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Category:Letter type:NLS
MONTHYEARNLS2024006, Response to Nuclear Regulatory Commission'S Request for Additional Information for Relief Request RC3-022024-01-25025 January 2024 Response to Nuclear Regulatory Commission'S Request for Additional Information for Relief Request RC3-02 NLS2024007, Emergency Plan Implementing Procedure 5.7.1, Revision 732024-01-16016 January 2024 Emergency Plan Implementing Procedure 5.7.1, Revision 73 NLS2024003, 30 Day Report - Unauthorized Disassembly of Liquid Scintillation Detector2024-01-15015 January 2024 30 Day Report - Unauthorized Disassembly of Liquid Scintillation Detector NLS2024004, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20232024-01-10010 January 2024 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2023 NLS2023053, ISFSI, Supplement to Exemption Request from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-30030 November 2023 ISFSI, Supplement to Exemption Request from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation NLS2023050, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation NLS2023045, Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program2023-11-15015 November 2023 Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program NLS2023051, Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2023-10-10010 October 2023 Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2023049, 10 CFR Part 21 Report Regarding HGA Relays2023-09-0606 September 2023 10 CFR Part 21 Report Regarding HGA Relays NLS2023029, License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks2023-09-0606 September 2023 License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks NLS2023047, Licensee Guarantees of Payment of Deferred Premiums2023-07-26026 July 2023 Licensee Guarantees of Payment of Deferred Premiums NLS2023033, 10 CFR 50.55a Relief Request RC3-022023-06-27027 June 2023 10 CFR 50.55a Relief Request RC3-02 NLS2023039, Preparation and Scheduling of Operator Licensing Examinations2023-06-0101 June 2023 Preparation and Scheduling of Operator Licensing Examinations NLS2023038, Nebraska Public Power District 2022 Financial Report2023-05-22022 May 2023 Nebraska Public Power District 2022 Financial Report NLS2023031, Annual Radiological Environmental Report2023-05-11011 May 2023 Annual Radiological Environmental Report NLS2023017, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2023-05-0303 May 2023 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2023018, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-0303 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling NLS2023030, Annual Radioactive Effluent Release Report2023-04-27027 April 2023 Annual Radioactive Effluent Release Report NLS2023007, Technical Specification Bases Changes2023-04-17017 April 2023 Technical Specification Bases Changes NLS2023027, Annual Report of Individual Exposure Monitoring2023-04-13013 April 2023 Annual Report of Individual Exposure Monitoring NLS2023021, Quality Assurance Program Changes2023-04-10010 April 2023 Quality Assurance Program Changes NLS2023020, Decommissioning Funding2023-03-29029 March 2023 Decommissioning Funding NLS2023019, Property Insurance Coverage2023-03-23023 March 2023 Property Insurance Coverage NLS2023010, Inservice Inspection OAR-1 Owner'S Activity Report for Cooper Nuclear Station2023-02-0909 February 2023 Inservice Inspection OAR-1 Owner'S Activity Report for Cooper Nuclear Station NLS2023005, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20222023-01-19019 January 2023 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2022 NLS2022054, Preparation and Scheduling of Operator Licensing Examinations2023-01-0505 January 2023 Preparation and Scheduling of Operator Licensing Examinations NLS2022055, Emergency Plan, Revision 812023-01-0404 January 2023 Emergency Plan, Revision 81 NLS2022053, CNS-2022-11 Post Exam Submittal2022-11-22022 November 2022 CNS-2022-11 Post Exam Submittal NLS2022050, Notification of Revision to Cooper Nuclear Station Emergency Response Data System Data Point Library2022-11-0909 November 2022 Notification of Revision to Cooper Nuclear Station Emergency Response Data System Data Point Library NLS2022048, Management Change and Correspondence Update2022-11-0101 November 2022 Management Change and Correspondence Update NLS2022047, Core Operating Limits Report, Cycle 33, Revision 02022-10-14014 October 2022 Core Operating Limits Report, Cycle 33, Revision 0 NLS2022042, 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2) Summary Report2022-10-0707 October 2022 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2) Summary Report NLS2022037, Emergency Plan, Revision 80, Summary of 50.54(q) Analyses2022-08-18018 August 2022 Emergency Plan, Revision 80, Summary of 50.54(q) Analyses NLS2022035, Evacuation Time Estimate Report for Cooper Nuclear Station2022-08-16016 August 2022 Evacuation Time Estimate Report for Cooper Nuclear Station NLS2022031, Licensee Guarantees of Payment of Deferred Premiums2022-07-19019 July 2022 Licensee Guarantees of Payment of Deferred Premiums NLS2022005, Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2022-06-16016 June 2022 Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements NLS2022025, Nebraska Public Power District Letter (NLS2022010) to U.S. Nuclear Regulatory Commission Dated April 5, 2022, Annual Report of Individual Exposure Monitoring2022-06-0606 June 2022 Nebraska Public Power District Letter (NLS2022010) to U.S. Nuclear Regulatory Commission Dated April 5, 2022, Annual Report of Individual Exposure Monitoring NLS2022016, Annual Radiological Environmental Report2022-05-10010 May 2022 Annual Radiological Environmental Report NLS2022020, Nebraska Public Power District, Cooper Nuclear Station, 2021 Financial