ML20196F546

Ack Receipt of 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)

See also: IR 05000298/1987028

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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

maintained.

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

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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 50-298/87-28. Therein you indicated that

certain of our activities were in violation of NRC requirements.

Following is a statement of the violati,ns and our response in accordance

w!.th 10CFR2.201.

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

drawings. 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 personnel.

CNS Procedure 2.2.71, "Service Water System". Appendix "A" Valve Checklist

requires Valve SW-195 to be open. 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 repair.

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 position. 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 inspectors.

This is a Severity 1.evel IV violation. (Supplement 1) (298/8728-01)

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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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drain. 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 requirements.

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 System. 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 meetings. 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

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plant equipment needs repair.

Date When Full Compliance Will Be Achieved

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

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Statement of Violation

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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 operation.

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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 ground. This constitutes a failure to

maintain secondary containment integrity.

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

Reason For Violation

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Secondary containment integrity is defined in CNS Technical Specifications

as the Reactor Building being intact and the following conditions being met:

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1. At least one door in each access opening is closed.

2. The Standby Cas Treatment System is operable.

I 3. 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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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

volume.

Given the above, the District cannot definitely conclude that the integrity

of secondary containment had not been maintained. Ilowever, since the potential

did exist, the District has taken action, accordingly.

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 opened.

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 doors. 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 airlock.

The rail seal plates are devices that, when placed over the track rails,

fill the void between the rail and track bed.

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 plates.

Corrective Steps Which Will Be Taken To Py vent Further Violation

Two procedures are being generated to prevent recurrence. The Mrst is

Surveillance Procedure 6.3.10.17, which was originated on November 14, 1987,

and deals with the inspection of eecondary containment penetrations. The

second procedure has also been generated and placed in SORC routing and will

provide stacific direction for the operation of the railroad airlock doors.

Steps to verify seal integrity after the opening and closing of a railroad

airlock door have been included in the procedure.

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 doors.

Date When Full Compliance Will Be Af seved

All corrective actions will be completed by March .. 1988.

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~Jc= ry 26,1983 ,

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If-you have . any questions regarding this response, please contact me or C.

R. Horn at the site. ' A one week extension for submission of this response

was granted in a telephone conversation with Region IV. ,

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- Sincerely, l

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C. A. Trevors

<- Divi 61on Manager

Nuclear Support  ;

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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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