ML20140D775

Responds to NRC Re Violations Noted in Insp Rept 50-298/85-24.Corrective Actions:Tech Spec for Reactor Water Chemistry During Startup Reviewed & Inventory of Safeguards Documents Conducted

ML20140D775
Person / Time
Site:	Cooper
Issue date:	12/09/1985
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Martin L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20140D762	List: ML20140D754 ML20140D775
References
CNSS850696, NUDOCS 8602030113
Download: ML20140D775 (7)

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-l DECl21985 Mr. L. E. Martin Acting Chief -

Ql1 Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to IE Inspection Report 50-298/85-24

Dear Mr. Martin:

This letter is written in response to your letter dated November 14, 1985 transmitting Inspection Report 50-298/85-24.

Therein you indicated that five of our activities were in violation of Nuclear Regulatory Commission requirements. The following are statements of the violations and our responses in accordance with 10CFR2.201:

1. Statement of Violation 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).

Reason For The Violation On August 20, 1985, during performance of CNS Procedure 2.1.1, " Cold Startup Procedure", the on duty Shift h lh 8602030113 860127 PDR G

ADOCK 05000298 PDR

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- ,', . L. E. Martin Page 2 December 9,1985 Supervisor documented that reactor water chemistry was adequate for startup. The NRC resident inspector had previously reviewed the chemistry report for reactor water and believed that reactor water pil was not within limits specified by the Technical Specification for reactor water chemistry during startup.

The Shift Supervisor was notified of this occurrence by the resident inspector and another sample was taken, the results of which were considered by the resident inspector to be within the Technical Specification. The failure to include quantitative or qualitative acceptance criteria for reactor water chemistry either in the chemistry sample data sheet or Procedure 2.1.1 was identified by the resident inspector as a violation.

Corrective Steps Which llave Been Taken And The Results Achieved The CNS Technical Specification for reactor water chemistry during startup has been reviewed. It is felt that this Technical Specification sets no specific limits for pil which must be immediately adhered to, prior to or during startup conditions. The Technical Specification requirement for reactor water chemistry states that "the reactor shall be shut down if pil is <5.6 or >8.6 for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period". It is not specifically stated that reactor water pil has to be in this range prior to or during startup, only that if reactor water is outside of these parameters for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period the reactor is to be shut down. It is felt then that CNS, during the cited startup, was not in violation of exceeding the Technical Specification parameter for reactor water pH.

Corrective Steps Which Will Be Taken To Avoid Further Violation The current CNS Technical Specifications in regards to reactor water chemistry requirements for startup will be evaluated. If required, a Technical Specification change will be initiated in order to clarify the reactor water chemistry requirement for startup. Also , CNS Procedure 2.1.1, " Cold Startup Procedure" , will be evaluated for possible changes upon completion of the Technical Specification evaluation. These steps will help to ensure that reactor water chemistry is adequate during future startup conditions.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by March 30, 1986.

, ,'. . L. E. Martin Page 3 December 9,1985

2. Statement of Violation Unattended and Unlocked Security Records Storage Container 10CFR 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)

Reason for the Violation

. The violation occurred due to inadequate safeguards storage procedures and inadequate office policies on document control and locking of containers responsibility.

Corrective Steps Which llave Deen Taken And The Results Achieved On August 28, 1985 a complete inventory of all safeguards documents was conducted upon discovery of the violation.

No documents were missing. On August 29, 1985 existing safeguards materials were consolidated from three containers to two containers. A document control sign-out sheet was developed to be used by all personnel except the immediate security office personnel. Additionally, a new office policy was initiated that requires the containers to be immediately locked when documents are removed. The containers are then unlocked, documents returned and locked again.

Since these changes were made, no repeat discrepancies have occurred.

Corrective Steps Which Will Be Taken to Avoid Further Violation Security office personnel will continue to follow the new policies.

Date When Full Compliance Will Be Achieved Cooper Nuclear Station is currently in full compliance.

3. Statement Of Violation 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

,'. . L. E. Martin Page 4 December 9,1985 plant is placed in a condition not covered by the plant's operating and emergency procedures.

Contrary to the above, the licensee failed 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).

