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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217G7401999-10-14014 October 1999 Forwards MOR for Sept 1999 for Cooper Nuclear Station. Rept Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20216J8061999-09-20020 September 1999 Forwards Rev 37 to Safeguards Plan,Iaw Provisions of 10CFR50.(p).Rev Withheld,Per 10CFR73.21 ML20212C4921999-09-15015 September 1999 Forwards Monthly Operating Rept for Aug 1999 for Cooper Nuclear Station.Rept Includes Operating Data Rept,Unit SD Rept & Documentation of Challenges to Safety/Relief Valves ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211N5271999-09-0202 September 1999 Responds to NRC 990823 RAI Re Y2K Readiness at Cooper Nuclear Station,Per GL 98-01,Suppl 1 05000298/LER-1999-006, Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl1999-08-26026 August 1999 Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl ML20211F1311999-08-24024 August 1999 Forwards Rev 1 to Calculation Nedc 97-044, NPSH Margins for RHR & CS Pumps, in Support of 990615 Proposed Amend to DPR-46 Re Containment Overpressure Contribution to ECCS Pumps NPSH Requirements 05000298/LER-1999-003, Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel1999-08-23023 August 1999 Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20210R0301999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Cooper Nuclear Station,Iaw Guidance Provided by GL 97-02.Rept Also Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6761999-08-10010 August 1999 Requests That Following Changes Be Made to Distribution on NRC Correspondence ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K6071999-08-0202 August 1999 Submits Withdrawal of Proposed License Amend Re Secondary Containment Isolation Description & Refueling Accident Analysis Results ML20210K3811999-08-0202 August 1999 Forwards Listed Info,Which NPPD Believes Demonstrates Ability to Obtain Funds in Amount of $10 Million for Payment of Such Premiums within Specified Three Month Period,Iaw 10CFR140.21 ML20210G5101999-07-28028 July 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 990101-0630,per Provisions of 10CFR26.71(d) ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20209B7851999-07-0101 July 1999 Forwards Corrected Occupational Radiation Exposure Repts, for Cys 1996 & 1997.Util Stated That Repts Did Not Properly Tabulate Number of Personnel Receiving Exposures Less than 100 Mrem by Work & Job Functions in CY96 & CY97 05000298/LER-1999-005, Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl1999-07-0101 July 1999 Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, 05000298/LER-1999-004, Forwards LER 99-004-01.Commitments Made by Util Are Encl1999-06-28028 June 1999 Forwards LER 99-004-01.Commitments Made by Util Are Encl ML20209B5451999-06-28028 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196H0331999-06-24024 June 1999 Informs NRC of Deletion of 1991 Commitment Contained in Ltr Re Feedwater Nozzle Bypass Leakage Monitoring at Plant ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20209A7221999-06-23023 June 1999 Submits Revised Pages to Proposed Change to Plant TS Previously Submitted in ,Per 990615 Telcon with NRC ML20196F5331999-06-22022 June 1999 Forwards Examination Summary Rept for FW Nozzle Examinations Performed During 1998 Fall Refueling Outage at Cooper Nuclear Station.Rept Covers Past Examinations Up to & Including 1998 Fall Refueling Outage ML20196B4681999-06-17017 June 1999 Forwards TS Bases Changes Made at Plant Subsequent to Receipt of License Amend 178,dtd 980731,for Conversion to Its,Through 990610.List of Effective Pages for TS Bases, Encl ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195H8891999-06-14014 June 1999 Forwards Response to NRC 990315 RAI Re GL 95-07, Pressure Locking & Thermal-Binding of SR Power-Operated Gate Valves, 180-day Response Submitted by District on 960213 ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20195E2351999-06-0808 June 1999 Forwards Response to NRC 990517 RAI Re Util Proposed Change to TS Re Calibr Frequency of Reactor Recirculation Flow Transmitters Associated with APRM ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217G7401999-10-14014 October 1999 Forwards MOR for Sept 1999 for Cooper Nuclear Station. Rept Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20216J8061999-09-20020 September 1999 Forwards Rev 37 to Safeguards Plan,Iaw Provisions of 10CFR50.