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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217G7401999-10-14014 October 1999 Forwards MOR for Sept 1999 for Cooper Nuclear Station. Rept Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20216J8061999-09-20020 September 1999 Forwards Rev 37 to Safeguards Plan,Iaw Provisions of 10CFR50.(p).Rev Withheld,Per 10CFR73.21 ML20212C4921999-09-15015 September 1999 Forwards Monthly Operating Rept for Aug 1999 for Cooper Nuclear Station.Rept Includes Operating Data Rept,Unit SD Rept & Documentation of Challenges to Safety/Relief Valves ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211N5271999-09-0202 September 1999 Responds to NRC 990823 RAI Re Y2K Readiness at Cooper Nuclear Station,Per GL 98-01,Suppl 1 05000298/LER-1999-006, Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl1999-08-26026 August 1999 Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl ML20211F1311999-08-24024 August 1999 Forwards Rev 1 to Calculation Nedc 97-044, NPSH Margins for RHR & CS Pumps, in Support of 990615 Proposed Amend to DPR-46 Re Containment Overpressure Contribution to ECCS Pumps NPSH Requirements 05000298/LER-1999-003, Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel1999-08-23023 August 1999 Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20210R0301999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Cooper Nuclear Station,Iaw Guidance Provided by GL 97-02.Rept Also Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6761999-08-10010 August 1999 Requests That Following Changes Be Made to Distribution on NRC Correspondence ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K6071999-08-0202 August 1999 Submits Withdrawal of Proposed License Amend Re Secondary Containment Isolation Description & Refueling Accident Analysis Results ML20210K3811999-08-0202 August 1999 Forwards Listed Info,Which NPPD Believes Demonstrates Ability to Obtain Funds in Amount of $10 Million for Payment of Such Premiums within Specified Three Month Period,Iaw 10CFR140.21 ML20210G5101999-07-28028 July 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 990101-0630,per Provisions of 10CFR26.71(d) ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20209B7851999-07-0101 July 1999 Forwards Corrected Occupational Radiation Exposure Repts, for Cys 1996 & 1997.Util Stated That Repts Did Not Properly Tabulate Number of Personnel Receiving Exposures Less than 100 Mrem by Work & Job Functions in CY96 & CY97 05000298/LER-1999-005, Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl1999-07-0101 July 1999 Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, 05000298/LER-1999-004, Forwards LER 99-004-01.Commitments Made by Util Are Encl1999-06-28028 June 1999 Forwards LER 99-004-01.Commitments Made by Util Are Encl ML20209B5451999-06-28028 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196H0331999-06-24024 June 1999 Informs NRC of Deletion of 1991 Commitment Contained in Ltr Re Feedwater Nozzle Bypass Leakage Monitoring at Plant ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20209A7221999-06-23023 June 1999 Submits Revised Pages to Proposed Change to Plant TS Previously Submitted in ,Per 990615 Telcon with NRC ML20196F5331999-06-22022 June 1999 Forwards Examination Summary Rept for FW Nozzle Examinations Performed During 1998 Fall Refueling Outage at Cooper Nuclear Station.Rept Covers Past Examinations Up to & Including 1998 Fall Refueling Outage ML20196B4681999-06-17017 June 1999 Forwards TS Bases Changes Made at Plant Subsequent to Receipt of License Amend 178,dtd 980731,for Conversion to Its,Through 990610.List of Effective Pages for TS Bases, Encl ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195H8891999-06-14014 June 1999 Forwards Response to NRC 990315 RAI Re GL 95-07, Pressure Locking & Thermal-Binding of SR Power-Operated Gate Valves, 180-day Response Submitted by District on 960213 ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20195E2351999-06-0808 June 1999 Forwards Response to NRC 990517 RAI Re Util Proposed Change to TS Re Calibr Frequency of Reactor Recirculation Flow Transmitters Associated with APRM ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations 1999-09-30
