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| | number = ML20140F286 | | | number = ML20140F286 |
| | issue date = 04/29/1997 | | | issue date = 04/29/1997 |
| | title = Responds to NRC 970331 Ltr Re Violations Noted in Insp Rept 50-298/97-02.Corrective Actions:Revised Procedure 7.3.1.6 to Address Deficiencies,Held Site Standown for Procedural Use & Adherence & Clarified Procedure 7.0.4 | | | title = Responds to NRC Re Violations Noted in Insp Rept 50-298/97-02.Corrective Actions:Revised Procedure 7.3.1.6 to Address Deficiencies,Held Site Standown for Procedural Use & Adherence & Clarified Procedure 7.0.4 |
| | author name = Graham P | | | author name = Graham P |
| | author affiliation = NEBRASKA PUBLIC POWER DISTRICT | | | author affiliation = NEBRASKA PUBLIC POWER DISTRICT |
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| | contact person = | | | contact person = |
| | document report number = NLS970077, NUDOCS 9705020224 | | | document report number = NLS970077, NUDOCS 9705020224 |
| | | title reference date = 03-31-1997 |
| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE |
| | page count = 6 | | | page count = 6 |
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| ==Reference:== | | ==Reference:== |
| : 1. Letter to G. R. Horn (NPPD) from T. P. Gwynn (USNRC) dated March 31, 1997,"NRC Inspection Report 50-298/97-02 and Notice of Violation" By letter dated March 31,1997 (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 violations and has completed all corrective actions necessary to return CNS to full compliance. | | : 1. Letter to G. R. Horn (NPPD) from T. P. Gwynn (USNRC) dated March 31, 1997,"NRC Inspection Report 50-298/97-02 and Notice of Violation" By {{letter dated|date=March 31, 1997|text=letter dated March 31,1997}} (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 violations and has completed all corrective actions necessary to return CNS to full compliance. |
| Should you have any questions concerning this matter, please contact me. | | Should you have any questions concerning this matter, please contact me. |
| I Sincerely, PBM P. D. Graham Vice President of Nuclear Energy | | I Sincerely, PBM P. D. Graham Vice President of Nuclear Energy |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217G7401999-10-14014 October 1999 Forwards MOR for Sept 1999 for Cooper Nuclear Station. Rept Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20216J8061999-09-20020 September 1999 Forwards Rev 37 to Safeguards Plan,Iaw Provisions of 10CFR50.(p).Rev Withheld,Per 10CFR73.21 ML20212C4921999-09-15015 September 1999 Forwards Monthly Operating Rept for Aug 1999 for Cooper Nuclear Station.Rept Includes Operating Data Rept,Unit SD Rept & Documentation of Challenges to Safety/Relief Valves ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211N5271999-09-0202 September 1999 Responds to NRC 990823 RAI Re Y2K Readiness at Cooper Nuclear Station,Per GL 98-01,Suppl 1 05000298/LER-1999-006, Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl1999-08-26026 August 1999 Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl ML20211F1311999-08-24024 August 1999 Forwards Rev 1 to Calculation Nedc 97-044, NPSH Margins for RHR & CS Pumps, in Support of 990615 Proposed Amend to DPR-46 Re Containment Overpressure Contribution to ECCS Pumps NPSH Requirements 05000298/LER-1999-003, Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel1999-08-23023 August 1999 Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20210R0301999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Cooper Nuclear Station,Iaw Guidance Provided by GL 97-02.Rept Also Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6761999-08-10010 August 1999 Requests That Following Changes Be Made to Distribution on NRC Correspondence ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K6071999-08-0202 August 1999 Submits Withdrawal of Proposed License Amend Re Secondary Containment Isolation Description & Refueling Accident Analysis Results ML20210K3811999-08-0202 August 1999 Forwards Listed Info,Which NPPD