ML20129F529
| ML20129F529 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/30/1996 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20129F535 | List: |
| References | |
| NUDOCS 9610020009 | |
| Download: ML20129F529 (5) | |
See also: IR 05000298/1995018
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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September 30, 1996
EA 96-202
Guy R. Horn, Vice President - Nuclear
Nebraska Public Power District
141415th Street
Columbus, Nebraska 68601
SUBJECT:
NOTICE OF VIOLAriON (NRC Inspection Report 50 298/96-18and
Investigation Case No. 4-96-002)
Dear Mr. Horn:
This refers to the matters discussed at the predecisional enforcement conference
conducted on August 5,1996, at the NRC's office in Arlington, Texas. As indicated in our
letter dated June 27,1996, the conference was conducted to discuss apparent violations
related to a control rod mispositioning event that occurred on January 7,1996, at the
Cooper Nuclear Station (CNS). A summary of the predecisional enforcement conference,
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including the information presented by the Nebraska Public Power District (NPPD) at the
conference, was issued on August 7,1996. Subsequent to the conference with NPPD,
the NRC also conducted individual conferences with two former CNS licensed operators
who were involved in the rod mispositioning event.
Based on the information developed during the inspection and investigation, a review of
NPPD's investigation of this matter, and the information obtained from the conferences,
the NRC has determined that violations of NRC requirements occurred. These violations
are cited in the enclosed Notice of Violation (Notice). Each involves a f ailure by licensed
operating personnel to follow procedural requirements, including: 1) a f ailure to insert
control rods in the proper sequence following a loss of a reactor recirculation pump; 2) a
f ailure to notify shif t supervision of an unexpected situation, i.e., a mispositioned control
rod, for approximately 20 minutes; and 3) a f ailure to obtain the concurrence of the shif t
supervisor and reactor engineer in developing a recovery plan for a rnispositioned control
rod.
This event began when the involved operators, after being directed to insert control rods in
reverse sequence following a reactor recirculation pump trip, mistakenly inserted control
rods on the wrong page of the control rod sequence book. The operators recognized their
mistake but continued inserting control rods without notifying shif t supervisory personnel
of their error and without seeking concurrence in a recovery plan. This event was
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investigated by NPPD and resulted in NPPD terminating the involved licensed operators.
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The NRC agrees with NPPD's expectation that the operators should have promptly
informed shift supervisory personnel of their mistake and the abnormal conditions that
developed. The information available to the NRC, however, does not support a conclusion
that they intentionally violated any CNS procedural requirements. Although their actions
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9610020009 960930
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violated CNS procedures and NPPD management expectations, the operators appear to
have been focused on inserting control rods to avoid exceeding plant administrative limits
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and an automatic plant trip. And, while they should have been mindful of the procedural
requirements, they were not. The f acts that they maintained accurate logs and informed
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the reactor engineer of the mistake when he approached the panel do not suggest a
deliberate intent to cover up their mistake or violate procedures.
The NRC recognizes that the actions taken by the involved operators did not place the
plant in an unsafe condition. Nonetheless, there is regtJatory significance to !icensed
operators;not recognizing their cbligation to obta:n shif t supervisor and reactor enoineer
concurrence before proceeding to insert control rods in this situation. The NRC also
attaches regulatory significance to the fact that the control room supervisor, despite being
aware that the operators were inserting rods on the Emergency Control Rod Movement
sheet, an unusual situation, did not take action to determine what was occurring and to
understand the situation. As noted in NPPD's investigation of this matter, the control room
supervisor's attention appears to have been focused heavily on balance of-plant activities.
While the NRC does not conclude that the control room supervisor's actions violated the
Conduct of Operations procedures, an apparent violation discussed at the conference, this
remains a concern. Finally, the NRC notes that NPPD's investigation team found
inconsistent crew members' knowledge of the requirements of CNS procedure 10.13,
" Control Rod Sequence and Movement Control," which calls into question the adequacy of
CNS's training on the specific requirements of this procedure.
Based on the regulatory significance of these violations, they have been categorized in the
aggregate in accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level lli problem.
In accordance with the Enforcement Policy, a civil penalty, with a base value of $50,000,
is considered for a Severity Level ll1 problem. Because your facility has been the subject of
escalated enforcement actions within the 2 years preceding the identification of this
problem,' the NRC considered whether credit was warranted for /denti// cation and
Corrective Action in accordance with the civil penalty assessment process in Section
VI.B.2 of the Enforcement Policy.
These violations were identified as a result of the involved operators informing NPPD
managers of their mistake, and NPPD's follow-up investigation into this matter. Thus,
credit for identification is warranted. The NRC also has determined that NPPD is deserving
of credit for its corrective actions, which consisted of: immediate actions to assure the
safety of the f acility and assure that thermallimits had not been exceeded; meetings with
all operating crews to discuss issues arising from this event; initiation of an independent
review team investigation; disciplinary action against the involved operators; clarification
and revisions to procedures and Ops Instructions; and assessment of the environment for
reporting errors.
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For example, on December 12, 1994, a Notice of Violation and Proposed imposition of Civil Penalties in
the amount of $300,000 was issued for three Severity level 111 problems involving primary containment
integrity, electrical buses, and the control room emergency filtration system (EAs94-164, 94-165,94-166).
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Therefore, to encourage prompt identification and comprehensive correction of violations, I
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have been authorized, af ter consultation with the Director, Office of Enforcement, not to
propose a civil penalty in this case. However, significant violations in the future could
result in a civil penalty.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part,
to determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
L.J Callan
Regional Administrator
Docket No.: 60-298
License No.: DPR-46
Enclosure: Notice of Violation
cc w/ Enclosure:
John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, Nebraska 68602-0499
John Mueller, Site Manager
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
Robert C. Godley, Nuclear Licensing
& Safety Manager
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
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R. J. Singer, Manager-Nuclear
Midwest Power
907 Walnut Street
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P.O. Box 657
Des Moine , Iowa 50303
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Mr. Ron Stoddard
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Lincoln Electric System
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- 11th and O Streets
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Lincoln, Nebraska 68508
Randolph Wood, Director
Nebraska Department of Environmental
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P.O. Box 98922
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Lincoln, Nebraska 68009-8922
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Chairman
Nemaha County Board of Cornmissioners
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Nemaha County Courthouse
7
1824 N Street
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Auburn, Nebraska 68305
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Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
Nebraska Department of Health
301 Centennial Mall, South
P.O. Box 95007
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Lincoln, Nebraska 68509-5007
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Dr. Mark B. Horton, M.S.P.H.
Director
Nebraska Department of Health
P.O. Box 950070
Lincoln, Nebraska 68509 5007
R. A. Kucera, Department Director
of intergovernmental Cooperation
Department of Natural Resources
P.O. Box 176
Jefferson City, Missouri 65102
Kansas Radiation Control Program Director
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