ML20153D906
| ML20153D906 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/22/1998 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-98-03, 50-298-98-3, NUDOCS 9809250257 | |
| Download: ML20153D906 (5) | |
See also: IR 05000298/1998003
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R EGION IV
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G. R. Horn, Senior Vice President
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Nebraska Public Power District
141415th Street
Columbus, Nebraska 68601
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SUBJECT: NRC INSPECTION REPORT 50-298/98-03
Dear Mr. Horn:
Thank you for your letter of September 14,1998, submitting a revised response to our
letter dated August 10,1998, and Notice of Violation dated June 23,1998. This violation
involved failing to explain the circumstances surrounding an inoperable service water effluent
. line ' radiation' monitor in the Annual Radioactive Materials Release Report. We find your reply
responsive to the concerns raised in our Notice of Violation. We will review your corrective
action implementation during a future inspection to determine that full compliance has been
achieved and will be maintained.
Sincerely,
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fivision of eactor Projects
Docket No.:
50-298
License No.: DPR-40
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' John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, Nebraska 68602-0499
9809250257 900922
ADOCK 05000298
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Nebraska Public Power District
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J. H. Swailes, Vice President 'of
Nuclear Energy
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Nebraska Public Power District
P.O. Box 98
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Brownville, Nebraska 68321
B. L. Houston, Nuclear Licensing
and Safety Manager -
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
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Dr. William D. Leech
MidAmerican Energy
907 Walnut Street
P.O. Box 657 '
Des Moines, Iowa 50303-0657
Mr. Ron Stoddard
Lincoln Electric System
1040 0 Street
P.O. Box 80869.
Lincoln, Nebraska 68501-0869
Randolph Wood, Director
Nebraska Department of Environmental
Quality
P.O. Box 98922
Lincoln, Nebraska 68509-8922
Cha!rman -
Nemaha County' Board bf Commissioners
Nemaha County Courthouse
1824 N Street
Auburn, Nebraska 68305
Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
Nebraska Department of Health
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301 Centennial Mall, South
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Lincoln, Nebraska 68509-5007
R. A. Kucera, Department Director
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. of Intergovernmental Cooperation
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Department of Natural Rescurces
P.O. Box 176
Jefferson City, Missouri 65102
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NLS980131
September 14,1998
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U.S. Nuclear Regulatory Commission
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Attention: Document Control Desk
Washington, D.C. 20555-0001
REGIONIV
Gentlemen:
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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) to USNRC Document Control Desk from M. F.
Peckham for J. H. 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
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
letter, its revised response to IR 50-298/98-03. The information revised is indicated by revision
bar in the right-hand margin of the attachment.
Should you have any questions concerning this matter, please contact me.
Sincer ly,
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Jo n H. 'wailes
Vice President of Nuclear Energy
9S-2.(34-
Cooper Nudear Station
P.o. Box 98 / Brownville, NE 68321-0098
Telephone: (402) 825-3811/ Fax: (402) 82S 5211
http //www nppd com
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. NLS980131
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September 14,1998
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Attachment
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. cc: Regional Administrator .
USNRC - Region IV
Senior Project Manager -
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- USNRC - NRR Project Directorate IV-1
Senior Resident Inspector
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' Attachment to
NLS980131
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Page 1 of 2
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
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
operable is one during releases via thepathway.
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Technical Specifications 3.21.A.J.d. required that, ifthe minimum number ofchannels is not
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 efluent line radiation monitors inoperable,
during liquiddischarges, form October 22 through December 31,1997, no explanation was
included in the subsequent Annual Radioactive Materials Release Report and the condition
was not repairedin a timely manner.
Admission or Denial to Violation
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The District admits the violation.
Reason far 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.1.d to completion.
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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
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' 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
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'(MOV) 89 A&B. When this entry was made, however, no entry was made concerning TS
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3.21.A.I.d, which stipulated the reporting requirements, if the condition exceeds 31 days.
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Attachment to
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NLS980131
Page 2 of 2
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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).
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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
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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
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. As a result of Operations shift mentoring performed in early 1998, increased awareness of the
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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
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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
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- 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.
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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ATTACHMENT 3
LIST OF NRC COMMITMENTS
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Correspondence No:NLS980131
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
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COMMITTED DATE
COMMITMENT
OR OUTAGE
Operations instructions associated with the Open LCO
Index System will be reviewed for adequate guidance on
Action completed
the completeness of LCO Action entries and revised, as
August 1998.
appropriate.
(Reference: NLS980112)
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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.
(Reference: NLS980112)
October 1998.
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The District is evaluating various options for
modification to 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.
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