Believes Demonstrates Ability to Obtain Funds in Amount of $10 Million for Payment of Such Premiums within Specified Three Month Period,Iaw 10CFR140.21 ML20210G5101999-07-28028 July 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 990101-0630,per Provisions of 10CFR26.71(d) ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20209B7851999-07-0101 July 1999 Forwards Corrected Occupational Radiation Exposure Repts, for Cys 1996 & 1997.Util Stated That Repts Did Not Properly Tabulate Number of Personnel Receiving Exposures Less than 100 Mrem by Work & Job Functions in CY96 & CY97 05000298/LER-1999-005, Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl1999-07-0101 July 1999 Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, 05000298/LER-1999-004, Forwards LER 99-004-01.Commitments Made by Util Are Encl1999-06-28028 June 1999 Forwards LER 99-004-01.Commitments Made by Util Are Encl ML20209B5451999-06-28028 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196H0331999-06-24024 June 1999 Informs NRC of Deletion of 1991 Commitment Contained in Ltr Re Feedwater Nozzle Bypass Leakage Monitoring at Plant ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20209A7221999-06-23023 June 1999 Submits Revised Pages to Proposed Change to Plant TS Previously Submitted in ,Per 990615 Telcon with NRC ML20196F5331999-06-22022 June 1999 Forwards Examination Summary Rept for FW Nozzle Examinations Performed During 1998 Fall Refueling Outage at Cooper Nuclear Station.Rept Covers Past Examinations Up to & Including 1998 Fall Refueling Outage ML20196B4681999-06-17017 June 1999 Forwards TS Bases Changes Made at Plant Subsequent to Receipt of License Amend 178,dtd 980731,for Conversion to Its,Through 990610.List of Effective Pages for TS Bases, Encl ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195H8891999-06-14014 June 1999 Forwards Response to NRC 990315 RAI Re GL 95-07, Pressure Locking & Thermal-Binding of SR Power-Operated Gate Valves, 180-day Response Submitted by District on 960213 ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20195E2351999-06-0808 June 1999 Forwards Response to NRC 990517 RAI Re Util Proposed Change to TS Re Calibr Frequency of Reactor Recirculation Flow Transmitters Associated with APRM ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217G7401999-10-14014 October 1999 Forwards MOR for Sept 1999 for Cooper Nuclear Station. Rept Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20216J8061999-09-20020 September 1999 Forwards Rev 37 to Safeguards Plan,Iaw Provisions of 10CFR50.(p).Rev Withheld,Per 10CFR73.21 ML20212C4921999-09-15015 September 1999 Forwards Monthly Operating Rept for Aug 1999 for Cooper Nuclear Station.Rept Includes Operating Data Rept,Unit SD Rept & Documentation of Challenges to Safety/Relief Valves ML20211N5271999-09-0202 September 1999 Responds to NRC 990823 RAI Re Y2K Readiness at Cooper Nuclear Station,Per GL 98-01,Suppl 1 05000298/LER-1999-006, Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl1999-08-26026 August 1999 Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl ML20211F1311999-08-24024 August 1999 Forwards Rev 1 to Calculation Nedc 97-044, NPSH Margins for RHR & CS Pumps, in Support of 990615 Proposed Amend to DPR-46 Re Containment Overpressure Contribution to ECCS Pumps NPSH Requirements 05000298/LER-1999-003, Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel1999-08-23023 August 1999 Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel ML20210R0301999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Cooper Nuclear Station,Iaw Guidance Provided by GL 97-02.Rept Also Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20210P6761999-08-10010 August 1999 Requests That Following Changes Be Made to Distribution on NRC Correspondence ML20210K6071999-08-0202 August 1999 Submits Withdrawal of Proposed License Amend Re Secondary Containment Isolation Description & Refueling Accident Analysis Results ML20210K3811999-08-0202 August 1999 Forwards Listed Info,Which NPPD Believes Demonstrates Ability to Obtain Funds in Amount of $10 Million for Payment of Such Premiums within Specified Three Month Period,Iaw 10CFR140.21 ML20210G5101999-07-28028 July 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 990101-0630,per Provisions of 10CFR26.71(d) 05000298/LER-1999-005, Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl1999-07-0101 July 1999 Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl ML20209B7851999-07-0101 July 1999 Forwards Corrected Occupational Radiation Exposure Repts, for Cys 1996 & 1997.Util Stated That Repts Did Not Properly Tabulate Number of Personnel Receiving Exposures Less than 100 Mrem by Work & Job Functions in CY96 & CY97 05000298/LER-1999-004, Forwards LER 99-004-01.Commitments Made by Util Are Encl1999-06-28028 June 1999 Forwards LER 99-004-01.Commitments Made by Util Are Encl ML20209B5451999-06-28028 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196H0331999-06-24024 June 1999 Informs NRC of Deletion of 1991 Commitment Contained in Ltr Re Feedwater Nozzle Bypass Leakage Monitoring at Plant ML20209A7221999-06-23023 June 1999 Submits Revised Pages to Proposed Change to Plant TS Previously Submitted in ,Per 990615 Telcon with NRC ML20196F5331999-06-22022 June 1999 Forwards Examination Summary Rept for FW Nozzle Examinations Performed During 1998 Fall Refueling Outage at Cooper Nuclear Station.Rept Covers Past Examinations Up to & Including 1998 Fall Refueling Outage ML20196B4681999-06-17017 June 1999 Forwards TS Bases Changes Made at Plant Subsequent to Receipt of License Amend 178,dtd 980731,for Conversion to Its,Through 990610.List of Effective Pages for TS Bases, Encl ML20195H8891999-06-14014 June 1999 Forwards Response to NRC 990315 RAI Re GL 95-07, Pressure Locking & Thermal-Binding of SR Power-Operated Gate Valves, 180-day Response Submitted by District on 960213 ML20195E2351999-06-0808 June 1999 Forwards Response to NRC 990517 RAI Re Util Proposed Change to TS Re Calibr Frequency of Reactor Recirculation Flow Transmitters Associated with APRM ML20207A0701999-05-19019 May 1999 Forwards Rev 3 to CNS Strategy for Achieving Engineering Excellence, Which Provides Effective Tool for Overall Engineering Work Mgt.Commitments Made by Util,Encl ML20206R7601999-05-17017 May 1999 Forwards Annual Radiological Environ Rept,Radiological Environ Monitoring Program,Jan-Dec 1998,per TS 5.6.2 ML20206P9681999-05-13013 May 1999 Forwards Monthly Operating Rept for Apr 1999 for Cooper Nuclear Station.Rept Includes Documentation of Challenges to Safety/Relief Valves ML20206J0741999-05-0404 May 1999 Forwards Rev 14 to CNS QA Program for Operation, Per 10CFR50.54(p) & 10CFR50.71.None of Changes Represent Reduction of Commitments.Summary of Changes,Encl ML20206J2331999-05-0303 May 1999 Forwards CNS Annual Radioactive Effluent Release Rept for 1998 & Offsite Dose Assessment Manual ML20206F2021999-04-30030 April 1999 Informs That NPPD Now Anticipates LAR Committed in Will Be Submitted by 990615.Operability Evaluations Presently in Effect Ensure That ECCS Pumps Are Operable But Nonconforming & Are Capable of Fulfilling Safety Functions ML20206E5461999-04-29029 April 1999 Forwards Cooper Nuclear Station Occupational Radiation Exposure Rept for 1998. Numbers Reported Reflected Tabulation of All Personnel on Site by Work & Job Function. Repts Will Be Corrected & Resubmitted by 990701 ML20205K1151999-04-0101 April 1999 Submits Extension of Commitment Date for Rev to Plant Strategy for Achieving Engineering Excellence from 990331 to 990519.Licensee Requires Addl Time to Finalize & Approve Rev 3 to Plant Strategy for Achieving Engineering Excellence ML20205E4331999-03-31031 March 1999 Forwards First Biennial Rept of Financial Assurance for Decommissioning for Cns,Per 10CFR50.75(f)(1) ML20205A0561999-03-23023 March 1999 Provides Info Detailing Property Insurance Coverage Maintained by NPPD & Midamerican Energy Co for Cns,In Compliance with 10CFR50.54(w)(3) 05000298/LER-1999-001, Forwards LER 99-001-00,including List of NRC Commitments Made by Util1999-03-22022 March 1999 Forwards LER 99-001-00,including List of