ML20198J884
| ML20198J884 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/14/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-97-13, NLS970179, NUDOCS 9710220180 | |
| Download: ML20198J884 (6) | |
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NLS970179 October 14,1997 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 No. 50-298/97-13 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
.1.
Letter to G. R. Horn (NPPD) from A. T. Howell Ill (USNRC) dated September 12,1997,"NRC Inspection Report 30-298/97-13 and Notice of Violation" By letter dated September 12,1997 (Reference 1), the 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 Notice of Violation in accordance with 10 CFR 2.201. The District admits to the violation and has completed all corrective actions necessary to return CNS to full compliance.
Should you have any questions concerning this matter, please contact me.
Sincerely, P&M-w\\
[4 P. D. Graham Vice President of Nuclear Energy
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/rar Attachment
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cc. Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1
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NLS970179 October 14,1997 Page 2 of 2 Senior Resident inspector USNRC NPG Distribution
Attachment I to'NLS970179
? age 1of3 REPLY TO SEPTEMBER 12,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from July 28,1997, through August 14,1997,one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
.Yio]ation Technical Specipcation 6.3.2, states, in part, that written procedures and instructions shall be established, implemented, and maintainedfor thefollowing:..H. Actions to be taken to correct specipc... malfunctions ofsafety-related systems or components.
Surveillance Procedure 6.1 ADS.301, " ADS Reactor Pressure Permissive Calibration and Function and Logic Tests (Reactor in Run) (Div I), " Revision I, Step 8.27, states, in part, that test personnel are to connect a meter to read resistance and venfy the contacts are closed.
Administrative Procedure 0.5, " Problem Identification and Resolution, " Revision 8, Section 14.2, requires, m part, that allpersonnel are responsiblefor reportingproblems that are, or potentially could be, conditions adverse to quality through the process of this procedure.
Contrary to the above, on July 23,1997, the licenseefailed to write a problem identification and resolutit>n reportfor a knownfaihtre tofollow a safety-relatedprocedure. Specifically, duringperformance ofStep 8.27 ofSurveillance Procedure 6. LADS.301, when contacts were found open rather than closed, test personnel raised the test pressure (which closed the contacts), and then proceeded with the test without reporting this condition in a problem identificujon and resolution report.
This is a Severity 1.evel Il' violation (Supplement 1)(298'9317-02).
Admission or D3Biglio Violation The District admits the violation.
Reason for Violation The failure to generate a Problem identification Report (PIR)is a procedural adherence problem.
Administrative Procedure 0.5, " Problem Identification and Resolution," contains the appropriate requirements with respect to initiation of a PIR; however, strict compliance with the Procedure l
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. 0.5 was not enforced by supervision. The failure to meet procedural conditions stated in Procedure 6,l ADS.301 was recognized and documented on a Discrepancy Sheet per Administrative Procedure 0.26, " Surveillance Program " However, the action plan to resolve the immediate condition created a " sense of correctness" in the plan and led to the completion of the surveillance without the generation of a PIR.
An additional contributing cause for the failure to generate a PIR when surveillance procedure conditions are not met is the redundancy in requirements of the 0.26 and 0.5 Procedures. The documentation of procedural discrepancies with Procedure 0.26 Discrepancy Sheets without the accompanying Procedure 0.5 PIR is a recurring problem at CNS.
Corrective Steps Taken and the Results Achieved Corrective actions taken include:
The generation of PIR Serial Number 2-16718.
Conducting an informal discussion of this event and the need to generate PIRs during a subsequent Instrument and Control (I AC) shop morning meeting.
The development of a tailgate training session for maintenance personnel on the requirements to generate PIRs in accordance with the guidance contained in Procedure 0.5.
Implementation of this training has been initiated.
As a result ofinformal discussion, during the weekly performance of this procedure, and the associated Division 11 procedure, six additional PIRs have been generated.
Oa going corrective actions to address the site wide issue of procedural adherence have been made a station alignment issue and incorporated into the business plan.
Corrective Steps That Will Be Taken to Avoid Further ViolatiQas CNS will revise Procedure 0.26 to eliminate the redundant procedural requirements which exist within Procedure 0.26 and Procedure 0.5.
This action will be complete by 10/24/97.
CNS will conduct additional tailgate training sessions to ensure Maintenance, Operations and
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' Engineering personnel that perform surveillance testing have been trained to the requirements of Procedure 0 5.
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to'NLS970179 Page 3 of 3
--. CNS willincorporate the above training requirements into recurring Industry Events training for Maintenance, Operations and Engineering Department personnel that perform surveillance
-- testing.
CNS will train Maintenance, Operations and Engineering Department personnel that perform surveillance testing on the requirements of revised Procedure 0.26.
- The above actions will be completed by November 30,1997.
- - CNS is continuing to review samples of surveillances with Procedure 0.26 discrepancy sheets attached to identify additional areas where PIRs should have been generated. Based on the-results of the review, appropriate corrective actions will be implemented.
Date When FulLCompJijtqce Will Be Achieved ;
The District is in full compliance with respect to the cited violation.
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
4 Correspondence No! NLS970179 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 OUTAJE CNS will revise Procedure 0.26 to eliminate the redundant 10/24/97 procedural requirements which exist within Procedure 0.26 and Procedure 0.5 CNS will conduct additional tailgate training sessions to ensure Maintenance, Operations and Engineering Department 11/30/97 personnel that perform surveillance testing have been t rained to the requirements of Procedure 0.5 CNS will incorporate requirements of training to ensure Maintenance, Operations and Engineering Department 11/30/97 personnel that perform surveillance testing have been trained to the requirements of Procedure 0.5 into recurring Industry Events training.
CNS will train Maintenance, Operations and Engineering 11/30/97 Department personnel that perform surveillance testing on the requirements of revised Procedure 0.26 CNS will continue to review samples of surveillances with Procedure 0.26 discrepancy sheeets attached to identify N/A additional areas where PIRs should have been generated.
Based on the results of the review, appropriate corrective actions will be implemented l
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PROCEDURE NUMBER 0.42 l
REVISION NUMBER 3 l
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