump
operability check be performed following establishment of m$ ted on May 30, reuetor recirculation flow but prior to a reactor mode switch change to the startup and hot standby mode.
Revise procedure 2.2.60 to provide guidance to allow use Com leted on June 14, of the 24-inch valves during the inerting process.
l Emphasize to the Shift Supervisors the requirements of fm$etedonJuly17, Technical Specifications 1.0.J Prepare a Training Work Request (TWR)to include the lessons learned from this condition and other similar Completed on July 23, events at other Nuclear Facilities into tne License 1997 Operator Training.
Perform a review of the Technical Specifications to identify all operability verifications required prior to September 2, 1997 a mode change to the startup and hot standby mode or the run mode, consistent with Technical Specification 1.0.J Revise, as necessary, procedure 2.1.1.2 to incorporate all of the operability verifications identified by the October 15, 1997 above Technical Specification review.
Evaluate TWR and perform License Operator Retraining to emphasize both the current requirements per Technical January 31, 1998 Specification definition 1.0.J and the five related industry events.
l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 4 OF 9 l
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Entergy Operations, Inc.
Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippl 39205 General Manager, Plant Operations Waterford 3 SES Entergy Operations, Inc, P.O. Box B Killona, Louisiana 70000 Manager Licensing Manager Waterford 3 SES Enterg/ Operations, in, P.O. Box B Killona, Louisiana 70003 Chairman Louisiana Public Service Commission Ono American Place, Suite 1030 Baton Rouge, Louisiana 70825 1697 Director, Nuclear Cafety & Regulatory Affairs Waterford 3 SES Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70000 William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884 2135 Parish Presiden' St. Charles Parc ( P.O. Box 302 - Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814 ~ . ... -
. - Entergy Operations, Inc.
3-Winston & Strawn 1400 L Street, N.W.
Washington, D.C. 20005 3502 }}