ML20216D639

Responds to NRC Re Violations Noted in Insp Rept 50-298/97-11.Corrective Actions:Ts Case Studies,Including Problem Identification Rept Associated W/Violation Have Been Developed & Presented at SS Meetings & to Crews

ML20216D639
Person / Time
Site:	Cooper
Issue date:	04/08/1998
From:	Swailes J NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-298-97-11, NUDOCS 9804150364
Download: ML20216D639 (9)

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l I COOPER NUCLEAR STATION P.O. BOX 98, BROWNVILLE NEBRASKA 68321 4, -

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Nebraska Public Power District

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NLS980045 April 8,1998 U.S. Nuclear Regulatory Commission  :

Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

Reply to a Notice of Violation NRC Inspection Report No. 50-298/97-11 Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

1. Letter to G. R. Ilorn (NPPD) from E. E. Collins (USNRC) dated February 23, 1998,"NRC Inspection Report 50-298/97-11 and Notice of Violation" l By letter dated February 23,1998 (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 Notices of Violation in accordance with 10 CFR 2.201. The District admits to the violations and has completed the corrective actions necessary to return CNS to full compliance.

This letter was due to the NRC no later than March 25,1998. Ilowever, per telephone conversation between E. E. Collins (NRC) and B. L. Ilouston (NPPD), the due date of the response had been extended to April 9,1998.

Should you have any questions concerning this matter, please contact me.

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. NLS980045

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,Page 2,of 3 cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution l

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, NLS980045 April 8,1998 Page 3 of 3 STATE OF NEBRASKA)

) I PLATTE COUNTY ) /

John 11. Swailes, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this correspondence on behalf of Nebraska -

Public Power District; and that the statements contained herein are true to the best of his knowledge and belief. I i

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Su ib.esidn my pr nce a d sworn to before me this day of 1998.

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. Attachment I to NLS980045 Page1of5, l

REPLY TO FEBRUARY 23,1998, NOTICE OF VIOLATION l COOPER NUCLEAR STATION l

NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from December 14,1997, through January 24,1998, l four violations of NRC requirements were identified, three of which require response. The particular violations and the District's reply are set forth below:

Violation A l

l Technical Specification 3.2.A states, in part, when primary containment integrity is required, l the limiting conditionsfor operationfor 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 l 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, ifthe minimum number of operable instrument channels per trip system requirement cannot be met by a trip system, i

that trip system shall be tripped. Note 2.E directs that, ifthe requirements cannot be met by both trip systems, isolate the reactor water sample valves.

1 Contrary to the above, on December 22,1997, while Alain Steam Line High Radiation Afonitor RhiP-Rhf-251B was inoperable andprimary containment integrity was required, the i 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 ofsperable instrument channels per trip system operable.

This is a Severity LevelIV violation (Supplement 1) (50-298/97011-01)

Admission or Denial to Violation The District admits the violation. Although a later engineering evaluation had determined that Main Steam Line High Radiation Monitor RMP-RM-251B (MSL "B") was operable on December 22,1997, the violation occurred in that incorrect actions were taken, given that MSL "B" had been declared inoperable.

Reason for Violation This violation is the result of a personnel error in that the Shill Supervisor (SS) failed to

( recognize that the 740/741 valves could not be administratively opened for sampling purposes during the period Limiting Condition for Operation (LCO) 3.2.A, Table 3.2.A, Note 2E was in effect.

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. kttachment I to NLS980045 Page 2 of 5 A major contributing factor included the fact that both TS LCO 3.2.A and 3.7.D were in elTect at the same time. TS LCO 3.7.D pennits primary containment isolation valves, under the control of this TS, to be opened on an intermittent basis under administrative controls. This factor led the SS to believe that it was acceptable to open the 740/741 valves on an intermittent basis instead of j going to TS and performing a " cold read" of the requirements. Above all, the SS recognized the need to satisfy TS SR 4.6.B, which resulted in the opening of valves RR-AO-740 and 741.

