ML20132H269

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/96-23

ML20132H269
Person / Time
Site:	Cooper
Issue date:	12/24/1996
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 9612300034
Download: ML20132H269 (5)

See also: IR 05000298/1996023

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DEC 2 41996

G. R. Horn, Senior Vice President

of Energy Supply

Nebraska Public Power District

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141415th Street

Columbus, Nebraska 68601

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SUBJECT: NRC INSPECTION REPORT 50-298/96-23

Dear Mr. Horn:

Thank you for your letter of December 16,1996,in response to our letter and Notice

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of Violation dated November 12,1996. 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 detr uiine that full compliance has been

achieved and will be maintained.

Sincerely,

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J. E. Dyer, Director

Division of Reactor Projects

Docket No.: 50-298

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License No.: DPR-46

cc:

John R. McPhail, General Counsel

Nebraska Public Power District

P.O. Box 499

Columbus, Nebraska 68602-0499

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P. D. Graham, Vice President of

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Nuclear Energy

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Nebraska Public Power District

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P.O. Box 98

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Brownville, Nebraska 68321

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9612300034 961224

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ADOCK 05000298

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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

Brownville, Nebraska 68321

R. J. Singer, Manager-Nuclear

Midwest Power

907 Walnut Street

P.O. Box 657

Des Moines, Iowa 50303

Mr. Ron Stoddard

Lincoln Electric System

11th and O Streets

Lincoln, Nebraska 68508

Randolph Wood, Director

Nebraska Department of Environmental

Quality

P.O. Box 98922

Linccin, Nebraska 68509-8922

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Chairman

Nemaha County Board of Commissioners

Nemaha County Courthouse

1824 N Street

Auburn, Nebraska 68305

Cheryl Rogers, LLRW Program Manager

Environmental Protection Section

Nebraska Department of Health

301 Centennial Mall, South

P.O. Box 95007

Lincoln, Nebraska 68509-5007

Dr. Mark B. Horton, M.S.P.H.

Director

Nebraska Department of Health

P.O. Box 950070

Lincoln, Nebraska 68509 5007

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Nebraska Public Power District

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R. A. Kucera, Department Director

of intergovernmental Cooperation

Department of Natural Resources

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P.O. Box 176

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Jefferson City, Missouri 65102

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Kansas Radiation Control Program Director

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DEC 2 41996

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L. J. Callan

Resident inspector

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DRP Director

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Branch Chief (DRP/C)

MIS System

Branch Chief (DRP/TSS)

RIV File

Project Engineer (DRP/C)

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

DOCUMENT NAME: R:\\_CNS\\CN623AK.MHM

To receive copy of document, irdcate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

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DEC 2 41996

bec to DMB (IE01)

bec distrib. by RIV:

L. J. Callan

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DRP Director

DRS-PSB

Branch Chief (DRP/C)

MIS System

Branch Chief (DRP/TSS)

RIV File

Project Engineer (DRP/C)

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

DOCUMENT NAME: R:\\_CNS\\CN623AK.MHM

To receive copy of document, indicate in box: "C" = Copy without enclosures

"E" = Copy with enclosures "N" = No copy

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COOPER NUCLE AR ST ATrJN

N Nebraska Public Power District

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P.O. GOX 98. BROWNVILLE. NE BRASKA 68321

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NLS960236

December 12,1996

U.S. Nuclear Regulatory Commission

DEC16

Attention: Document Control Desk

Washington, D.C. 20555-0001

Gentlemen:

Subject:

Reply to a Notice of Violation

NRC Inspection Report No. 50-298/96-23

Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

1. Letter to G. R. Horn (NPPD) from J. E. Dyer (USNRC) dated November 12,

1996, "NRC Inspection Report 50/298/96-23 and Notice of Violation"

By letter dated November 12,1996, (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 District admits to the violation and has completed all corrective actions

necessary to return CNS to full compliance.

Should you have any questions concerning this matter, please contact me.

Since

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P. D. Graham

Vice President - Nuclear

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Attachment

cc: Regional Administrator

USNRC - Region IV

Senior Project Manager

USNRC - NRR Project Directorate IV-1

Senior Resident inspector

USNRC

NPG l)istribution

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Attaclunent I

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Page1 of3

IEPLY TO NOVEMBER 12,1996, NOTICE OF VIOLATION

COOPER NUCLEAR STATION

NRC DOCKET NO. 50-298, LICENSE DPR-46

During NRC inspection activities conducted from September 8,1996, through October 19,1996,

one violation of NRC requirements was identified. The particular violation and the District's

reply are set forth below:

Violation

10 CFR Part 50.65, "Requirementsfor Afonitoring the Effectiveness ofAlaintenance at

Nuclear Power Plants, " as described in 10 CFR 50.65(a)(2) states, in part, that monitoring

under (a)(1) is not required where it has been demonstrated that the pe-formance or

condition ofa structure, system or component has been effectively controlled through the

performance ofappropriate preventive maintenance ofthe structure, system, or component

and that the structure, system or component remains capable ofperforming its intended

function.

