ML20150A285
| ML20150A285 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/24/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-96-24, 50-298-96-31, NLS970144, NUDOCS 9707300089 | |
| Download: ML20150A285 (16) | |
Text
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I, P.O. 00X OF WN LL NEB A 68321 Nebraska Public Power District "E%Ni
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NLS970144 July 24,1997 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 Nos. 50-298/96-24 and 96-31 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from E. W. Merschoff(USNRC) dated June 25, 1997, " Notice of Violation and Exercise of Enforcement Discretion (NRC Inspection Report Nos. 50-298/96-24 and 96-31)"
By letter dated June 25,1997 (Reference 1), the Nuclear Regulatory Commission (NRC) cited Nebraska Public Power District (District) as being in violation of NRC requirements. This letter, including Attachment 1, constitutes the District's reply to the referenced Notices of Violation in accordance with 10 CFR 2.201. The District admits to the violations and has completed corrective actions necessary to return Cooper Nuclear Station (CNS) to full compliance regarding the enforcement issues.
Although the District is not in full compliance with respect to all Updated Safety Analysis Report (USAR) issues, CNS is working to achieve full compliance via the USAR Rebaselining Project.
Should you have any questions concerning this matter, please contact me.
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Sincerely, G
h P. D. Graham
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z Vice President of Nuclear Energy
/lrd Attachment 9707300089 970724 PDR ADOCK 05000298 O
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l NLS970144 July 24,1997 Page 2 l
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Regional Administrator USNRC - Region IV 1
Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident inspector USNRC
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to NLS970144 Page 1 of 13 REPLY 10 JUNE 25,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION l
NRC DOCKET NO. 50-298, LICENSE DP.R-46 During NRC inspection activities conducted from October 7,1997, through February 19,1997, violations of NRC requirements were identified. The particular violations and the District's reply l
are set forth below:
Violation A. 10 CFR 50. 71 (e) requires that the Updated Safety Analysis Report be updatedperiodically to assure that the information in the UpdatedSafety Analysis Report contains the latest material developed. 10 CFR 50. 71(e)(4) requires that revisions hefiled annually or 6 months aper each nfueling outage provided the interval between successive updates does not exceed 24 months. 1he revisions must reject all changes up to a maximum of 6 months prior to the date offiling.
Contrary to the above, the licensee didnot update the USAR within the required timeframe for thefollowing examples, each ofwhich constitutes a separate violation.
1hese violations npresent a Severity Level HIproblem (Supplement 1) (50-29W96024-14).
1.
As ofNovember I,1996, Updated Final Safety Analysis Report Section Xil-2.3.5.2.2, "l Seismic Analysis] Piping,"and UpdatedSafety Analysis Report, Appendix C,
" Structural Loading Criteria, " Section 3.3.3.2, " Piping Seismic Analysis, " was not updated to accurately reflect the seismic analysis practices at the time. Since initial 1
construction of thefacility, these sections of the Updated Safety Analysis Report (and the Final Safety Analysis Report), have described, in detail, the procedurefor dynamically analy:ing Class-1 seismicpiping systems without restricting the requirementfc>r dynamic analysis to large bore piping. However, as ofNovember 1,1996 (cmdsince initial construction), the dynamic seismic analysis describedin the Updated Safety Analysis Report ':
not performedfor 2-inch and smaller piping systems.
Admission or Denial to Violation The District admits the violation.
to NLS970144 Page 2 of 13 Reason for Violation Consistent with industry practices at the time, the piping systems at CNS were designed in accordance with USAS B.31.1-1967, which does not require detailed calculations for pipe support locations and has less restrictive requirements for piping less than 2-1/2" in diameter than for the large bore piping; the small bore piping systems were designed and installed using bounding static analysis (span charts and load tables). The NRC has accepted this method of analysis as documented by NRC Bulletin No. 79-14, Revision 1, and NUREG-0800.