Reason For The Violation On July 24,1985, NCR 04688 was written to document an occurrence where an unchanneled fuel bundle was suspended and moved without being properly grappled. A Licensee Event Report was not submitted to document the occurrence. A Licensee Event Report was required for this occurrence because no procedure existed which covered the fuel handling methodology in the occurrence, nor did any procedure instruction exist to provide instructions to recover from such an occurrence. The resident inspector identified the failure to submit a Licensee Event Report for this occurrence as a violation.

Corrective Steps Which Have Been Taken And The Results Achieved CNS Procedure 10.25, " Refueling", has been changed to require a visual confirmation that the grapple is properly engaged prior to raising a fuel assembly. This step should ensure that a fuel assembly will not be moved without having the grapple properly engaged. An LER for this event will be submitted within 30 days of the date of this response.

Corrective Steps Which Will Be Taken To Avoid Further Violation In order to provide instructions to recover from such an i occurrence, CNS Procedure 10.25, " Refueling", will be reviewed and a change made in order to provide such instruction. This will help ensure that a violation in this regard does not recur.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by February 28, 1986.

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.' . L. E. Martin Page 5 December 9,1985

4. Statement Of Violation 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).

Reason For The Violation On August 29, 1985, CNS Surveillance Procedure 6.1.3, "APRM System Excluding 15% Trip Functional Test", was performed. The resident inspector, after completion of the surveillance, observed that the intermediate range nuclear instrumentation channels D and F OPERATE / TEST switches were not in the OPERATE position. The resident inspector then reviewed the completed CNS Procedure 6.1.3 and noted that step 10 required the affected switches to be placed in the OPERATE position. The failure to return the test switches to normal as directed by Procedure 6.1.3 was identified as a violation.

Corrective Steps Which IIave Been Taken And The Results Achieved The Operations Supervisor has spoken to the individual who was involved in the performance of CNS Surveillance Procedure 6.1.3, "APRM System Excluding 15% Trip Functional Test". The individual was counseled and the importance of correctly following station procedures and returning components back to normal positioning following testing done in surveillances was stressed. These steps should ensure that the individual involved is aware of the need to correctly follow station procedures and of returning components back to normal positioning or lineup following testing done in surveillances.

Corrective Steps Which Will Be Taken To Avoid Further Violations In addition to the corrective steps which have been taken, the Operations Supervisor will continue to stress the need for personnel to be aware of and correctly follow station

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- , " .. - L. E. Martin Page 6 December 9,1985 procedures. A lack of adherence to station procedures, specifically the failure to return components back to normal positioning or lineup following surveillance testing, will become a basis for further discussion or disciplinary actions by the Operations Supervisor.

Date When Full Compliance Will Be Achieved The District is presently in full compliance.

5. Statement Of Violation 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).

The Reason For The Violation On September 23, 1985, a control room operator recorded in CNS Surveillance Procedure 6.2.4.1, " Daily Surveillance (Technical Specifications)", the control room vent monitor gaseous activity reading following a source test. The NRC resident inspector, in his review of the completed surveillance, noted that the gaseous activity reading that was logged following the source test was the same value as that recorded during the source check instead of the lower background value that existed prior to the source test.

This incorrect data entry had been reviewed by the Control Room Supervisor and Shift Supervisor and neither identified the mistake. The failure to adequately document, review and evaluate test results in Procedure 6.2.4.1 was identified as a violation.

Corrective Steps Which Have Been Taken And The Results Achieved The Operations Supervisor has spoken to the individual involved in recording the incorrect data in Surveillance Test 6.2.4.1, " Daily Surveillance (Technical Specifications)". The individual was counseled and the need to correctly record data values required per station procedures was stressed. The Control Room Supervisor and Shift Supervisor were also spoken to about the occurrence and it was stressed to these individuals that in evaluating and reviewing test results to ensure that

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[.. . L. E. Martin Page 7 December 9,1985 recorded data values are correct. These steps should ensure that the individucls involved are now aware of the need to record data values correctly and to verify this correctness in the evaluation and review of test results.

Corrective Steps Which Will Be Taken To Avoid Further I Violations The Operations Supervisor, in his weekly crew meetings, will speak to all licensed operators about this occurrence and the need to correctly record data values and to verify this correctness in the evaluation and review of test results. These steps should ensure that no further violations in this regard occur.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by February 28, 1986.

If you have any questions regarding these responses, please contact me.

Sincerely, lH.

J. M. Pilant Technical Staff Manager Nuclear Power Group l JMP/MLS/IITil:lk9/12(DAIL9A) l l

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