NRC Commitments Made by Util ML20204G8811999-03-22022 March 1999 Forwards CNS Inservice Insp Summary Rept,Fall 1998 Refueling Outage (RFO-18), IAW Provisions of 10CFR50.55a. Analytical Evaluation for RPV Shell Weld Indications & Augmented Exam Results of RPV Also Included ML20204J4841999-03-19019 March 1999 Requests NRC Review & Approval of CNS ISI Relief Request (RR) PR-04,rev 1.ISI RR PR-04,rev 0 Required CNS to Perform Visual Insp of RPV Head Flange Seal Leak Detection Line. Approval Is Required Because Test Methodology Was Changed 05000298/LER-1998-013, Forwards LER 98-013-01 Re Missed Surveillance of Secondary Containment Isolation Valve.List of NRC Commitments Encl1999-03-16016 March 1999 Forwards LER 98-013-01 Re Missed Surveillance of Secondary Containment Isolation Valve.List of NRC Commitments Encl ML20204C9641999-03-15015 March 1999 Forwards Monthly Operating Rept for Feb 1999 for Cooper Nuclear Station.Rept Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20207J5811999-03-10010 March 1999 Forwards Rev 1 to Calculation Nedc 98-024, APRM - RBM Setpoint Calculation ML20207F9661999-03-0101 March 1999 Responds to NRC Re Violations Noted in Insp Rept 50-298/98-08.Corrective Actions:Circumstances Surrounding Four Examples Have Been Discussed with Individuals Involved & Counseled,Where Appropriate ML20203C6961999-02-0808 February 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 980701-1231,per 10CFR26.71(d) ML20202H6721999-02-0202 February 1999 Informs of Changes in Schedule Affecting Four Commitments in ,By Greater than One Month & Notifies of Plans to Issue Rev 3 to Strategy for Achieving Engineering Excellence ML20202E2231999-01-28028 January 1999 Forwards Response to NRC 980603 RAI Re NRC Ongoing Review of IPEEE for Cooper Nuclear Station,Submitted 961030 ML20199K6721999-01-19019 January 1999 Requests Extension of Present Due Date to 980202,as Addl Time Is Required to Resolve Issues Raised on Corrective Actions During Senior Mgt Review of Insp Rept 50-298/98-15 05000298/LER-1998-011, Forwards LER 98-011-00,per 10CFR50.73(a)(2)(v).Commitments Made by Util,Encl1999-01-19019 January 1999 Forwards LER 98-011-00,per 10CFR50.73(a)(2)(v).Commitments Made by Util,Encl ML20199E6281999-01-14014 January 1999 Forwards Monthly Operating Rept for Dec 1998 for Cooper Nuclear Station.Rept Also Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20206P4171998-12-31031 December 1998 Informs of Extended Completion Due Date of Third Commitment Re EOP Calculations,Per Licensee 980723 Response to Violations Noted in Insp Rept 50-298/98-02.Date Has Been Extended to 990228 ML20199D2251998-12-30030 December 1998 Forwards 1998 CNS Simulator Certification Rept,As Required by 10CFR55.45.Rept Describes Performance Tests Conducted from 1995-98,discusses Performance Test Discrepancies from 1995-98 & Provides Revised Test Plan for 1999-2002 ML20198K2491998-12-23023 December 1998 Discusses RAI Re Response to NRC GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps ML20205A4411998-12-17017 December 1998 Forwards Initial Exam Outline for RO Written Exam to Be Given Week of 990208.Preliminary Copies of License Applications for Candidates Encl ML20196C4011998-11-20020 November 1998 Forwards Rev 1 to Cooper Nuclear Station COLR Cycle 19. Licensee Discovered That COLR Submitted with Contained Incorrect Max Average Planar Linear Heat Generation Rate Curves Specified in Figures 1 to 4 1999-09-20
[Table view] |
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6 F P.O. BOX B NC 68M1 Nebraska Public Power District
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NLS970077 April 29,1997 l
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/97-02 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. Letter to G. R. Horn (NPPD) from T. P. Gwynn (USNRC) dated March 31, 1997,"NRC Inspection Report 50-298/97-02 and Notice of Violation" By letter dated March 31,1997 (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 violations and has completed all corrective actions necessary to return CNS to full compliance.