This description in the USAR, which has existed since the original Final Safety Analysis Report (FSAR), did not differentiate between <2-1/2" piping due to a general industry understanding that because there were no detailed analyses required, a dynamic seismic analysis would not be performed. The District acknowledges that when the original FSAR was updated, this should have been clarified but apparently was not identified as the discrepancy was not the result of a change introduced subsequent to transmittal of the original FS AR.
Corrective Steos Taken and the Results Achieved USAR Section XII-2.3.5.2.2 and Appendix C Section 3.3.3.2 were revised to indicate that for Class I Seismic piping systems 2-1/2" and greater in diameter, dynamic analyses were performed, and for Class I Seismic piping systems less than 2-1/2" in diameter, piping and supports were field routed using span and load chart tables.
Corrective Steos That Will Be Taken to Avoid Further Violations The District has processes and programs in place to prevent similar violations, specifically the USAR Rebaselining Project'.
Date When Full Comoliance Will Be Achieved 1
The District is in full compliance regarding the identified violation.
2.
As ofNovember 1,1996, UpdatedSafety Analysis Report, Section lH-9.3, "[ Standby l
Liquid Control System] Description, " was not updated to accurately reflect the expected l
room temperaturesfor the standby liquid controlsystem and the controls in place to ensure safe operation with a room temperature of 50"F. Updated Safety Analysis Report, Section X-10.3.2 "[ Heating, Ventilation and Air Conditioning Systems] Station Heating System, states that winter design temperaturesfor the system are give in lable X-10-1.
l'able X-10-1, "[ Heating, Ventilation and Air Conditioning Systems] Station Heating Design Temperatures (Winter), " states that the normal minimum indoor temperaturefor NLS970053, Letter from P.D. Graham (NPPD) to NRC Document Control Desk, "USAR Rebaselining Project Description," dated March 31,1997.
. Attachment 1 to NLS970144 o
Page 3 of 13 the reactor building is 50"F. The equipment containing the solution is installed in a
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room in the reactor building. However, as ofNovember I,1996 (andsince initial construction), Updated Safety Analysis Report, Section IH-9.3, "[ Standby Liquid Control Systeml Description, " stated that, "The equipment containing the solution is installed in a room in which the air temperature is to be maintained within the range of 65"F to l
100"F. "
i Admission or Denial to Violation The District admits the violation.
Reason for Violation At the time this language was placed in the FS AR, prior to the promulgation of 10 CFR 50.71(e),
the description did not take credit for heaters which are installed to maintain solution temperatures. When the FSAR was updated in 1983, it was updated based on the best available information, which may have lacked clarity and completeness. Thus the wording is unclear in that the District did not include in the USAR that although the minimum temperature in the reactor building is 50"F, the Standby Liquid Control System solution minimum temperature is maintained with the addition of heaters or dilution if the heaters fail.
Corrective Steps Taken and the Results Achieved USAR Section III-9.3 was revised to clarify the normal room temperature in which the Standby Liquid Control System equipment is located to be consistent with the description found in Section X-10.3.2. The revised section now reads,"The equipment containing the solution is installed in a room in which the air temperature is normally maintained within the range of 50 to 100"F.
Corrective Steos That Will Be Taken to Avoid Further Violations The USAR Rebaselining Project and increased focus on identification and timely correction of US AR inconsistencies are currently in place to prevent similar violations.
Date When Full Comoliance Will Be Achieved The District is in full compliance regarding the identified violation.
3.
