ML20135C286

Notice of Violation from Insp on 961007-970219.Violation Noted:Licensees Design Criteria Documents Were Not Identified as Conditions Adverse to Quality Until 961220

ML20135C286
Person / Time
Site:	Cooper
Issue date:	02/25/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135C277	List: ML20135C274 ML20135C286 ML20135C301
References
50-298-96-24, NUDOCS 9703030458
Download: ML20135C286 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION Nebraska Public Power District Docket No.: 50-298 Cooper Nuclear Station License No.: DPn-46 During an NRC inspection conducted on October 7 through February 19,1997, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action," requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, on or about June 1995, potential conditions adverse to quality identified by a contractor's review of the licensee's design criteria documents were not identified as conditions adverse to quality until December 20, 1996. For example:

1. Technical Specification 3.9 A.1.b and the associated surveillance requirement for ensuring adequate supply of emergency diesel generator fuel did not ensure a sufficient fuel oil supply to meet the safety design basis specified in USAR Section Vlli-5.2.7, " Standby AC Power Source, Safety Design Basis."

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2. The sizing calculation for the automatic depressurization system accumulators included non-conservative assumptions that did not assure that the accumulators would support the safety function of the main steam relief valves.

This is a Severity Level IV violation (Supplement l} (50-298/9624-09)

B. Technical Specification 6.3.2 requires, in part, that written procedures be established and implemented for emergency conditions involving possible releases of radioactive materials.

1 Contrary to the above: l

1. As of November 1,1996, Emergency Operating Procedure 5.8.8, " Alternate Boron Injection and Preparation," Revision 3, had been established for emergency conditions involving possible releases of radioactive materials.

However, the procedure was inadequate because it f ailed to provide appropriate instructions to ensure that adequate space was available in the reactor vessel when the reactor core isolation cooling system was utilized for alternate boron injection.

9703030458 970225 PDR ADOCK 05000298 G PDR

2. As of November 1,1996, Standard Operating Procedure 2.2.69.2, "RHR

[ residual heat removal] System Shutdown Operations," Revision 19, was being used for emergency conditions involving possible releases of radioactive materials. However, the procedure failed to provide appropriate instructions to ensure that design basis boron concentrations would not be compromised during an anticipated transient without scram event.

3. As of November 1,1996, Standard Operating Procedure 2. 2.69.2,"RHR

[ residual heat removal) System Shutdown Operations," was being used for emergency conditions involving possible releases of radioactive materials.

However, the procedure failed to provide appropriate instructions to ensure that the containment of radioactive materials would not be compromised during an r'.Wipated transient without scram event or a design basis accident.

This is a fieverity Level IV vio'ation (Supplement Vill) (50-298/9624-07)

, C. Technical Specification 5.3.1, " Introduction," requires that station personnel shall l be provided detailed written procedures to be used for maintenance of system components and systems that could have an effect on nuclear safety.

I Technical Specification 6.3.3 C., " Maintenance and Test Procedures," states that procedures will be provided for preventive or corrective maintenance of plant equipment and systems that could have an affect on nuclear safety.

l Maintenance Procedure 7.2.55.2,"HCU SCRAM Valve Operator Diaphragm Replacement," Revision 2, requires that scram valve mounting assembly capscrews be torqued to 240 in-lbs.

Contrary to the above, licensee personnel did not fully use Maintenance Procedure 7.2.55.2,in that, on or about November 21,1996, one capscrew i

on each of the mounting brackets for inlet Scram Valve CRD-AO-CV126 and Outlet Scram Valve CRD-AO-CV127 on Hydraulic Control Unit 38-23 were not torqued to 240 in-Ibs. l This is a Severity Level IV violation (Supplement 0 (50-298/9624-06)

Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Pc.wer District is hereby required to submit a written statement or explanation to the U.b Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the f acility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and j should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the l

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results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information I that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Arlington, Texas this 25th day of February 1997 l