ML20140D754

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/85-24.Requests Addl Info Re Specific Violations Noted Per 860103 Telcon within 30 Days of Ltr Date

ML20140D754
Person / Time
Site:	Cooper
Issue date:	01/27/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
Shared Package
ML20140D762	List: ML20140D754 ML20140D775
References
NUDOCS 8602030109
Download: ML20140D754 (2)

See also: IR 05000298/1985024

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JAN 2 71526

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In Reply Refer To:

Docket: 50-298/85-24

Nebraska Public Power District

ATTN: J. M. Pilant, Manager, Technical

Staff-Nuclear Power Group

P. O. Box 499

Columbus, Nebraska 68601

Gentlemen:

Thank you for your letter of December 9,1985, in response to our letter

and the attached Notice of Violation dated November 14, 1985. As a result of

our review, we find that additional information, as discussed with your

Messrs. Pilant, Weaver and Trevors during a telephone call on January 3,

1986, is needed. Specifically, we request that you provide information about

the specific violations as indicated below:

Violation 1. We disagree with your statement that the water chemistry

requirement is not effective until the pH exceeds the limits of <5.6 or

>8.6 for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is because we believe that, unless

specifically allowed by Technical Specificatiens, you should not change

to a higher mode of operation unless the limiting conditions of operation

for the new mode can be met. We recognize, however, that the lower pH

limitation of 5.6 is more restrictive than that allowed by standard

Technical Specifications. Therefore, we believe your commitment to

initiate a Technical Specification should not be caveated as "if

required." We request you provide us with your modified response to

violation 1.

Violotion 2. It is not clear from your response whether or not the

policy discussed is a written policy.

Violation 4. It is not clear from your response that training of other

personnel was conducted so that similar violations would not occur in the

future. You are requet,ted to provide information concerning the

training.

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Please provide the supplemental information within 30 days of the date of this

letter.

Sincerely,

os.-jr! Ormd GY,

J. E. GL5i lardo

J. E. Gagliardo, Chief

Rcactor Projects Branch

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

bcc to DMB (IE01)

bcc distrib. by RIV:

RPB Resident Inspector

R. D. flartin, RA Section Chief (RPB/A)

D. Weiss, LFMB (AR-2015 RIV File

RSTS Operator

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APPENDIX A

NOTICE OF VIOLATION

Nebraska Public Power District Docket: 50-298/85-24

Cooper Nuclear Station License: DPR-46

During an NRC inspection conducted during the period August 1-September 30,

1985, violations of NRC requirements were identified. The violations involved

an inadequate procedure, unlocked and unattended safeguards materials storage

files, failure to meet NRC reportability requirements, lack of adherence to

procedures, and inadequate test data reviews. In accordance with the " General

Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,

Appendix C (1985), the violations are listed below:

1. Inadequate Operating Procedure

10 CFR Part 50, Appendix B, Criterion V requires that activities affecting

quality be prescribed by documented instructions or procedures which shall

include appropriate quantitative or qualitative acceptance criteria for

determining that important activities have been satisfactorily

accomplished.

Contrary to the above, CNS Procedure 2.1.1, " Cold Startup Procedure,"

Revision 39, requires licensee personnel to verify that reactor water

chemistry is adequate for startup but does not include criteria for making

that determination.

This is a Severity Level V violation (Supplement I.E)(50-298/8524-01).

2. Unattended and Unlocked Security Records Storage Container

10 CFR Part 73.21(d)(2) requires that unattended safeguards information be

stored in a locked security storage container.

Contrary to the above, licensee security storage containers were left

unlocked and unattended.

This is a Severity Level IV violation (Supplement III.E)(50-298/8524-02).

3. Failure to Meet an NRC Reportability Requirement

10 CFR Part 50.73(a)(2)(ii)(C) requires the licensee to submit a Licensee

Event Report if the nuclear power plant is placed in a condition not

covered by the plact's operating and emergency procedures.

Contrary to the above, the licensee f ailed to submit a Licensee Event

Report to address movement of irradiated fuel that was not properly

supported and grappled. This condition was not covered by plant

procedures.

This is a Severity Level IV violation (Supplement I.D)(50-298/8524-03).

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4. Failure to Perform Surveillance Testing According to Procedure

10 CFR Part 50, Appendix B, Criterion XI requires that all testing

required to demonstrate that systems will perform satisfactorily in

service will be performed in accordance with written test procedures.

Contrary to the above, licensee personnel did not perform testing in

accordance with the requirements of CNS Surveillance Procedure 6.1.3,

"APRM System Excluding 15% Trip Function Test," Revision 12.

This is a Severity Level IV violation (Supplement I.E)(50-298/8524-04).

5. Inadequate Evaluation of Surveillance Test Results

10 CFR Part 50, Appendix B, Criterion XI requires that test results be

documented and evaluated to assure that test requirements have been

satisfied.

Contrary to the above, three licensee persons reviewed Surveillance

Procedure 6.2.4.1, " Daily Surveillance (Technical Specifications),"

Revision 49, without identifying the presence of an incorrect data entry.

This is a Severity Level IV violation (Supplement I.E)(50-298/8524-05).

Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District is

l hereby required to submit to this office, within 30 days of the date of the

letter transmitting this Notice, a written statement or explanation in reply,

including for each violation: (1) the reason for the violations if admitted;

(2) the corrective steps which have been taken and the results achieved;

(3) corrective steps which will be taken to avoid further violations; and

(4) the date when full compliance will be achieved. Where good cause is shown,

consideration will be given to extending the response time.

Dated at Arlington, Texas

this /fdday of /[M ,1985.

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