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations ML20206Q6171999-05-17017 May 1999 Forwards RAI Re 990301 & 10 Ltrs Re Proposed TS Changes to Calibr Frequency of Recirculation Flow Transmitters from Once Every 184 Days to Once Every 18 Months.Util Responses Should Be Provided within 30 Days of Ltr Date ML20206P0171999-05-12012 May 1999 Discusses GL 96-05 Issued on 960918 & NPPD Responses Submitted on 961118,970317,980504 & 990222 for Cooper Nuclear Station.Forwards Safety Evaluation Concluding That NPPD Adequately Addressed Actions Requested in GL 96-05 IR 05000298/19980091999-05-12012 May 1999 Refers to Insp Rept 50-298/98-09 Conducted Between 981227-990130.During Insp,Apparent Violation of 10CFR50.50 Identified & Being Treated as non-cited ML20206M1791999-05-11011 May 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328. Reorganization Chart Encl ML20206H4191999-05-0707 May 1999 Informs That on 990407,NRC Administered Gfes of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However,Copy of Master Exam with Answer Key,Encl for Info.Without Encl ML20206P8961999-05-0707 May 1999 Refers to Meeting Conducted at Region IV Office on 990506 Re Licensee Upcoming Rev to Strategy for Achieving Engineering Excellence & Plans to Achieve Performance Improvements.List of Attendees & Util Presentation,Encl ML20206H7541999-05-0505 May 1999 Forwards Insp Rept 50-298/99-01 on 990207-0320.Violations Being Treated as non-cited Violations ML20205R5541999-04-16016 April 1999 Submits Summary of 990330 Public Meeting in Brownville,Ne to Discuss Results of PPR Completed on 990211,which Allowed for Exchange on New Assessment Process,Current Performance Review & Upcoming Actions Taken in Response to Y2K Concerns IR 05000298/19980221999-03-19019 March 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/98-22 on 990107.Finds Reply Responsive to Concerns Raised in NOV ML20205E8991999-03-19019 March 1999 Advises of Completion of Plant Performance Review on 990209 to Develop Integrated Understanding of Safety Performance. Overall Performance Was Acceptable.Problems with Communication in CR Resulted in Several Minor Events ML20204D9451999-03-18018 March 1999 Forwards Insp Rept 50-298/98-09 on 981227-990206.Three Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20207M9591999-03-15015 March 1999 Forwards Request for Addl Info Re Licensee Response to GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20204B6771999-03-15015 March 1999 Submits Withdrawal of Amend Request for Operating License DPR-46.Proposed Change Would Have Modified Facility TSs Pertaining to Neutron Monitoring Neutron Detectors ML20207M9811999-03-15015 March 1999 Advises That Which Withdrew 980415 Amend Request, Being Treated as Withdrawal.Proposed Change Would Have Modified Facility TSs Pertaining to Neutron Monitoring,Flow Biased Rod Block Monitor ML20204B3301999-03-11011 March 1999 Forwards SE Accepting Third 10-year Interval Inservice Insp Program Plan Requests for Relief Numbers RI-13,RI-17 & RI-25 for Plant ML20204B7061999-03-11011 March 1999 Requests Approval of Proposed Operability Criteria for Use in Evaluation & Interim Resolution of Degraded & Nonconforming Conditions with Piping & Pipe Supports at Facility ML20205A5811999-03-0909 March 1999 Forwards Exam Rept 50-298/99-301 for Exam Administered on 990212.Exam Included Evaluation of Four Applicants for Reactor Operator License ML20207K3231999-03-0808 March 1999 Discusses 990224 Meeting Re Staff Critique of Refueling & Equipment Outage RE-18 & Implementation Status of Improvement Strategy for Engineering.List of Attendees & Matl Used in Presentation Encl ML20202G1701999-02-0202 February 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam at Util Facility on 990407.Authorized Representative from Facility Must Submit Ltr Listing Names of Candidates ML20202E3121999-01-22022 January 1999 Forwards Insp Rept 50-298/98-08 on 981115-1226 & Notice of Violation.First Violation Re Staff Failure to Follow Procedures (Two in Operations,One in Maint & One in Plant Support) ML20199G6041999-01-19019 January 1999 Informs That Effective 990118,JN Donohew Has Assumed NRC Project Mgt Responsibility for Cooper Nuclear Station ML20199E1521999-01-0707 January 1999 Forwards Insp Rept 50-298/98-22 on 981116-1208 & Notice of Violation Re Lack of Effective Oversight by Plant Mgt 1999-09-30
[Table view] |
See also: IR 05000298/1997007
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ARLINGioN.1f xAs 7f 0118064
3,***** December 1, 1997
EA 97 424
G. R. Horn, Senior Vice Precident
of Energy Supply
Nebraska Public Power District
141415th Street
Columbus, Nebraska 68001
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$ 110,000
(NRC Inspection Report Nos. 50-298/97 07 and 9712)
Dear Mr. Horn:
This refers to the inspections conducted on June 29 through August 9,1997, and July 8
through September 5,1997, at your Cooper Nuclear Station f acility. The inspections were
conducted to review the circumstances surrounding severalinstances of failures to
identify, correct, or prevent recurrence of conditions adverse to quality. These issues were
discussed with you during an exit briefing conducted on September 5,1997, and were
documented in NRC Inspectinn Report Nos. 50 298/97 07 and 9712 dated September 4,
and October 3,1997, respectively. A predecisional enforcement conference was held in
the NRC Region IV office in Arlington, Texas, on October 17,1997, to discuss apparent
violations identified during these inspections.
