IR 05000298/1987028

Ack Receipt of 880126 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/87-28

ML20196F546
Person / Time
Site:	Cooper
Issue date:	02/26/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8803040107
Download: ML20196F546 (1)

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FEB 261988 In Reply' Refer To:

Docket: 50-298/87-28 Nebraska Public Power District ATTN: George A. Trevors-Division Manager-- Nuclear Support P.O. Box 499 Columbus, NE 68601'

Gentlemen:

Thank you for your letter of January 26, 1988, in response to our letter and Notice of Violation dated December 21, 1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, L. J. Callan, Director Division of Reactor Projects CC:

Cooper Nuclear Station ATTN: Guy Horn, Division Manager of Nuclear Operations P.O. Box 98 Brownville, Nebraska 68321 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bec distrib. by RIV:

• RRI R. D. Martin, RA

• SectionChief(DRP/C) Lisa Shea, RM/ALF

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• RSTS Operator *W. Long, NRR Project Manager

• R. Hall *DRS

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CNSS880042 Januany 26, 1988 li ! .

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U.S. Nuclear Regulatory Commission .

Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Subject: NPPD Response to Inspection Report 50-298/87-28 This letter is written in response to your letter dated December 21, 1987, transmitting Inspection Report 50-298/87-2 Therein you indicated that certain of our activities were in violation of NRC requirement Following is a statement of the violati,ns and our response in accordance w!.th 10CFR2.20 Statement of Violation Failure To Follow Procedures Appendix B, Criterion V, of 10 CFR Part 50, and the Itcensee's approved Quality Assurance program require that activities affecting quality be accomplished in accordance with approved instructions, procedures, and drawing CNS Procedure 0.4, "Preparation. Review, and Approval of Procedures," Revision 10 dated October 15, 1987, specifies that approved written station procedures shall be adhered to by all station personne CNS Procedure 2.2.71, "Service Water System". Appendix "A" Valve Checklist requires Valve SW-195 to be ope Procedure 0.9, "Equipment Clearance and Release Orders " Revision 5, dated May 14, 1987, requires a caution tag to be issued when any station personnel discover or recognize an abnormal condition where there is a need for additional instruction in regard to the safe operation of station equipment. Maintenance Procedure 7.0.1 Revision 9, dated October 29, 1987, requires a Work Item Tracking (WIT) request to be issued when attempting to determine the cause for unidentified Icakage and repai Contrary to the above, on November 18, 1987, during the performance of a partial system walkdown by the NRC inspectors of CNS Procedure 2.2.71,

"Service Water (SW) System". Appendix "A" Valve Checklist. Valve SW-19'

was found in the closed positio No caution tag or WIT was issued until November 18, 1987, when the improper position of Valve SW-195 was brought to the licensee's attention by the NRC inspector This is a Severity 1.evel IV violatio (Supplement 1) (298/8728-01)

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' U.S. Nuclect Rsguistory Commission  :

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January 26, 1988 l

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Reason For The Violation Thia violation is a result of inadequate follow-up by ' the operator who discovered the leaking in the valve (s) and closed the manual one inch tell-tale

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drai Although the action taken' was appropriate, failure to issue a Work

Item and identify the abnormal position of the valve is a vi.;4 tion of CNS Procedure requirement Corrective Steps Which Have Been Taken And The Results Achieved >

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The Operations Department determined the valve, a manual one inch tell-tale drain, had been closed because of leakage from either the Demineralizer Water System or the Service Water Syste A Work Item Tracking (WIT) request and Work Item was initiated, and the subject valve caution tagged closed ots November 18, 1987, correcting the nonconforming condition.

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Corrective Steps Which Will Be Taken To Avoid Further Violation i The Operations Supervisor will discuss this event with all operating crew -

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personnel during scheduled weekly Operations Supervisor meeting Specifically stressed will be the requirements of CNS procedure 0.9 regarding caution

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tagging, and procedure 7.0.1 regarding initiating a Work ltem Request when

plant equipment needs repai Date When Full Compliance Will Be Achieved I

Full compliance will be achieved by March 31, 1988..

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Statement of Violation i

i Failure to Maintain Secondary Containment ."egrity j Technical Specification 3.7.C.1 requires that secondary containment j integrity shall be maintained during all modes of plant operatio t i Contrary to the above, on November 9, 1987, the inner door to the Reactor

) Building railroad airlock was open for at least two hours while gaps existed between the outer door and the groun This constitutes a failure to

maintain secondary containment integrity.

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This is a Severity Level IV Violatio (Supplement I) (298/8728-03)

Reason For Violation i

Secondary containment integrity is defined in CNS Technical Specifications as the Reactor Building being intact and the following conditions being met:

' At least one door in each access opening is close . The Standby Cas Treatment System is operable.

I All automatic ventilation system isolation valves are operable or are secured in the isolated position.

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U.S. Nuciccr Rsgulctory Commission

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Pcg3 3 Jcnuary 26, 1988 The Secondary Containment System is designed to be s u f ' i c i e n t i .- toak-tight to allow the Standby Gas Treatment System to reduce the Reactor Building pressure to a minimum sub-atmospheric pressure of 0.25 inches of water (under calm wind conditions) when the Standby Gas Treatment System fans are exhausting the Reactor Building at a rate of 1001 per day of the Reactor Building free volum Given the above, the District cannot definitely conclude that the integrity of secondary containment had not been maintaine Ilowever, since the potential did exist, the District has taken action, accordingl The reason for this violation was lack of procedural guidance end failure to recognize the need to maintain the exact configuration of the outer railroad airlock door when the inner door is opene Corrective Steps Taken And Results Achieved The gaps that were noted to exist consisted of a small section around each rail beneath the outside railroad airlock door These gaps were a result of not replacing the rail seal plates prior to shutting the outside doors, subsequent to moving a rati car into the airloc The rail seal plates are devices that, when placed over the track rails, fill the void between the rail and track be The seal plates vere immediately installed when notified of the condition by the Resident Inspector and the personnel involved counseled about the importance of replacing the rail seal plate Corrective Steps Which Will Be Taken To Py vent Further Violation Two procedures are being generated to prevent recurrenc The Mrst is Surveillance Procedure 6.3.10.17, which was originated on November 14, 1987, and deals with the inspection of eecondary containment penetration The second procedure has also been generated and placed in SORC routing and will provide stacific direction for the operation of the railroad airlock door Steps to verify seal integrity after the opening and closing of a railroad airlock door have been included in the procedur Additionally, to heighten personnel awareness of the concern, the District will fabricate and mount signs on the airlock doors stating: "PRIOR TO SilUTTING EITilER RAILROAD AIRLOCK DOOR, ENSURE TilAT Tile ASSOCIATED RAIL SEAL PLATES ARE INSTALLED".

In the interim period until these pre..dures are approved, a Special Order has been issued by the Division Mr .ia * , of Nuclear Operations designating specific individuals responsible to cor e inate opening and closing the railroad airlock door Date When Full Compliance Will Be Af seved All corrective actions will be completed by March .. 198 _ _ >

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.- - . - U.S. Musicer. Regttlatory Commission  !

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~Jc= ry 26,1983 ,

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If-you have . any questions regarding this response, please contact me or R. Horn at the site. ' A one week extension for submission of this response was granted in a telephone conversation with Region I ,

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Sincerely, l

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./ Y C. A. Trevors

<- Divi 61on Manager

Nuclear Support  ;

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i cci U.S.' Nuclear Regulatory Comunission .

Region IV "

Arlington, TX

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NRC Resident Inspector i

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Cooper Nuclear Station L

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