ML20151Z571
| ML20151Z571 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/14/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-98-03, 50-298-98-3, NLS980131, NUDOCS 9809220026 | |
| Download: ML20151Z571 (5) | |
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Nebraska Public Power District Nebraska's Energy Leader NLS980131 September 14,1998 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 l-Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/98-03 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from Elmo Collins (USNRC) dated June 23, 1998,"NRC Inspection Report 50-298/98-03 and Notice of Violation"
- 2. Letter (No. NLS980112) te L'SNRC Document Control Desk from M. F.
j Peckham for J. IL Swailes (NPPD) dated July 23,1998, " Reply to a Notice of Violation"
- 3. Letter to G. R. Horn (NPPD) from Thomas P. Gwynn (USNRC) dated August 10,1998,"NRC Inspection Report 50-298/98-03" In Reference 2, the Nebraska Public Power District (District) submitted its response to inspection Report (IR) 50-298/98-03 (Reference 1) and Notice of Violation (NOV) for the Cooper Nuclear Station (CNS). On August 4,1998, per telephone conversation between M. Peckham (NPPD) and C. Marschall (USNRC) of the Nuclear Regulatory Commission (NRC), it was agreed that the
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District's response to the NOV would be revised. Reference 3 provides a confirmation of that agreement. Per the request of Reference 3, the District hereby provides, in the attachment to this
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letter, its revised response to IR 50-298/98-03. The information revised is indicated by revision L
bar in the right-hand margin of the attachment.
Should you have any questions conceming this matter, please contact me.
N Sm.ce ly, h
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L Jo n H, Swailes Vice President of Nuclear Encrev 9809220026 990914 PDR ADOCK 05000298 G
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PO. Box 98/ Smwnville NE 68321D098 Cooper Nudear Station
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- %-Lk-Telephone: (402) 82S-38H / Fax: (402) 825-5211
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http1/www nppd com i
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'NLS980131
. September 14,1998
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Page 2 of 2
- /dnm Attachment cc: Regiorial Administrator 1
USNRC - Region IV i
i Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution l
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4 Attachment to L
- NLS980131 Page1of2
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REPLY TO JUNE 23,1998, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from April 19,1998, through May 30,1998, one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
Violation l
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. Technical Specifications Table 3.21.A.1 specifies that,for the service water effluent line, the minimum required number ofgross beta or gamma radioactivity monitoring channels being l
operable is one during releases via the pathway.
Technical Specifications 3.21.A.J.d. required that, ifthe minimum number ofchannels is not i
returned to OPERABLE status within 31 days, in lieu ofany other report, explain in the next Annual Radioactive Materials Release Report why the instrument was not repaired in a timely manner.
Contrary to the above, with the service water effluent line radiation monitors inoperable, during liquid discharges, form October 22 through December 31,1997, no explanation was included in the subsequent Annual Radioactive Materials Release Report and the condition was not repaired in a timely manner.
' Admission or Denial to Violation The District admits the violation.
Reason for Violation The reason for the violation is that the CNS person responsible for the Limiting Condition for Operation (LCO) tracking system did not utilize this system appropriately. This person failed to make the appropriate entries that would have tracked all the actions affiliated with Technical Specification (TS) 3.21.A.Ld to completion.
The District utilizes a Computerized LCO Index System for tracking open LCOs. When an LCO is entered, the LCO action requirements are entered into this computerized tracking system. On October 22,1997, LCO Track Number 97-0892 was opened to document the actions to be taken in Table 3.21.A.1, Item 2, due to water leakage past Service Water (SW) motor operated valves o
-(MOV) 89 A&B. When this entry was made, however, no entry was made concerning TS
' 3.21.A.l.d, which stipulated the reporting requirements, if the condition exceeds 31 days.
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e, Attachment to l
NLS980131 Page 2 of 2 A contributing factor to the personnel error described above is that a weakness in the Operations instruction which governs information put into the TS Tracking System also exists. While the instruction directs Operations personnel to identify all conditions of the LCO, it does not include guidance to look for reporting conditions.
Another contributing factor is that the current design of the SW radiation monitors does not match that which is required to support monitoring capability during other than design flow conditions (e.g., low flow conditions encountered as a result of SW-MOV-89A&B leak-by).
This required the SW radiation monitors to be declared inoperable, and thus, required entry into Table 3.21.A.1, Item 2. Entry into this table ensured that radiological monitoring was being accomplished through daily grab samples. These grab samples provided compensatory measures in recognition that valves SW-MOV-89A&B were in a degraded condition (water leakage past valves). Valves SW-MOV-89A&B have historically experienced leakage and are being redesigned to better withstand the environment associated with the SW system. Implementation of the design change will be completed during Refueling Outage (RFO) 18.
Corrective Stens Taken and the Results Achieved As a result of Operations shift mentoring performed in early 1998, increased awareness of the I
necessity of making complete and concise LCO Action Statements in the Open LCO Index System has occurred. This is apparent in four LCO entries during the last two months where the required additional reporting was found to be included in the LCO Action Statement.
The Operations instruction associated with the LCO Index System has been reviewed for adequate guidance on the completeness of LCO Action entries, and was revised during August 1998.
Corrective Stens That Will Be Taken to Avoid Further Violations l
- The District is evaluating various options for modification to the SW radiation monitors that would permit the monitors to be operable under various system flow conditions. These options include, but are not limited to, relocation of the sample connections or changing the monitors to an external monitor attached directly to the SW effluent piping. The District will complete this evaluation by March 31,1999.
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To address the leakage associated with SW-MOV-89A and B, these valves are being redesigned. Implementation of the design change will be completed during RFO-18, currently scheduled to commence October 1998.
Date When Full Comnliance Will Be Achieved The District is currently in compliance.
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS e
l Correspondence No:NLS990131 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 NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE Operations instructions associated with the Open LCO Index System will be reviewed for adequate guidance on Action completed August 1998.
the completeness of LCO Action entries and revised, as appropriate.
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Reference:
NLS980112) l Valves SW-MOV-89A and B are being redesigned to better withstand the environment associated with the Service RFO-18, currently Water system.
Implementation of the design change will scheduled to commence be completed during RFO-18.
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Reference:
NLS980112)
October 1998.
l The District is evaluating various options for modification t.' the SW radiation monitors that would March 31, 1999.
permit the monitors to be operable under various system flow conditions.
The District will complete this evaluation no later than March 31, 1998.