ML20140H791
| ML20140H791 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/11/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-97-03, 50-298-97-3, NLS970119, NUDOCS 9706180457 | |
| Download: ML20140H791 (4) | |
Text
.
P.O. BOX 00 Lt.E NED SKA 68321
(
.e
] Nsbraska Public Power District "M"aitt"
, = _ = =
= = _ _. - _ _
NLS970119 June 11,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violatior.
NRC Inspection Report No. 50-298/97-03 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from T. P. Gwynn (USNRC) dated May 16, 1997,"NR.C Inspection Report 50-298/97-03 and Notice of Violation" By letter dated May 16,1997 (Reference 1), the NRC cited Nebraska Public Power District
- District) as being in violation of NRC requirements. This letter, ine'uding 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 violation and has completed all corrective actions necessary to return CNS to full compliance.
Should you have any questions concerning this matter, please contact me.
Sincerely, PBKL~
l P. D. Graham j
Vice President of Nuclear Energy
/
9706180457 970611 PDR ADOCK 05000298
/nr G
PDR Attachment
-1 p b
,/, 4-cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident inspector USNRC llljl!l(ljll(j;lgj!!jjllljjllllll!lgl 170136 NPG Distribution mmw p y,~v m,s w-.4y g y p y g g g.gygggggnm v 3 _~ 7. a a. m
,~
l 3 :- -.
i to NLS970119 Page1of2 REPLY TO MAY 16,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE UPR-46 During NRC inspection activities conducted from Febmary 23,1997, through April 5,1997, one violation of NRC requirements was identified. The particular v,4ation and the District's reply are set forth below:
Violation Technical Specification 6.3.2, states, inpart, writtenprocedures and instructions shall be established, implemented, and maintainedfor thepre protection program.
Procedure 0.39, " Fire Watches, " Revision 12, Step 8.4.1, states in part, that allpre watch personnel shall be diligent in their obsenunce of the affected area and alertfor signs ofpre and smoke. Fire watchpersonnelshall maintain continuous observation of the affected area.
Procedure 0.39, Step 8.1.4, states, in part, that immediately prior to the start of the hot work, thepre watch shall ensure combustible materialshall be protectedfrom hot work.
Protection is requiredfor a radius of 35feetfrom the hot work.
Contrary to the above, on March 6,1997, during installation ofModification 94-072, pre watch personnel did not maintain continuous obsen ation of the affected area in that sparks from welding andgrinding extended beyond the range of the view of the camera usedforfire watch observation. Also, pre watchpersonneldidnot ensure that combustible material, which was located within 35 feet ofhot work in progress, wasprotected.
Admission or Denial to Violation The District admits the violation.
Reason for Violation Interviews conducted with the fire watches associated with this work indicated that Procedure 0.39, " Fire Watches," contained the appropriate requirements with respect to control and protection of combustible material in the vicinity of hotwork; however, strict compliance with the procedure was not enforced by supervision. The fire watches' tolerance of an inadequate field of view was also evidence of procedure adherence problems. A contributing cause to these procedural adherence problems was that a weakness existed in the procedure in that it did not l
provide specific guidance on the use of cameras and the authority to stop work if conditions were not in accordance with procedure requirements.
1
Attachmerit I toNLS970119 Page 2 of 2 Corrective Steos Taken and the Results Achieved immediate corrective actions taken included:
The conditions in the room were corrected by removing or protecting combustible materials and the addition of a third camera to increase the field of view.
l A site-wide moratorium on hotwork was implemented until briefings with fire protection personnel could be held for eachjob and work group to outline expectations for fire watch performance and to emphasize fire watch stop work authority if fire safe conditions do not l
exist.
A site wide stand down on work for procedure adherence was held the following day.
Included in this stand down was training and testing to procedure adherence expectations and requirements.
Procedure 0.39 was revised to clearly delineate the requirements for control and protection of combustible material in the vicinity of hotwork to aid procedural adherence.
As a result of these actions, no hotwork related fires occurred during the recently completed refueling outage. In addition, the following actions have been taken:
Ongoing corrective actions to address the site wide issue of procedural adherence have been made a station alignment issue and incorporated into the business plan.
Administrative Procedure 0.39 was revised to specify the conditions under which and how cameras may be utilized for fire watch activities and to include a discussion on fire watch authority in addition to responsibilities.
Corrective Steos That Will Be Taken to Avoid Further Violations No further corrective actions beyond those discussed above are required.
Date When Full Comoliance Will Be Achieved The District is in full compliance with respect to the cited violation.
l I
l
l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
~
- e 1
Correspo'dence No: NLS970119 n
i The following table identifies those actions committed to by the District in this document.
Any other actions discussed in the submittal represent intended or l
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 t
j COMMITTED DATE COMMITMENT OR OUTAGE None i
i 1
1 1
)
l I
i l
l l
PROCEDURE NUMBER 0.42 l
REVISION NUMBER 4 l
PAGE 8 OF 9 l
l l
.