Based on the information developed during the inspection and the information that you
provided during the conference, the NRC has determined that violations of NRC <
requirements occurred. These violations are cited in the enclosed Notice of Violation and
Proposed imposition of Civil Penalty and the circumstances surrounding them were
described in detailin the subject inspection reports. These violations involve several
examples of failures to meet the requirements of 10 CFR Part 50, Appendix B,
Criterion XVI. The first example involves a failure to recognize and correct instances
whereby large volumes of water could cause both trains of the standby gas treatment
system to be inoperable under certain circumstances. This problom htad been identified in
1994 (reference LER 94 035 and NRC Inspection Report 90 26) when plant personnel
recognized that backflow of water from Sump Z, under design basis accident conditions,
could render both trains of the standby gas treatment system inorserabic. However, the
corrective actions taken in 1994 were ineffective and the District identified this as an issue
again in July 1997 (reference LER 97-010).
The second example involves a failure to identify and correct significant blockage of
Residual Heat Removal (RHR) Heat Exchanger B which reduced the heat transfer capability
- below design requirements. After questioning by an NRC inspector, the District opened a
condition adverse to qt,ality tracking number (CAO 97-0742) regardin0 the issue of mud ,
found in the heat exchanger. The CAO was closed after concluding that the heat
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Nebraska Public Power District 2-
exchanger had been operable, that the condition was not reportable, and (of concern to the
NRC) that na condition adverse to nuclear safety or unexpected condition existed. Attor
significant involvement from the NRC expressing concerns about the District's conclusion
that the condition was not adverse to nuclear safety, several months later, the
CAO 07 0742 and related CAQs were reopened to more thoroughly review the issues.
The remaining seven violations also involve situations in which the District inadequately
identified or corrected conditions adverse to quality. These violations occurred during
similar timeframes and had similar causes.
During the conference, your staff discussed severaiinitiatives that the District has
implemented to improve its safety focus, especially in the area of problem identification
and resolution. The District noted that an alert radwaste operator identified the issue
involving the standby gas treatment system (the first example in the Notice). The NRC
recognizes that the District identified this issue, but notes that this condition could have
resulted in a common modo failure for a safety system, and was not corrected for over
2 years. There also were prior missed opportunities to identify this problem. The situation
involving RHR Heat Exchanger B (the second example in the Notice) is significant because
your staff did not recognize a significant condition adverse to quality on a safety system,
even af ter significant NRC involvement. The circumstances surrounding these two
violations, as well as the other seven, indica'.e contemporary weaknesses in your staff's
ability to recognize and correct problems. Therefore, these violations are classified in the
aggregate in accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions" (Enforcement Policy), NUREG 1600, as a Severity Level lli problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 ;
is considered for a Severity Level lll problem. Because your f acility has been the subject of
escalated enforcement actions within the last 2 years,' the NRC considered whether credit
was warranted for /dentification and Conective Action in accordance with the civil penalty
assessment process in Section VI.B.2 of the Enforcement Policy. Given the circumstances
surrounding the identification of the violation involving RHR Heat Exchanger 8, and the fact
that NRC identified most of the violations, the NRC has determined that the District is not
deserving of Identification credit. in evaluating whether credit is warranted for the
Conectivo Action factor, the NRC considered whether the District's corrective actions will
prevent recurrence of the specific violations, and are sufficiently comprehensive, given the
significance and complexity of the violations, to prevent recurrence of violations with
similar root causes. The District has been undertaking actions to improve personnel
performance in problem identification and resolution. Examples of the District's actions
include evaluating self identification rates, focusing on engineering teamwork, better
' A Notice of Violation and Exercise of Discretion (EA97-017) was isst ed on June 25.1997 involving a
Severity level til probletn telated to failurn to update the USAR and to perform adequate safety evaluations in
accordance with 10 CFR $0.$9. The NRC exerdsed discretion and did not propose a civil penalty.
