ML20127G653

Responds to NRC Re Violations Noted in Insp Rept 50-298/85-11.Corrective Actions:Surveillance Procedures 6.3.10.8 & 6.4.8.7 Revised,Standby Gas Treatment Sys Reviewed & Licensed Operator Training Will Be Conducted

ML20127G653
Person / Time
Site:	Cooper
Issue date:	05/03/1985
From:	Kuncl L NEBRASKA PUBLIC POWER DISTRICT
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20127G618	List: IR 05000298/1985011 ML20127G653
References
CNSS850213, EA-85-036, EA-85-36, NUDOCS 8505210109
Download: ML20127G653 (4)

Text

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,,_o S$~c2 ?l S~ U Y EA 85-34 Nebraska Public Power District """?N[k$ShkhM"***

CNSS850213 May 3,1985 MAY - 61985 Mr. Robert D. Martin , _ _

d Regional Administrator U. S. Nuclear Regulatory Commission Region IV Gil Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to Notice of Violation EA 85-36 Reference 1: Letter from R. D. Martin to J. M. Pilant dated April 4,1985

Dear Mr. Martin:

Referen~ce 1 provided notice of a Severity Level llI violation related to establishing and maintaining secondary containment integrity during defueling activities at Cooper Nuclear Station.

In accordance with the provisions of 10 CFR 2.201, the District hereby submits as Attachment 1, a written explanation regarding the alleged violation. It is believed that the actions taken by the District will ensure that secondary containment integrity is established and maintained in accordance with the Technical Specifications for all future fuel handling activities.

Sincerely,

.cd L. G. uncl Assistant General Manager-Nuclear LGK:rs3/2 Attachment 8505210109 850516 hDR ADOCK 05000298 PDR h '

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r f Mr. R:bert. D.1 M rtin P;gs 2 May 3,1985 STATE OF NEBRASKA )

)ss PLATTE COUNTY )

L. G. Kunc1, being first duly sworn, deposes and says that he is - an authorized representative of the Nebraska Public Power District , a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this information on behalf of Nebraska Public Power District; and that the statements contained .herein are true to the best of his knowledge and belief.

L G. Kuncl N Subscribed in my presence and sworn .to before me this /g/

day of D'ltt4, , 1985.

' '# 3 camt em-si.i. e .a,.u.

JANIE THOM AS

')!Lh 4 /%Mo djQ My comm. En sept 1,155 g NOTARY PUBLIC

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= ATTACHMENT'1

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- ' , RESPONSE TO NOTICE OF VIOLATION EA 85-36 J

e fALLEGED VIOLATION' ,

= Technical-Specification-section 3.7.C.1.d requires secondary containment

,  ; integrity to be maintained when irradiated fuel is being handled in the

. secondary conr,iinment.

. Contrary.to.the above, secondary containment integrity was not maintained during defuelin'g activities conducted for the period September 22-29

- 1984iin.that the-Standby-Gas Treatment System was not capable of establishing.-1/4 inch of water vacuum in the secondary containment as

. - required by Technical Specification section 4.7.C.I.c.

' RESPONSE ~

The statements contained in this response are. numbered to correspond to

those specified in the Notice of Violation.

. 1.- Admission or-denial of the alleged violation

' Admission.

.2 . - The reasons'for the violation This vio1'a tion;is' attributed to a combination of procedural and personnel errors.--Surveillance' Procedure 6.3.10.8, " Secondary Containment Leak Test", was inadequate in that it did not specify the exact plant conditions necessary to ensure that a valid.

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Secondary Containment' Leak ~ Test was performed. As a result,~1t.was.

not recognized at the time of testing that-the mechanical vacuum pumps were= aligned'in such a way as to assist the Standby Gas-Treatment System in establishing 1/4 inch of water vacuum in the secondary containment. . This~1ed station personnel to believe that=

Surveillance Procedure 6.3.10.8 had been successfully performed,'and

'therefore, reactor core defueling operations were commenced.

Surveillance Procedure 6.4.8.7, "Offgas Loopseal Blowdown and Fill",

was inadequate in that it did not address the maintenance of the

__ drain' loop seal from one of the two Standby Gas Treatment System

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- underground' discharge lines to the elevated release point.- As a result, the drain loop seal'became plugged and the respective discharge line accumulated a substantial amount of water. The.

'resulting decrease in Standby Gas Treatment System discharge flow

. contributed'to the inability of the~ system to establish a 1/4 inch of water vacuum in the secondary containment.

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3. .The corrective: steps which have been taken and the results achieved

'The procedural inadequacies.that were identified, have been eliminated by-revising Surveillance Procedures 6.3.10.8 and 6.4.8.7.

Surveillance Procedure 6.3.10.8 " Secondary Containment Leak Test",

.was revised.by adding provisions to ensure.that the mechanical

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, . . . 4-y..t r vacuum pumps are'not running and the main steam isolation. valves are closed while the test is in progress..~ Surveillance Procedure

-6.4.8.7, "Offgas Loopseal Blowdown and Fill", was revised by adding the steps' required to maintain the previously neglected Standby Gas Treatment discharge line drain loop seal in an operable condition.

.To ensure that the Standby. Gas Treatment System is in compliance with'the applicable requirements of Regulatory Guide 1.52,.an independent architect / engineering firm was retained to conduct an independent review of the system. This. review was intended to i determine if modifications to the system are required and to

-determine if changes are necessary to improve testing procedures, operating procedures, and the-Technical Specifications.

4. The corrective steps which will be taken to avoid further violations 1To preclude recurrence of this event, training will be conducted for

' licensed operators on the interrelationship between various systems

'and plant conditions that affect the validity of testing conducted

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to verify secondary-containment integrity.

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As a result of the system review by-the architect / engineering firm, design modifications will be made to the Standby Gas Treatment System to meet the intent of Regulatory Guide 1.52. ' Licensee Event Report 85-002 has been submitted to document these design ,

inadequacies.

5. The date when full compliance will be achieved CNS is presently in full compliance with respect to the procedural changes-to Surveillance Procedures 6.3.10.8 and 6.4.8.7. .The training of licensed operators referred to above has begun and will be completed by August 1, 1985. The Standby Gas Treatment System it . design modifications recommended as a result of the system. review are currently in progress and will be completed prior to movement of any irradiated fuel.

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