ML20237A631
| ML20237A631 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/10/1998 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-98-03, 50-298-98-3, NUDOCS 9808140222 | |
| Download: ML20237A631 (4) | |
See also: IR 05000298/1998003
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UNITED STATES
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NUCLEAR REGULATORY COMM!SSION
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REGION IV
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611 RYAN PLAZA DRIVE. SUITE 400
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ARUNGioN, TE XAS 76011-8064
AUG I O 1998
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G. R. Horn., Senior Vice President
of Energy Supply
Nebraska Public Power District
141415th Street
Columbus, Nebraska 68601
SUBJECT: NRC INSPECTION REPORT 50-298/98-03
Dear Mr. Horn:
Thank you for your letter of July 23,1998, in response to our letter and Notice of
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Violation dated June 23,1998. On August 4,1998, Mr. Peckham, Cooper Nuclear Station Plant
Manager, and Charles Marschall, Acting Chief, Project Branch C, discussed this violation
response. Based on this conversation, we understand that you plan to revise the violation
response. We will review this response upon receipt.
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Sincerely,
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Division of R ' actor Projects
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Docket No.: 50-298
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License No.: DPR-46
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cc:
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John R. McPhail, General Counsel
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' Nebraska Public Power District
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P.O. Box 499
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Columbus, Nebraska 68602-0499
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J. H. Swailes, Vice President of
Nuclear Energy
Nebraska Public Power District
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P.O. Box 98
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Brownville, Nebraska 68321
980814022p 980810
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Nebraska Public Power District
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B. L. Houston, Nuclear Licensing
and Safety Manager
Nebraska Public Power District
P.O. Box 98
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Brownville, Nebraska 68321
Dr. William D. Leech
MidAmerican Energy
907 Walnut Street
P.O. Box 657
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Des Moines, Iowa 50303-0657
Mr. Ron Stoddard
Lincoln Electric System
1040 O Street
P.O. Box 80869
Lincoln, Nebraska 68501-0869
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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
" Auburn, Nebraska 68305
Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
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Hebraska Department of Health
. 301 Centennial Mall, South
P.O. Box 95007
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Lincoln, Nebraska 68509-5007
R. A. Kucera, Department Director
of Intergovemmental Cooperation
Department of Natural Resources
P.O. Box 176
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. Jefferson City, Missouri 65102
- Kansas Radiation Control Program Director
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NLS980112
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July 23,1998
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U.S. Nuclear Regulatory Commission
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Attention: Document Control De 1:
Washington, D.C. 20555-0001
Gentlemen:
Subject:
Reply to a Notice of Vic,1ation
NRC Inspection Repe,t No. 50-298/98-03
Cooper Nuclear Stason, NRC Docket 50-298, DPR-46
Reference:
1. Letter to G. rc Horn (NPPD) from Elmo Collins (USNRC) dated June 23,
1998, "NIC Inspection Report 50-298/98-03 and Notice of Violation"
By letter dated June 23,1998 (Reference 1), the NRC cited Nebraska Public Power District
(District) as being in vir,tation of NRC requirements. This letter, including Attachment 1,
constitutes the Distric'es 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
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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
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compliance.
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Should you have any questions concerning this matter, please contact me.
Sincerel',
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John H.
ailes
Vice President of Nuclear Energy
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Attachment
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NLS980112
July 23,1998
Page 2 of 2
cc: Regional Administrator
USNRC - Region IV
Senior Project Manager
. USNRC - NRR Project Directorate IV-1
Senior Resident Inspector
NPG Distribution
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NLS980112
July 23,1998
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Page 1 of 2
REPLY TO JUNE 23,1998, NOTICE OF VIOLATION
COOPER NUCLEAR STATION
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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 .
TechnicalSpecifications 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 thepathway.
Technical Specifications 3.21.A. J.d. required that, if'the minimum number ofchannels is not
returned to OPERABLE status within 31 days, in lieu ofany other report, explain in the next
Annual Radioactive Afaterials Release Report why the instrument was not repaired in a
timely manner.
Contrary to the above, with the service water effluent line radiation monitors inoperable,
during liquid discharges, form October 22 through December 31,1997, no explanation was
included in the subsequent Annual Radioactive Afaterials 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
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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
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3.21.A' l .d, which stipulated the reporting requirements, if the condition exceeds 31 days.
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NLS980112
July 23,1998
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Page 2 of 2
A contributing factor 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
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
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
pressure for the SW radiation monitors to provide continuous monitoring. Valves SW-MOV-
89A&B have historically experienced leakage and are being redesigned to better withstand the
environment associated with the SW system. Implementation of the design change will be
completed during iwfueling Outage (RFO) 18.
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Corrective Stens Taken and the Results Achieved
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As a result of Operations shift mentoring performed in Early 1998, increased awareness of the
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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
required additional reporting was found to be included in the LCO Action Statement.
Corrective Steps That Will Be Taken to Avoid Further Violations
Operations instructions associated with the Open LCO Index System will be reviewed for
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adequate guidance on the completeness of LCO Action entries and revised, as appropriate, by
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August 14,1998.
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- To address the leakage associated with SW-MOV-89A and B, these valves are being
redesigned. Implementation of the design change will be completed during RFO-18,
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currently scheduled to commence October 1998.
Date When Full Comnliance Will Be Achieved
The District is currently in compliance.
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ATTACHMENT 3
LIST OF NRC COMMITMENTS
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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 legarding this document or any associated
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COMMITTED DATE
COMMITMENT
OR OUTAGE
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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
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appropriate.
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RFO-18, currently
Valves SW-MOV-89A and B are being redesigned to better
scheduled to
withstand the environment associated with the Service
commence
Water system.
Implementation of the design change will
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October 1998
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be completed during RFO-18.
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PROCEDURE NUMBER 0.42
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REVISION NUMBER 6
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PAGE 9 OF 13
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