ML20199B375
| ML20199B375 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/13/1997 |
| From: | Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-97-13, NUDOCS 9711180291 | |
| Download: ML20199B375 (5) | |
See also: IR 05000298/1997013
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NUCLEAR REGULATORY COMMISSION
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November 13,1997
G. R. Horn, Senior Vice President--
'of Energy Supply
Nebraska Public Powar Dietrict
141415th Street
Columbus, Nebraska 68601
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' SUBJECT:
RdSPONSE TO NRC NOTICE OF VIOLATION (INSPEC s .ON
REPORT 50-298/97 13)
Dear Mr. Horn:
' Thank you fet your letter of October 14,1997, in response to our September 12,1997,'-
letter and Notice of Violation concerning a f ailure to initiate a problem identification and
resolution report foi a test on the automatic depressurization system. We have ieviewed
your reply, and additional information discussed with Mr. Mike Peckham, Plant Manager,
and members of your staff, during a telephone call on October 28,1997.
Inspection Report 50-298/96 31 and followup resident reports have identified f ailures to
document conditions adverse to quality according to the problem identification end
resolution .eport process. During the telepho s call, your staff clarified that a historical
review for determining generic implications from the failure to initiate a problem
identification resolution report is included within the scope of a problem resolution team
comprised of plant staff and contracted personnel.
We find your respon::e and specifically, the clarification on a historical review for
determining any generic implicatiom which may have resulted from the failure to initiate a
problem identification and resolution report, as a sufficient response 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 'ull compliance has been achieved and will be
maintained.
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Sincerely,
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Dr. Dale A. Powers, Chief
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Maintenance Branch
Division of Reactor Safety
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-. Nebraska Public Power District -
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Docket No.: 50 298-
License No.: DPR 46 ;
_ cc:
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' John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499 -
Columbus, Nebraska 68602-0499
P. D Graham, Vice President of
Nuclear Energy
Nebraska Public Power District
P.O. Box 98
- Brownville, Nebraska 68321
- B. L. Houston,- Nuclear Licensing
and Safety Manager
Nebraska Public Power District
' P.O. Box 98
<
Brownville, Nebraska 68321
Dr. William D. Leech
MidAmerican Energy
907 Walnut Street
P.O. Box 657
Des Moines,' lowa 50303 0657
Mr. Ron Stoddard
- Lincoln Electric System
11th and O Streets
Lincoln, Nebraska 68508
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Randolph Wood, Director
Nebraska Department of Environmental
Quality
P.O. Box 98922
Lincoln, Nebraska 68509-8922
' Chairman -
~ Nemaha County Board of Commissioners
Nemaha Countv Courthouse -
1824 N Street
A'uburn, Nebraska ' 68305 :
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Nebraska Public Power District
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Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
Nebraska Department of Health
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007
R. A. Kiscera, Department Director
of Int <,rgovernmental Cooperation
Department of Natural Resources
' P.O. Box 176
Jefferson City, Missouri 65102
Kansas Radiation Control Program Director
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Nebraska Public Power District
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E-Mail report to T. Frye (TJF)
E-mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bec to DCD (lE01)
bec distrib. by RIV:
Regional Administrator
DRP Director
Project Engineer (DRP/C)
DRS Director
Resident inspector
DRS Deputy Director
DRS PSB
Branch Chief (DRP/C)
MIS System
Branch Chief (DRP/TSS)
RIV File
DRS ACTION ITEM NO: 97-G-0117
DOCUMENT NAME: R:\\_,CNS\\CN713AK.PCG
To receive copy of document. Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV: SRI:MB & N
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PCGagellmb ~
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OFFICIAL RECORD COPY
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E Mail report to T. Frye (TJF)
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E-mail report to T. Hiltz (TGH)
' E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bec to DCD (IE01)
bec distrib. by RIV:
Regional Administrator
DRP Director
Project Engineer (DRP/C)
DRS Director
Resident inspector
DRS Deputy Director
DRS-PSB
Branch Chief (DRP/C)
MIS System
Branch Chief (DRP/TSS)
RIV File
DRS ACTION ITEM NO: 97-G 0117
DOCUMENT NAME: R:\\_CNS\\CN713AK.PCG
To receive copy of docurnent, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV: SRI:MB W N
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OFFICIAL RECORD COPY
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NLS970179
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October 14,1997
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U.S. Nuclear Regulatory Commission
ngarn ar
Attention: Document Control Desk
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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 III (USNRC) dated
September 12,1997,"NRC Inspection Report 50-298/97-13 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&nuk
P. D. Grahain
Vice President of Nuclear Energy
/rar
Attachment
cc: Regional Administrator
USNRC - Region IV
Senior Project Manager
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USNRC - NRR Project Directorate IV-1
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NLS970179
October 14,1997
Page 2 of 2
Senior Resident Inspector
NPG Distribution
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< Attachment 1-
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REPLY TO SEPTEMBER 12,1997, NOTICE OF VIOLATION
COOPER NUCLEAR STATION
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NRC DOCKET NO. 50-298, LICENSE DPR-46.
