IR 05000298/1997010
| ML20202H957 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/12/1998 |
| From: | Collins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-97-10, NUDOCS 9802230052 | |
| Download: ML20202H957 (5) | |
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SUBJECT:
NRC INSPECTION REPORT 50 298/9710
Dear Mr. Horn:
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Thank you for your letter of February 11,1998, in response to our letter and Notice of Violation dated January 12,1998, involving inadequate procedures for air in-leakgage testing of secondary containment doors. 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 been achieved and will be maintained.
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Sincerely,
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l Elmo E. Collins, Chief l
Project Branch C j
Division of Reactor Projects l
Docket No.: 50 298 l
License No.: DPR-46 cc:
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John R. McPhall, General Counsel
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Nebraska Public Power District P.O. Box 499 I
Columbus, Nebraska 68602-0499 l
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Nebraska Public Power District
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J. H. Swalles, 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 Dr. Wdliam 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 Linco!n, Nebraska 68509 5007
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Nebraska Public Power D' strict 3-b R. A. Kucera Department Director
of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 Kansas Radiation Controf Program Director
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Nebraska Public Power District-4-FEB l 21998 bec to DCD (IE01)
bec distrib. by RIV:
Regions! Administrator nesluont inspector DRP Director DRS PSB Branch Chief (DRP/C)
MIS System Branch Chief (DRP/TSS)
RIV File Project Engineer (DRP/C)
DOCUMENT NAME: R:\\_CNS\\CN710AK.MHM -
To receive copy of document, Indicato in bou:"C" = Copy without encio uys *E" = Copy with enclosures "N" = No copy RIV:PE:DRP/C C:D8P/,Q CSMarschall;dfGO'T EECoilfns 2/Ik/98 2/if-/98-OFFICIAL RECORD COPY s
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Nebraska Public Power District
FEB l 2 1998 l
MOCOf(IE01)M bec distrib. by RIV:
Regional Administrator Resident inspector DRP Director DRS-PSB Dranch Chlef (DRP/C)
MIS System Branch Chief (DRPRSS)
RIV File Project Engineer (DRP/C)
DOCUMENT NAME: R:\\ CNS\\CN710AK.MHM To recobre copy of document, Indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures "N" =
RIV:PE:DRP/C l C:DF3P/,Q CSMarschall;df GO'\\
EECollins 2/lk/98 2/l 4 08 OFFICIAL RECORD COPY
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NLS980017 February 11,1996 U.S. Nuclear Regulatory Comrnission Attention: Doctunent Controf Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notlee of Wlation NRC Inspection Report No. 50 29W97-10 Cooper Nuclear Station, NRC Dooket 50 298, DPR-46 Refwence:
1. leter to G. R. Ilom (NPPD) from E. B. Collins (USNRC) dated January 12,
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1998, "NRC Inspection Report 50-298/97 10 and Notice of Violation" By letter dated Jarmary 12,1998 (Reference 1), the NRC cited Nebraska Public Power District (District) for 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 the corrective actions necessary to return CNS to fhll compliance.
Should you have any questions concerning this matter, please contact me.
Sincerely,
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'o2/11/96 20:03 C402 ans 86 7 cNs uct.Ns No coon
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NL5980017 February 11,1998 Page 2 of 2 cc: Regional Admialstrator USNRC RegionIV Senior Projoot Manager USNRC - NRR ProjoM Directorate IV 1 Senior Resident Inspector USNRC NPO Distnbution
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'02/11/96 20:04 C402_ ass sta7 cNs-ucWSING Cood
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Attachment I to NLS980017 Page 1 of 2 REPLY TO JANUARY 12,1998, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50 298, LICENSE DPR-46 During NRC inspection activities conducted from November 2 through December 13,1997, one violation of NRC requirements was identlSed. The particular violation and the District's reply ate set forth below; Mainatori 10 CFR Parl 30, Appendix B, Crtterton V, requires, in part, Ilmt activities t#ecstm quaslity
.ukell be prwscribed byprocedwres ofa type tappropriate to the circumstances. These procaatres shallinclude qppropriate quantitative or qualitattw acceptance critertafor determining that important activilles haw been satisfactorily acconplished.
