ML20203F875

Notice of Violation from Insp on 971214-980124.Violation Noted:On 971222,while MSL High RM Was Inoperable & Primary Containment Integrity Was Required,Licensee Opened Both Reactor Water Sample Valves

ML20203F875
Person / Time
Site:	Cooper
Issue date:	02/23/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20203F862	List: IR 05000298/1997011 ML20203F857 ML20203F875
References
50-298-97-11, NUDOCS 9803020077
Download: ML20203F875 (3)

Text

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• I ENCLOSURE 1 NOTICE OF VIOLATION Nebraska Public Power District Docket No.: 50-298 Cooper Nuclear Station License No.: DPR-46 During an NRC inspection conducted on December 14,1997, through January 24,1998, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below; A. Technical Specification 3.2.A states, in part, when primary containment integrity is required, the limiting conditions for operation for the instrumentation that initiates primary containment isolation are given in Table 3.2.A.

Technical Specification Table 3.2.A states, in part, two main steam line high radiation monitors are required to be operable per trip system or take the action given in Note 2.

Technical Specification Table 3.2.A, Note 2, states, in part, that, if the minimum number of operable instrument channels per trip system requirement cannot be met by a trip system, that trip system shall be tripped. Note 2.E directs that, if the requirements cannot be met by both trip systems, isolate the reactor water sample valves.

Contrary to the above, on December 22,1997, while Main Steam Line High Radiation Monitor RMP-RM-251B was inoperable and primary containment integrity was req'Jired, the licensee opened both reactor water sample valves between 2:34 and 3:09 a.m., and between 4:58 and 5:50 a.m., with less then the required number of operable instrument channels per trip system operable.

This is a Severity Level IV violation (Supplement 1) (50 298/97011-01).

l B. 10 CFP - ;rt 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Contrary to the above, l (1) On January 10,1998. Procedures 6.SC.501, " Secondary Containment Leak Test," Revision 3c2, and 6.SC.502, " Secondary Containment Penetration Examination," Revision 2c1, was not appropriate to the circumstances in that it did not measure or properly determine the amount of in-leakage through the secondary containment south vestibule door, an activity affecting quality. Also, Procedure 6.SC.502 did not require the proper testing configuration for secondary l

containment air lock doors in that no requirement was provided to open one set r,f

! doors while testing the redundant set.

i 9803020077 980223 PDR ADOCK 05000298 G PDR l

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2 (2) Procedure 0.5, " Problem identification and Corrective Action," Revision 13c1, Step 2.1, requires that problem identification reports be processed promptly, an activity affecting quality.- As of January 8,1998,25 problem identification reports which had been initiated in December 1997 and January 1998 had not been processed promptly. These 25 reports had been held in a group and not processed for up to 28 days.

l This is a Severity Level IV violation (Supplement 1) (50-298/97011-02).

C. 10 CFR Part 50, Appendix B, Criterion 111. " Design Control," requires, in part, that measures shall be established for the selection and review for suitability of application of materials, parts, equipmera, and processes that are essential to the safety-related functions of the structures, systems, and components.

Contrary to the above, as of December 20,1997, established measures for the selection and review of material, Pro % e 1.8," Warehouse issue, Return and Shipping,"

Revision 23, inappropriately e.ved the selec; ion of nonessential, nondedicated fuses to be installed in essential applications.

This is a Severity l_evel IV violation (Supplement 1) (50-298/97011-03).

D. 10 CFR Part 50, Appendix B. Criterion XVI, " Corrective Action," requires that measures shall be established to assure that conditions adverse to quality such as deficiencies and nonconformances are promptly identified and corrected.

Contrary to the above, from May 10,1988, to May 1.1997, established measures did not assure that deficient Technical Specification Surveillance Requiremsat 4.4.A.2.a was promptly identified and corrected. The surveillance requirement was deficient, because setting the relief valve at the low end of the allowed range resulted in the potential for an expected relief valve lift (1407 psig) which was less than the highest expected discharge pressure for an anticipated transient without scram (1433 psig). As a result, the Technical Specification surveillance requirement would not have prevented the relief valve from prematurely lifting and recycling the liquid control solution, as specified in Technical Specification Basis Section 3.4 (EA 97-362).

This is a Severity Level IV violation (Supplement I) (50-298/97011-06); no response is required.

i Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District is hereby required to submit a wntten statement or explanation to the L'.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to he NRC Resident inspector at the facility that is the subject of thb Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have

3-been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of En'orcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR and provide the legal basis to support your request for withholding the information from the public.

Dated at Arlington, Texas this 23rd day of February 1998