IR 05000298/1997013

Ack Receipt of 971014 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-298/97-13 on 970912

ML20199B375
Person / Time
Site:	Cooper
Issue date:	11/13/1997
From:	Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
50-298-97-13, NUDOCS 9711180291
Download: ML20199B375 (5)

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i November 13,1997 G. R. Horn, Senior Vice President--

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Nebraska Public Powar Dietrict 141415th Street Columbus, Nebraska 68601 ,

' SUBJECT: RdSPONSE TO NRC NOTICE OF VIOLATION (INSPEC s .ON REPORT 50-298/97 13)

Dear Mr. Horn:

' Thank you fet your letter of October 14,1997, in response to our September 12,1997,'-

letter and Notice of Violation concerning a f ailure to initiate a problem identification and resolution report foi a test on the automatic depressurization system. We have ieviewed your reply, and additional information discussed with Mr. Mike Peckham, Plant Manager, and members of your staff, during a telephone call on October 28,1997.

Inspection Report 50-298/96 31 and followup resident reports have identified f ailures to document conditions adverse to quality according to the problem identification end resolution .eport process. During the telepho s call, your staff clarified that a historical review for determining generic implications from the failure to initiate a problem identification resolution report is included within the scope of a problem resolution team comprised of plant staff and contracted personnel.

We find your respon::e and specifically, the clarification on a historical review for determining any generic implicatiom which may have resulted from the failure to initiate a problem identification and resolution report, as a sufficient response 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 'ull compliance has been achieved and will be maintained.

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Sincerely,

-r6 (, . D v, Dr. Dale A. Powers, Chief Maintenance Branch Division of Reactor Safety 7 {

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Docket No.: 50 298-License No.: DPR 46 ;

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' John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 -

Columbus, Nebraska 68602-0499 P. D Graham, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98

Brownville, Nebraska 68321

- B. L. Houston,- Nuclear Licensing and Safety Manager Nebraska Public Power District

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' P.O. Box 98 Brownville, Nebraska 68321 Dr. William D. Leech MidAmerican Energy 907 Walnut Street P.O. Box 657 Des Moines,' lowa 50303 0657 Mr. Ron Stoddard

Lincoln Electric System 11th and O Streets

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Lincoln, Nebraska 68508 Randolph Wood, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, Nebraska 68509-8922

' Chairman -

~ Nemaha County Board of Commissioners Nemaha Countv Courthouse -

1824 N Street A'uburn, Nebraska ' 68305 :

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Nebraska Public Power District 3-Cheryl Rogers, LLRW Program Manager Environmental Protection Section Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 R. A. Kiscera, Department Director of Int <,rgovernmental Cooperation Department of Natural Resources

' P.O. Box 176 Jefferson City, Missouri 65102 Kansas Radiation Control Program Director

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Nebraska Public Power District -4-E-Mail report to T. Frye (TJF)

E-mail report to T. Hiltz (TGH)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (lE01)

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Regional Administrator DRP Director Project Engineer (DRP/C)

DRS Director Resident inspector DRS Deputy Director DRS PSB Branch Chief (DRP/C) MIS System Branch Chief (DRP/TSS) RIV File DRS ACTION ITEM NO: 97-G-0117 DOCUMENT NAME: R:\_,CNS\CN713AK.PCG To receive copy of document. Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV: SRI:MB & N C:MB E l PCGagellmb ~ DAPowers f('

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4ebraska Public Power District -4-E Mail report to T. Frye (TJF) i E-mail report to T. Hiltz (TGH) I

' E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (IE01)

bec distrib. by RIV:

Regional Administrator DRP Director Project Engineer (DRP/C)

DRS Director Resident inspector DRS Deputy Director DRS-PSB Branch Chief (DRP/C) MIS System Branch Chief (DRP/TSS) RIV File DRS ACTION ITEM NO: 97-G 0117 DOCUMENT NAME: R:\_CNS\CN713AK.PCG To receive copy of docurnent, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV: SRI:MB W N C:MB E l l PCGage/tmb ~ DAPowers 10!Jy97 10A%97 OFFICIAL RECORD COPY l

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NLS970179 -@ 0 0 Si f.5 l7 3 ~!l I!

October 14,1997 .. OCT2 0m 3 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

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Gentlemen:

Subject: Reply to a Notice of Violation NRC Inspection Report No. 50-298/97-13 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 Reference: 1. Letter to G. (NPPD) from A. T. Howell III (USNRC) dated September 12,1997,"NRC Inspection Report 50-298/97-13 and Notice of Violation" By letter dated September 12,1997 (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 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.

