ML20063M180
| ML20063M180 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/04/1994 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS946080, NUDOCS 9403110054 | |
| Download: ML20063M180 (3) | |
Text
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M COOPER NUCLEAR STATION
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P.O. BOX 98, BROWNVILLE, NE 68321 m-Ed.
TELEPHONE:(402) 825-5769
) Nebraska Publ.ic Power District-r^xa402) s23-5384 -
a x-1 GUY R. HORN L Vice-President, Nuclear (402) 825-5769
'CNSS946080 March 4, 1994 U. S. Nuclear Regulatory Commission Docimient Control Desk Washington, DC 20555 Subj ec t : NPPD Response to IE Inspection Report No. 50-298/93-029
Dear Sir:
This letter is written in response to your letter dated February 3,
- 1994, transmitting IE Inspection Report No. 50.-298/93-029. Therein you indicated that certain of our activities were in violation of NRC requirements.
7 Following is the statement of the violation and our response in accordance with-10 CFR 20.201:
Statement Of Violation 10 CFR' Part 50, ' Appendix B,
Criterion V,
" Instructions, Procedures, - and -
3 Drawings," states, in part, " Activities affecting 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."
.. i Station Procedure 7.0.4, " Conduct of Maintenance," Revision 0, Step 8.4.1, states that lube oil samples taken from rotating equipment are analyzed for wear products and the results are sent to the system engineer for review and trending.
Contrary to the above, six lube oil samples taken in the period of December 1992 through November 1993 from the safety-related Reactor Core Isolation Cooling system were not sent out for analysis of wear products and, consequently, no system engineer review and trending was performed.
This is a Severity Level IV violation (Supplement I).
Reason For The Violation
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In' addition to:the discussion of sampling and analysis of lube oil.. step.8.4.1 also refers the ' individual to Maintenance Procedure (MP) '7.0.9, " Lubrication and -
t Hydraulic 011 Sampling. "
Step 8.2.4 of MP 7.0.9 - requires the ' oil sample be.
forwarded to Health Physics for radionuclide analysis. Some of the monthly oil 1-samples taken from the RCIC turbine were contaminated with low levels. of i
radioactivity and could not be released uncontrolled for laboratory analysis. f 0
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- U.S. Nuclear Regulatory Commission March 4. 1994 Page 2 3
Prior to November 1993, the. District did not have access to a laboratory that' accepted radioactively contaminated samples.
The District recognized the need to have a laboratory that accepts radioactively contaminated oil samples following the failure of both Reactor Water-Clean Up (RWCU) pumps in October 1993, and had taken steps to secure the services of such laboratory.. Historically, the need for - such a laboratory had not been a
acknowledged, because it was not recognized that oil sample analysis was a procedural requirement, necessary to be performed on a consistent basis in order to properly monitor equipment performance; and because the number of contaminated samples not being analyzed was small.
For example, only 14 out of 199. samples (7%) taken in 1993 were not sent due to being radioactively contaminated.
Corrective Steps Which Have Been Taken And The Results Achieved r
The District has contracted with PdMA Corporation of Tampa, Florida to analyze oil samples which are contaminated with low levels of radioactivity, and all samples are now being analyzed, Corrective Steps Which Will Be Taken To Avoid Further Violations This incident, and the underlying procedural requirement, will' be discussed with the involved craft and supervisory personnel as an example of working around a known problem.
Date When Full Compliance Will Be Achieved Cooper Nuclear Station is currently in full compliance. The incident review with the involved craf t and supervisory personnel will be completed on or before April 1, 1994.
Unresolved Item (298/93029-02)
The inspection report discussed an event that resulted from the failure to follow procedures. The issue was identified as an unresolved item pending NRC. review of corrective action.
To address this and other human performance - issues, 5
Operations Department personnel met on January 7 and February 16, 1994, to review several recent operational events involving human error.
Discussions are continuing and recommendations to prevent recurrence are being developed.
For.
example, actions have been initiated to provide training on fuse identification, improve fuse labeling, and to label panel doors in the Control Room and Auxiliary Relay Room. In addition, an INPO assist team evaluation of human performance was i
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U,S Nuclear Regulatory Conunission March 4, 1994 Page 3 conducted during the period of February 14 through 16, with a written report including recommendations to follow.
If you have any questions regarding this response, please contact me.
Sin erel',
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U. S. Nuclear Regulatory Conunission Resident Inspector Regional Office - Region IV Cooper ~ Nuclear Station i
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