IR 05000298/1986014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/86-14

ML20212N390
Person / Time
Site:	Cooper
Issue date:	08/22/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
Shared Package
ML20206N532	List: IR 05000298/1986014 ML20206N528
References
NUDOCS 8608280208
Download: ML20212N390 (2)

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AUG 2 21990

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In Reply Refer To:

Docket: 50-298/86-14 ,

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 August 18, 1986, in response to our letter and Notice of Violati'no dated July 17, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will i review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, Orldnct rt,neg g,

.!. E. Gac.'irdo J. E. Gagliardo, Chief ,

Reactor, 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 Ra f ation Control Program Director /y f 0\

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RPB DRSP Resident Inspector R. D. Martin, RA SectionChief(RPB/A) D. Weiss,LFMB(AR-2015).

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CNSS860604  % 2 @ B D W M_ D

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August 18# 1986

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O J.* E. Gagliardo, Chief U RO I D

Mr.

Reactor Projects Branch MON U.S. Nuclear Regulatory Commtssion Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 Subject: NPPD Response to Inspection Report 50-298/86-14

Dear Mr. Gagliardo:

This letter is written in respons'e to your letter dated July 17, 1986, trans-mitting Inspection Report 50-298/86-14. Therein you indicated certain of our activities were in violation / deviation of NRC requirements. Attached are the statements of the violations / deviations and our responses in accord-anee with 10CFR2.201.

In accordance with the provisions of 10 CFR Part 73.*21, we request that Attach- *

ment B, " Response to Notice of Deviation" be treated as safeguards information and withheld from public disclosure.

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

Sincerely,

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Jay . Pilant Manager, Technical Staff Nucicar Pover Group JMP:HTHerg Attachment: A. Response to Notice of Violatica I

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Response to Notice of Deviation (sal;.CUARDS) a B.

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ATTACHMENT A .

RESPONSE TO NOTICE OF VIOLATION Nebraske Public Power District Cooper Nuclear Station - *

Docket: 50-298/86-14 Attachment "A" to NPPD Correspondence CNSSS60604 Page 1 of 4:

Statement Of Violation

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A. Deficient As-Built Inst rument ravings 10 CFR Part 50. Appendix B, Criterion V, and the licensee's approved quality assurance plan requires that activities affecting quality shall be prescribed by documented drawings of a type appropriate to the circumstances. '

Contrary .to the above, as built ' instrument drawings for the Standby Liquid Control system and Core Spray System "A", did not label, number, or otherwisa identify valves associated with the instrument detectors. g This is a Severity Level IV violation. (Supplement I.D.)

(50-298/8614-01)

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Reason for the Violation .

The valves associated with the instrument detectors were never shown on the General Electric rack drawings or the flow diagrams but were originally intended to be handled in the Station Operating Procedures.

The District believes this approach to be in conformity with 10CFR50, Appendix B Criterion V, which states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in l accordcnce with these instructions, procedures, or drawings." '

Corrective Steps Taken and the Results Achieved  !

l The District is in the process of checking as-built drawings of 1

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safety-related systems at CNS. In May of 1986 it was discovered that the

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valves associated with the instrument detectors were not shown for the I core spray or SLCS systems. The drawing change notices have been written to as-build the General Electric drawings to show the valve numbers and ,

arrangement:. It is believed that placing valve configurations and l numbers on the rack drawings is a good practice and will facilitate the operation at CNS.

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.* Attcchment "A" to NPPD Correspondence CNSS860604

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Pade 2 of 4t Corrective Steps Taken to Avoid Further Violations The District is in the procese of developing a total configuration management program, a cart of which is checking as-built safety-related I drawings. It is anticipated that if there are other areas where valves are listed in the procedures but not shown on the applicable drawings, that consideration will be given for the valve (s) to be added to the applicable drawings.

Date When Full Compliance Will Be Achieved The drawing change notices have been prepared and it is anticipated the actual core spray and SLCS drawings will be updated by September 30, 1986.

Statement of Violation B. Failure to Follow Procedures 10 CFR Part 50, Appendix B, Criterion V, and the licensee's approved quality assurance plan require that activities affecting quality be accomplished in accordance with drawings and procedural instructions. '

Contrary to the above, during the performance of surveillance testing, station personnel did not follow the requirements of the following procedures in that sequential steps were missed during the performance of the test procedure:

6.1.25, "RBM Calibration and Functional / Functional Test", conducted on April 10, 1986.