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i Nebraska Public Power District 3- -
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focusing on conservative decision-making, emphasizing fundamentals such as procedure
use and adherence, reducing challenges in the control room, enhancing training,
conducting self assessments, and improving the tracking and trending of prngrams such as .
CAQ/SCAQ. Many of these actiont were ongoing at the time of the violations, and little !
information was provided at the conference relative to additional actions, timetables, etc.,
that would result in improved performance. Given the District's past performance as well
as the circumstances surrounding the violations, the NHC was unable to justify giving the-
District credit for time Correct /va Act/on factor.
Therefore, to emphasize the importance of prompt identification and comprehensive
correction of violations, and in recognition of your previous escalated enforcement actions,
I have been authorized, after consultation with the Director, Office of Enforcement, to
issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice)in
the amount of $110,000 for the Severity Levellli problem,
it should be noted that, on the basis of information provided to the NRC during the~
conference, the apparent violation related to the Automatic Depressurization System relief
valve accumulator low pressure alarm was not a violation. As such, this issue was not
cited in the encinse.1 Notice.
You are required to respond to this letter and should follow the instructions specified in the
encloted Notice when preparing your response, in your response, you should document
the specific actions taken and any additional actions you plan to prevent recurrence. The
NRC will use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements,
in accordance with 10 CFR 2,790 of the NRC's " Rules of Practice," a copy of this letter, e
its enclosure, and your response will be placed in the NRC Public Document Room.
Sincerely,
Ellis W. Merse f
Regional Ad , fiistrator
Docket No. 50 298
License No. DPR-4G
Enclosure: Notice of Violation and
Proposed imposition of Civil Penalty
cc w! Enclosure: (see next page)
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Nebraska Public Power District - 4I i
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cc w/ Enclosure:~ ,
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-John R. McPhail, General Counsel '
Nebraska Public Power District i
P.O. Box 499
Columbus, Nebraska 68602 0499
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P. D. Graham, Vice President of :
Nuclear Energy - 1
Nebraska Public Power District
- P.O. Box 98
Brownville, Nebraska 68321 l
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B. L. Houston, Nuclear Licensing
and Safety Manager l
Nebraska Public Power District
P.O. Box 98
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Brownville, Nebraska 68321 *
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Dr. William D. Leech
MidAmerican Energy t
4
007 Walnut Street !
P.O. Box 657 -
Des Moines, Iowa 50303 0657 l
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Mrz Hon Stoddr d
Lincoln Electric Gystem '
i 11th'and O Streets
Lincoln, Nebraska 68508 i
Randolph Wood, LJt ector
Nebraska Departmt at of Environmental '
Ouality
P.O. Box 98922
-Lincoln, Nebraska 68509 8922. !
Chairman.-
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Nemaha County Board of Commissioners !
Nemaha County Courthouse *
1824 N Street ' i
Auburn, Nebraska 68305 ~
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Nebraska Public Power District -
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Chery! Ro0ers, LLRW Program Manager
Environmental Protection Section
flebraska Department of Health
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 08509 5007
R. A. Kucera, Department Director
of intergovernmental Ccoperation
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Department of Natutal Resources
P.O. Box 170
Jefferson City, Missouri 05102
Kantas Radiation Cortrol Program Director
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Nebraska Public Power District 6-
bec w/ Enclosure:
PDR IE 14
.LPOR NUDOCS
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