As ofNovember I,1996, Updated Safety Analysis Report, Section Hl.9.4, "l Standby Liquid Control System] Safety Evaluation, " was not updated to correctly describe the safety basisfor the standby liquid control system relief valves. Design Change 86-34A, "SLC/A TWSModifications, " Revision 0, datedMarch 4,1988, changed the safety basis for the standl,y liquid control system relief valve settingsfrom:
Attachment I to NLS970144 o
Page 4 of 13 assuring injection into the reactor above the normal l emphasis added]
pressure of approximately 1030 psig in the bottom of the reactor, 10:
assuring injection into the reactor above the anticipated transient
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without scram reactorpressure conditions, which would ectual the reactor safety / relief valves 'setpointsplus the accumulation at the
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maximum anticipated transient without scram steamflow, (i.e.,
approximately 1100psigplus the static headin the reactor vessel).
j Specifically, Section HI-9.4 continued to state that "The SLC system andpumps have sufficient pressure margin, up to the allowedsystem relief valve setting range of1450 to 1680 psig, to assure solution injection into the reactor above the normal (emphasis added) pressure ofapproximately 1030psig in the bottom of the reactor. "
Admission or Denial to Violation The District admits the violation.
Reason for Violation Design Change 86-34A, "SLC ATWS Modifications," changed the Standby Liquid Control (SLC) system relief valve settings such that the system would be capable ofinjecting liquid control solution at the reactor pressure which would be expected during an Anticipated Transient Without Scram (ATWS) event. The wording in the USAR was not clear in that the USAR did not specifically mention " anticipated ATWS pressures" when describing SLC spem capabilities.
This is due to an apparent lack of thoroughness in updating the USAR as a result of a design change.
Corrective Steos Taken and the Results Achieved USAR Section III-9.4 was clarified to be more consistent with the change in the safety basis resulting from Design Change 86-34A. ~ Section 111-9.4 now states, "The SLC system and pumps have sufficient pressure margin, up to the allowed system relief valve setting range of 1450 to 1680 psig, to assure solution injection into the reactor at anticipated A TWSpressures (near 1100 psig), which are [ emphasis added] above the normal pressure of approximately 1030 psig in the bottom of the reactor."
Corrective Steos That Will Be Taken to Avoid Further Violations The USAR Rebaselining Project and increased focus on identification and timely correction of j
USAR inconsistencies are currently in place to prevent similar violations.
._m._
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. Attachment 1 to NLS970144 Page 5 of 13 Date When Full Comoliance Will B( Achieved The District is in full compliance regarding the identified violation.
4.
As ofNovember 1,1996, UpdatedSafety Analysis Report, Section 111.9.3, "l Standby Liquid Control] Description, " was not updated to be consistent with Techraical Specification Figure 3.4.2. The UpdatedSafety Analysis Report states that at the minimum room temperature of 65 F, the maximumpermittedsolution concentration is l
12.5 weightpercent. Section 111-9.3 also states that a concentration of11.5 percent corresponds to an adjustedsaturation temperature of 61 F. The UpdatedSafety Analysis Report adjusted saturation temperature includes a 10 F margin over saturation, which corresponds to the definitionfor the TechnicalSpecification minimum allowable temperature. However, TechnicalSpecylcation Figure 3.4.2, " Percent Sodium Pentaborate by Weight ofSolutions versus Temperature, " indicates that at 65 F, the maximum permitted concentration was 12.1 percent. At 11.5 percent concentration, the 1
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minimum allowable temperature was 62 F.
l Adm.ission or Denial to Violation The District admits the violation.
4 4
Reason for Violation The USAR did not state the same requirements as the Technical Specifications, and therefore the USAR description was unclear. This inconsistency was apparently introduced with the implementation of Design Change 94-041 and the attending Operating License Amendment, which revised the volume-concentration envelope to specify a new minimum concentration of 11.5 weight percent. The failure to recognize this deficiency was principally caused by an evolving USAR control process which did not initially include a rigorous content comparison and update standard.
Corrective Stens Taken and the Results Achieved USAR Section 111-9.3 was updated to be consistent with the Technical Specifications Figure 3.4.2 and clarify SLC system requirements by describing the dilution of solution in the suction line and referring to the Technical Specifications for the temperature versus concentration curve. The USAR description was clarified to state that at the minimum allowable 11.5% solution concentration, the adjusted saturation temperature is 62'F. The USAR also was clarified to indicate that the ".. adjusted saturation temperature is equal to the actual saturation temperature plus 10 F."