6.2.2'.5.12. "RHR Loop A & B Pump and Valve Contral Logic Functional Test", conducted on April 5,1986.

6.3.1.8, " Electrical Penetrations Leak Check", conducted on April 10, 1986.

This is a Severity Level IV Violation (Supplement I.D.) (50-298/8514-02).

Reason For The Violation During performance of station surveillance procedure 6.1.25, "RBM Calibration and Functional / Functional Test", conducted on April 10, 1986, a licenseo operator failed to follow the requirements of the procedure in testing channel "B" of the RBM system. During performance of station surveillance procedure 6.2.2.5.12. "RHR Loop A & B Pump and Valve Control Logic Functional Test, conducted on April 5, 1986, a licensed operator failed to follow the requirements of the procedure in testing RHR Loop

"A", pump "B". During performance of station surveillance procedure 6.3.1.8, " Electrical Penetrations Leak Check", conducted on April 10, 1986, a station operator failed to properly follow the requirements of the procedure in that a valve for testing an electrical penetration was incorrectly positioned. The failure of these individuals to follow the requirements of procedures during surveill.ance testing was identified by the NRC Resident Inspector as a violation.

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= * 'Attccbrent "A" to NPPD Correspondence CNSS860604 Page 3 of 4:

Corrective Steps Which Have Been Taken And The Results Achieved

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The individuals involved were immediately counseled by the Operations Supervisor about the need to follow procedural requirements. A copy of the violation has been sent t,o each Shift Supervisor for crew discussion in order to stress to all operators the need to properly follow procedures.

The procedures related to the violation have besn reviewed to identify procedural deficiencies. Based on the procedural review conducted, surveillance procedure 6.1.25, "RBM Calibration and Functional / Functional Test", has been revised in order to separate into individual steps, *

multiple related actions previously contained in a single step.

Surveillance procedure 6.3.1.8, " Electrical, Penetrations Leak Check", has been revised to provido a precaution and note to ensure that the pressure of each electrical penetration tested is recorded prior to opening isolation valves and equalizing pressure. .

No procedural deficiencies were identified in the review of surveillance procedure 6,.2.2.5.12. "RRR Loop A & B Pump and Valve Control Logic Functiunal Test".

Correceive Steps Which Will Be Taken To Avef1 Further Violations The Operations Supervisor will meet and discuss with each operating crew'

, the importance of following procedures and ensu. ring all requirements

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stated in the procedures are adhered to. The corrective described herein and the Operations Supervisor's meeting with each operating crew to i

review and discuss this concern should alleviate further violations in this area.

l Date When Full Compliance Will Be Achieved Cooper Nuclear Station is presently in full compliance. The procedure revisions and the corrective meecings to review and discuss this concern with the operating crews will be completed by September 30, 1986.

Statement Of Violation C. Inadequate Procedure 10 CFR Part 50, Appendix B, Criterion VI and the licensee's approved QA plan require that measures be established to control the issuance of

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pro:edures, including char.ges thereto, and that procedur.e changes be reviewed and approved by the same organizations that performed the original review.

Contrary to above, Procedures 2.1.10, 6.1.19, 6.1.21A, 6.3.8.2, and 6.4.8.8 were changed in technical content without being reviewed and approved by the originating reviewing orgaaization.

This is a Severity Level IV violation (Supplement I.E.) (50-298/8614-03)

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Reason for the Violation Station Operating Procedure 0.4 " Preparation, Review, and Approval of

• Proceduros" did not clearly define the proper control of clerical changes to approved procedures.

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Corrective Steps Which Have Been Taken and the Results Achieved , ,

Station Operating procedure 0.4, Section V_.G has been revised, clarifying the control of clerical changes. Specifically, clerical changes will be distributed under the same controlled distribution process as are normal

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procedure revisions.

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Corrective Steps Which Will Be Taken to Avoid Further Deviation The control of clerical changes to procedures has been discussed with the -

Procedure Specialist and Procedure Clerk with rer.pect to specifics as described in the new rev;sion of Station Opertting procedure 0.4. It is felt that this training and the revision to Station Opc *ing procedure

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0.4 will prevent any further deviations.

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Date When Full Compliance Will Be Achieved

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Full compliance was achieved on July 2, 1986.

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