ML20141F061

Provides Addl Info Re Insp Rept 50-298/96-31 Re Problem Identification Rept Generation for Maint Discrepancies. Util Performed Addl Sampling of Completed Maint Work Requests

ML20141F061
Person / Time
Site:	Cooper
Issue date:	06/24/1997
From:	Graham P NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-298-96-31, NLS970097, NUDOCS 9707020002
Download: ML20141F061 (3)

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s P.O. BOX B ILL NEB 68321 Nebraska Public Power District TMS""

NLS970097 June 24,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

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Gentlemen:

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Subject:

Supplemental Response to NRC Inspection Report No. 50-298/96-31 l Cooper Nuclear Station, NRC Docket 50-298, DPR-46 l

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Reference:

1. Letter to G. R. Horn (NPPD) from T. P. Gwynn (USNRC) dated June 13,  :

1997,"NRC Inspection Report 50-298/96-31"

2. Letter (No. 970047) to USNRC Document Control Desk from P. D. Graham dated March 31,1997," Reply to a Notice of Violation; NRC Inspection Report No. 50-298/96-31" ,

3. Letter to G. R. Horn (NPPD) from T. P. Gwynn (USNRC) dated June 9,1997, "NRC Inspection Report 50-298/97-05" i

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, As requested in your June 13,1997 letter (Reference 1) the Nebraska Public Power District (District) provides this supplemental response to NRC Inspection Report 50-298/96-31 for Cooper Nuclear Station (CNS). The following discussion provides additional information concerning violation 298/96031-02 regarding problem identification report (PIR) generation for maintenance discrepancies.

4 The District's March 31,1997 response to IR 96-31 (Reference 2) indicated that a sampling of 200 closed Maintenance Work Requests (MWRs) revealed nine MWRs with discrepancies which t may have required PIRs. None of these discrepancies were significant. However, the response did not indicate whether a PIR to address these discrepancies was generated as part of the corrective actions. The District has written a PIR to address these discrepancies.

Further, as discussed in the NRC's June 13,1997 letter, the District's initial response to Violation 298/96031-02 did not address whether an expansion of the MWR review was performed or warranted to bound this issue based on the results of the initial sampling. The District has performed additional sampling of completed MWRs. The scope of this review included 51 recently completed MWRs to provide an indication of the effectiveness of corrective actions to date, and focused on larger, more complex MWRs. Ten of these MWRs contained discrepancies which should have resulted in generation of PIRs but did not. PIRs were written to address these issues. None of these issues were determined to be sinnificant.

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.U. S. Nuclear Regulatory Commission June 24,1997 Page 2 of 2 These reviews did not identify any significant issues requiring further evaluation. Based on these results, the District has determined that no further review ofclosed MWRs is necessary. The District acknowledges that continued communication of management expectations concerning PIR initiation for identified maintenance discrepancies is necessary. However, based on the low significance of those issues identified during the MWR reviews, the District has determined that further sampling of closed MWRs is not warranted.

As discussed in NRC Inspection Report 50-298/97-05 (Reference 3), there has been an increase in the quantity and quality of PIRs generated recently by the CNS maintenance organization, demonstrating improvement in this area. Ilowever, as discussed above, continued management attention is necessary. Therefore, the District will continue to communicate managen:ent's expectations regarding use of the CNS Corrective Action Program to address conditions identified during performance of maintenance activities.

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

Sincerely, P876PL P. D. Graham Vice President - Nuclear

/dnm Attachment cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident inspector USNRC f

NPG Distribution

l. ATTACHMENT 3 LIST OF NRC COMMITMENTS l Correspondence No: NLS970097 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 document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None "^

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l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l I