Report2022-05-0202 May 2022 Nebraska Public Power District, Cooper Nuclear Station, 2021 Financial Report NLS2022014, Annual Radioactive Effluent Release Report2022-04-27027 April 2022 Annual Radioactive Effluent Release Report NLS2022010, Annual Report of Individual Exposure Monitoring2022-04-0505 April 2022 Annual Report of Individual Exposure Monitoring NLS2022009, Property Insurance Coverage2022-03-23023 March 2022 Property Insurance Coverage NLS2022011, Preparation and Scheduling of Operator Licensing Examinations2022-03-18018 March 2022 Preparation and Scheduling of Operator Licensing Examinations NLS2022004, Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Relief Request RR5-01, Revision 12022-02-0707 February 2022 Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Relief Request RR5-01, Revision 1 NLS2022003, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20212022-01-20020 January 2022 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2021 NLS2021067, ISFSI - Independent Spent Fuel Storage Installation Decommissioning Funding Plan2021-12-16016 December 2021 ISFSI - Independent Spent Fuel Storage Installation Decommissioning Funding Plan NLS2021069, Withdrawal of Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2021-12-15015 December 2021 Withdrawal of Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2021066, Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Alternative Request RI5-02, Revision 32021-12-10010 December 2021 Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Alternative Request RI5-02, Revision 3 NLS2021065, Clarification of Response to Nuclear Regulatory Commission'S Request for Additional Information for Alternative Request RS-012021-12-0606 December 2021 Clarification of Response to Nuclear Regulatory Commission'S Request for Additional Information for Alternative Request RS-01 NLS2021056, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2021-11-16016 November 2021 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements 2024-01-25
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARNLS2015084, Reply to Notice of Violation; EA-15-0892015-07-22022 July 2015 Reply to Notice of Violation; EA-15-089 NLS2014092, Response to NRC Security Inspection Report 05000298/2014202, Denial of Non-Cited Violation No. 05000298/2014202-12014-10-22022 October 2014 Response to NRC Security Inspection Report 05000298/2014202, Denial of Non-Cited Violation No. 05000298/2014202-1 NLS2013061, Reply to Notice of Violation EA- 13-0752013-06-0606 June 2013 Reply to Notice of Violation EA- 13-075 IR 05000298/20120042013-03-21021 March 2013 Reply to Notice of Violation (NRC Inspection Report 05000298-12-004) NLS2012127, Reply to Notice of Violation IR 05000298-12-004-02; EA-12-2062012-12-10010 December 2012 Reply to Notice of Violation IR 05000298-12-004-02; EA-12-206 NLS2011091, Reply to Notice of Violation 05000298-11-006-052011-09-0707 September 2011 Reply to Notice of Violation 05000298-11-006-05 NLS2011070, Reply to a Notice of Violation2011-07-0808 July 2011 Reply to a Notice of Violation NLS2011050, Reply to Notice of Violation 2011002-02; EA-2011-0902011-06-0202 June 2011 Reply to Notice of Violation 2011002-02; EA-2011-090 IR 05000298/20080022008-09-12012 September 2008 Reply to a Notice of Violation for Failing to Perform Maintenance Affecting Performance of Safety-related Equipment with Written Procedures or Documented Instructions Appropriate to the Circumstances - NRC IR 05000298-08-002 NLS2008068, Reply to a Notice of Violation for Failing to Perform Maintenance Affecting Performance of Safety-related Equipment with Written Procedures or Documented Instructions Appropriate to the Circumstances - NRC IR 05000298-08-0022008-09-12012 September 2008 Reply to a Notice of Violation for Failing to Perform Maintenance Affecting Performance of Safety-related Equipment with Written Procedures or Documented Instructions Appropriate to the Circumstances - NRC IR 05000298-08-002 NLS2008029, Triennial Fire Protection Unresolved Issue2008-03-10010 March 2008 Triennial Fire Protection Unresolved Issue NLS2007072, Reply to Notice of Violation; EA-07-0902007-10-15015 October 2007 Reply to Notice of Violation; EA-07-090 IR 05000298/20050022005-08-29029 August 2005 Letter to Nebraska Public Power District IR 05000298/2005-02 Denial of Noncited Violation, 05000298/2005002-02 NLS2004089, Reply to a Notice of Violation NRC Letter No. EA-04-1202004-07-26026 July 2004 Reply to a Notice of Violation NRC Letter No. EA-04-120 NLS2004021, Contesting of Finding in Inspection Report 05000298/2003-0072004-02-26026 February 2004 Contesting of Finding in Inspection Report 05000298/2003-007 NLS2002123, Reply, IR 05000298-02-007, Dated 09/20/02, Cooper Nuclear Station2002-10-18018 October 2002 Reply, IR 05000298-02-007, Dated 09/20/02, Cooper Nuclear Station NLS2002048, Reply to a Notice of Violation, NRC Letter No. EA-01-2982002-04-15015 April 2002 Reply to a Notice of Violation, NRC Letter No. EA-01-298 NLS2002037, Reply to a Notice of Violation2002-04-0101 April 2002 Reply to a Notice of Violation 2015-07-22
[Table view] |
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Nebraska Public Power District Always the-e when you need us NLS2004021 February 26, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Contesting of Finding in Inspection Report 50-298/03-07 Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46
References:
- 1. Letter to Nebraska Public Power District from Kris Kennedy (U.S. Nuclear Regulatory Commission) dated January 27, 2004 "Cooper Nuclear Station -
NRC Integrated Inspection Report 50-298/03-07"
- 2. Letter to U.S, Nuclear Regulatory Commission from John Christensen (Nebraska Public Power District) dated December 19, 2003, "Licensee Event Report No. 2003-006", NLS20030127.