Should you have any questions concerning this matter, please contact me.
I Sincerely, PBM P. D. Graham Vice President of Nuclear Energy
/nr '
Attachment ec: Regional Administrator USNRC - Region IV r J I
Senior Proj.ect Manager s USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution
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l Attachment I to NLS970077 l
Page1of4 REPLY TO MARCil 31,1997, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 During NRC inspection activities conducted from January 12, through February 22,1997, two violations of NRC requirements were identified. The particular violations and the District's reply are set forth below:
Violation Criterion V ofAppendix B to 10 CFR Part 50 requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, ofa type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above on February 4,1997, the inspectors determined that Procedure 7.3.1.6, "125/250v Station Battery Charger Protective Relays Testing and Calibration, "
Revision 7, was not properly implemented. Inparticular: (1) Section 4 ofProcedure 7.3.1.6 contained a note requiring the performance ofan action, which was notperformed until addressed by the inspector after completion ofsubsequent steps; (2) Section 4 did not contain instructions on the method to determine the asfbund condition ofa relay ifit was outside its calibration range, which caused technicians to perform actions not stated in the procedure; and (3) the procedure incorrectly stated the test position ofa relay contact and the techniciansfailed to recogni:e this during at least three performances ofthisprocedure.
Admission or Denial to Violation The District admits the violation.
Reason for Violation On February 4,1997, MWR 97-0168 was performed for replacement of a battery charger relay.
The MWR instructions required the as-found values for the old relay be determined using Procedure 7.3.1.6,"125/250 VDC Station Battery Charger Protective Relays Testing and Calibration," Revision 7. Procedure 7.3.1.6 was not appropriate to the circumstances in that three problems were noted during performance of this procedure:
- 1) A note preceding step 4.1 required an action to be performed. The actions that satisfy the instructions in steps 4.1 and 4.2 were performed during the installation of the battery charger relay and were therefore, not performed during the testing being performed in section 4 of procedure 7.3.6.1. Ilowever, following review, it was determined that the procedure was inconsistent with the Procedure Writer's Guide (PWG). Per the PWG, notes are to provide information only. The subject note in Procedure 7.3.1.6 contained instructional steps.
4 Attachment I to NLS970077 Page 2 of 4
- 2) Step 4.7 required that the voltage be increased until the relay closed. Since the relay was already closed, to determine the as-found condition, the electrician decreased the voltage until the relay opened then increased the voltage until the relay closed. While these actions determined the as-found condition, the procedure did not contain any steps specifying the actions the electrician performed.
- 3) Step 4.15 required decreasing voltage until the relay contact opens, instead of until the relay contact closes which was in error. While the error was corrected prior to completion of the procedure, the procedure had been previously completed without the error being corrected, contrary to management expectations that errors be corrected prior to continuing. Note that this scenario is inconectly characterized in Inspection Report 97-02 (Section M3.l(b), page
- 8) in that it implies the relay is initially open.
i The reason for this violation is that management failed to establish and reinforce a rigorous approach to procedure adherence within the Maintenance Department resulting in a culture that has used " skill of the crafr' as a work around for procedural deficiencies.
, Corrective Stens Taken and the Results Achieved Procedure 7.3.1.6 was revised to address the deficiencies noted above.
Additionally, a CNS site standown for procedural use and adherence was held in March 1997. ,
The issue of procedural adherence was given a top management priority, becoming one of the l principal CNS alignment issues. To address the continuing procedural adherence problems at !
