ML20202F120
| ML20202F120 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/11/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-97-10, NLS980017, NUDOCS 9802190133 | |
| Download: ML20202F120 (5) | |
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OCOPER NVOLL AR $1 AT10N pal. DOX 98. DROWNYLLE. NE BRASF.A 683F1 Nebraska Public Power District
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nw =u l NLS980017 February 11,1998 U S. Nuclear Regulatory Commission Attention: Document Contr01 Desk Washington, D C. 20555 0001 Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/97-10 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
Letter to G. R. Horn (NPPD) from E. E. Collins (USNRC) dated January 12, 1998, "NRC Inspection Report 50 298/97-10 and Notice of Violation" Ily letter dated January 12,1998 (Reference 1), the NRC cited Nebraska Public Power District (District) for being in violation of NRC req.iirements. This letter, including Attachment 1, constitutes the District's reply to the referenced Notice of Violation in accordance witti 10 CFR 2.201. The District admits to the violation and has completed the corrective actions necessary to return CNS to full compliance.
Should you have any questions concerning this matter, please contact me.
Sincerely, d
JoEl[.v s
Vi be Pre i nt o Nuclear incrgy l
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Attachment Ib.
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NI,S980017 February 11,1998 Page 2 of 2 cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV 1 Senior Resident inspector USNRC NPG Distribution 1
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e Attachment I to NLS980017
'Page 1 of 2 REPLY TO JANUARY 12,1998, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50 298, LICENSE DPR 46 During NRC inspection activities conducted from November 2 through December 13,1997, one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
Violation 10 CFR Part 30, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed byprocedures ofa type aty>ropr, ate to the circumstances. 1hese procedures shallinchtde appropriate quantitative or qualitative acceptance criteriafor determining that irnportant activilles have been satisfactorily accomplished.
Contrary to the above, as ofDet ember 13,1997, Procedure 6.SC,302, " Secondary Containruent Penetration Examination, " Revision 2, u hich conducts an assessment of air in-leakage through redundant secondary containment doors, an activity affecting quality, uns not appropriate to the circumstances in that it did not include appropriate acceptance criteria. 1hisprocedure summed the minin:um ik>or leakage in each set of tuo doors to establish the secondary containment in leakage rate. 1he use of the minimum in leakagefor each door set u as potentially nonconsenutive.
7his is a Severity Level 1l' violation (Supplement 1) (30-29W9710-01)
Admission or Denial to Violation The District admits the violation.
Reason for Violation The reason for this violation is that the indi
- failed to consider all potential operating conditions when the acceptannt criteria wer. ssst developed, and CNS's failure to identify interim compensatory measures for inappropriate acceptance criteria.
At no time was secondary containment challenged. An Operability Assessment (OA) determined that margin (approximately 135 cfm compared to 165 cfm using minimum flows) existed for secondary containment to remain operable.
. After the SRI discussed the issue with the System Engineer, he planned to evaluate the procedure and make appropriate changes. On December 15,1997 (approximately two weeks later), the SRI
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'to NLS980017 Page 2 of 2 was concerned that, aller having identified the potential no.
.servative acceptance criteria, no information had been provided to the operations crews indicat t that the senice margin could be less than documented in the most recent surveillance test under normal operational conditions.
A formal communication was not made when the issue was identified due to the fact tha' the total path leakage was still significantly less thr.n the service margin limit, and that operations would contact the System Engineer to ensure any work which could impact the available service margin was evaluated. CNS recognizes this s a weakness in that Operations must at all times be aware of plant conditions. The System Engineer discussed the issues with the SRI and determined an immediate procedure change was in order.
Corrective Stens Taken and the Results Achieved Procedure 6 SC.502, " Secondary Containment Penetration Examination" was revised on 12/17/98 to account for the possibility that the maximum leakage path may be the actual secondary containment boundary. This revised procedure allows for conservative evaluations of future test results and emergent conditions.
The new Operability Determination Procedure,0 5.1, provides guidance for consideration of 3
generic concerns, interim compensatory measures, and the impact of changes in plant conditions on operability. This procedure was made effective January 28,1998.
Corrective Stens That Will Be Taken to Avoid Further Violations
- 1. Specific guidance for determination of appropriate acceptance criteria will be developed and incorporated in the Procedure Writers Guide.
2 As an enhancement, guidance for establishing appropriate interim compensatory measures for issues ofinadequate acceptance criteria will be incorporated in CNS Procedure 0.5.1,
" Operations Review of Problem identification Reports / Operability Determination."
Date When Full Comoliance Will Be Achieved The District is in full compliance regarding the identified violation.
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ATTACHMENT 3 L8ST OF NRC COMMITMENTS l
Correspondence No! NL9990017
'The following table identifies those actions cornmitted to )y the '/istrict in this document.
Any other actions discussed in the submittal r<preser, intended or planned actions by the District. They are described to tne NRC for the NRC's information and are not regulatory commitments.
Please no,'f',
the Licensing Mana *r at Cooper Nuclear Station of any questions regarding this document or any associated regulatory committnents.
COMMITTED DATE COMMITMENT 03 OUTAGE Specific guidance for detennination of appropriate acceptance criteria will be developed N/A
,vid incorporated in the Pnvedure Writers Guide, As an enhancement, guidance for establishing appropriate interim compensatory measures for issues ofinadequate acceptance cnteria will be incorporated in CNS N/A Pncedure 0.51," Operations Revi-1 i Problem Identification Reports / Operability I)ctermination "
l PROCEDURE NUMBER 0.42 l
REVISION NUMBER S l
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