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- During NRC inspection activities conducted from July 28,1997, through August 14,1997,one
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violation of NRC requirements was identified? The particular violation and the District's reply are
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set forth below:
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Violation
TechnicalSpect) cation 6.3.2, states, inpart, that writtenprocedures andinstructions shall
- he established, implemented, and maintainedfor thefollowing: ...B. Actions to be taken to
correct specific ... malfunctions ofsafety-related systems or components.
<
. Surveillance Prccedure 6. LADS.301, " ADS Reactor Pressure Permissive Calibration and
. Function and Logic Tests (Reactor in Run) (Div 1), " Revision 1, Step 8.27, states, in part,
that test personnel are to connect a meter to read resistance and venfy the contacts are
closed,
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Administrative Procedure 0.5, " Problem Idents) cation arulResolution, " Revision 8, Section
14.2, requires, inpart, that allpersonnelare 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 identspcation
and resolution reportfor a knownfailure tofollow a safety-relatedprocedure. Specifically,
duringperformance ofStep 8.27 ofSurveillance Procedure 6. LADS.301, when contacts were
faimd open rather 6ais closed, testpersonnel raised the testpressure (which closed the
contacts), and thenproceeded with the test without reporting this condition in a problem -
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identspcation amiresolution report.
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1his is a Severity LevelIV violation (Supplement 1)(298/9317-02).
Admission or Denial to Violation
- The District admits the violation.
Reason for Violation
The failure to generate a Problem Identifict. tion 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
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Attachment I
to NLS970179
Page 2 of 3
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
Administratise Procedure 0.26, " Surveillance Progiam." 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 Proceduresc 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 Seiial Number 2-16718.
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Conducting an informal discussion of this event and the need to generate PIRs during a
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subsequent Instrument and Control (IAC) shop morning meeting.
The development of a tailgate training session for maintenance personnel on the requirements
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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 D; vision 11 procedure, six additional PIRs have been generated.
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On going currective actions to address the site wide issue of proc.edural adherence have been
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made a station alignment issue and incorporated into the business plan.
C_onective Steps That Will Be Taken to Avoid Further Violations
CNS will revise Procedure 0.26 to climinate the redundant procedural requirements which
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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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Engineerinb Personnel that perform surveillance testing have been trained to the requirements
of Procedure 0.5.
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Attachment 1
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Page 3 of 3
CNS will incorporate the above training requirements into recurring Industry Events training
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for Maintenance, Operations and Engineering Department personnel that perfctm surveillance
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testing.
CNS will train Maintenance, Operations and Engineering Department personnel that perform
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surveillance testing on the requireroents of revised Procedure 0.26.
The above actions will be completed by November 30,1997.
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CNS is continuing to review samples of surveillances with Procedure 0.26 discrepancy sheets
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attached to identify additional areas where PIRs should have been generated. Based on the
results of the review, appropriate corrective actions will be implemented.
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Qate When Full Con 1pliance Will Be Achievest
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. The District is in full compliance with respect to the cited violation.
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ATTACHMENT 3 LTST OF NRC COMMITMENTS
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Correspondence No:lhS970179
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
COMMITTED DATE
COMMITMENT
OR OUTAGE
CNS will revise Procedure 0.26 to elindnate the redundant
procedural requirements which exist within Procedare 0.26
10/24/97
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
trained to the requirements of Procedure 0.5
CNS will incorporate requirements of training to ensure
Maintenance, Operations and Engineering Department
personnel that perform surveillance testing have been
11/30/97
trained to the requirements of Procedure 0.5 into
recurring Industry Events training.
CNS will train Maintenance, Operations and Engineering
11/30/97
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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.
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Based on the results of the review, appropriate
cort-ctive actions will be implemented
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PROCEDURE NUMllER 0,42
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REVISIJN NUMllER S
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PAGE 9 OF 13
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