ML20196F546
| ML20196F546 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/26/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8803040107 | |
| Download: ML20196F546 (1) | |
See also: IR 05000298/1987028
Text
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FEB 261988
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In Reply' Refer To:
Docket: 50-298/87-28
Nebraska Public Power District
ATTN: George A. Trevors-
Division Manager-- Nuclear Support
P.O. Box 499
Columbus, NE 68601'
Gentlemen:
Thank you for your letter of January 26, 1988, in response to our letter
and Notice of Violation dated December 21, 1987. We have reviewed your reply
and find it responsive to the concerns raised in our Notice of Violation. We
will review the implementation of your corrective actions during a future
inspection to determine that full compliance has been achieved and will be
maintained.
Sincerely,
L. J. Callan, Director
Division of Reactor Projects
CC:
Cooper Nuclear Station
ATTN: Guy Horn, Division Manager
of Nuclear Operations
P.O. Box 98
Brownville, Nebraska 68321
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
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Januany 26, 1988
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U.S. Nuclear Regulatory Commission
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Attention: Document Control Desk
Washington, DC 20555
Gentlemen:
Subject: NPPD Response to Inspection Report 50-298/87-28
This letter is written in response to your letter dated December 21, 1987,
transmitting Inspection Report 50-298/87-28.
Therein you indicated that
certain of our activities were in violation of NRC requirements.
Following is a statement of the violati,ns and our response in accordance
w!.th 10CFR2.201.
Statement of Violation
Failure To Follow Procedures
Appendix
B,
Criterion
V,
of 10 CFR Part 50, and the Itcensee's approved
Quality Assurance program require that activities affecting quality be
accomplished in accordance with approved instructions, procedures, and
drawings.
CNS Procedure
0.4,
"Preparation.
Review,
and Approval
of
Procedures," Revision 10
dated October 15, 1987, specifies that approved
written station procedures shall be adhered to by all station personnel.
CNS Procedure 2.2.71, "Service Water System". Appendix "A"
Valve Checklist
requires Valve SW-195 to be open.
Procedure
0.9,
"Equipment Clearance
and Release Orders " Revision
5,
dated May 14, 1987, requires a caution
tag to be issued when any station personnel discover or recognize an
abnormal condition where there is a need for additional instruction in
regard to the safe operation of station equipment.
Maintenance Procedure
7.0.1 Revision
9,
dated October 29, 1987, requires a Work Item Tracking
(WIT) request to be issued when attempting to determine the cause for
unidentified Icakage and repair.
Contrary to the above, on November 18, 1987, during the performance of
a partial system walkdown by the NRC inspectors of CNS Procedure 2.2.71,
"Service Water (SW) System". Appendix
"A" Valve Checklist. Valve SW-19'
was found in the closed position.
No caution tag or WIT was issued until
November 18, 1987, when the improper position of Valve SW-195 was brought
to the licensee's attention by the NRC inspectors.
This is a Severity 1.evel IV violation.
(Supplement 1) (298/8728-01)
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January 26, 1988
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Reason For The Violation
Thia violation is a result of inadequate follow-up by ' the operator who
discovered the leaking in the valve (s) and closed the manual one inch tell-tale
drain.
Although the action taken' was appropriate, failure to issue a Work
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Item and identify the abnormal position of the valve is a vi.;4 tion of CNS
Procedure requirements.
Corrective Steps Which Have Been Taken And The Results Achieved
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The Operations Department determined the valve, a manual one inch tell-tale
drain, had been closed because of leakage from either the Demineralizer Water
System or the Service Water System.
A Work Item Tracking (WIT) request and
Work Item was initiated, and the subject valve caution tagged closed ots
November 18, 1987, correcting the nonconforming condition.
Corrective Steps Which Will Be Taken To Avoid Further Violation
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The Operations Supervisor will discuss this event with all operating crew
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personnel during scheduled weekly Operations Supervisor meetings.
Specifically
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stressed will be the requirements of CNS procedure 0.9 regarding caution
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tagging, and procedure 7.0.1 regarding initiating a Work ltem Request when
plant equipment needs repair.
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Date When Full Compliance Will Be Achieved
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Full compliance will be achieved by March 31, 1988..
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Statement of Violation
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Failure to Maintain Secondary Containment ."egrity
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Technical Specification 3.7.C.1
requires
that
secondary
containment
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integrity shall be maintained during all modes of plant operation.
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Contrary to the above, on November 9,
1987, the inner door to the Reactor
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Building railroad airlock was open for at least two hours while gaps existed
between the outer door and the ground.
This constitutes a failure to
maintain secondary containment integrity.
This is a Severity Level IV Violation.
(Supplement I) (298/8728-03)
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Reason For Violation
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Secondary containment integrity is defined in CNS Technical Specifications
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as the Reactor Building being intact and the following conditions being met:
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At least one door in each access opening is closed.
2.
The Standby Cas Treatment System is operable.
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3.
All automatic ventilation system isolation valves are operable or
are secured in the isolated position.
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Jcnuary 26, 1988
The Secondary Containment System is designed to be s u f ' i c i e n t i .- toak-tight
to allow the Standby Gas Treatment System to reduce the Reactor Building
pressure to a minimum sub-atmospheric pressure of 0.25 inches of water (under
calm wind conditions) when the Standby Gas Treatment System fans are exhausting
the Reactor Building at a rate of 1001 per day of the Reactor Building free
volume.
Given the above, the District cannot definitely conclude that the integrity
of secondary containment had not been maintained.
Ilowever, since the potential
did exist, the District has taken action, accordingly.
The reason for this violation was lack of procedural guidance end failure
to recognize the need to maintain the exact configuration of the outer railroad
airlock door when the inner door is opened.
Corrective Steps Taken And Results Achieved
The gaps that were noted to exist consisted of a small section around each
rail beneath the outside railroad airlock doors.
These gaps were a result
of not replacing the rail seal plates prior to shutting the outside doors,
subsequent to moving a rati car into the airlock.
The rail seal plates are devices that, when placed over the track rails,
fill the void between the rail and track bed.
The seal plates vere immediately installed when notified of the condition
by the Resident Inspector and the personnel involved counseled about the
importance of replacing the rail seal plates.
Corrective Steps Which Will Be Taken To Py vent Further Violation
Two procedures are being generated to prevent recurrence.
The Mrst is
Surveillance Procedure 6.3.10.17, which was originated on November 14, 1987,
and deals with the inspection of eecondary containment penetrations.
The
second procedure has also been generated and placed in SORC routing and will
provide stacific direction for the operation of the railroad airlock doors.
Steps to verify seal integrity after the opening and closing of a railroad
airlock door have been included in the procedure.
Additionally, to heighten personnel awareness of the concern, the District
will fabricate and mount signs on the airlock doors stating:
"PRIOR TO
SilUTTING EITilER RAILROAD AIRLOCK DOOR, ENSURE TilAT Tile ASSOCIATED RAIL SEAL
PLATES ARE INSTALLED".
In the interim period until these pre..dures are approved, a Special Order
has been issued by the Division Mr .ia *
of Nuclear Operations designating
,
specific individuals responsible to cor e inate opening and closing the railroad
airlock doors.
Date When Full Compliance Will Be Af seved
All corrective actions will be completed by March .. 1988.
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If-you have . any questions regarding this response, please contact me or C.
R. Horn at the site. ' A one week extension for submission of this response
was granted in a telephone conversation with Region IV.
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Sincerely,
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C. A. Trevors
Divi 61on Manager
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Nuclear Support
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U.S.' Nuclear Regulatory Comunission .
Region IV
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NRC Resident Inspector
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Cooper Nuclear Station
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