ML20137J779
| ML20137J779 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/31/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS970047, NUDOCS 9704040121 | |
| Download: ML20137J779 (6) | |
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NLS970047 i
March 31,1997 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. 50-298/96-31 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
1.
Letter to G. R. Horn (NPPD) from A. T. Howell III (USNRC) dated February 28,1997, "NRC Inspection Report 50-298/96-31 and Notice of Violation" Ily letter dated February 28,1997_(Reference 1), the NRC cited Nebraska Public 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 Violation in accordance with 10 CFR 2.201. The District admits to the two cited violations and has completed all corrective actions 1
necessary to return CNS to full comphance.
Should you have any questions concerm.y this matter, pletse contact me.
Sincerely, PMA P. D. Graham Vice President - Nuclea
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1 Attachment I l
to NLS970047 Page1of4 REPLY TO FEBRUARY 28,1997, NOTICE OF VIOLATION
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COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from December 1,1996, through February 19,1997, two violations of NRC requirements were identified. The particular violations and the District's reply are set forth below:
Violation A l
Criterion VofAppendiv B to 10 CFR Part 50 requires, in part, that activities affecting quality shall be prescribed by documentedprocedures and instructions appropriatefor the circumstances.
Contrary to the above, on November 26,1996, the inspectors determined that proceduralinstructions did not existfor operators to mitigate slush buildup in the circulating waterintake bays.
This is a Severity LevelIV violation. (Supplement 1)(298/96031-01)
Admission or Denial to Violation The District admits the violation.
Reason fbr Violation CNS procedures were not sufficient to preclude a challenge to the plant Operations staff by the slush buildup. In addition, high water levels prohibited the installation of the designed ice deflection system at the time of the occurrence which had previously provided acceptable deflection of river ice back into the river current. The reason for the violation is that the operating procedures did not address the effects of either the high water level or the absence of the ice deflection system. There were several contributing factors which are discussed below.
It is believed that an induced slush buildup had occurred previously at CNS, but not within the last ten years. Because the slushing condition had not occurred recently, this de-emphasized the need for procedures to address the slushing condition.
The ice deflector is normally positioned for the winter months; it is typically installed subsequent to the conclusion of the navigational season for the Missouri River, at which time the water levels are reduced by the U.S. Army Corps of Engineers. Ilowever, the District was not able to install the ice deflector due to the persistent high water level conditions. As a result o f high
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Attachment l' to NLS970047
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Page 2 of 4 water levels, the effectiveness of the circulating water de-icing system was also impaired as suflicient ~
' pressure to provide proper flow distribution was not capable of being achieved.
This resulted from the hydrodynamics of the flow stream and its interaction with the regulating discharge gate.
Corrective Stens Taken and the Results Achieved The CNS Operations Department was aware of the slush build up conditions and was monitoring the river water level for the earliest possible opportunity to install the ice deflection system. This system was installed once the river level had subsided. There have been no subsequent problems related to slush or ice buildups during the balance of the 1996-97 Winter season.
- Abnormal Procedure 2.4.93.2," Flow Blockage in Intake Bays," has been revised to address the lessons learned from this event.
Corrective Steps That Will Be Taken to Avoid Further Violations in response to the specific event (slush /high water conditions) discussed above, the District is performing an evaluation to determine the feasibility of additional modifications to allow installation of the ice deflection system during future high water level conditions. The evaluation will be completed by October 1,1997.
Date When Full Compliance Will Be Achieved The District is in full compliance with the requirements of 10 CFR 50, Appendix B with respect to this violation.
Violation B Criterion V ofAppendix B to 10CFR Part 50 requires, in part, that activities affecting quality shall be prescribed by documentedprocedures and shall be accomplished in accordance with these procedures.
Licensee Administrative Procedure 0.S, " Problem Identyication and Resolution,"
Revision 8, Section 14.2, requires, in part, that allpersonnel are responsiblefor reporting problems that are, or potentially could be, conditions adverse to quality.
Contrary to the above, the licenseefailed to write a problem identification reportfor a known leakage problem with the replacement _ valvefor the Service Water Rooster Pump 1A Gland Seal Flow Indicator Switch (FIS-2703A) Drain Valve SW-861.
to NLS970047 Page 3 of 4 This is a Severity LevelIV violation (Supplement 1)(29M6031-02)
Admissiotwr Denial to Violation The District admits the violation.