. Attachment 1 to NLS970144 Page 6 of 13 Corrective Steos That Will Be Taken to Avoid Further Violations The US AR Rebaselining Projec: and timely correction of USAR inconsistencies are currently in place to prevent similar violations.
Date When Full Comoliance Will Be Achieved The District is in full compliance regarding the identified violation.
5.
As ofNove nber I,1996, Updated Safety Analysis Repor Laion Il'-9.3, "l Reactor ll'ater Cleamip & stem] Description, " was not updated tr :mrlyindicate the effect ofa modification on the reactor water cleanup system isolation <alves ' controllogic.
i Further, neither Sectio n'-9.3 nor Section 111-9.3 "l Standby Liquid Control System]
Description, " were updated to indicate thatfollowing the modification it was always necessary to operate both SLC trains to clow both motor operated valves and maintain comparable defense aga,nst a singlefaihn nf the reactor water cleatmp isolation valves.
At Ihe time of the inspection, UpdatedSafety Analysis Report, Section IV-9.3, "l Reactor IVate. Cleamip System] Descdption, " stated that, In the inlet piping to the cleamtp recirculation pumps, two motor operatedisolation tw'ves, one on either side of the primary containment, are automatically closed by. s andby liquidcontrolsystem actuation. " Design Change 86-34A, "SLC/A 11VS Afodifications, " Revision 0, Afarch 4,1988, changed the reactor water clearr:p system isolation vcdves ' contnllogic
.sch that initiatwn of one train of the SLC sysicm no longer closed both motor operated
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vidves. In order to achieve comparable defense against a singlefailure of the reactor water cleanup isolation valve, the licensee inquemented administrative procedures which require operators to ahrays op' ' ate both trains of the standby liquid control system.
tt mion or Denial to Violation The District admits the violation.
j Reason for Violation Design change 86-34A, in response to 10 CFR 50.62, changed the logic such that starting the
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SLC Pump A closes the inboard Reactor Water Cleanup (RWCU) isolation valve, and starting the SLC Pump B closes the outboard RWCU isolation valve. The USAR Section on SLC was updated to reflect the design change accurately, howe.er le design change was not reflected in great detail in the RWCU description. The isolations are described in greater detail in the SLC section of the USAR since initiation of that system initiates the RWCU isolations. This should have been clarified in the RWCU sectic,n as well, but was apparently included in the USAR at a level af descriptiveness commensurate with the other four RWCU isolation valves listed.
. Attachment 1 to NLS970144 Page 7 of 13 Corrective Steos Taken and the Results Achieved USAR Section IV-9.3 (RWCU system description) was updated to clarify that starting SLC Pump A closes the inboard RWCU isolation valve, and starting SLC Pump B closes the outboard RWCU isolation valve.
Corrective Steos That Will Be Taken to Avoid Further Violations The USAR Rebaselining Project and increased focus on identification and timely orrection of USAR inconsistencies are wrrently in place to prevent recurrence of this violation.
D2tr When Full Comoliance Will Be Achieved The District is in full compliance regarding the identified violation.
6.
In 1994, during the surveillance test mlidationprogram status review, the licensee identified at lemt two discrepancies in the Updated Safety Analysis Report, which were not correctedin the July 22,1996 update to the UpdatedSafety Analysis Report.
(a)
Updated Safety Analysis Report, lable Vll-3-1, " Pipeline Penetrating Containment, " Note 4 incorrectly state <' that the control rod drive system solenoid valves open during a reactor wm. On reactor SCRAM the solenoid mlves remain closed and the air-operated SCRAM valves open to insert the control rods and to exhaust water to the SCRAM discharge volume.