Sincerely, P&nuk P. D. Grahain Vice President of Nuclear Energy

/rar Attachment cc: Regional Administrator USNRC - Region IV l

Senior Project Manager l USNRC - NRR Project Directorate IV-1 93-Ol'i-D

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NLS970179 October 14,1997 Page 2 of 2 Senior Resident Inspector USNRC NPG Distribution

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i REPLY TO SEPTEMBER 12,1997, NOTICE OF VIOLATION

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COOPER NUCLEAR STATION  ;

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

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During NRC inspection activities conducted from July 28,1997, through August 14,1997,one violation of NRC requirements was identified? The particular violation and the District's reply are i

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set forth below:

Violation TechnicalSpect) cation 6.3.2, states, inpart, that writtenprocedures andinstructions shall

- he established, implemented, and maintainedfor thefollowing: ...B. Actions to be taken to correct specific ... malfunctions ofsafety-related systems or components. <

. Surveillance Prccedure 6. LADS.301, " ADS Reactor Pressure Permissive Calibration and

. Function and Logic Tests (Reactor in Run) (Div 1), " Revision 1, Step 8.27, states, in part, that test personnel are to connect a meter to read resistance and venfy the contacts are closed, i

Administrative Procedure 0.5, " Problem Idents) cation arulResolution, " Revision 8, Section 14.2, requires, inpart, that allpersonnelare responsiblefor reportingproblems that are, or potentially could be, conditions adverse to quality through the process of this procedure.

Contrary to the above, on July 23,1997, the licenseefailed to write a problem identspcation and resolution reportfor a knownfailure tofollow a safety-relatedprocedure. Specifically, duringperformance ofStep 8.27 ofSurveillance Procedure 6. LADS.301, when contacts were faimd open rather 6ais closed, testpersonnel raised the testpressure (which closed the contacts), and thenproceeded with the test without reporting this condition in a problem - ,

identspcation amiresolution report. '

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1his is a Severity LevelIV violation (Supplement 1)(298/9317-02).

Admission or Denial to Violation

The District admits the violation.

Reason for Violation The failure to generate a Problem Identifict. tion Report (PIR)is a procedural adherence problem.

- Administrative Procedure 0.5," Problem Identification and Resolution," contains the appropriate requirements with respect to initiation of a PIR; however, strict compliance with the Procedure

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Attachment I to NLS970179 Page 2 of 3 0.5 was not enforced by supervision. The failure to meet procedural conditions stated in Procedure 6.l ADS.301 was recognized and documented on a Discrepancy Sheet per Administratise Procedure 0.26, " Surveillance Progiam." However, the action plan to resolve the immediate condition created a " sense of correctness" in the plan and led to the completion of the surveillance without the generation of a PIR; An additional contributing cause for the failure to generate a PIR when surveillance procedure conditions are not met is the redundancy in requirements of the 0.26 and 0.5 Proceduresc The documentation of procedural discrepancies with Procedure 0.26 Discrepancy Sheets without the accompanying Procedure 0.5 PIR is a recurring problem at CNS.

Corrective Steps Taken and the Results Achieved Corrective actions taken include:

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The generation of PIR Seiial Number 2-16718.

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Conducting an informal discussion of this event and the need to generate PIRs during a subsequent Instrument and Control (IAC) shop morning meeting.

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The development of a tailgate training session for maintenance personnel on the requirements to generate PIRs in accordance with the guidance contained in Procedure 0.5.

Implementation of this training has been initiated.

As a result ofinformal discussion, during the weekly performance of this procedure, and the associated D; vision 11 procedure, six additional PIRs have been generated.

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On going currective actions to address the site wide issue of proc.edural adherence have been made a station alignment issue and incorporated into the business plan.

C_onective Steps That Will Be Taken to Avoid Further Violations

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CNS will revise Procedure 0.26 to climinate the redundant procedural requirements which exist within Procedure 0.26 and Procedure 0.5.

This action will be complete by 10/24/97.

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CNS will conduct additional tailgate training sessions to ensure Maintenance, Operations and Engineerinb Personnel that perform surveillance testing have been trained to the requirements of Procedure 0.5.

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Attachment 1

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CNS will incorporate the above training requirements into recurring Industry Events training for Maintenance, Operations and Engineering Department personnel that perfctm surveillance t

testing.

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CNS will train Maintenance, Operations and Engineering Department personnel that perform t surveillance testing on the requireroents of revised Procedure 0.26.

The above actions will be completed by November 30,1997.

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CNS is continuing to review samples of surveillances with Procedure 0.26 discrepancy sheets attached to identify additional areas where PIRs should have been generated. Based on the results of the review, appropriate corrective actions will be implemented.

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Qate When Full Con 1pliance Will Be Achievest

. The District is in full compliance with respect to the cited violation.

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l ATTACHMENT 3 LTST OF NRC COMMITMENTS

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Correspondence No:lhS970179 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 CNS will revise Procedure 0.26 to elindnate the redundant 10/24/97 procedural requirements which exist within Procedare 0.26 and Procedure 0.5 CNS will conduct additional tailgate training sessions to ensure Maintenance, Operations and Engineering Department 11/30/97 personnel that perform surveillance testing have been trained to the requirements of Procedure 0.5 CNS will incorporate requirements of training to ensure Maintenance, Operations and Engineering Department personnel that perform surveillance testing have been 11/30/97 trained to the requirements of Procedure 0.5 into recurring Industry Events training.

CNS will train Maintenance, Operations and Engineering Department personnel that perform surveillance testing on 11/30/97

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the requirements of revised Procedure 0.26 CNS will continue to review samples of surveillances with Procedure 0.26 discrepancy sheeets attached to identify N/A additional areas where PIRs should have been generated.

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Based on the results of the review, appropriate cort-ctive actions will be implemented

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l PROCEDURE NUMllER 0,42 l REVISIJN NUMllER S PAGE 9 OF 13 l l

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