ML20134F204
| ML20134F204 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/30/1996 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS960196, NUDOCS 9611050047 | |
| Download: ML20134F204 (7) | |
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Nebraska Public Power District P.O. 90X ROWNVILLE NE 88321
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u NLS960196 October 30,1996 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. 50-298/95-18 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from L. J. Callan (USNRC) dated September 30, 1996, "NRC Inspection Report 50/298/95-18 and Notice of Violation" 13y letter dated September 30,1996 (Reference 1), the NRC cited Nebraska Pub:ic Power District (District) as being in violation of NRC requirements. This letter, including Attachment 1, 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.
Should you have any questions concerning this matter, please contact me.
Si erely
/n R. Horn Sr.
'e President of Energy Supply
/nr I@/ e Attachment f
cc: Regional Administrator Senior Resident Inspector USNRC - Ragion IV USNRC i
Senior Project Mans 3er NPG Distribution USNRC - NRR Project Directorate IV-1 9611050047 96103d PDR ADOCK 05000298 G
PDR e
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NLS960196 Octobdr 30,.1996 Page 2 of 2 STATE OF NEBRASKA
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)ss NEMAHA COUNTY
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G. R. Horn, 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 correspondence on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.
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R. Horn Subscribed in my presence and sworn to bef dO day of hvo_T'_r(,1996.
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j Attachment I to NLs960196 Page1of4 REPLY TO SEPTEMBER 30,1996, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During an NRC investigation concluded on May 8,1996, three violations.of NRC requirements were identified. The particular violations and the District's reply are set forth below:
Violation A.
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, andDrawings," requires, in l
part, that, " Activities affecting quality shall be... accomplished in accordance with these mstructions, procedures, and drawings. "
Step 8.2.6 5 of Cooper Nuclear Station Operations Manual, " Conduct of Operations '
l P?ocedure 2.0.3, " Revision 20, datedAugust 21,1995, states, " Operators should notify the control room supervisor and shift supervisor of any unexpected situations encountered in monitoring the main control boards. "
Contrary to the above, on January 7,1996, operators did not notify the control room l
supervisor and shift supervisor ofa mispositioned control rod, an unexpected situation l
encountered in monitoring the main control boards, until approximately 20 minutes after
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discovery.
A_dmission or Denial to Violation A.
The District admits the violation.
Reason for Violation A.
Gross Misconduct. Both operators separately made a conscious decision to procced with selection and movement of rods without informing supervision of the unexpected situation encountered.
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Corrective Steps Taken and the Results Achieved - Violation A.
A Periodic Core Performance Log was performed to verify that no thermal limits had been i
exceeded.
I Once made aware, the Shif1 Supervisor immediately informed plant management of the event.
The Shift Supervisor and members of plant management observed crew performance to assure themselves that the crew wr.s able to safely continue with reacter operations.
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3 to NLS960196 Page 2 of 4 4
On January 8,1996, line management took action to remove the crew from further active control i
room watch standing duty pending completion ofits assessment and evaluation of the event. The crew was not reassigned to active Control Room watch standing status until crew dynamics and performance issues had been addressed as confirmed by observation in the simulator.
The Vice President Nuclear initiated an independent review team to investigate the reactivity mismanesement event.
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Disciplinary action was taken against both operators. A site stand-down was held to address this issue and the necessity to report errors with all personnel on January 16,1996.
t Corrective Steps to Avoid Further Violations - Violation A.
No further corrective actions are required.
Date When Full Compliance Will Be Achieved - Violation A.
The District is in full compliance with 10 CFR 50, Appendix B, Criterion V.
Violation B.
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, andDrawings," requires in part, that, " Activities affecting quality shall be... accomplished in accordance with these instructions, procedures, and drawings. "
Step 8.1.5 of Cooper Nuclear Station Operations Afanual, Nuclear Performance Procedure 10.13, " Control Rod Sequence and Afovement Control," Revision 26, dated December 24, 1995, requires that operators, "...ryLt deviatefrom the sequence unless approved by a reactor engineer (or shift supervisor in an emergency) or per a SORC approvedprocedure. "
Contrary to the above, on January 7,1996, operators deviatedfrom the approvedsequence when operators inserted control rods starting with the incorrect page of the control rod sequence book without the expresspermission of a reactor engineer or the shift supervisor, or a SORC approvedprocedure.
Admission or Denial to Violation B.
The District admits the violation.
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to NLS960196 I~
Page 3 'of 4 Reason for Violation B.
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This procedural violation resulted from personnel error. The Reactor Operator responsible for-movement of the control rods did not verify he was on the right page of the sequence book prior to selecting the first rod to be moved.
Corrective Steps Taken and the Results Achieved _Yipjation B.
Written management expectations of the roles and renonsibilities of the Reactor Operator and Second Checker during control rod manipulations was }zomulgated by the Operations Supervisor
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i and Operations Manager Operations management further reviewed the areas where second checking and concurrent verification are used (including Procedure 10.13) to ensure their expectations are being met.
While current procedures were found to be adequate, Operations Instruction #7 was revised to provide additional information regarding concurrent verification.
Corrective Steps to Avoid Further Violations - Violation B.
f No further corrective actions are required.
Date When Full Compliance Will Be Achieved - Violation B.
The District is in full compliance with 10 CFR 50, Appendix B, Criterion V.
Violation C.
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, andDrawings," requires, in.
part, that, " Activities affecting quality shall be...accomplishedin accordance with these instructions, procedures, and drawings. "
" Step 8.4.4 of Cooper Nuclear Station Operations Manual, Nuclear Performance Procedure 10.13, "ControlRodSequence andMovement Control," Revision 26, datedDecember 24, 1995, requires that operators, "With concurrence of the shift supervisor arulreactor engineering, implement a recoveryplan... " when recoveringfrom mispositioned control rods.
Contrary to the above, on January 7,1996, operatorsfailed toproperly implement this procedure when the control room operators took actions to recoverfrom mispositioned control rods using their ownjudgement rather than a recoveryplan which had been concurred in by the shift supervisor and the reactor engineer.
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1 Attachmeht I to NLS960196 Page 4 of 4 Admission or Denial to Violation C.
j The District admits the violation.
. 1 B_eason for Violation C.
Gross misconduct. Both operators separately made a conscious decision to proceed with selection and movement of rods without the concurrence or notification of the shift supervisor and reactor engineer, Corrective Steps Taken and the Results Achieved - Violation C.
As discussed in response to Violation A, disciplinary actions were taken against the involved operators. Procedure 10.13 was reviewed and the requirements for compliance were discussed j
with operations personnel to ensure a common understanding of the procedure.
Corrective Steps to Avoid Further Violations - Violation C.
No further corrective actions are required.
l Date When Full Comoliance Will Be Achieved - Violation C.
The District is in full compliance with 10 CFR 50, Appendix B, Criterion V.
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
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Correspondence No: NLS960196
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The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or l
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 j
at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
l COMMITTED DATE COMMITMENT OR OUTAGE l
None 4
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l PROCEDURE NUMBER 0.42 l REVISION NUMBER 1. 2 l PAGE 8 OF 10 l