I (b)
Updated Safety Analysis Report, Section V11-4.5.44l4.5.4.4], "l Core Spray System ControlandInstrumentation] Core Spray Valvc Control," incorrectly stated t! at two pressure switches monitor system pressurc (for the low pressure permissive). In addition, it indicates that wither switch can initiate opening of the discharge valvesfor core spray. There actually arefourpressure switches designed in a 1. out-of-2 twice logic and a minimum of two switches are required to actuate to initiate opening of the core spray valves.
Admission or Der.ial to Violation The District admits the violation.
Reason for Violation During the Surveillance Test Validation Program project, there was minimal focus on the U%R, no single update control process, and an inadequate validation process resulted in the delay in properly correcting the US AR once the deficiencies had been identified.
. Attachment 1 i
to NLS970144 1
Page 8 of 13 Corrective Steos Taken and the Results Achieved USAR Table VII-3-1, Note 4 was updated to indicate the correct control rod drive system valve positions on a reactor scram. USAR Section VII-4.5.4.4 was also updated to indicate the correct Core spray system pressure switch logic for opening the discharge valves.
In addition, Procedure 0.29.2,"USAR Change Requests," has been revised to ensure proper control and verification oflicense change documents.
Corrective Steos That Will Be Taken to Avoid Further Violations The US AR Rebaselining Project and increased focus on correction of USAR inconsistencies are in place to ensure timely identification and upiating deficient USAR information and prevent recurrence of this violation.
Date When Full Comnliance Will Be Achieved The District is in full compliance regarding the identified violation.
7.
As ofMarch 16,1996, UpdatedSafety Analysis Report, Table V-2-2, " Penetration Schedule, "pages V-2-9 to V-2-12, was not updated to correctly list all the penetrations; the quantity oflines in three penetrations; and line descriptions infive penetrations.
8.
As ofMay 4,1996, UpdatedSafety Analysis Report, Table V-2-7, " Testable Primary Containment isolation Valves, "pages V-2-44 to V-2-46, did not list 23 penetrations (X20, X-30E and -30F, X-33E and-33F, X-35A through E, X-45D, andX-229A through L) and their associated valves.
Admission or."Wal to Violation The District admits the violations.
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.Attachmeia 1 to NLS970144 Page 9 of 13 Reason for Violation Several of the discrepancies noted were a result of the USAR tables not being reviewed and updated to reflect new configurations brought about by design changes. Prior to the discovery that these deficiencies existed, the US AR was not properly corrected in a timely manner, primarily due to the low priority consistent with industry and regulatory practices at the time. Contributing to this was a general lack of knowledge of the USAR tables with respect to primary coctainment penetrations. Once recognizing the deficiencies existed, extensive research and implemer tation of corrective actions was perfonned.
Corrective Stens Taken and the Results Achieved A walk down of primary containment penetrations and valves was conducted in 1994 and documented in Condition Report 94-412. A review of primary containment design change documents, drawings, and walk down results was performed to determine the extent of discrepancies in the USAR Tables V-2-2 and V-2-7. During this review it was discovered that Figure V-4-1, which includes a penetration schedule, was inconsistent with the information listed in Table V-2-2. In addition, it was determined that the existence of the tables and the figure rendered the description of primary containment penetrations and associated valves less clear and more prone to errors. Thus, to consolidate and clearly identify the correct configuration, USAR Tables V-2-2 and V-2-7 were removed and the information incorporated into USAR Figure V 1. Specifically, as a result of the review conducted, corrected and legible copics of Burns & Roe Drawing 4259 Sheets 1 & 1 A were generated for USAR Figure V-4-1, and a new Figure V-4-3 was generated using Burns & Roe Drawing 4260 Sheets 2A & 28. These drawings, which accurately reflect the primary containment penetrations and associated valves, have replaced the US AR tables to avoid further inaccuracies.
USAR Figures V-4-1 and V-4-3 accurately list the penetrations, quantity oflines in the penetrations, and the line descriptions. These figures also now list penetrations X20, X-30E and -
30F, X-33E and -33F, X-35A thogh E, X-45D, and X-229A through L) and their associated i
valves.
