ML20207R728

Responds to NRC Re Violations Noted in Insp Rept 50-298/87-03.Corrective Actions:Addl Procedure Changes Made to SOP 2.2.59,SOP 2.2.60 & Alarm Procedure 2.3.2.21A to Address Drywell Pneumatic Header Pressure Concerns

ML20207R728
Person / Time
Site:	Cooper
Issue date:	03/09/1987
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CNSS877136, NUDOCS 8703180072
Download: ML20207R728 (3)

Text

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4 COOPER NUCLEAR ST ATioN Nebraska Public Power District "" " * "A"#"o"On n""^"^ "'"

CNSS877136 March 9, 1987 Nuclear Regulatory Commission Douement Control Desk Washington, D.C. 20555

Subject:

NPPD Response to Inspection Report 50-298/87-03 Gentlemen:

This letter is written in response to your letter dated February 13, 1987, transmitting Inspection Report 50-298/87-03. Therein you indicated that certain of our activities were in violation of hTC requirements.

Following is a statement of our violations and our response in accordance with 10CFR2.201.

STATEMENT OF VIOLATION A. Failure to Provide Adequate Procedures Technical Specifications, paragraph 6.3.2, requires, " Written procedures and instructions. . . .shall be established, implemented, and maintained for.... normal startup, operation...."

Contrary to the above procedures S0P 2.2.59, " Plant Air System",

SOP 2.2.60, " Primary Containment Cooling and Nitrogen Inerting System",

and alarm procedure 2.3.2.21A, " Panel 9 Annunciator 9-3-4", were found on January 10, 1987, during a plant startup, not to have been properly revised (maintained) to reflect accurately a plant modification (Design Change 86-36) which required the revision.

This is a Severity Level IV violation. (Supplement I.D.)(298/8703-01)

Reason for the Violation The violation is not completely correct as stated and should be revised as follows:

Contrary to the above, procedures S0P 2.2.59, " Plant Air System",

S0P 2.2.60, " Primary Containment Cooling and Nitrogen Inerting System",

and alarm procedure 2.3.2.21A, " Panel 9.3 - Annunciator 9-3-4", were found on January 10, 1987, during a plant startSp, not to have been properly revised (maintained) to reflect accurately the following:

PDR ADOCK 05000298 PDR SW

March,9, 1987 Page 2

1. A plant modification (Design Change 86-36) which installed a drywell pneumatic header low pressure alarm.

2. A revised method of purging the drywell to allow Primary Containment inerting without the Standby Gas Treatment (SGT)

System, allowing increased nitrogen purge flows.

3. An operating setpoint change to both of the nitrogen system pressure regulators during the 1986 outage from 150 psig to 110 psig.

The District attributes these procedural deficiencic , to the failure of various personnel involved to fully comprehend the synergistic effects of the changes noted above.

Corrective Steps Taken and Results Achieved Additional procedure changes were made to SOP 2.2.59, S0P 2.2.60, and alarm procedure 2.3.2.21A to address drywell pneumatic header pressure concerns during inerting. Additionally, nitrogen system pressure regulators were reset to higher values (140 psig and 145 psig).

Corrective Steps Which Will Be Taken to Prevent Further Violations This event will be reviewed by the Operations Supervisor during meetings routinely conducted with each shif t's crew when they are attending requalification training. Additionally, this event will be reviewed by the appropriate engineering personnel.

Date When Full Compliance Will Be Achieved All necessary procedure changes have been completed. All other corrective actions will be completed by October 1,1987.

STATEMENT OF VIOLATION B. Failure to Follow Procedures Criterion V of Appendix B to 10CFR Part 50 and the licensee's approved Quality Assurance Plan require that activities affecting quality be prescribed by documented procedures and accomplished in accordance with these procedures. Licensee Engineering Procedure 3.4, " Station Design Changes", Revision 4, dated July 2, 1986, requires that design change packages, which are used to control safety-related activities, identify procedures which must be revised as a result of the design change.

Contrary to the above, Design Change 86-36 was found on January 10, 1987, after installation of this change not to identify a major procedure, General Operating Procedure 2.1.1, which required a revision as a result of this change.

This is a Severity Level IV violation. (Supplement I.D.)(298/8703-02) l

l

M,rch 9,.1987.

FIsi 3 Reason for the Violation The violation is incorrect as stated. The apparent violation states that

".... Design Change 86-36 was found on January 10, 1987, after

-installation of this change, not to identify a major procedure, Operating Procedure 2.1.1, which required revision as a result of this change".

DC 86-36 was implemented to install a pressure switch in ' the drywell pneumatic supply header. The basis'for the design change stems from a

_ District commitment regarding the Hydrogen Recombiner Capability issue-and from the existing CNS ' Emergency Operating Procedures (EOP's) which require the operator to have available positive indication of drywell' pneumatic pressure. This positive indication allows the operator to execute certain critical mitigating actions as directed by the applicable E0P.

The requirement to change Operating Procedure 2.1.1 (isolation of backup air to drywell. pneumatic system) stems not from DC 86-36, but from the aforementioned regulatory commitment regarding control of combustible gas concentrations in Containment. following a LOCA. Accordingly, the necessary change to Procedure 2.1.1 was made on January 2,1987, eight days before the January 10, 1987, event. However, due to the synergistic effects described in the response to violation 298/8703-1, this change proved to be inadequate. Further corrective procedure changes were implemented subsequent to the January 10, 1987, event to prevent future occurrences.

In summary, the District concludes that, notwithstanding the inadequacies identified by violation 298/8703-1, Design Change 86-36 identified the appropriate station procedures requiring revision.

Furthermore, the District concludes that Procedure 2.1.1 did not require revision by DC 86-36. As such, the District feels that consideration shculd be given to retraction of the apparent statement of violation.

If you have any questions regarding this response, please contact me or G. R. Horn at Cooper Nuclear Station.

. . Trevors Division Manager of Nuclear Support GAT:SSF:ss cc: U.S. Nuclear Regulatory Commission Regional Office, Region IV NRC Resident Inspector Cooper Nuclear Station