(p).Rev Withheld,Per 10CFR73.21 ML20212C4921999-09-15015 September 1999 Forwards Monthly Operating Rept for Aug 1999 for Cooper Nuclear Station.Rept Includes Operating Data Rept,Unit SD Rept & Documentation of Challenges to Safety/Relief Valves ML20211N5271999-09-0202 September 1999 Responds to NRC 990823 RAI Re Y2K Readiness at Cooper Nuclear Station,Per GL 98-01,Suppl 1 05000298/LER-1999-006, Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl1999-08-26026 August 1999 Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl ML20211F1311999-08-24024 August 1999 Forwards Rev 1 to Calculation Nedc 97-044, NPSH Margins for RHR & CS Pumps, in Support of 990615 Proposed Amend to DPR-46 Re Containment Overpressure Contribution to ECCS Pumps NPSH Requirements 05000298/LER-1999-003, Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel1999-08-23023 August 1999 Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel ML20210R0301999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Cooper Nuclear Station,Iaw Guidance Provided by GL 97-02.Rept Also Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20210P6761999-08-10010 August 1999 Requests That Following Changes Be Made to Distribution on NRC Correspondence ML20210K6071999-08-0202 August 1999 Submits Withdrawal of Proposed License Amend Re Secondary Containment Isolation Description & Refueling Accident Analysis Results ML20210K3811999-08-0202 August 1999 Forwards Listed Info,Which NPPD Believes Demonstrates Ability to Obtain Funds in Amount of $10 Million for Payment of Such Premiums within Specified Three Month Period,Iaw 10CFR140.21 ML20210G5101999-07-28028 July 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 990101-0630,per Provisions of 10CFR26.71(d) 05000298/LER-1999-005, Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl1999-07-0101 July 1999 Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl ML20209B7851999-07-0101 July 1999 Forwards Corrected Occupational Radiation Exposure Repts, for Cys 1996 & 1997.Util Stated That Repts Did Not Properly Tabulate Number of Personnel Receiving Exposures Less than 100 Mrem by Work & Job Functions in CY96 & CY97 05000298/LER-1999-004, Forwards LER 99-004-01.Commitments Made by Util Are Encl1999-06-28028 June 1999 Forwards LER 99-004-01.Commitments Made by Util Are Encl ML20209B5451999-06-28028 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196H0331999-06-24024 June 1999 Informs NRC of Deletion of 1991 Commitment Contained in Ltr Re Feedwater Nozzle Bypass Leakage Monitoring at Plant ML20209A7221999-06-23023 June 1999 Submits Revised Pages to Proposed Change to Plant TS Previously Submitted in ,Per 990615 Telcon with NRC ML20196F5331999-06-22022 June 1999 Forwards Examination Summary Rept for FW Nozzle Examinations Performed During 1998 Fall Refueling Outage at Cooper Nuclear Station.Rept Covers Past Examinations Up to & Including 1998 Fall Refueling Outage ML20196B4681999-06-17017 June 1999 Forwards TS Bases Changes Made at Plant Subsequent to Receipt of License Amend 178,dtd 980731,for Conversion to Its,Through 990610.List of Effective Pages for TS Bases, Encl ML20195H8891999-06-14014 June 1999 Forwards Response to NRC 990315 RAI Re GL 95-07, Pressure Locking & Thermal-Binding of SR Power-Operated Gate Valves, 180-day Response Submitted by District on 960213 ML20195E2351999-06-0808 June 1999 Forwards Response to NRC 990517 RAI Re Util Proposed Change to TS Re Calibr Frequency of Reactor Recirculation Flow Transmitters Associated with APRM ML20207A0701999-05-19019 May 1999 Forwards Rev 3 to CNS Strategy for Achieving Engineering Excellence, Which