ML20198P778
| ML20198P778 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/07/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-97-16, NLS970196, NUDOCS 9711100103 | |
| Download: ML20198P778 (5) | |
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P.O. DOX B LL NLB S G 68321 Nebraska Public Power District
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NLS970196 November 7,1997 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. 50-298/9716 Cooper Nuclear Station, NRC Docket 50 298, DPR-46
Reference:
- 1. Letter to G. R. llorn (NPPD) from D. A. Powers (USNRC) dated October 9, 1997,"NRC Inspection Report 50-298/97-16 and Notice of Violation"-
I' Ily letter dated Octoba 9,1997 (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 accoidance with 10 CFR 2 201. The District admita to the violation and has completed the corrective actions necessary to return CNS t full compliance. It should be noted that Reference 1 contains several editorial errors. These errors are discussed at the conclusion of the District's response to the violation.
Should you have any questions concernir.g this matter, please contact me.
Sincerely, P, D. Graham Vice President of Nuclear Energy
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Senior Project Manager USNRC - NR.R Project Directorate IV-1 Senior Resident inspector USNRC.
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. to NLS970196 Page1of3 REPLY TO OCTOBER 9,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50 298, LICENSE DPR-46 During NRC inspection activities conducted from September 15,1997, through September 24, 1997, one violation of NRC requirements was identified. The particular violation and the District's reply is set forth below. Note that inspection Report 50 298/9716 contains several errors that are discussed at the conclusion of this response.
Violation Technical Specification 6. 3.2, states, in part, that written procedures and instructions shall be established, implemented, and maintained... to correct specific.. malfunctions of safety-related systems or components.
Administrative Procedure U.5, " Problem Identification andResolution, " Revision 10, Section 3.1, requires, in part, that the problem identification report originator s supervisor shall complete items 15-17 of the problem identification report and mark the appropriate block u.,follows, using criteria providedin Attachment 5. Sect on 1 ofAttachment 3 identified " example 1.9, equipmentfailures" as an example of u hen a condition report is aty'ropriate.
Contrary to the above, on February 28,1P97, the licenseefailed to correctly complete item 16 ofProblem Idents)1 cation Report 2 12489, to disposition thefaihire of a safety-related service waterpiping Reducer Sil'-DG-1-R-2 as a condition report.
1his is a Severity 1.evelIl' violation (Supplement 1)(298/9716-01j.
Ad;nission or. Denial to VinlAtion The District admits the violation.110 wever, it is the District's understanding, as per ccmmunications with Clifford Clark of the NRC, that the correct number for the violation is "203/9716-02."
Reason for Violation On February 28,1997, PIR 2-12489 was initiated documenting a pinhole leak on Service Water (SW) piping on Emergency Diesel Generator number one (EDG 1). The Problem identification Report (PIR) was processed in accordance with Procedure 0.5, " Problem Identification aad Resolution," by the originator's supervisor, the Shin Supersisor in the Control Room, and the Work Control Center (WCC) Each of these reviews failed to identify the problem as a Condition Report (CR) an.J the PIR was incorrectly processed as a " Work Item (WI) Only."
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Attachm:nt 1 to NLS970196 Page 2 of 3 The cause of this violation is personnel error associated with the application of Procedure 0.5.
The evaluation to determine the cause of this violation also identified human factors issues in the procedure which are considered to be a coltributing cause for the violation. While the procedure contains adequate guidance for classification of PIRs, certain sections of the procedure do not provide adequate references to this guidance.
The safety significance of processing PIR 2 12489 as a " Work Item Only" is low. In this case, the degraded piping elbow was replaced, EDG-1 was restored to OPERABLE status, and the redundant EDO was inspected, all within the scope of the work item. The District recognizes that there may be other PIRs that have been processed as " Work Items Only" when they should have been identified as CRs; however there is no indication that this is a common occurrence. If such errors should happen, administrative controls such as Limiting Condition for Operability (LCO) tracking process and the System Operability Assessment Committee are in place to address system / component operability prior to exiting Technical Specification required LCOs or prior to reactor startup from a shutdown condition.
Corrective Steps Taken and the Results Achisygd The indhiduals involved (Originator's St., enisor, Control Room Shift Supenisor, and WCC reviewer) were informed of the misapplication of Procedure 0.5.
PIR 2-12489 has been re-opened and upgraded to a Significant Condition Adverse to Quality to address the root cause and generic implic~ations for failure of the Erosion / Corrosion Monitoring Program to identify and repair the piping prior to leakage occurring.
Corrective Steps That Will Be Taken to Avoid Further Violations The portions of Procedure 0.5 that provide instructions to the originator's supervisor and the WCC review section will be revised to provide clear guidance for determining recommended disposition of PIRs. A copy of the revised procedure will be forwarded to Cooper Nuclear Station (CNS) supervisors and WCC personnel for review.
CNS will perform a sample review of completed Work Item only PIRs for correct classification.
A Corrective Action Program (CAP) representative will review PIRs for the correct classifications. This review will continue until it becomes evident that this review is no longer necessary.
Date When Full Compl_iangg_Will Be Achieved The District is currently in full compliance.
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Attachtnent 1 o
to NLS970196 Page 3 of 3 Errors associated with NRC Inspection Repori 50-298/9.7-jii The following editorial errors have been identified in Reference 1 during the District's development ofits response to the subject notice ofviolation:
NOTICE OF VIOLATION, Page 1 of 2: The violation number is incorrect. The correct numerical assignment for this violation is "298/9716-02." This number has been confirmed through telephone communications with the NRC.
Page 12, Second Paragraph, Last Line: This paragraph should be linked to an inspector follow-up item number based on the ATTACilMENT (next page). The IFI number should be "298/9716-01."
ATTACllMENT, ITEMS OPENED, CLOSED, AND DISCUSSED: This section fails to list Violation 50 298/9716 02.
LIST OF DOCUMENTS REVIEWED: This section failed to mention CNS Procedure R3. The failure to properly fill out Line 16 of a PIR would be a violation of CNS Procedure 0.5.
l ATTACHMENT 3 LIST OF NRC COMMfTMENTS l
e Correspondence Not NL5970196 The fo119. ting table identifies those actions connaitted 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.
CCH4ITTED DATE COMMITMENT OR OUTAGE The portions of Procedure 0.5 that provide instructions to the origrnator's superviror and the WCC review section will be N/A revised to provide clear guidance for determining recommended disposition of PIR.
A copy of revised Procedure 0.5 will be forwarded to all CNS N/A supervisors and WCC personnel.
A CAP representative will review PIRs for the correct classifications. This review will continue until it becomes N/A evident that future review is no longer necessary.
CNS will perform a sample review of completed Work Item only PIRs N/A for correct classification.
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER S l
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