The purpose of this letter is to contest a specific finding in the referenced inspection report as discussed in Section 40A2. 1. The inspection report states that the finding is:
"...associated with the failure to evaluate and take corrective actions for a fire on the Booneville 345 kV transmission line. This led to a similar fire on a transmission tower between the main transformers and the main generator disconnect switches, which induced a plant transient".
The Booneville 345 kV transmission line fire occurred in 1997. The "similar" fire in the referenced inspection report occurred in 2003. The Nuclear Regulatory Commission (NRC) concluded that a thorough evaluation of the 1997 fire could have prevented the fire in 2003.
Attachment I provides further detail on the event.
Cooper Nuclear Station (CNS) concludes that linking a recent event, which was investigated under the scope of the current corrective action program that is dissimilar to the scope that existed six years ago, is inappropriate in several ways. CNS reviewed NRC guidance regarding the timeliness of inspection findings and the use of crosscutting aspects and believes that guidance is instructive in this matter.
COOPER NULEAR STATION P.O. Box 98/Brownville. NE 68321-0098 Telephone: (402) 825-381 / Fax: (402) 825-5211 www.nppd.com 1I L v
NLS2004021 Page 2 of 3 NRC practice is to link contemporary events to demonstrate ineffective corrective action. For instance, Section 4.2.1c of the NRC Enforcement Manual states that a repetitive violation is:
"A violation that could reasonably have been prevented by the licensee's corrective action for a previous violation or a previously docketed noncompliance finding that occurred within the 2 years prior to the date of the violation".
Further, the NRC states in the referenced inspection report that the finding is not a violation of NRC requirements since the electrical distribution system affected by the fire is not safety-related. The use of the term "finding" to cite a utility for a non-violation performance deficiency came into practice by the NRC with the advent of the Reactor Oversight Process in 1999.
In addition, Inspector Manual Chapter (IMC) 0612 Section 06.03.c (4) states that:
"The cross-cutting aspect of a finding is not considered a separate cross-cutting finding but rather is documented as a contributing cause of the finding, as appropriate".
In other words, a utility cannot be cited for a cross-cutting finding in and of itself.
The NRC did not cite CNS for an Appendix B Criterion XVI violation for the 1997 event, properly so, and the term, "finding", referring to a non-violation performance deficiency, was not in use in that context at that time. Therefore, per guidance in the Enforcement Manual regarding repetitive violations and the guidance in IMC 0612, the station should not be cited for a cross-cutting finding in 2003.
In conclusion, CNS believes that linking a non-violation performance deficiency six years ago as evidence of a cross-cutting finding and performance deficiency in 2003 is not in accordance with NRC guidance.
Should you have any questions concerning this matter, please contact Mr. Paul Fleming at (402) 825-2774.
Sincerely, all K. Edington Vice President- Nuclear and Chief Nuclear Officer cc: Regional Administrator w/attachment USNRC Director W/attachment USNRC - Office of Enforcement
NLS2004021 Page 3 of 3 Senior Project Manager Nv/attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector wv/attachment USNRC NPG Distribution w/o attachment Records W/attachment
Attachment to NLS2004021 Page 1 of 1 ATTACHMENT Event Description On October 28, 2003, CNS experienced a fire on the cross-arm of a wooden 345 kV transmission tower adjacent to the 345 kV switchyard. The tower supported the main generator output lines and was located between the main transformers and the main generator disconnect switches. The plant was shutdown due to the imminent loss of the main generator output line to the switchyard.
The physical root cause of the fire was the failure to properly ground the insulator strings on the wooden structure cross member. The event was recorded in the NRC Unplanned Scrams for 7000 Critical Hours performance indicator and an LER was submitted (Reference 2) describing the event.
In 1997, a fire occurred on the 345 kV transmission line south of CNS that transmitted power from the CNS switchyard to Booneville, IA. That line had a similar tower configuration as the tower that experienced the 2003 fire. In the referenced inspection report, the NRC indicated that CNS performed no root cause or extent of condition evaluation of the 1997 event.
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©l Correspondence Number: NLS2004021 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None I
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