Regulatory Guide 1,160, "Afonitoring the Effectiveness ofAfaintenance at Nuclear Power

Plants, " Revision 1, January 1995, endorses NUMARC 93-01, " Industry Guidelinesfor

Afonitoring the Effectiveness ofAlaintenance at Nuclear Power Plants, " as an acceptable

methodfor implementing the requirements of10 CFR 50.65. Regulatory Guide 1.160 states

that the methods described in the guide will be used in the evaluation ofthe effectiveness of

maintenance activities by licensees who are required to comply with 10 CFR 50.65 unless a

licensee hasproposed an acceptable alternative methodfor compliance. The licensee

subscribed to the NUAfARC 93-01 methodology in Administrative Procedure 0.27,

"Afaintenance Rule Program, " Revision 1, Section 2.2, which stated, in part, thisprocedure

provides guideline methodology to ensure compliance with 10 CFR 50.65 criteria by

incorporating NUAfARC 93-01.

NUAfARC 93-01, Section 9.3.2, states, inpart, that performance criteriafor risk sigmficant

structures, systems, and components should be established to assure reliability and

availability assumptions used in the plant-specific probabilistic risk assessment, individual

plant examination, or other risk determining analysis are maintained or adjusted when

necessary.

Procedure 0.27, Step 4.11, states, in part, that the Operations department is responsiblefor

reco',ni:mg the impact on the Afaintenance Rule Program with regard to risk sigmficance

and unavailability when taking equipment out ofservice, recording out-of; service time, and

recording return-to-service time.

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Attachment I

to NLS960236

Page 2 of 3

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Contrary to the above:

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On October 2,1996, whileperforming Surveillance Procedure 6.1 ADS 303, "ADSLogic

Functional Test (Div 1), " Revision 1, the control room crewplaced both Trains A and B of

the automatic depressurization system in the inhibitpositions but recorded only Train A out-

of-service and return-to-service timesfor unavailability evaluation with respect to the

klaintenance Rule.

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This is a Severity Level IV violation (Supplement 1) (298/96023-01).

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Adaliscion or Denial to Violation

The District admits the violation.

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Reason for Violation

As detailed below, this violation is a result of a weakness associated with the application of

Allowed Out-of-Service Times (AOTs) for accumulating unavailability for risk significant

functions under the CNS Maintenance Rule Program.

Allowed Out-of-Service Times are used withm the CNS Surveillance Testing Program to address

operability of equipment required by the CNS Technical Specifications during testing. They are

based on reasonable out-of-service times required to perform the testing and focus on the out-of

service time of the affected system as opposed to individual components or steps within the

procedure. Accordingly, the AOT logs do not require documentation of all components made

unavailable within an existing AOT window. While this approach is adequate to satisfy the

requirements of the Surveillance Testing Program, it does not fully satisfy the requirements for

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accumulating unavailability under the Maintenance Rule Program.

A contributing factor to this violation is the ambiguity of Procedure 0.27," Maintenance Rule

Program." relative to the program requirements for accumulating unavailability for risk

significant functions.

Corrective Steps Taken and the Results Achieved

Each surveillance procedure that affects the operability of equipment controlled by the CNS

Technical Specifications has an associated AOT tracking sheet (or log). Accordingly, the AOT

tracking sheets for both Surveillance Procedures 6.l ADS.303," ADS Logic Functional Test (Div

1)," and 6.2 ADS.303, " ADS Logic Functional Test (Div 2)," have been modified to reflect the

fact that both Train A and Train B of the automatic depressurization system (ADS) are rendered

unavailable during performance of these procedures.

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Attaclunent 1

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Page 3 of 3

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in addition, the unavailability accumulated for ADS Trains A and B have been adjusted to

account for the error. (While the second train was inhibited only 6 seconds per surveillance on

the average, the full unavailability recorded since January 1996 for Train A as a result of

Procedure 6.1 ADS.303 has been conservatively added to the unavailability accumulated for

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Train B and vice versa for Procedure 6.2 ADS.303.) This did not result in either of the trains

approaching their unavailability performance criteria limits.

Corrective Steps That Will Be Taken to Avoid Further Violations

Other surveillance procedures monitored under the AOT program will be reviewed to ensurelhat

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the requirements of the Maintenance Rule Program are being met with respect to the

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accumulation of unavailability for risk significant functions. This review will be completed by

January 24,1997. To minimize the potential for a repeat violation prior to the completion of this

review, appropriate operations personnel have been sensitized to this issue. Further, Procedure

0.27, " Maintenance Rule Program," will be revised to clarify the program requirements for

accumulating unavailability for risk significant functions. This revision will be implemented by

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February 7,1997.

Date When Full Comnliance Will Be Achieved

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The District has completed all corrective actions necessary to return CNS to full compliance with

respect to the identified violation.

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ATTACHMENT 3

LIST OF NRC COMMITMENTS

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Correspondence No: NLS960236

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 Licensing Manager

at Cooper Nuclear Station of any questions regarding this document or any associated

regulatory commitments.

COMMITTED DATE

COMMITMENT

OR OUTAGE

Other surveillance procedures monitored under the AOT

program will be reviewed to ensure that the requirements

January 24, 1997

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of the Maintenance Rule Program are being met with

respect to the accumulation of unavailability for risk

significant functions.

Procedure 0.27, " Maintenance Rule Program," will be

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revised to clarify the program requirements for

February 7,

1997

accumulating unavailability for risk significant

functions.

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PROCEDURE NUMBER 0.42

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REVISION NUMBER 1.2

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PAGE 8 OF 10

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