ML20129C388
| ML20129C388 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/09/1996 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS960187, NUDOCS 9610240012 | |
| Download: ML20129C388 (6) | |
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t COOPER NUCLEAR STATION P.O. 90X 96, BROWNVILLE. NEBRASKA 68321 Nebraska Public Power District mg"g2rd'"
P. D. Graham Vice President, Nuclear (402) 825-5769 NLS960187 October 9,1996 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-13 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from J. E. Dyer (USNRC) dated September 9,1996, "NRC Inspection Report 50-298/96-13 and Notice of Violation" By letter dated September 9,1996 (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation of NRC requirements. This letter, including, constitutes the District's reply to the referenced Notice of Violations in accordance with 10 CFR 2.201. The District admits to the violations and has completed all corrective actions necessary to return CNS to full compliance with respect to the identified violations.
Should you have any questions concerning this matter, please contact me.
Sincerely, P. D. Graham Vice President - Nuclear 7-(
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4 4 e 6 NLS960187 October 9,1996 Page 2 of 2 cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution i i l l l l 1 i
to NLS960187 Page 1 of 3 REPLY TO SEPTEMBER 9,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCFET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from June 16,1996, through July 27,1996, two violations of NRC requirements were identified. The particular violations and the District's reply are set forth below: A. "10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures. Procedure 7.11, ' Reactor Building RoofAccess Hatch Operation and Maintenance,' Revision 2.1, Step 7.5, requires Shift Supervisor signature and date on an attachment of the procedure prior to accessing the reactor building roof via the reactor building hatch. Step 9.1 requires that, during hatch restoration, Operations verify that the reactor building hatch was closed, sealed tight, and locked. Contrary to the above: On June 19,1996, a security officer, a radiation protection technician, and two engineers opened the reactor building hatch without the shift supervisor's approval. As of June 20,1996, the reactor building hatch had not been verified by Operations to be restored. B. 10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions orprocedures ofa type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures. Procedure 2.0.1, ' Plant Operations Policy,' Revision 27, Step 8.4.2, states that approved procedures require step-by-step adherence by all personnel. Contrary to the above, the following procedures were not adhered to step by step: 1. On June 15,1996, Section 8.2 ofProcedure 4.15, ' Elevated Release Point and Building Radiation Monitoring Systems,' Revision 14, was performed without performing Section 8.1 where the step to open the suction valve was located. Procedure 4.15 does not state that each section can be performed independently. 2. On April 10,1996, Step 8.10.2.4, to open the pump suction valve, ofProcedure 6.4.6.4.1, ' Turbine Building Kaman Monitor Calibration,' Revision 5, was not performed, resulting in the turbine building radiation monitor being returned to operable status with the pump suction valve closed. 3. On July 14,1996, maintenance technicians, while performing Procedure 7.2.55.1, ' Replacement ofHCU Accumulator,' Revision 2, removed the cart before directed by Step 8.5 and before the fasteners were torqued. 1 j
Attachment I to NLS960187 Page 2 of 3 4. On July 11,1996, while performing Procedure 6.1EE.302, '4160v Bus 1F Undervoltage Relay and Relay Timer Functional Test,' Revision 0, the operator logged the allowed outage stop time at Step 8.187 instead ofStep 8.189." Admission or Denial to Violations The District admits the violations. Reason for Violation A. This violation resulted from personnel failing to implement Procedure 7.11 due to an unawareness of procedural control of the secondary containment hatch, lack of signage indicating requirements for access and egress, and the lack of a questioning attitude by the personnel involved. Corrective Steps Taken and the Results Achieved - Violation A. Operations immediately declared Secondary Containment inoperable and entered the Technical Specification 3.7.C action statement. Within three hours Operations performed Surveillance Procedure 6.SC.502 to verify the integrity of the reactor building hatch prior to declaring secondary containment operable. The unescorted badges of the two engineering contractors were withheld pending a review of the event. The badges have since been reactivated. Placards were placed on the ladder leading to the hatch and on the hatch indicating that the hatch is a secondary containment boundary and that the requirements of Procedure 7.11 must be met before opening the hatch. Security Procedure 2.8 was revised to require Security Shift Supervisor approval ofissuing the reactor building roof hatch key after coordination with the Station Shift Supervisor. Corrective Steps That Will Be Taken to Avoid Future Violations - Violation A. No further corrective actions are required. Reason for Violation B. Collectively, the four examples resulted from personnel failing to follow procedure. l Corrective Steos Taken and the Results Achieved - Violation B. On July 25,1996, CNS stopped plant work and training activities so that departmental meetings could be held to focus attention on current problems regarding procedural compliance. Several issues were identified during this meeting and are being resolved through the corrective action process. The stand down continued until departmental managers were confident that expectations regarding procedural compliance were clearly communicated and understood. The specific procedural violations are being discussed with personnel from the applicable departments.
Attachment I to NLS960187 Page 3 of 3 Corrective Steps That Will Be Taken to Avoid Future Violations - Violation B. 1. Procedure 4.15 will be revised by November 19,1996, to create independent sections for placing either the normal or high range monitors in service. 2. Kaman calibration procedures will be revised by December 3,1996, to include specific check offs or initials when component manipulations are performed. 3. The crew leader was counseled regarding this event and no further corrective steps are required. 4. Allowed Outage Time implementation guidance will be reviewed for appropriate application by December 11,1996. Date When Full Compliance Will Be Achieved The District has completed all corrective actions necessary to return CNS to full compliance with respect to the identified violations. l l l
ATTACHMENT 3 LIST OF NRC COMMITMENTS Correspondence No: NLS960187 _ 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 Procedure 4.15 will be revised to create independe placing either the normal or high range momtors mnt sect, ions for November 19,1996 service. Kaman calibration procedures will be revised to include specific December 3,1996 check offs or initials when component manipulations are performed. Allowed Outage Time implementation guidance will be reviewed for December 11,1996 appropriate application. l PROCEDURE NUMBER 0.42 l REVISION NUMBER 1.2 l PAGE 8 OF 10 l}}