ML20141F013

Responds to NRC Re Violations Noted in Insp Rept 50-298/96-25.Corrective Actions:Revised Procedure 0.7.1, Developed Performance Indicator for Transient Combustible Control & Held Ongoing Roundtable Discussions

ML20141F013
Person / Time
Site:	Cooper
Issue date:	06/26/1997
From:	Graham P NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-298-96-25, NLS970125, NUDOCS 9707010308
Download: ML20141F013 (5)

Text

.<

e P.O. BOX B LL NEBRA A 68321 Nebraska Public Power District "iE*ME""

NLS970125 June 26,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

Reply to a Notice of Violation NRC Inspection Report No. 50-298/96-25 Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

1. Letter to G. R. Horn (NPPD) from K. E. Brockman (USNRC) dated March 4,1997,"NRC Inspectim Report 50-298/96-25, Exercise of Enforcement Discretion and Notice of Violation"

2. Letter to U.S. Nuclear Regulatory Commission from P. D. Graham (NPPD) dated April 17,1997," Reply to a Notice of Violation"

3. Letter to G. R. Horn (NPPD) from A. T. Howell, III (USNRC) dated June 6, 1997, "NRC Inspection Report 50-298/96-25, Exercise of Enforcement Discretion and Notice of Violation" By letter dated March 4,1997, (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation of NRC requirements. Reference 2 forwarded the District's reply to NRC Inspection Report 50-298/96-25. Reference 3 acknowledged receipt and noted that the District's reply was responsive to violation A; however, noted that the response to violation B needed further clarification.

This letter, including Attachment 1, constitutes the District's revised reply to the referenced Notice ofViolation in accordance with 10 CFR 2.201. It replaces the previous reply in its entirety and any commitments made in that reply. The District admits to the violation and will be in full compliance upon completion of the corrective actions.

I

)

o fs 43 I@

NON10308 970626 l{ll(({fl!!!!)lfl!,,,(.,

PDR ADOCK 05000298 G

PDR N M M N Nkb b hN MO N 2DINNf!Nbb2[YNADNN~i[

'be%

b

=== w w = m w-

=

u== = - = a==

j i

(.

NLS970125 June 26,,1997

.Page 2 of 2 Should you have any questions concerning this matter, please contact me.

I Sincerely, hbhh P. D. Graham Vice President of Nuclear Energy -

/nr l

t

. Attachment cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution i

i l-l

t

' Attachment 1 to NLS970125 Page1of2 REPLY TO MARCH 4,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted on November 18-22 and December 9-13,1996, two violations of NRC requirements were identified. The District's response was provided in a letter from P. D. Graham to U.S. Nuclear Regulatory Commission dated April 17,1997. In reply you indicated that our reply was responsive to Violation A; however, noted that our response to Violation B needed further clarification. Our revised response is provided below.

?

Violation l

l 10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures be established to j

assure that corditions adverse to quality, such asfailures, malfunctions, deficiencies, deviations,

}

\\

defective material and equipment, and nonconformances are prompdy identified and corrected.

[

In the case ofsigmficant conditions adverse to quality, the measures shall ensure that the cause l

of the condition is determinedand corrective action taken to preclude repetition.

i Contrary to the above, on November 20, 1996, one of the corrective actionsfor Quality Assurance Audit 96-08, which included revising Procedure 0. 7.1, " Control of Combustibles, "

personnel training on this revision, amt interim plant walkdowns to identify and correct transient combustible controlproblems, was inadequate. Specifically, the plant walkdownsfailed to identify and correct three transient combustible controlproblems.

l This is a Sever : LevelIV violation (Supplement 1) (50-298/9625-07).

Admission or Denial to Violation i

l The District admits the violation.

Reason for Violation I

1. Interim corrective actions taken in response to Quality Assurance (QA) audit 96-08 have not been effective in maintaining compliance with procedure 0.7.1 requirements. Specifically, the interim corrective actions have not resolved concerns regarding control of small amounts of transient combustibles and procedure adherence. Although, interim corrective actions taken have resulted in elimination of accumulation of significart amounts of transient combustibles, they failed to maintain compliance with the requirements in Section 8.2 of Procedure 0.7. L In reference 2 the District indicated that housekeeping concems involving small quantities of transient combustibles had not been resolved. In reference 3 you stated that the lack of control of transient combustible materialis a significant condition adverse to quality. The District agrees that this lack of control of transient combustibles is the concern that should be addressed. Housekeeping has been a j

major focus at CNS and the cleanliness of the plant has been significantly improved. However, j

inadequate monitoring of feedback from the weekly walk downs resulted in a failure to adequately control transient combustibles.

... _. _ m __ _. _ _ _ _ _ _ _ _

Attachment I to NLS970125 Page 2 of 2 -

borrective Steos Taken and ' he Results Achieved t

The specific e.camples identified by this violation were resolved. Weekly plant walk downs by Fire Protection personnel are continuing and have succeeded in limiting the accumulation of transient combustibles to levels that do not challenge the Fire Hazards Analysis. In addition the following i

corrective actions have been completed to strengthen transient combustible control:

1. Procedure 0.7.1 was revised to address programmatic weaknesses

[

2. A performance indicator for transient combustible control has been developed to continually monitor and trigger management and supervisory intervention for procedure adherence.

L

3. Ongoing round table discussions have been held between the Engineering Support Manager, Maintenance Manager, Senior Staff Fire Protection Engineer, Maintenance Supervisors, and i

Maintenance Crew Leaders concerning the requirements of the transient combustible program and implementation ownership. During this discussion, the expectations of the Senior Fire Protection Engineer and the Maintenance Manager were clearly discussed and understood and this information was conveyed to the work force during daily meetings with the crew leaders.

Gz rective Steos That Will Be Taken to Avoid Further Violations T aining on the revision to Procedure 0.7.1 will be completed by August 1,1997.

Date When Full Comoliance Will Be Achieved The District is will be in full compliance with respect to the cited violation upon completion of the training.

\\

l h

l

4 b

~

l ATTACHMENT 3 LIST OF NRC COMMITMENTS l

l l

Correspondence No: NLS970125 The following table identifies those actions committed to by the District in this i

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 l

information and are not regulatory commitments.

Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE Training on the revision to Procedure 0.7.1 will be g

3 997 completed.

I l

PROCEDURE NUMBER 0.42 l

REVISION NUMBER 4 l

PAGE 7 OF 9 l