ML20140D754
| ML20140D754 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/27/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20140D762 | List: |
| References | |
| NUDOCS 8602030109 | |
| Download: ML20140D754 (2) | |
See also: IR 05000298/1985024
Text
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JAN 2 71526
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In Reply Refer To:
Docket: 50-298/85-24
Nebraska Public Power District
ATTN:
J. M. Pilant, Manager, Technical
Staff-Nuclear Power Group
P. O. Box 499
Columbus, Nebraska 68601
Gentlemen:
Thank you for your letter of December 9,1985, in response to our letter
and the attached Notice of Violation dated November 14, 1985. As a result of
our review, we find that additional information, as discussed with your
Messrs. Pilant, Weaver and Trevors during a telephone call on January 3,
1986, is needed. Specifically, we request that you provide information about
the specific violations as indicated below:
Violation 1.
We disagree with your statement that the water chemistry
requirement is not effective until the pH exceeds the limits of <5.6 or
>8.6 for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is because we believe that, unless
specifically allowed by Technical Specificatiens, you should not change
to a higher mode of operation unless the limiting conditions of operation
for the new mode can be met. We recognize, however, that the lower pH
limitation of 5.6 is more restrictive than that allowed by standard
Technical Specifications. Therefore, we believe your commitment to
initiate a Technical Specification should not be caveated as "if
required." We request you provide us with your modified response to
violation 1.
Violotion 2.
It is not clear from your response whether or not the
policy discussed is a written policy.
Violation 4.
It is not clear from your response that training of other
personnel was conducted so that similar violations would not occur in the
future.
You are requet,ted to provide information concerning the
training.
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Nebraska Public Power District
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Please provide the supplemental information within 30 days of the date of this
letter.
Sincerely,
os.-jr! Ormd GY,
J. E. GL5 lardo
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J. E. Gagliardo, Chief
Rcactor Projects Branch
cc:
Guy Horn, Division Manager
of Nuclear Operations
Cooper Nuclear Station
P. O. Box 98
Brownville, Nebraska 68321
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
bcc to DMB (IE01)
bcc distrib. by RIV:
RPB
Resident Inspector
R. D. flartin, RA
Section Chief (RPB/A)
D. Weiss, LFMB (AR-2015
RIV File
RSTS Operator
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APPENDIX A
Nebraska Public Power District
Docket:
50-298/85-24
Cooper Nuclear Station
License:
During an NRC inspection conducted during the period August 1-September 30,
1985, violations of NRC requirements were identified.
The violations involved
an inadequate procedure, unlocked and unattended safeguards materials storage
files, failure to meet NRC reportability requirements, lack of adherence to
procedures, and inadequate test data reviews.
In accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1985), the violations are listed below:
1.
Inadequate Operating Procedure
10 CFR Part 50, Appendix B, Criterion V requires that activities affecting
quality be prescribed by documented instructions or procedures which shall
include appropriate quantitative or qualitative acceptance criteria for
determining that important activities have been satisfactorily
accomplished.
Contrary to the above, CNS Procedure 2.1.1, " Cold Startup Procedure,"
Revision 39, requires licensee personnel to verify that reactor water
chemistry is adequate for startup but does not include criteria for making
that determination.
This is a Severity Level V violation (Supplement I.E)(50-298/8524-01).
2.
Unattended and Unlocked Security Records Storage Container
10 CFR Part 73.21(d)(2) requires that unattended safeguards information be
stored in a locked security storage container.
Contrary to the above, licensee security storage containers were left
unlocked and unattended.
This is a Severity Level IV violation (Supplement III.E)(50-298/8524-02).
3.
Failure to Meet an NRC Reportability Requirement
10 CFR Part 50.73(a)(2)(ii)(C) requires the licensee to submit a Licensee
Event Report if the nuclear power plant is placed in a condition not
covered by the plact's operating and emergency procedures.
Contrary to the above, the licensee f ailed to submit a Licensee Event
Report to address movement of irradiated fuel that was not properly
supported and grappled.
This condition was not covered by plant
procedures.
This is a Severity Level IV violation (Supplement I.D)(50-298/8524-03).
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4.
Failure to Perform Surveillance Testing According to Procedure
10 CFR Part 50, Appendix B, Criterion XI requires that all testing
required to demonstrate that systems will perform satisfactorily in
service will be performed in accordance with written test procedures.
Contrary to the above, licensee personnel did not perform testing in
accordance with the requirements of CNS Surveillance Procedure 6.1.3,
"APRM System Excluding 15% Trip Function Test," Revision 12.
This is a Severity Level IV violation (Supplement I.E)(50-298/8524-04).
5.
Inadequate Evaluation of Surveillance Test Results
10 CFR Part 50, Appendix B, Criterion XI requires that test results be
documented and evaluated to assure that test requirements have been
satisfied.
Contrary to the above, three licensee persons reviewed Surveillance
Procedure 6.2.4.1, " Daily Surveillance (Technical Specifications),"
Revision 49, without identifying the presence of an incorrect data entry.
This is a Severity Level IV violation (Supplement I.E)(50-298/8524-05).
Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District is
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hereby required to submit to this office, within 30 days of the date of the
letter transmitting this Notice, a written statement or explanation in reply,
including for each violation:
(1) the reason for the violations if admitted;
(2) the corrective steps which have been taken and the results achieved;
(3) corrective steps which will be taken to avoid further violations; and
(4) the date when full compliance will be achieved.
Where good cause is shown,
consideration will be given to extending the response time.
Dated at Arlington, Texas
this /fdday of /[M ,1985.
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