Provides Effective Tool for Overall Engineering Work Mgt.Commitments Made by Util,Encl ML20206R7601999-05-17017 May 1999 Forwards Annual Radiological Environ Rept,Radiological Environ Monitoring Program,Jan-Dec 1998,per TS 5.6.2 ML20206P9681999-05-13013 May 1999 Forwards Monthly Operating Rept for Apr 1999 for Cooper Nuclear Station.Rept Includes Documentation of Challenges to Safety/Relief Valves ML20206J0741999-05-0404 May 1999 Forwards Rev 14 to CNS QA Program for Operation, Per 10CFR50.54(p) & 10CFR50.71.None of Changes Represent Reduction of Commitments.Summary of Changes,Encl ML20206J2331999-05-0303 May 1999 Forwards CNS Annual Radioactive Effluent Release Rept for 1998 & Offsite Dose Assessment Manual ML20206F2021999-04-30030 April 1999 Informs That NPPD Now Anticipates LAR Committed in Will Be Submitted by 990615.Operability Evaluations Presently in Effect Ensure That ECCS Pumps Are Operable But Nonconforming & Are Capable of Fulfilling Safety Functions ML20206E5461999-04-29029 April 1999 Forwards Cooper Nuclear Station Occupational Radiation Exposure Rept for 1998. Numbers Reported Reflected Tabulation of All Personnel on Site by Work & Job Function. Repts Will Be Corrected & Resubmitted by 990701 ML20205K1151999-04-0101 April 1999 Submits Extension of Commitment Date for Rev to Plant Strategy for Achieving Engineering Excellence from 990331 to 990519.Licensee Requires Addl Time to Finalize & Approve Rev 3 to Plant Strategy for Achieving Engineering Excellence ML20205E4331999-03-31031 March 1999 Forwards First Biennial Rept of Financial Assurance for Decommissioning for Cns,Per 10CFR50.75(f)(1) ML20205A0561999-03-23023 March 1999 Provides Info Detailing Property Insurance Coverage Maintained by NPPD & Midamerican Energy Co for Cns,In Compliance with 10CFR50.54(w)(3) 05000298/LER-1999-001, Forwards LER 99-001-00,including List of NRC Commitments Made by Util1999-03-22022 March 1999 Forwards LER 99-001-00,including List of NRC Commitments Made by Util ML20204G8811999-03-22022 March 1999 Forwards CNS Inservice Insp Summary Rept,Fall 1998 Refueling Outage (RFO-18), IAW Provisions of 10CFR50.55a. Analytical Evaluation for RPV Shell Weld Indications & Augmented Exam Results of RPV Also Included ML20204J4841999-03-19019 March 1999 Requests NRC Review & Approval of CNS ISI Relief Request (RR) PR-04,rev 1.ISI RR PR-04,rev 0 Required CNS to Perform Visual Insp of RPV Head Flange Seal Leak Detection Line. Approval Is Required Because Test Methodology Was Changed 05000298/LER-1998-013, Forwards LER 98-013-01 Re Missed Surveillance of Secondary Containment Isolation Valve.List of NRC Commitments Encl1999-03-16016 March 1999 Forwards LER 98-013-01 Re Missed Surveillance of Secondary Containment Isolation Valve.List of NRC Commitments Encl ML20204C9641999-03-15015 March 1999 Forwards Monthly Operating Rept for Feb 1999 for Cooper Nuclear Station.Rept Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20207J5811999-03-10010 March 1999 Forwards Rev 1 to Calculation Nedc 98-024, APRM - RBM Setpoint Calculation ML20207F9661999-03-0101 March 1999 Responds to NRC Re Violations Noted in Insp Rept 50-298/98-08.Corrective Actions:Circumstances Surrounding Four Examples Have Been Discussed with Individuals Involved & Counseled,Where Appropriate ML20203C6961999-02-0808 February 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 980701-1231,per 10CFR26.71(d) ML20202H6721999-02-0202 February 1999 Informs of Changes in Schedule Affecting Four Commitments in ,By Greater than One Month & Notifies of Plans to Issue Rev 3 to Strategy for Achieving Engineering Excellence ML20202E2231999-01-28028 January 1999 Forwards Response to NRC 980603 RAI Re NRC Ongoing Review of IPEEE for Cooper Nuclear Station,Submitted 961030 ML20199K6721999-01-19019 January 1999 Requests Extension of Present Due Date to 980202,as Addl Time Is Required to Resolve Issues Raised on Corrective Actions During Senior Mgt Review of Insp Rept 50-298/98-15 05000298/LER-1998-011, Forwards LER 98-011-00,per 