ML20137U335

Discusses Insp on 851118-22 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000

ML20137U335
Person / Time
Site:	Cooper
Issue date:	02/13/1986
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Kuncl L NEBRASKA PUBLIC POWER DISTRICT
Shared Package
ML20137U340	List: ML20137U335 ML20137U349
References
EA-86-003, EA-86-3, NUDOCS 8602190137
Download: ML20137U335 (3)

Text

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FEB 131936 Docket No. 50-298 License No. DPR-46 EA 86-03 Nebraska Public Power District ATTN: Larry G. Kunci Vice-President Nuclear P. O. Box 499 Columbus, Nebraska 68601

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT N0. 50-298/85-31)

This refers to the inspection conducted on November 18-22, 1985, at the Cooper Nuclear Station, Brownville, Nebraska which examined secondary containment integrity, pipe support surveillance and the fire protection program and its implementation. Two violations were identified, one by you and the second by NRC inspectors. The violations were discussed at an enforcement conference held on December 17, 1985, at the Region IV office in Arlington, Texas.

Violation I. A in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty occurred when jumper wires used for surveillance testing were left installed after the testing was completed. Leaving the jumpers installed rendered the automatic start capability of both trains of the standby gas treatment system (SGTS) inoperable and also negated the capability of automatically isolating the reactor building (RB) ventilation systen if a signal for such isolation had occurred. During the period the jumpers were installed (November 13 - November 18,1985), this condition violated an LC0 concerning the maintenance of secondary containment integrity. During this period, secondary containment integrity was required by technical specifications because irradiated fuel was moved (November 14,1985).

Violation I.B. involves your surveillance prcgram for snubber operability. In July 1985, you performed surveillance inspections on 50 drywell snubbers at Cooper and found no operability problems. Subsequent to those inspections, an NRC inspector identified a potential problem with one snubber installed in the drywell. Since your July inspection had not identified this problem, the 50 snubbers were reinspected by you and one additional snubber out of the 50 was discovered to have an operability problem. Both snubbers were replaced. The surveillance inspection was then expanded to include all 144 drywell snubbers and 148 outside of the drywell. A total of 25 out of 292 safety-related snubbers were' eventually identified to have problems that could have prevented them from performing their intended safety function. This indicates that your surveillance program and correttive actions taken in response to identified problems were not adequate.

In both of these instances, the failure to properly control the surveillance process lef t systems designed to mitigate or prevent accidents in a condition in CERTIFIED MAIL RETURN RECEIPT REQUESTED B602190137 860213 PDR ADOCK 05000298 G PDR y

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which they could not do so. As previously stated, this occurred in one instance i because a surveillance test was not correctly carried out and a safety system was j left inoperable at the end of the test. In the other instance, you inadequately l performed surveillance tests because of inadequate instructions to the test l

performer. ,

i To emphasize the need to improve the overall performance of surveillance testing, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dallars

($50,000) for the violations described in the enclosed Notice. In accc rdance i with the " General Statement of Policy and Procedure for NRC Enforcement Actions," ,

10 CFR Part 2, Appendix C (1985) (Enforcement Policy), the violations described j in the enclosed Notice have been categorized as a Severity Level III problem.

The base value of a civil penalty for a Severity Level III problem, $50,000, has i

been proposed because the factors supporting mitigation of the penalty in this case appear to be offset by prior poor performance as evidenced by an April 1985 violation that also involved surveillance procedures for the Standby Gas Treatment System.

l Other violations identified in the same inspection, which are of lesser significance and categorized accordingly as a Severity Level IV problem, are ,

also included in the attached Notice of Violation.

You are required to respond to this letter and should follow the instructions

! specified in the enclosed Notice when preparing your response. In your j response, you should document the specific actions taken and any additional 1 actions you plan to prevent recurrence. After reviewing your response to this i Notice, including your proposed corrective actions, the NRC will determine I whether further NRC enforcement action is necessary to ensure compliance with ,

NRC regulatory requirements.

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In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, l

3 Title 10, Code of Federal Regulations, a copy of this letter and its enclosure l will be placed in the NRC Public Document Room.

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The responses directed by this letter and the enclosed Notice are not subject i to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

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! Sincerely, l

Original signed by: l j Robert D. Ifartin l

l Robert D. Martin i Regional Administrator

Enclosure:

! Notice of Violation and i Proposed Imposition of j Civil Penalty 2

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