4 Finally, revisions to the training qualifications and increased management oversight for safety evaluations and 50.59 screens have been implemented to ensure that changes to the USAR are appropriately identified and that the USAR is subsequently updated in a timely manner to accurately reflect plant configuration.
Corrective Steos That Will Be Taken to Avoid Further Violations The USAR Pebaselining Project and increased focus on correction of USAR inconsistencies are in place to e. cure timely identification and updating deficient USAR information.
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. Attachment 1 to NLS970144 Page 10 of 13 Date When Full Comnliance Will Be Achieved The District is in full compliance regarding the identified violations.
B.
10 CFR 50.59(b)(1) requires that the licensee maintain records ofchanges in thefacility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in *hefacility as described in the safety analysis report or to the extent that they constitute changes in the procedures as described in the safety analysis report. Further, these records must inchide a written safety evaluation which provides the basesfor the determination that the change does not involve an unreviewed safety questions.
Contrary to the above, the licensee either did not perform the required written safety evahtation orperformed an inadequate safety evaluation as shown in thefollowing examples, each ofwhich constitutes a separate violation.
1.
Updated Safety Analysis Report,Section X.8.2.8.C, " Common Mode Failure Analysis -
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Fire, " required that combustibles not be locatedin the service water boosterpump room area since both trains of the service water system were located in close proximity.
However, Procedure 0. 7.1, " Control of Combustibles, " Revision 6, allowed up to 90 pounds of wood or 5 gallons offlammable liquidfor this area of the plant. In addition, on December 2,1996, combustible materials (rags, papers, andflammable chemicals) were locatedin the service water system boosterpump room. The written safety evaluationfor this chantre in procedure was inadequate, in that, a common modefailure analysis had not been performed tojustify the presence of combustible materials in the service water boosterpump area, and therefore, the safety evaluation did notprovide a basesfor the determination that the change does not involve an unreviewed safety question.
Admission or Denial to Violation The District admits the violation. However, the District continues to believe that the NRC finding should be considered a violation of 50.71(e). This conclusion is primarily based on the fact that the as-found condition had been previously reviewed and evaluated by the NRC in a CNS Appendix R exemption request (and subsequent Safety Evaluation Report granted), and is controlled by approved proceaures. Therefore it is not clear to the District what additional 50.59 reviews should have been performed.
Reason for violation Changes to procedures require a 50.59 review, and when Procedure 0.7.1 was revised, the 50.59 performed did not identify the inconsistency between the Fire Hazards Analysis and the USAR.
Sinc.e the NRC relies upon in part, the descriptions in the US AR as the licensing basis, the District acknowledges these descriptions must be consistent with NRC approved evaluations and
. Attachment 1 to NLS970144 Page 11 of 13 reflect actual plant conditions and configuration, and as such the changes to Procedure 0.7.1 should have identified a discrepancy between the USAR and the Fire Hazards Analysis.
Corrective Stens Taken and the Results Achieved in accordance with station procedures, USAR Section X-8.2.8.C was revised to indicate that the presence of combustibles in the service water booster pump area is limited. This included a 50.59 applicability screen, which concluded that an unreviewed safety question determination was not required since this item had been previously reviewed and approved by the NRC in the form of the Appendix R SER, Section 2.6.1.
c Corrective sigs That Will Be Taken to Avoid Further Violations Processes and program, including the USAR Rebaselining Project, are in place to prevent recurrence of similar violations.
Date When Full Comoliance Will Be Achieved The District is in full compliance regarding the identified violation.
2.
Updated Safety Analysis Report, Section XH.2.2. 7.1, " Intake Structure, " states, in part, that in order to keep ice awayfrom the intake structure during cold weather, an ice deflector is installed during the winter months. Although aportion of the ice deflector was installed on December 18,1996, the deflector had not beenfidly installed at any time during the winter months. 1hefailure toftdly install the ice deflector by the winter months was a configuration changes / change] that had not been evaluated, through a written safety evaluation, as a change to thefacility.
