ML20236T888
| ML20236T888 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/23/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-98-03, 50-298-98-3, NLS980112, NUDOCS 9807290125 | |
| Download: ML20236T888 (5) | |
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m NLS980ll2 July 23,1998 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. 50-298/98-03 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 i
Reference:
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1998,"NRC Inspection Repod 5" 298/98-03 and Notice of Violation" By letter dated June 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 Notice of Violation in accordance with 10 CFR 2.201. The information contained in Attachment I also constitutes the District's special report required per Cooper Nuclear Station (CNS) Technical Specification 3.21.A.I.d. The District
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, admits to the violation and has completed the corrective actions necessary to return CNS to full compliance.
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Should you have any questions concerning this matter, please contact me.
Sincerel
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bd John H.
ailes Vice President ofNuclear Energy
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NLS980112 July 23,1998 Page 2 0f 2 l
cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution
NLS980ll2 C
July 23,1998 Page1of2 REPLY TO KNE 23,1998, NOTICE OF VIOLATION COUliR NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from April 19,1998, through May 30,1998, one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
Violation Technical Specifications Table 3.21.A.] specifies that,for the service water effluent line, the minimum required number ofgross beta or gamma radioactivity monitoring channels being operable is one during releases via the pathway.
TechnicalSpecifications 3.21.A. J.d. required that, ifthe minimum number ofchannels is not returned to OPERABLE status within 31 days, in lieu ofuny other report, explain in the next Annual Radioactive Materials Release Report why the instrumnt was not repaired in a timely manner.
Contrary to the above, with the service water effluent line radiation monitors inoperable, during liquid discharges, Jbrm October 22 through December 31,1997, no explanation was included in the subsequent Annual Radioactive Materials Release Report and the condition was not repairedin a timely manner.
Admission or Denial to Violation The District admits the violation.
Reason for Violation The reason for the violation is that the CNS person responsible for the Limiting Condition for Operation (LCO) tracking system did not utilize this system appropriately. This person failed to make the appropriate entries that would have tracked all the actions affiliated with Technical Specification (TS) 3.21.A.I.d to completion.
The District utilizes a Computerized LCO Index System for tracking open LCOs. When an LCO is entered, the LCO action requirements are entered into this computerized tracking system. On October 22,1997, LCO Track Number 97-0892 was opened to document the actions to be taken in Table 3.21.A.1, Item 2, due to water leakage past Service Water (SW) motor operated valves (MOV) 89 A&B. When this entry was made, however, no entry was made concerning TS 3.21.A.l.d, which stipulated the reporting requirements, if the condition exceeds 31 days.
NLS980ll2
- July 23,1998 Page 2 of 2 I
A contributingfactor to the personnel error described above is that a weakness in the Operations instruction which governs information put into the TS Tracking System also exists. While the instruction directs Operations personnel to identify all conditions of the LCO, it does not include l
guidance to look for reporting conditions.
While it was not required for Table 3.21.A.1, Item 2 to be entered, because the SW radiation monitors were not inoperable, the District had taken this conservative measure to ensure that I
radiological monitoring was being accomplished through daily grab samples. These grab samples provided compensatory measures in recognition that valves SW-MOV-89A&B were in a degraded condition (water leakage past valves), and that there was insufficient water flow and t
pressure for the SW radiation monitors to provide continuous monitoring. Valves SW-MOV-l 89A&B have historically experienced leakage and are being redesigned to better withstand the l
environment associated with the SW system. Implementation of the design change will be completed during Refueling Outage (RFO) 18.
Corrective Stens Taken and the Results Achieved As a result of Operations shift mentoring performed in Early 1998, increased awareness of the necessity of making complete and concise LCO Action Statements in the Open LCO Index System has occurred. This is apparent in four LCO entries during the last two months where the
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required additional reporting was found to be included in the LCO Action Statement.
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Corrective Stens That Will Be Taken to Avoid Further Violations Operations instructions associated with the Open LCO Index System will be reviewed for adequate guidance on the completeness of LCO Action entries and revised, as appropriate, by i
August 14,1998.
To address the leakage associated with SW-MOV-89A and B, these valves are being l
redesigned. Implementation of the design change will be completed during RFO-18, l
currently scheduled to commence October 1998.
i Date When Full Comnliance Will Be Achieved The District is currently in compliance.
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ATTACID4ENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: NLS980112 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 NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE j
COMMITMENT OR OUTAGE Operations instructions associated with the Open LCO Index System will be reviewed for adequate guidance on August 14, 1998 the completeness of LCO Action entries and revised, as appropriate.
1 RFO-18, currently Valves SW-MOV-89A and B are being redesigned to better scheduled to l
withstand the environment associated with the Service commence Water system.
Implementation of the design change will October 1998 be completed during RFO-18.
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REVISION NUMBER 6 l
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