ML20217Q875
| ML20217Q875 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/25/1997 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-97-06, 50-298-97-6, NLS970159, NUDOCS 9709030429 | |
| Download: ML20217Q875 (4) | |
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- - = =.n NLS970159 August 25,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Reiurt No. 50-298/97-06 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Ilom (NPPD) from T. P. Gwynn (USNRC) dated July 25,1997, "NRC Inspection Report 50-298/97-06, Notice of Violation" By letter dated July 25,1997 (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 violation and has completed all of the corrective actions necessary to return Cooper Nuclear Station (CNS) to full compliance with respect to the cited violation.
Should you have any questions concerning this matter, please contact me.
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P. D. Graham Vice President of Nuclear Energy I /f 9709030429 970825
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Attachment I to NLS970159 Page 1 of 2 REPLY TO JULY 25,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted May 18 through June 28,1997, a violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
Violatinu 10CFR Part So, Appendix B, Criterion l', requires, inpart, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
l Con!?ary to the above, on June 14,1997, the licensee 's proceduresfor inerting containment were not appropriate to the circumstances in that they did not allow the use ofinstalled 24-inch valves; and, on May 19,1997, the licensee implemented a change to Procedure 2.1.1, "Startup Procedure, "
which was not appropriate to the circumstances in that it would have allowed verification ofjet pump operability afterplacing the reactor mode switch to the "startup" position, conflicting with TechnicalSpecylcations.
This is a Severity Level 11' violation (Supplement 1) (29W97006-01, Ibf 97-322).
Admission or Denial to Violation The District admits the violation.
Reason for Violation The cause for these procedural deficiencies are as follows:
- 1) With regard to the verification of the jet pump operability, this is attributed to a lack of understanding and application of procedural requirements to assure that all Technical Specifications are fulfilled and documented prior to changes in the mode switch.
- 2) With regard to the procedure for inerting the containment, this is attributed to an inadequate review of a procedure prior to performing an evolution involving the procedure. Procedure 2.2.60 was conservatively written to prohibit use of the 24-inch valves during containment inerting. Technical Specification 3.7.A.2.b restricts the use of the 24-inch valves to no more than 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per calender year when the coolant temperature is over 212 degrees Fahrenheit. The fact that the procedure was unduly restrictive was not discovered by station personnel during the procedure review prior to the down power evolution. Therefore the cause for the procedural inadequacy was a less than adequate review by personnel who should have recognized the l
4 Attachment I to NLS970159 Page 2 of 2 prohibitive restriction in the procedure and initiated a procedure change to remove the barrier prior to the down power.
Corrective Steps Taken and the Results Achieved The following immediate actions have been taken:
- 1) Procedure 2.1.1 was revised on May 30,1997 to require that ajet pump operability check be perfonned following establishment of reactor recirculation flow but prior to a reactor mode switch change to the startup and hot standby mode.
- 2) Procedure 2.2.60 was revised on June 14,1997, to provide guidance to allow use of the 24-inch valves during the inerting process.
In addition, the following corrective actions have also been taken:
- 3) Emphasize to the Shiti Supervisors the requirements of Technical Specification 1.0.J to ensure safety equipment operability as required for a given mode, prior to placing the plant in that mode.
This action has been completed.
- 4) Prepare a Training Work Request (TWR) to include the lessons learned from this condition and other similar events at other Nuclear Facilities into the License Operator Training. This action has been completed.
Corrective Stens That Will Be Taken to Avoid Further Violations The following actions will be taken to avoid the situations described above, or similar conditions, in the future:
- 1) Perform a review of the Technical Specifications to identify all operability verifications required prior to a mode change to the startup and hot standby or the run modes, consistent with Technical Specification 1.0.J. The expected completion date is September 2,1997,
- 2) Revise, as necessary, procedure 2.1.1.2 to incorporate all of the operability verifications identified by the above Technical Specification review. The expected completion date is October 15,1997.
- 3) Evaluate TWR and perform License Operator Retraining to emphasize both the current requirements per Technical Specification definition 1.0.J and related industry events. The expected completion date is January 31,1998.
Date When Full Comnliance Will Be Achieved The District is currently in full compliance with respect to the cited violation.
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ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: HLS970159 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 fc. the l'ic's information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE Revise procedure 2.1.1 to require that a jet pump ml operability check be performed following establishment of 9$etedonMay30, reactor recirculation flow but prior to a reactor mode switch change to the startup and hot standby mode.
Co leted on June 14, Revise procedure 2.2.60 to provide guidance to allow use g
of the 24-inch valves during the inerting process.
Emphasize to the Shift Supervisors the requirements of fm$letedonJuly17, Technical Specifications 1.0.J Prepare a Training Work Request (TWR)to include the ml lessons learned from this condition and other similar 9$etedonJuly23, events at other Nuclear Facilities into the License Operator Trainino.
Perform a review of the Technical Specifications to identify all operability verifications required prior to September 2, 1997 a mode change to the startup and hot standby mode or the run mode, consistent with Technical Specification 1.0.J Revise, as necessary, procedure 2.1.1.2 to incorporate October 15, 1997 all of the operability verifications identified by the
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above Technical Specification review.
Evaluate TWR and perform License Operator Retraining to emphasize both the current requirements per Technical January 31, 1998 Specification definition 1.0.J and the five related industry events.
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PROCEDURE NUMBER 0.42 l
REVISION NUMBER 4 l
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