Contrary to the abow, as ofDecember 13,1997, Procedure 6.SC.302, " Secondary Containment Penetration & amination, " Revistort 2. which c,mducts an assesment of air in.
leannpr through redemamt secondary containment scors, an activt(y qtfccting quakty, uns twt qppropriate to the circumstances in that it dudnot include tppmpriate ~p criteria. 1hisprocedure summed the mirrimum door leakage in each set of two doors to establish the secondary containment in leakqge mte. The use of the minimum in leahngefor each door set uns potentially owncomenative.
1his is a Sewrity Lew! IV violation (Supplement 1) (30-298/9710-01)
A"--% or Danimi to Vint.sinn The District admits the siolation.
Mr Vinlatian_
The reason for this violation is that the individual failed to consider all potential oi,erating conditions when the acceptance criteria were first developed, and CNS's failure to identify interim compensatory measures for inappropriate acceptance criteria.
At no time was secondary containment challenged. An Operability Assessment (OA) determined that margin (approximately 135 cfm compared to 165 cfm using minimum flows) existed for secondary containtpent to remain operable After the SRI discussed the issue with the System Engineer, he planned to evaluate Ge procedure and make appropriate changes. On December 15,1997 (approximately two weeks later), the SRI
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Attachment I to NLS980017 Page 2 of 2 was concerned that, aAer having identified the potential nonconservative acceptance criteria, no indbemation had been provided to the operations crews indicating that the nervice margin could be less than documented in the most ecent surveillance test under abnonnal operational conditions.
A formai communication was not snade when the issue was identiSed due to the fhet that the total path leakage was still significantly less than the service margin limit, and that operations would contact the System Engirwor to ensure any work which could hnpact the available servios margin was evaluated. CNS recognizes this as a weakness in that Operations must at all times be aware of plant conditions. The System Engineet discussed the issues with the SRI and determined an immediate procedure change was in order.
Corrective Slapa Takm and the Ra-len Ac%nd Procedure 6 SC.502, " Secondary Contakunent Penetration Ev==laation" was revised on 12/17/98 to account for the possibility that the maximum leakage path may be the actual secondary containtnent boundary This revised proculare allows for conservative evaluations ofibture test results and emergent conditions.
The new Operability Determination Procedure,0.5.1, provides guidance far consideration of generic concerns, interim compensatory measures, ar.d the kupact of changes in plant conditions on operability. This procedure was made effective January 28,1998.
Cormative Stane %* Will Be Takem to Avoid Funhar Vinissions 1. Specific guidance for detennination of appropriate acceptance criteria will be develoted and incorporated in the Piucedure Writer s Guide, 2. As an enhancement, guidance for establishing appropriate interim compensatory meuures for issues ofinadequate acceptance criteria will be incorporated in CNS Procedure 0.5.1,
" Operations Review of Problem Identification Reports / Operability Detenmination "
Date When Full Comnlimace Will Be Achicyed The Distdct is in fhll compliance regarding the identined violation.
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'02/11/96 20:05 C402 626 6827 tto-tit ame t M'
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LIST [0[F NRC C080(I'DGBf78
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ArrAcmeerr 3 correspondence Nos_WLs99001'1 The following table identifies those actions committed to by the District in this document.
Any other actione discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's infor1 nation and are not regulatory comunitments.
Picago notify the Licensing Manager at Cooper Nuclear Rtation of any questions regarcing this docuar.ent or any associated regulatory conenitments.
Co>t(ITTED DATE cche<rTMENT OR QUTAGE Spooi6o guidame for detenmination of spivopriate soooptenos oriwis will be developed N/A and inearponted in ths Prosedme Wrners Guide.
As an C r-w; guidance for estoblishing appropdata interim *_e;
-- M seemeures for issues ofinadequate noceptance criterin will be inanrpar esed in CNS N/A Pseesdure 0.5.1, *0peneens Review of Pmblem identinastian ReparWOperabatty nan nnmanum a
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I paocroun utnetR 0.42 l
REVISION NUMBER 5 l
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