ML20140G545
| ML20140G545 | |
| Person / Time | |
|---|---|
| Site: | Cooper |
| Issue date: | 05/02/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-96-26, NLS970092, NUDOCS 9705120019 | |
| Download: ML20140G545 (5) | |
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NLS970092 May 2,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Revised Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-26 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from J. E. Dyer (USNRC) dated December 26, 1996, "NRC Inspection Report 50-298/96-26 and Notic.; of Violation" 1
- 2. Letter to USNRC from P. D. Graham (NPPD) dated January 27,1997," Reply to a Notice of Violation, NRC Inspection Report No. 50-298/96-26, Cooper j
Nuclear Station, NRC Docket 50-298, DPR-46" By letter dated December 26,1996 (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation of NRC requirements. The District's reply to the referenced Notice of Violation was provided by letter dated January 27,1997 (Reference 2). Subsequent to the January 27,1997, response, the District took additional actions to bound the condition cited in the original Notice of Violation. This letter, including Attachment 1, revises the District's previous response to inform the NRC of these actions and results achieved.
Should you have any questions concerning this matter, please contact me Sincere I
W i
P. D. Graham y
l Vice President - Nuclear s
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NLS970092
. May 2,1997 Page 2 of 2 l
cc: Regional Administrator
-USNRC - Region IV Senior Project Manager i
USNRC - NRR Project Directorate IV-1 Senior Resident Inspector US'NRC l
NPG Distribution 4
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to NLS970092 Page1 of2 l
REPLY TO DECE' !IlER 26,1996, NOTICE OF VIOLATION COG,'ER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 (REVISED) l During NRC inspection activities conducted on October 20 through is avember 30,1996, one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
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Violation
" Technical Specification 4.5.F.1.c states, in part, when it is determined that one diesel generator is inoperable, to determine within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the operable dieselgenerator is not inoperable due to common causefailure orperform Technical Specification Surveillance Requirement 4.9.A.2.a.1.
i On October 21,1996, Diesel Generator 2 was declared inoperable due to afuel oilleak on the supplyline toInjector 7L On October 23,1996, during the postmaintenance test on Diesel Generator 2, the motor-i operatedpotentiometerfailed, causing the diesel to drop load.
l Contrary to the above,for the two abovefailures, the licensee did not determine within 24 l
hours that the operable dieselgenerator was not inoperable due to common causefailure and did notperform TechnicalSpecipcation Surveillance Requirement 4.9.A.2.a.1 (to run l
the operable dieselgenerator) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. "
l Admission or Denial to Violation The District admits the violation.
Reason for Violation i
The surveillance requirement of Technical Specification 4.5.F.1.c was implemented in Amendment j
~ 175 to the CNS operating license on April 29,.1996. ~ Administrative controls for documenting the l
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required common cause failure analysis were not developed. This violation resulted from the failure of management to adequately communicate expectations through the development or initiation of administrative controls for the staff to implement the Technical Specification 4.5.F.1.c
'survedlance requirement regarding documentation of a common mode failure analysis.
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Attachment I 4
to NLS970092 Page 2 of 2 i
Corrective Stens Taken and the Results Achieved In both examples, Operations personnel were aware of the Technical Specification surveillance requirement. Common mode failure analyses that determined Diesel Generator 1 was operable were performed but not documented. Common mode failure evaluations were subsequently documented for both occurrences of Diesel Generator 2 inoperability. Both evaluations indicated Diesel Generator 1 was not inoperable due to a common cause.
Other occurrences of diesel generator inoperability since the Technical Specifica. tion surveillance
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requirement was implemented were reviewed for other examples of undocumented common cause failure analyses. No other examples were found.
Operations Management discussed this violation with all Shin Supervisors and Shift Technical Engineers to communicate expectations regarding review and documentation of Technical Specification requirements.
1 Additionally, the Tech Spec Tracker h6dlddsstiveli6tio5 programs have been revised to prompt personnel to perform and document the common cause failure analysis required when a Diesel Generator becomes inoperable.
T666und ihis b6sditidsf amendm~esiffe6eifid iAerMisesdmssi165%srs isvisned 16'srisure thafimplemestingshtisns*hAd beca'appropriaislyiaken3NAddNidual dierspanciedwere identified $(Ond piovisiori of Anishdment1175^)rovidingfdr in 6pildnsifsidWstsWilestlbt tlfi diesslisseEatofs nas purpossfully~noiLinunediatbiflimplemenied t6[ill6W fousiaintinanceland festins hessssary 16 suppoff;itA intplenisstatierQTheselictiohs;hnse snbsestuentip;bsen eonspisisa
' nd surveillande tes pfosedure5'resissd to suppshthis' optics)?Antendsnentneseissd pridrlt6 a
kmssdmenE166 had been'previodsip revisnedlddiisg the[1994 $1R95lltimsl;frsnik$i pattll6f th$
SdrveillancelTisttyslidatidnLPf6grinilSTYPN Corrective Steps That Will Be Taken to Avoid Further Violations N6ns!
Date When Full Compliance Will Be Achieved The District is in full compliance with respect to the identified violation.
l ATTACHMENT 3 LIST OF WRC COMMITMZNTS l
Correspondence No: NLS970092 The 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 docunent or any associated regulatory commitments.
l COMMITTED DATE COMMITMENT OR OUTAGE None.
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PROCEDURE NUMBER 0.42 l
REVISION NUMBER 4 l
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