ML20205G796

Ack Receipt of 870309 Ltr Informing NRC of Corrective Actions Taken Re Violations Discussed in 870213 Notice of Violation.Violation B Not Correctly Stated & Withdrawn. Corrective Actions for Violation a Acceptable

ML20205G796
Person / Time
Site:	Cooper
Issue date:	03/26/1987
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8703310544
Download: ML20205G796 (1)

Text

MAR 2 01987

. .i In Reply Refer To:

Docket: 50-298/87-03 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 March 9,1987, in response to our letter and Notice of Violation dated February 13, 1987. We have reviewed your response and find that it addresses the specific corrective actions apparently necessary.

We also agree that Violatior. B was not correctly stated and agree that your corrective action for Violation A appears to answer the issue raised in Violation B. Accordingly, Violation B is withdrawn, and we shall review your implementation of corrective action relative to Violation A during a future inspection Sincerely, 0: Wrd SI Cned By E. H. Jahrvem Eric H. Johnson, Director Division of Reactor Safety and Projects cc:

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

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Nuclear Regulatory Commission Doucment Control Desk Washington, D.C. 20555

Subject:

NPPD Response to Inspection Report 50-298/87-03 Gentlemen:

This letter is written in response to your letter dated February 13, 1987, transmitting Inspection Report 50-298/87-03. Therein you indicated that certain of our activities were in violation of NRC requirements.

Following is a statement of our violations and our response in accordance with 10CFR2.201.

STATEMENT OF VIOLATION A. Failure to Provide Adequate Procedures Technical Specifications, paragraph 6.3.2, requires, " Written procedures and instructions. . . .shall be established, implemented, and maintained for.... normal startup, operation...."

Contrary to the above procedures S0P 2.2.59, " Plant Air System".

S0P 2.2.60, " Primary Containment Cooling and Nitrogen Inerting System",

and alarm procedure 2.3.2.21A, " Panel 9 Annunciator 9-3-4", were found on January 10, 1987, during a plant startup, not to have been properly revised (maintained) to reflect accurately a plant modification (Design Change 86-36) which required the revision.

This is a Severity Level IV violation. (Supplement I.D.)(298/8703-01)

Reason for the Violation The violation is not completely correct as stated and should be revised as follows:

Contrary to the above, procedures S0P 2.2.59, " Plant Air System".

S0P 2.2.60, " Primary Containment Cooling and Nitrogen Inerting System",

and alarm procedure 2.3.2.21A, " Panel 9.3 - Annunciator 9-3-4", were found on January 10, 1987, during a plant startup, not to have been properly revised (maintained) to reflect accurately the following:

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1. A plant modification (Design Change 86-36) which installed a drywell pneumatic header low pressure alarm.

2. A revised method of purging the drywell to allow Primary Containment inerting without the Standby Gas Treatment (SGT)

System, allowing increased nitrogen purge flows.

3. An operating setpoint change to both of the nitrogen system pressure regulators during the 1986 outage from 150 psig to 110 psig.

The District attributes these procedural deficiencies to the failure of various personnel involved to fully comprehend the synergistic effects of the changes noted above.

Corrective Steps Taken and Results Achieved Additional procedure changes were made to SOP 2.2.59, S0P 2.2.60, and alarm procedure 2.3.2.21A to address drywell pneumatic header pressure concerns during inerting. Additionally, nitrogen system pressure regulators were reset to higher values (140 psig and 145 psig).

Corrective Steps Which Will Be Taken to Prevent Further Violations This event will be reviewed by the Operations Supervisor during meetings routinely conducted with each shif t's crew when they are attending requalification training. Additionally, this event will be reviewed by the appropriate engineering personnel.

Date When Full Compliance Will Be Achieved All necessary procedure changes have been completed. All other corrective actions will be completed by October 1,1987.

STATEMENT OF VIOLATION B. Failure to Follow Procedures Criterion V of Appendix B to 10CFR Part 50 and the licensee's approved Quality Assurance Plan require that activities affecting quality be prescribed by documented procedures and accomplished in accordance with these procedures. Licensee Engineering Procedure 3.4, " Station Design Changes", Revision 4, dated July 2, 1986, requires that design change packages, which are used to control safety-related activities, identify procedures which must be revised as a result of the design change.

Contrary to the above, Design Change 86-36 was found on January 10, 1987, after installation of this change not to identify a major procedure, General Operating Procedure 2.1.1, which required a revision as a result of this change.

This is a Severity Level I" violation. (Supplement I.D.)(298/8703-02)

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' Peg 2 3 Reason for the Violation The violation is incorrect as stated. The apparent violation states that

".... Design Change 86-36 was found on January 10, 1987, after installation of this change, not to identify a major procedure, Operating Procedure 2.1.1, which required revision as a result of this change".

DC 86-36 was implemented to install a pressure switch in the drywell pneumatic supply header. The basis for the design change stems from a District commitment regarding the Hydrogen Recombiner Capability issue and from the existing CNS Emergency Operating Procedures (EOP's) which require the operator to have available positive indication of drywell pneumatic pressure. This positive indication allows the operator to execute certain critical mitigating actions as directed by the applicable E0P.

The requirement to change Operating Procedure 2.1.1 (isolation of backup air to drywell pneumatic system) stems not from DC 86-36, but from the eforementioned regulatory commitment regarding control of combustible gas concentrations in Containment following a LOCA. Accordingly, the necessary change to Procedure 2.1.1 was made on January 2, 1987, eight days before the January 10, 1987, event. However, due to the synergistic effects described in the response to violation 298/8703-1, this change proved to be inadequate. Further corrective procedure changes were implemented subsequent to the January 10, 1987, event to prevent future occurrences.

In summary, the District concludes that, notwithstanding the inadequacies identified by violation 298/8703-1, Design Change 86-36 identified the appropriate station procedures requiring revision.

Furthe rmore , the District concludes that Procedure 2.1.1 did not require revision by DC 86-36. As such, the District feels that consideration should be given to retraction of the apparent statement of violation.

If you have any questions regarding this response, please contact me or G. R. Horn at Cooper Nuclear Station.

LWC

.. KI Trevors Division Manager of Nuclear Support GAT:SSF:ss cc: U.S. Nuclear Regulatory Commission Regional Office, Region IV NRC Resident Inspector Cooper Nuc1 car Station l

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