10CFR50.73(a)(2)(v).Commitments Made by Util,Encl1999-01-19019 January 1999 Forwards LER 98-011-00,per 10CFR50.73(a)(2)(v).Commitments Made by Util,Encl ML20199E6281999-01-14014 January 1999 Forwards Monthly Operating Rept for Dec 1998 for Cooper Nuclear Station.Rept Also Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20206P4171998-12-31031 December 1998 Informs of Extended Completion Due Date of Third Commitment Re EOP Calculations,Per Licensee 980723 Response to Violations Noted in Insp Rept 50-298/98-02.Date Has Been Extended to 990228 ML20199D2251998-12-30030 December 1998 Forwards 1998 CNS Simulator Certification Rept,As Required by 10CFR55.45.Rept Describes Performance Tests Conducted from 1995-98,discusses Performance Test Discrepancies from 1995-98 & Provides Revised Test Plan for 1999-2002 ML20198K2491998-12-23023 December 1998 Discusses RAI Re Response to NRC GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps ML20205A4411998-12-17017 December 1998 Forwards Initial Exam Outline for RO Written Exam to Be Given Week of 990208.Preliminary Copies of License Applications for Candidates Encl ML20196C4011998-11-20020 November 1998 Forwards Rev 1 to Cooper Nuclear Station COLR Cycle 19. Licensee Discovered That COLR Submitted with Contained Incorrect Max Average Planar Linear Heat Generation Rate Curves Specified in Figures 1 to 4 1999-09-20
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P.O. BOX NFB SKA 68321 T&Ni M Nebraska Public Power District _
NLS950081 March 23,1995 Director, Office of Enforcement U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Reply to a Notice of Violation and Enforcement Discretion, dated February 21, 1995 (EA 95-012)
(NRC Investigation Report No. 4-93-020R and EA 94-177)
Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. NRC Letter from James L. Milhoan to NPPD dated November 10,1994,
" Demand for Information."
l
- 2. NPPD Letter from Guy R. Horn to NRC dated December 12, 1994,
" Cooper Nuclear Station- Reply of NPPD to Demand for Information of November 10,1994."
- 3. NPPD Letter from Guy R. Horn to NRC dated December 23, 1994, regarding Station Operations Review Committee (SORC) improvements.
Gentlemen:
This letter and its Attachment constitute Nebraska Public Power District's (the District) reply to the subject Notice of Violation (NOV) and Enforcement Discretion in accordance with 10 CFR 2.201. The violations alleged in the NOV pertain to the movement of heavy loads over irradit ted fuel prior to establishing secondary containment integrity at Cooper Nuclear Station (CNS. in March of 1993. In sum, Part A of the NOV states that the reactor pressure vessel (RPV) head, dryer, and separator were moved without secondary containment integrity being i established in violation of Technical Specification (TS) 3.7.C.1.d (secondary containment integrity required during movement of loads which have the potential to damage irradiated fuel).
Part B of the NOV states that the Procedure Change Notices (PCNs) approved to eliminate the procedural requirement for secondary containment integrity during removal of the reactor pressure vessel head, dryer, and separator were not accurate in all material respects as required l by 10 CFR 50.9.
The District takes the violations seriously and has conducted a careful and thorough review of this matter. The District's letter to the NRC dated December 12,1994 (Reference 2), in response to the NRC Demand for information (DFI) (EA 94-177) (Reference 1), has addrsssed the substance ogvj9%tyns. ,
9503290098 950323 }8 PDR ADOCK 05000298 ,
O PDR
. Director, Offica of Enforcemtnt U. S. Nuclear Regulatory Commission March 23,1995 Page 2 of 3 With respect to the violation of 10 CFR 50.9, the District stated in Reference 2 (page 5) that I the PCN form reviewed by the Station Operations Revie w Committee (SORC) on March 9,1993 i should have been complete and accurate in all material espects, but contained some potentially confusing information concerning TS Amendment 147 and, arguably, TS Amendment 150.
