ML20134C804
| ML20134C804 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/27/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS970003, NUDOCS 9702040052 | |
| Download: ML20134C804 (5) | |
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COOPER NUCLEAR STATION F_-
P.O. 90X 98. 3ROWNVILLE. NEBRASKA 68321 Nebraska Public Power District "El%""
NLS970003 January 27,1997 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. 50-298/96-26 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to Horn (NPPD) from Dyer (USNRC) dated December 26,1996,"NRC Inspection Report 50-298/96-26 and Notice of Violation" By letter dated December 26,1996, (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 Violation in accordance with 10 CFR 2.201. The District admits to the violation and has completed all corrective actions necessary to return CNS to full compliance.
Should you have any questions concerning this matter, please contact me.
Si cere r,
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W P. D. Graham Vice President - Nuclear
/cct Attachment 040021 I
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9702040052 970127 PDR ADOCK 05000298 G
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I NLS970003 l
January 24,1997 Page 2 of 2 cc: Regional Administrator USNRC - Region IV i
Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution I
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I Page1of2 REPLY TO DECEMBER 26,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted on October 20 through November 30,1996, one
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violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
Violation
" Technical Specification 4.5.F.1.c states, in part, when it is determined that one diesel generator is inoperable, to determine within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the operable diesel generator is i
not inoperable due to common causefailure orperform TechnicalSpecification Surveillance Requirement 4.9.A.2.a. l.
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On October 21,1996, Diesel Generator 2 was declared inoperable due to afuel oilleak on the supplyline toInjector 7L On October 23,1996, during the postmainten mce test on Diesel Generator 2, the motor-operatedpotentiometerfailed, causing the diesel to drop load.
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Contrary to the above,fc>r the two abovefailures, the licensee did not determine within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the operable dieselgenerator was not inoperable due to common causefailure s
and did not perform Technical Specification Surveillance Requirement 4.9.A2.a.] (to run the operable dieselgenerator) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. "
Admission or Denial to Violation l
The District admits the violation.
Reason for Violation The surveillance requirement of Technical Specification 4.5.F.1.c was implemented in Amendment 175 to the CNS operating license on April 29,1996. Administrative controls for documenting the required common cause failure analysis were not developed. This violation resulted from the failure of management to adequately communicate expectations through the development or initiation of administrative controls for the staff to implement the Technical Specification 4.5.F.1.c surveillance requirement regarding documentation of a common mode i
failure analysis.
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Page 2 of 2 Corrective Stens Taken and the Results Achieved l
l In both examples, Operations personnel were aware of the Technical Specification surveillance requirement. Common mode failure analyses that determined Diesel Generator 1 was operable were performed but not documented. Common mode failure evaluations were subsequently documented for both occurrences of Diesel Generator 2 inoperability. Both evaluations indicated Diesel Generator I was not inoperable due to a common cause.
Other occurrences of diesel generator inoperability since the Technical Specification surveillance requirement was implemented were reviewed for other examples of undocumented common cause failure analyses. No other examples were found.
l Operations Management discussed this violation with all Shift Supervisors and Shift Technical l
Engineers to communicate expectations regarding review and documentation of Technical Specification requirements.
Additionally, the Tech Spec Tracker program has been revised to prompt personnel to perform and document the common cause failure analysis required when a Diesel Generator becomes inoperable.
Corrective Steos That Will Be Taken to Avoid Further Violations l
Administrative controls are being evaluated to provide a consistent mechanism to document i
common mode failure analyses.
Date When Full Compliance Will Be Achieved The District is in full compliance with respect to the identified violation.
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c ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: NLS97003 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended orplanned actions by the District.
They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the Licen, sing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE Administrative controls are being evaluated to provide a consistent mechanism to document common mode failure analyses.
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l PROCEDURE NUMBER 0.42 l REVISION NUMBER 1.2 l PAGE 8 OF 10 l
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