Corrective Steps Taken and the Results Achieved The SS that was on watch at the time of the violation participated in the root cause evaluation associated with this violation. TS case studies, including the problem identification report associated with this violation, have been developed and presented at SS meetings and to the crews.

l l Corrective Stcos That Will Be Taken to Avoid Further Violations j l

There are no additional corrective actions necessary at this time.

j Date When Full Compliance Will Be Achieved

( The District is currently in full compliance.

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Violation B l 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality l shall be prescribed by documented instructions, procedures, or drawings ofa type l appropriate to the circumstances.

Contrary to the above, (1) On January 10,1998, Procedures 6.SC.501, " Secondary Containment Leak Test, " Revision 3c2, and 6.SC.502, " Secondary Containment Penetration ,

Examination, " Revision 2c) was not appropriate to the circumstances in that it '

did not measure or properly determine the amount ofin-leakage through the i secondary containment south vestibule door, an activity afecting quality. Also,

\ Procedure 6.SC.502 did not require the proper testing configurationfor l secondary containment airlock doors in that no requirement was provided to open i

one set ofdoors while testing the redundant set.

(2) Procedure 0.5, " Problem Identification and Corrective Action, " Revision 13ci, Step 2.1, requires thatproblem identification reports be processedpromptly, an activity affecting quality. As ofJanuary 8,1998, 25 problem identification reports which had been initiated in December 1997 andJanuary 1998 had not

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. Attachment I to NLS980045 j Page 3 of 5 t

! been processedpromptly. These 25 reports had been held in a group and not l processedfor up to 28 days.

This is a Severity LevelIV violation (Supplement 1) (50-298/97011-02) i.

Admission or Denial to Violation The District admits the violation.

Esason for Violation i (1) The violation cited above consists of two issues: The lack of adequate testing of the secondary containment (SC) south vestibule door (Door R109), and the lack of procedural l guidance to test each door with the associated door blocked open. For the first issue, the reason for the violation is that the individual who revised Procedure 6.SC.502 in 1993 (then l Procedure 6.3.10.17), failed to consider all potential operating conditions when the l acceptance criteria were developed. The test conditions were based on the " typical" i

configuration of the SC doors, and the worst case scenario was not considered. {

l With respect to the second issue, although Procedure 6.SC.502 did not explicitly state that one door is to be blocked open when the other door is being tested, this activity was being consistently performed correctly. As such, the need for the revision was perceived as an enhancement, as opposed to being a requirement that needed to be explicitly stated in the procedure. 4

, (2) The reason for the violation of Procedure 0.5 is poorjudgement on behalf of the individual l involved. This individual was aware of the management expectations for processing problem identification reports (PIRs) but determined, for the project he was working on, that holding the PIRs would result in a higher quality er.1 pi sduct. lie had made a conscious decision to not process the 25 PIRs as tbg were acceived. 'l S intent of the delay was to enable the supervisor to better reemmend disposition ar.d is ntify any trends associated with the subject PIRs. 'k mdividual also knew that all Seld work discrepancies associated with the individual PIRs had been successfully resolved.

Corrective Steos Taken and the Results Achieved (1) Specific to the Secondary Containment (SC) south vestibule door, Procedure 6.SC.502 has been revised to require that a pipe penetration, located in the vestibule between Door R109 l and RI15, be opened during the subject surveillance test, thus creating the required  ;

differential pressure across Door R109. The procedure has also been revised to require that when testing the SC airlock doors, one set of doors will be open while testing the redundant set, i

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. Attachment 1 I to NLS980045 l Page 4 of 5 Specific guidance for determination of appropriate acceptance criteria has also been developed and incorporated into the Procedure Writers Guide.