Accordingly, the District admits the violation of 10 CFD 50.9 as explained in the attached NOV response (Attachment 1). ,
With respect to Part A of the NOV, in hindsight, we understand how the decision reached by SORC could be viewed as a nonconservative interpretation of TS 3.7.C.1.d. The District, therefore, accepts this violation. TS 3.7.C.1.d does not explicitly describe the movement of RPV disassembly loads or specify other loads that are covered. At the time of the March 9, 1993 SORC approval of the procedure changes associated with movement of the RPV disassembly loads,it could no2 be established with certainty that the proposed changes could be made consistently with the Technical Specifications. ,
As requested on page 4 of the NOV, the District has documented the improvements made and planned to ensure that the processes used to review proposed changes to the Technical Specifications and associated procedures are appropriate (see References 2 and 3 in addition to the responsive actions discussed under Violations A and B of this document).
The NRC stated that it had determined not to propose a civil penalty for the violations. Instead, ,
the NRC exercised enforcement discretion (as described in Section Vll.B.6 of the NRC Enforcement Policy,10 CFR Part 2, Appendix C). The District agrees with the NRC's exercise of enforcement discretion and believes that no purpose would be served by the imposition of a civil penalty. ,
l Should you have any questions concerning this matter, please contact my office. <
Sincerely, i l
l MM John H. Mueller Acting Vice-President, Nuclear Attachment cc: Regional Administrator USNRC Region IV NRC Resident Inspector Cooper Nuclear Station NPG Distribution l l
l 4
. Dircct:r, Offica of Enfore:m:nt I U. S. Nuclear Regulatory Commission !
March 23,1995 Page 3 of 3
)
STATE OF NEBRASKA)
)
NEMAHA COUNTY )
J. H. Mueller, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this response on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.
I b>]
J. H. Mueiler Subscribed in my presence and sworn to before me this 23 day of Lfft4Ib ,1995.
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$TARY PUBLIC D
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- Attzchment 1 :
to NLS950081. l Page 1 of 5- .l
REPLY TO FEBRUARY 21,1995 NOTICE OF VIOLATION AND ENFORCEMENT DISCRETION - EA NO.95-012 I (NRC INVESTIGATION REPORT NO. 4-93-020R AND EA 94-177) [
COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR :
i In its letter to the District dated February 21,1995, the NRC identified two violations of NRC :
requirements. These violations were classified as a single Severity Level lli problem.
The particular violations (Parts A and B of the NOV) and the District's replies are set forth
- below:
Statement _of_Violatian_A Technical Specification (15) 3.7.C.I.d, " Secondary Containment," requires that secondary containment integrity shall be maintained in allmodes ifirradiatedfuelis being handledin the secondary containment andloads which couldpotentially damage irradiatedfuel are being moved '
in the secondary containment. ,
i Contrary sc the above, on March 10,1993, the reactorpressure vessel head, dryer, and separator, ;
which were loads that had thepotential to damage irradiatedfuel, were movedin the secondary I containment without secondary containment integrity being maintained. . The results of a surveillance test cemduded to demonstrate secondary containment integrity, performed on March 8,1993, were unsatisfactory. The test was not satisfactorily performed untilMarch 11,1993. . ,
Admissiottor_Denialnf_ Violation i i
For the reasons discussed below, the District accepts the violation.
ReasonsJor_ Violation )
As explained in Reference 2 (page 34), the language of TS 3.7.C.1.d (". . . no loads I which could potentially damage irradiated fuel . . .") could be considered unclear. The i TS provides a functional standard, as opposed to a definite quantifiabla standard, for i determining which loads are permitted to be moved without prior testing to verify secondary containment integrity. A judgment must be made as to whether a particular load could potentially damage irradiated fuel. This leaves the TS open to differing interpretations. The SORC, at the March 9,1993 meeting, made a judgment as to the intent of TS 3.7.C.1.d. The District accepts that the SORC decision could be viewed as I
nonconservative as underscored in the NOV.
