ML20217F154

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Forwards Insp Rept 50-298/97-12 on 970708-0905.Apparent Violations Re Failure to Promptly Recognize,Document or Correct Conditions Adverse to Quality,Being Considered for Escalated EA
ML20217F154
Person / Time
Site: Cooper Entergy icon.png
Issue date: 10/03/1997
From: Gwynn T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Horn G
NEBRASKA PUBLIC POWER DISTRICT
Shared Package
ML20217F159 List:
References
50-298-97-12, EA-97-424, NUDOCS 9710070380
Download: ML20217F154 (6)


See also: IR 05000298/1997012

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OCT - 31997

EA 97 424

G. R. Horn, Senior Vice President

of Energy Supply

Nebraska Public Power District

141415th Street

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Columbus, Nebraska 68001

SUBJECT: NRC INSPECTION REPORT 50 298/97 12

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Dear Mr. Horn:

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An NRC inspection was conducted July 8 through September 5,1997, at your Cooper

Nuclear Station reactor facility. The enclosed report presents the scope and results of that

inspection.

Based on the results of this inspection, apparent violations were identified and are being

considered for escalated enforcement action in accordance with the " General Statement of

Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600.

The apparent violations consist of several examples in which your staff f ailed to promptly

recognize, docurnent, or correct conditions adverse to quality. We consider two of these

conditions to be significant. One was your f ailure, until recently, to recognize and correct

instances whereby large volumes of water could cause both standby gas treatment system

trains to potentially be inoperable. The other was the failure to recognize and assess

significant blockage of Residual Heat Removal Heat Exchanger B, which reduced the heat

transfer capability below design. In this instance, important information about the as found

condition was lost when workers proceeded to clean the heat exchanger without collecting /

as found data. Also, station evaluations of the condition considered this blockage to be

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expected and not to be a condition adverse to quality. As a result, by the end of the

inspection, no corrective actions had been formulated or implemented to address the heat

exchanger cleaning and testing programs.

We recognize your efforts to resolve issues in a timely manner. However, your failure to

recognize, document, or correct these fundamental requirements for quality activities is a

concern. For some of these conditions, your staff missed opportunities to recognize and

cor.ect the problem earlier this year. Also, some conditions were not questioned and

resolved because a similar condition had occurred in the past and, therefore, the condition

was considered expected. Lastly, although in several cases you corrected physical plant

problems with a modification or precedure change, you had not addressed the broader '

aspects of weakness in problem resolution.

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A Notice of Violation is not presently being issued for these insp '.!,sn findings. In

addition, please be 3dvised that the number and characterization of 3pparent violations

described in the enclosed inspection report may change as a result of further NRC review.

An open predecisional enforcement conference to discuss these apparent violations has

been scheduled for October 17,1997. The decision to hold a predecisional enforcement

conference does not mean that the NRC has determined that violations occurred or that

enforcement action will be taken. This conference is being held to obtain information to

enable the NRC to make an enforcement decision, such as a common understanding of the

f acts, root causes, missed opportunities to identify the apparent violation sooner,

corrective actions, significance of the issues, and the need for lasting and effective

corrective action._ in particular, we expect you to address in detail the technical and

problem resolution aspects _of the heat exchanger degradation and the impa::t of water on

standby gas treatment system operability. Also, please include what actions you have

taken to address the ability of site personnel to recognize problems. The technical aspects

of the additional examples of weak problem resolution discussed and referenced in this

report do not need to be discussed in detail, but rather should be discussed in summary

fashion. However, how these additional examples contribute to the issue of problem

resolution should be included in your discussion,

in addition, this is an opportunity for you to point out any errors in our_ inspection report

and for you to provide any Information concerning your perspectives on: (1) the severity

of the violation, (2) the application of the factors that the NRC considers when it

determines the amount of a civil penalty that may be assessed in accordance with

Section VI.B.2 of the Enforcement Policy, and (3) any other application of the Enforcement

Policy to this case, including the exercise of discretion in accordance with Section Vll.-

You will be advised by separate correspondence of the results of our deliberations on this

matter No recponse regarding the apparent violation is required at this time,

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosure wl;i be placed in the NRC Public Document Room (PDR),

Should you have any questions concerning this inspection, we will be pleased to discuss

them with you.

Sincerely,

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JW

onias

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irector

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ivision of Reactor Projects

Docket No.: 50 298

License No.: _ DPR-46

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Nebraska Public Power District

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Enclosure:

NRC Inspection Report

50 298/97 12

cc w/ enclosure:

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John R. McPhail, General Counsel

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Nebraska Public Power District

P.O. Box 499

Columbus, Nebraska 68002 0499

P. D. Graham, Vice President of

Nuclear Energy

Nebraska Public Power District

P.O. Box 98

Brownville, Nebraska 68321

8. L. Houston, Nuclear Licensing

and Safety Manager

Nebraska Public Power District

P.O. Box 98

Brownville, Nebraska 68321

Dr. William D. Leech

MidAmerican Energy

907 Walnut Street

P.O. Box 657

Des Moines, Iowa 50303-0057

Mr. Ron Stoddard

Lincoln Electric System

11th and O Streets

Lincoln, Nebraska 68508

Randolph Wood, Director

Nebraska Department of Environmental

Quality

P.O. Box 98922

Lincoln, Nebraska 68509-8922

Chairman

Nemaha County Board of Commissioners

Nemaha County Courthouse

1824 N Street

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Auburn, Nebraska 68305

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Nebraska Public Power District

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Cheryl Rogers, LLRW Program Manager

Environmental Protection Section

Nebraska Department of Health

301 Centennial Mall, South

P.O. Box 95007

Lincoln, Nebraska 68509 5007

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Dr. Mark B. Horton, M.S.P.H.

Director

Nebraska Department of Health

P.O. Box 950070

Lincoln, Nebraska 68509 5007

R. A. Kucera, Department Director

of Intergovernmental Cooperation

Department of Natural Resources

P.O. Box 176

Jefferson City, Missouri 65102

Kansas Radiation Control Program Director

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