Admission or Denial to Violation The District admits the violation.
Reason for Violation The ice deflector is usually installed at the end of the Missouri navigation season, based on seasonal temperaturce and river water level. Typically this occurs around the first of December.
Io November of 1996, environmental conditions were conducive to the formation ofice and fk ating ice on the river was apparent. However, the ice deflector was not fully installed because of lifliculties encot.nt red with a high river level. This conflicted with the USAR statement that the deflector is installed during the winter mentbs in order to keep ice away from the intake structure. The installation procedure did not direct that a 50.59 evaluation be performed in the event that the ice deflector cannot ne installed but ice is present and personnel failed to recognize that the plant configuration (ice deflector fully installed) represented a change to the facility as
rAttachment 1 to NLS970144 Page 12 of 13 described in the USAR (ice deflector is installed during winter months, which implies that the ice deflector should be in place whenever ice is present).
Corrective Steos Taken and the Results Achieved J
A 50.59 safety evaluation was per.'ormed which addresses the fact that the ice deflector may not be in place during periods when ico is on the river. The safety evaluation determined that "..the ice deflector is not required to support any safety related system and its absence will not result in an accident or abnormal transient." It further states that, ".. failure or absence of the ice deflector will have no impact on the ability of the service water system to satisfy its safety functions." This is based on an evaluation of the effects a failure of the ice deflector and subsequent ice buildup in the intake structure would have on safety systems supported by circulating water and service water. Thus it was determined that an unreviewed safety question did not exist.
As a result of the evaluation, USAR Sections XII-2.2.7.1 and X11-4.0 were updated to clarify the description of the ice deflector: "An Ice Deflector is placed in the Missouri River to direct float ice away from the intake Structure. The Ice Deflector is a non-essential component which enhances plant operations. The presence of the Ice Deflector is scheduled around the Missouri River navigational season."
Corrective Steos That Will Be Taken to Avoid Further Violations Processes and programs are in place to prevent recurrence of this violation.
Date When Full Comoliance Will Be Achieved The District is in full compliance regarding the identified vietation.
3.
Updated Safety Analysis Report,Section IV.10.3, " Nuclear System Leakage Rate Limits -
Description, " states, in part, that each containment drywell sump has an alarm. system and automatic starting sequence on rising water level. Both containment dr>well sumps
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are equipped with apil rate timer and alarm. This alarm can be set at or below the 1
Technical Specification limits and wouldprovide immediate indication when this preselected rate is reached or exceeded. Huwever, the safety evahiation dated December 20.1996, that addressed thefaihire of the automatic pump starting system, and the failure of the sumpfill rate timer and high level alarm, was inadequate in that it did not j
address the lack of control room alarm. A separate written safety evaluation did not existfor this change to thefacility.
Admission or Denial to Violation The District admits the violation.
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, Attachment 1 to NLS970144 Page 13 of 13 Reason for Violation The sections of the USAR referenced in the 50.59 safety evaluation do not include descriptions of the control room alarm function. Due to lack of attention to detail, the evaluation failed to reference Section IV-10.3, and thus the control room alarm function was not discussed in the evaluation.
Corrective Steos Taken and the Results Achieved The 50.59 safety evaluation was revised to include USAR Section IV-10.3, and it was determined that no unreviewed safety question existed.
Cocrective Steos That Will Be Taken to Avoid Furthe-Violations Processes and programs are in place to prevent the recurrence cf similar violations.
Date When Full Comoliance Will Be Achieved The District is in full compliance regarding the identified violation.
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ATTACHMENT 3 LIST OF NRC COMMITMENTS l
4 Correspondence No: NLS970144 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 d
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 l
PROCEDURE NUMBER 0.42 l
REVISION NUMBER 4 l
PAGE 8 OF 9 l