i l
- Attachm:nt 1 ~l to NLS950081 Page 2 of,5 The District believed that various documents including NUREG-0612 and General Electric PRC 88-11 (discussed in detailin Reference 2) provided a threshold of load movements that could occur without additional analysis:
In accordance with NUREG-0612, " Control of Heavy loads at Nuclear Power Plants" (July 1980), the District had chosen to utilize a single-failure proof design for the reactor building crane. As allowed by NUREG-0612, this was done in lieu of a load drop analysis demonstrating that the effects of dropping heavy loads such as the RPV head and internals would remain within specified limits. The NRC accepted the District's Phase Iimplementation of NUREG-0612 guidelines in a Safety Evaluation Report dated October 31,1983. Accordingly, the failure j of the crane was not considered credible.
l The interpretation that TS 3.7.C.1.d did not include disassembly loads appeared I
consistent with a docketed NRC Staff position (March 28,1988 memorandum from NRC Project Manager to the District and NRC Inspection Report 88-07, page 9, dated May 11, 1988) that the performance of the secondary containment surveillance test was not required until actual handling of irradiated fuel was to begin. Therefore, RPV disassembly could proceed prior to completing the secondary containment leak test as long as the test was successfully completed " prior to refueling," which had br.en interpreted by the NRC to mean prior to actual movement of irradiated fuel.
It was not the District's intent when it took the initiative in 1991 to amend TS 3.7.C.1.d (approved by the NRC as Amendment 147) to change its prior practices for RPV disassembly. The District had performed such heavy load movements during prior outages. As explained in Reference 2. the provision added to TS 3.7.C.1.d in 1991 was intended to address the movement of much smaller loads (e.g., a local power range monitor over the open RPV or the spent fuel pool), which were not necessarily as well controlled as movement of heavy loads.
The District believes that it is entitled to rely on its choice of using a single-f ailure proof crane, in lieu of providing analysis of heavy load drops, as a means of reducing the potential for accidental dropping of heavy loads in accordance with NUREG-0612.
Moreover, the NRC indicated prior (1983) acceptance of the District's Phase i NUREG-0612 implementation (where this position was articulated).
Corrective 3tepslaken_and_thallesultsLAchieved The District has implemented broad based actions to ensure the effectiveness of SORC as detailed in the Phase i Performance Improvement Plan Action (see also Reference 3).
The actions taken include:
- 1. Changing the composition of SORC with the addition of the new Plant Manager (Chairman), the new Engineering Manager (Vice Chairman), and the new Operations Manager;
- 2. The new SORC Chairman has established new standards and expectations for SORC meetings, with a broadened focus on the nuclear safety aspects of the l
issues presented;
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' 3. A'SORC Administrator has been appointed to improve meeting coordination and '
conduct, es.well as the quality and completeness of SORC records;
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- 4. The governing procedure for the SORC was revised. it now more accurately ;
describes SORC activities and clarifies SORC's focus on issues relevant to . t nuclear safety and the proper identification and addressing of safety implications: 'f
- 5. ' A Nuclear Safety Training course has b'een provided to SORC' members and' ;
alternates. l The District believes that it is prudent to have Secondary Containment Integrity.,
established prior to RPV disassembly. Accordingly, the associated procedures have been j revised to reflect this. l
- Correctiva_ Steps That_WilLBa Takan to Avoidfurther Viniations v
The District has proposed changes to the CNS Technical Specifications which, among other changes, would clearly and more specifically restrict the ability to move heavy !
loads which could potentially damage irradiated fuel.
The District has commissioned an Improved Standard Technical Specifications ;
conversion assessment for CNS the purpose of which is to determine the feasibility and l practicality of converting to the improved Standard Technical ' Specifications. 1 Completion of this assessment is expected by mid-year,1995. One advantage of the )
Improved Standard-Technical Specifications is the enhanced Bases Section which I describes in detail the meaning and purpose of each Technical Specification, j l
Data _When Full Compliance Will Be Achiavad -
CNS is in full compliance with the requirements for maintaining Secondary Containment- 'l Integrity when loads that could potentially damage irradiated fuel are being moved in the Secondary Containment. .