(2) The individual was counseled on the importance of timely processing of PIRs and the 25 PIRs were processed through the Condition Review Group. Interviews, conducted as part of the root cause evaluation associated witn the subject violation, with crew leaders, maintenance shop supervisors, a shift supervisor, two department managers and a senior  ;

manager have indicated that management expectations for the prompt processing of PIRs is  !

consistently understood. Since the time (late January - early February 1998) of these interviews, there have been no new problems concerning the failure to promptly process PIRs identified in the Maintenance organization.

Corrective Steps That Will Be Taken to Avoid Further Violations (1) The District will present the circumstances related to this violation as a case study to the i Engineering organization. The case study wn! describe the occurrence, major causes, and lessons learned. This will be accomplishe( by September 1,1998.

Engineering orientation training will be revised tc. include expectations for developing I acceptance criteria, including lessons learned from thic case study. This will be accomplished by August 1,1998.

(2) There are no additional corrective actions necessary at this time.

l Dg When Full Comnliarm Will Be achieved The District is currently in full compliance.

Violation C 10 CFR Part 50, Appendix B, Crherson 111, " Design Control," requires, inpart, that measures shall be establishedfor the selection and reviewfor suitability of application ofmaterials, parts, equipment, andprocesses that are essential to the safety-relatedfamctions ofthe structures, systems, and components.

Contrary to the above, as ofDecember 20,1997, established measuresfor the

., election and review ofmaterial, Procedure 1.8, " Warehouse issue, Return and Shipping," Revision 23, inappropriately allowed the selection ofnonessential, nondedicatedfuses to be installed in essential applications.

Dds is a Severity LevelIV violation (Supplement 1) (50-298/97011-03)

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. (taclunent I to NLS980045 Page 5 of 5 Admission or Denial to Violqtin The District admits the violation.

Reason for Violatin This condition stems from failure to implement all programmatic elements necessary to effectively control acceptance and issuance of non-essential fuses for use in safety related applications. Specifically, fuses were maintained on the Procedure 1.8 consumables list which allowed the issuance of these fuses without a formal verification of suitability.

Corrective Steps Taken and the Results Achieved Immediate corrective actions included immediate cessation of the practice ofissuing fuses as consumables. An Operability Assessment was performed to address the impact of existing commercial grade fuses installed in essential applications. This assessment concluded that adequate assurance exists that the installed fuses will perform as required based on the following factors: Fuses are highly standardized, simple design devices and are tested to Underwriter Laboratory requirements, few fuse failures have been identified by either CNS or the industry, and historical dedication of fuses have resulted in approximately 100% acceptance levels.

Further immediate corrective actions included returning all fuses characterized as " bench spares" to the warehouse, placing all inventories of non-dedicated fuses on hold, and reviewing all essential spare fuse inventories.

Further actions were taken to revise Procedure 1.8 to eliminate fuses from the consumables list. Upon revision of Procedure 1.8, non-essential fuse inventories were -

removed from hold. Currently, issuance of non-essential fuses to essential work items requires an engineering review for suitability of application.

A root cause evaluation was conducted to address a number of fuse related issues, along with the development of a comprehensive corrective action plan.

Corrective Steps That Will Be Taken to Avoid Further Violations The District will review the consumables list in Procedure 1.8 and the basis for inclusion of each item on the list. The District will complete this review by July 31,1998.

Date When Full Compliance Will Be Achieved The District is currently in full compliance.

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( . ATTACHMENT 3 LIST OF NRC COMMITMEMTS l l

Corre,spondence No: NLS900045 )

l 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 questiens regarding this document or any associated I regulatory commitments.

i COMMITTED DATE COMMITMENT OR OUTAGE The District will present the circamstances related to I this violation as a case study to the Engineering I organization. The case study will describe the September 1, 1998 occurrence, major causes, and lessons learned.

l Engineering orientation training will be revised to l include expectations for developing acceptance criteria, August 1, 1998 including lessons learned from this case study.

The District will review the consumables list in Procedure 1.8 and the basis for inclusion of each item on July 31, 1998 the list.

l l PROCEDURE NUMBER 0.42 l REVISION NUMBER 5 l PAGE 8 OF 13 l

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