Cooper, several actions were taken which included:
a focus group was established to address the magnitude of problem and establish a plan to address procedural adherence, a talking point paper for managers, supervisors, and leads was developed and presented to station managers, supervisors and lead personnel, ,
I a site-wide procedure adherence pre-test was administered to establish a baseline and l determine where improvements needed to be made, site personnel were provided with training sessions on procedural adherence, and; personnel were then re-examined and those not passing the test by receiving a score of 100%
were immediately remediated before returning to work.
Maintenance management continues to monitor and reinforce Maintenance procedural compliance and in addition to the corrective actions discussed in response to the second violation, management expectations for maintaining a questioning attitude regarding procedural inadequacies and noncompliance has been disseminated to Maintenance Department personnel.
1 Attachment I to NLS970077 Page 3 of 4 Corrective Steps That Will Be Taken to Avoid Further Violations Performance in this area will be monitored through the performance indicators also established in the response to the second violation.
Date When Full Comnliance Will Be Achieved The District is currently in full compliance with respect to the identified violation.
Violation l
Criterion XVI ofAppendix B to 10 CFR Part 50 requires that conditions adverse to quality, such asfailures, malfimetions, deficiencies, deviations, defective material and equipment, and[nonconfhrmances] are promptly identified and corrected. In the case ofsignificant conditions adverse to quality, thc measures shall assure that the cause ofthe condition is ,
determined and corrective action taken to preclude repetition.
Procedure 0.5, " Problem Identification and Resolution, " Revision 8, Step 14,13.1, reqwres {
that any individual aware ofa problem that is orpotentially could be a condition adverse to l
quality is responsiblefor initiating a problem identification report. Step 1 states, in part,
{
that this procedure provides instructionsfor identification ofproblems and includes significant conditions adverse to quality as defined in 10 CFR Part 50, Appendix B. j Contrary to the above, on February 6,1997, the inspectors determined that the licensee failed to enter into the problem identification reportprocess three examples ofafailure to '
properly implement Procedure 7.3.1.6.
Admission or Denial to Violation The District admits the violation.
Reason for Violation The discussion in response to the first violation identified examples of procedural deficiencies which should have been immediately documented in the CNS Corrective Action Program (CAP) through the use of Procedure 0.5," Problem Identification and Resolution," when identified by the electricians. This is a failure to provide clear expectations for when a PIR is to be initiated.
At the time of this violation, there was a common misunderstanding within the Maintenance Department as to what discrepancies require initiation of a Discrepancy Resolution Sheet versus a Problem Identification Report (PIR). Although CNS Procedure 7.0.4," Conduct of Maintenance," provided instructions for the use of Discrepancy Sheets, including documentation requirements when PIRs are warranted, Procedure 7.0.4 did not explicitly restate the general requirements of Procedure 0.5.
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I Attachment I to NLS970077 Page 4 of 4 Corrective Stens Taken and the Results Achieved 1
- 1) Procedure 7.0.4 was clarified to require all problems that could be adverse to quality to be 'j addressed by a PIR. j l
- 2) The Maintenance Manager has articulated and clarified his expectations for PIR initiation to all Maintenance personnel. This expectation has also been applied to historical issues that should have resulted in generation of a PIR.
- 3) A more consistent set of criteria was established and provided to maintenance personnel. i Performance indicator (s) have been developed to monitor compliance with Procedures 7.0.4 and ;
0.5 and, as discussed in the response to the first violation, for procedural inadequacies. !
Preliminary results of these corrective actions show a prompt improvement in maintenance self-
)
identification of conditions adverse to quality through the use of PIRs, but lack sufficient data to '
indicate a long-term trend.
Corrective Stens That Will Be Taken to Avoid Further Violations Maintenance management will continue to monitor compliance with Procedures 7.0.4 and 0.5 through the use of performance indicator (s) based on procedural adherence and procedural inadequacies. It is anticipated that adequate data to indicate trends in these areas will be available by July 1,1997.
Date When Full Comnliance Will Be Achieved The District is currently in full compliance with respect to the identified violation.
l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: NLS970077 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 Maintenance management will continue to monitor compliance with procedures 7.0.4and 0.5 through the use July 1, 1997 of performance indicator (s) based on procedural adherence and procedure inadequacies.
d l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l 1