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Statement _nf_ViolatiorLB ;
10 CFR 50.9, " Completeness andAccuracy ofInformation," requires, in part, that information l required by the Commission 's regulations, orders, or license conditions, to be maintained by the .I licensee shall be complete and accurate in all material respects. !
I Contrary to the above, Procedure Change Notices (PCNs), dated March 9,1993, pertaining to Maintenance Procedures 7.4.4, 7.4.5, and 7.4.6, which are records required by the TS to be maintained, were not accurate in all material respects. The PCNs approved changes to ,
maintenanceprocedures which eliminated the requirement that secondary containment integrity ;
he maintained during removal ofthe readorpressure vessel head, dryer, and separator. Sedion !
i 6 ofthe PCNs stated, in part, " tech. spec changes l amendments to thefacility operating license] 147 and 150 removed the requirements to demonstrate secondary containment prior to the time the .
primary containment is openedfor refueling," and Sedian S ofthe PCNs indicate that the PCNs :
constituted a change to the Technical Specifications approved by License Amendments 147 and 'l 150. Infad, License Amendment 147 imposed a requirement to maintain secondary containment l integrity during movement ofloads with the potential to damage irradiatedfuel, and neither
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' to NLS950081 Page 4 of 5 License Amendment 147 por 150 constitutedprior approval of the changes to Maintenance lyocedures 7.4.4, 7.4.5, and 7.4.6 to eliminate the requirementfor secondary containment integrity :
during reactor pressure vessel head, dryer, and separator removal. These inaccuracies were material because the decision ofthe Station Operations Review Committee to approve the PCNs resultedin the nun'ement ofthe reactor vessdpressure head [ sic], dryer, and separator in violation of TS 3. 7.C1.d.
Adtnission_ar_Danialta_ Violation The District admits the violation.
Reasons _for._ Violation As explained in detail on pages 25-32 of Reference 2, the District concurs that the information on the PCN forms should have been complete and accurate in all material respects, but were partially in error and potentially confusing. Specifically, Section 5 of the PCNs dated March 9,1993 indicated that the proposed revisions to procedures involved a change to the Technical Specifications and Section 8 contained a statement indicating that TS Amendment 147 " removed" requirements to demonstrate secondary containment capability prior to the time the primary containment is opened for refueling.
The District's review indicated that the errors in the PCN forms were inadvertent. The references in question were added for the purpose of disclosing to SORC members the ;
results of research on the proposed procedure changes, including NUREG-0612 and other pertinent documents, which indicated that prior TS amendments (147 and 150) were relevant to the procedure changes under consideration.
Correctiva_Stepslaken_and_tha_Besults.Achiavad To avoid the possibility of confusion involving the relationship between previous TS amendments and proposed changes to procedures, the PCN form has been revised to ask specifically if a Tech Spec change is required prior to PCN approval.
The specific PCNs dated March 9,1993, pertaining to Maintenance Procedures 7.4.4, 7.4.5, and 7.4.6 have been superseded by subsequent procedure revisions.
The PCN files for the affected procedures have been annotated to indicate the discrepancies that existed as referenced in this NOV. ;
The Phase 1 Performance improvement Plan for improving SORC effectiveness has been completed. The District believes that the corrective actions (discussed in more detail in Violation A) have improved SORC ability to ensure completeness and accuracy of information.
Corrective _Stepslhat_WilLBelaken_ta. Avoid _Eurther_Vintations The District believes that the PCN form change coupled with the previously noted broad based corrective actions to restore the effectiveness of SORC will avoid further violations of this nature and enhance the safety culture at CNS.
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Data _When' Full Comnliance Will En Achiaved With respect to the PCN form discrepancies referenced in the NOV, the District is in full -
. compliance.
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o l LIST OF WRC COMMITMENTS l ATTACHMENT 3 l Correspohdence No: NLS950081 The following table identifies those actions conunitted 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 The District has commissioned an Improved Standard Technical Specifications conversion assessment for CNS June 30, 1995 the purpose of which is to determine the feasibility and practicality of converting to the Improved Standard Technical Specifications.
PROCEDURE NUMBER 0. 42 REVISION NUMBER 0 PAGE 10 OF 16