Reason for Violation Violation B discusses a situation where Maintenance Work Request (MWR) 94-0111 was utilized, in part, to identify and resolve a leak associated with Service Water (SW) valve SW-861. The leaky valve was discovered during the implementation of the MWR; however, a Problem Identification Report (PIR) was not written upon discovery of the problem because the work was still "in-process" and that the corrections would be completed prior to the closecut of the MWR. During NRC Inspection 50-298/96-31, the District agreed that the maintenance practices of addressing identified deficiencies through an open work package appeared to create a confusion factor for maintenance personnel with regard to when a PIR should be written. The failure to write a PIR for the condition described above has been identified as a violation of 10CFR Part 50, Appendix B, Criterion V, and CNS Procedure 0.5.
The reason for the violation is that there was a common misunderstanding within the Maintenance Department as to what discrepancies contained in open MWRs require PIR i
. initiation. This common misunderstang is reinforced by Maintenance Department's interpretation of CNS Procedure 7.0.4, " Conduct of Maintenance." Although Procedure 7.0.4, Revision 7, Steps 8.7.1 and 8.7.2 provide instructions for the use of Discrepancy Sheets, including documentation requirements when PIRs are warranted, the steps do not explicitly restate the general requirement of Procedure 0.5," Problem Identification and Resolution," that problems that potentially could be a condition adverse to quality be addressed by initiating a PIR.
Additionally, Step 8.7.2.9 of Procedure 7.0.4 allows for revision of the MWR when problem resolution is not currently provided within the scope of the MWR or the applicable procedure.
This procedural provision is reflected in a practice where some discrepancies, identified during the implementation of MWRs. are documented in the MWR packages and are only addressed by PIRs if the discrepancies remain open at the time the affected MWRs are being closed.
Corrective Stens Taken and the Results Achieved 1
A PIR has been written to address the failure to immediately write a PIR for the SW-861 leakage issue. A PIR had also been written to further research leakage-related issues associated with SW-861, as well as SW-862. The mechanic involved with MWR-94-0111 was instructed on the need to write PIRs for future discrepancies that fall within the scope of Procedure 0.5.
Attachment i to NLS970047 Page 4 of 4 The District conducted some informal interviews with the Maintenance staff and had determined that there were some misunderstandings as to what discrepancies contained in open MWRs require PIR initiation. As a result, the District conducted a samph: review of 200 closed MWRs to determine the extent of the problem that PIRs had not been written for discrepancies within the scope of Procedure 0.5. Out of the 200 MWRs reviewed, there were nine MWRs which contained discrepancies which may have required PIRs. None of the subject discrepancies are safety significant.
The District has discussed the subject violation with all of the personnel in the Maintenance Department. The District has communicated its expectations that PIRs are to be written for discrepancies that potentially could be a condition adverse to quality.
Corrective Stens That Will 13e Taken to Avoid Further Violations Based on the sample review of the 200 closed MWRs, the District has confirmed that there is a misunderstanding within the Maintenance Department as to the expectation that all discrepancies that potentially could be a condition adverse to quality will have PIRs written to document such.
The District will continue to communicate its expectations to the Maintenance Department regarding the need to utilize the PIR process for any condition that could be adverse to quality or i
safety independent of the associated MWR status.
The District is reviewing Procedures 7.0.4 and 0.40," Work Control Program," with respect to Procedure 0.5. The end product will result in one or more revised procedures addressing how MWR-related discrepancies are addressed within the larger corrective action program at CNS.
The procedural revision will be completed by June 30,1997.
Date When Full Comnliance Will 13e Achieved The District is in full compliance with the requirements of 10 CFR 50, Appendix 13 with respect to this violation. The commitment to revise one or more of the above described procedures is to ensure that compliance is maintained in the future.
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j ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: NLS970047 Ttc 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 The District is performing an evaluation to determine the feasibility of additional modifications to allow installation of October 1, 1997 the ice deflection system during future high water level conditions.
The District will continue to communicate its expectations t ongoing - No commitment the Maintenance Department regarding the need to utilize the PIR due date provided.
process for any condition that could be adverse to quality or safety independent of the associated MWR status.
The District is reviewing Procedures 7.0.4 and 0.40,
" Work Control Program," with respect to Procedure 0.5.
The end June 30, 1997 product will result in one or more revised procedures addressing how MWR-related discrepancies are addressed within the larger corrective action program at CNS.
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 4 l
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