IR 05000298/1990029

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/90-29

ML20058H630
Person / Time
Site:	Cooper
Issue date:	11/09/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 9011210057
Download: ML20058H630 (2)

Text

N

>

.. .

.. .. .

NW 9 ngo Docket No. 50-298/90-29-License No. DPR-46

Nebraska Public Power District ATTN: George _ A. Trevors, Senior Staff Advisor - Nuclear Power Group P.O. Box 499~

Columbus, Nebraska 68602-0499 .

Gentlemen: ,

Thank you for your letter of October 25, 1990, in response to our letter and Notice of Violation dated September 27, 1990.. - We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future L inspection to determine that full compliance has been achieved and will be

- maintaine

Sincerely,

!

Samuel J. Collins, Director L Division of Reactor Projects cc:-

L .Nebrbska Public; Power District

"

ATTN: G. D. Watson, General Counsel P.O.' Box 499 Columbus, Nebraska 68602-0499 Ccoper Nuclear Station ATTN: John M. Heacham, Division Manager, Nuclear Operations

'P.O. Box 98 Brownville, Nebraska 68321

,

n

- _@

9011210057 DR 902109 ADOCK 05000298 PNU

• RIV:DRP/C RVAzua;df

• C:DRP/C P}lHarrell 0:DRP 0h SJCollins 11/}/90 11/89 /P0 11/ef/90

• previously concurred I/f a /

, Ilt

. - .

'

_-6

.

-

..

-l

-

, ,'

{

3. . -

-

I l Nebraska Public Power District -2-

>

Nebraska' Department of Environmental *

Control ATTW: Dennis Grams, Director P.O. Box 98922 Lincoln, Nebraska 68509-8922 Nemaha County Board of Commfssioners ATTN: Larry Bohlken, Chairman Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305

,

-

Nebraska Department of Health ATTN: Harold Borchert, Director Division of Radiological Health 301 Centennial Mal":, South P.O. Box 95007 Lincoln, Nebraska 68509-5007

,

Kansas Radiation Control Program Director

'bec to DMB (IE01) w/ licensee 1t bec distrib.'by RIV w/ licensee ltr.:

, R. D. Martin- Resident Inspector l SectionChief(DRP/C)- Lisa:Shea,RM/ALF l DRSS-FRPS MIS System L RIV File ProjectEngineer(DRP/C)

-RSTS Operator DRP;

-P. O'Connor, NRR Project Manager (MS: 11-D-23) DRS l

q r

. . . - - _

. .

<

, ,

,.

,

.

COOPER NUCLE AR STATION l

• • * * i'A"c", J"~R4 00.^i?^ ""'

M Nebraska Public Power District I

% M @ M D V1 M %

_

'CNSS905903 October- 25, 1990

.

,"',g, gg l

I

U. S. Nuclear Regulatory Commission l Attention: Document Control Desk 1 Washington, DC 20555 Subj ect: NT?D Response to Inspection Report 50-298/90 29 Gentlemen:

During an NRC inspection conducted July 16, 1990, through September 3,  ;

1990, a violation was issued for failure to follow procedure. Following is the statement of violation and our response thereto in accordance with E

10 CFR 2.20 Statement of Violation Failure'to Follow Procedure

> '

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

,

quality shall be accomplished in accordance with instructions,

, procedures, or drawings.

Maintenance Procedure (MP) 7.0.1, " Work Item Tracking Corrective Maintenance," Revision 13, dated November 11, 1989, specifies in Step 4.9.2 that maintenance affecting safety related equipment will be performed in accordance with documented instruction MP 7.2.49, "ASCO Solenoid Valve Maintenance," Revision 3, dated January 25, 1990,' requires in Step 7.5 that a special instruction l' sheet with signature points for assigned Quality Control (QC) be l~ provide Contrary to the-above, two instances were identified, Maintenanco -

Work Requests 89-4566 and 90 0295, where personnel were not provided p special instruction sheets with appropriate assigned QC requirements.

l- This is a Severity Level IV violatio (Supplement I) (298/9029-01).

Reason for Violation I-Although the two referenced Maintenance Work Requests (MWR's) did not contain special instruction sheets as required by Step 7.5 of MP 7.2.49,

"ASCO Solenoid Valve Maintenance", the scope of the work performed did not warrant the use of special instructions as detailed below l _L,C_. Ro .-B

' n.In1} W .

17" n~= ==- === --======n========u==

- -

'.

.. , 4T.S. Nuclocr R9gulctory C:mmissicn

. Octtbar 25, 1990

'

Pago 2 During the QC review of the work package as required by the Prerequisites section of MP 7.2.49 for MWR 89 4566, the solenoid valve was identified as needing replacemen This, fact is. documented by an N/A (not applicable) in Step 7.4 of the rcocedure. This indicated that a rebuild kit was not to be used. The intent of Step 7.5 is to perform a QC review of the ASCO repair kit's bulletin and assign QC hold and witness steps in the form of special instruction Since the valve was to be replaced, a repair kit was not to be used and Step 7.5 also became not applicable. Therefore, the requirement to provide a special instruction sheet to the craft did not exist. However,'the QC Inspector who reviewed Step 7.5 exercised poor judgement and signed this step instead of marking it N/A. As such, from an overview of documentation associated with MWR 89-4566, it would appear that a special instruction sheet was require The second MWR (90 0295) used in the basis for the alleged violation did

-

use an ASCO repair kit to rebuild the solenoid-valve. This MWR was reviewed per the requirements of Steps 3.1.2, 3.1.6, and 7.5 of MP 7.2.4 During the QC review of the ASCO repair kie's bulletin, it was determined that the bulletin did not contain any specific criteria, e.g. torque values, for which QC or special instructions should be applied. As such, special instructions were not generated for this MWR. The failure of the QC Inspecter to document that no QC or special instructions were required was a poor judgemen Corrective Steos and the Results Aehleved Interim actions that have been taken include a review of the potential-i violation with the applicable Maintenance Department personnel and the l issuance of an Inter District letter from the Division Manager of Nuclear l

Operations. The letter was to all CNS craft personnel and re emphasized l

the necessity for strict compliance with approved station procedure Correcrive Steos Which Vill be Taken to Avoid Further Violations R

L A thoroug,h review of MP'7.2.49 has resulted in a procedure change being

_

l initiated which will provide better guidance for the craf t and should

. preclude violations of this nature in the futur The revised procedure.

l will include a separate attachment for recording special instructions and will also require the craftsman to record the ASCO bulletin number in the

. procedur Changes have also been made to clarify the Q.C. review requirements for this proceduro. It is expected thac this procedure revision will be approved:and implemented by January 1, 199 Date When Full Como11ance Will Be Ach ly.gd

- Full compliance will be achieved with the approval of Revision 4 - to MP 7.2.49, "ASCO Solenoid Valve Maintenance". This ravision is expected

.to be approved by January 1, 199 "

a s . ;.= , ' , 6.S. Nucicer Regulottry Ctanission i .. Octcber 25, 1990 i

• . Pago 3 l l

Should you have any questions concerning this matter, please' contact my offic j

.

Sincerely, j

l . Trevors Senior Staff Advisor GAT:sg:Ju cc: . S. Nuclear Regulatory Commission Region Office . Region IV NRC Resident Inspector -

Cooper Nuclear Station l-L I

i l <

l:

!

..

i i

i