ML19324C114

Responds to Jl Milhoan 891010 Request for Addl Info Re Util Response to Violations Noted in Insp Rept 50-298/89-28. Corrective Actions:Random Sample of Design Changes, Classified as Essential Selected for Detailed Review

ML19324C114
Person / Time
Site:	Cooper
Issue date:	11/09/1989
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS8900416, NUDOCS 8911150008
Download: ML19324C114 (2)

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GENERAL OFFICE Nebraska Public Power District '

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NLS8900416  ;

November 9, 1989 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Subj ect: Supplemental Response to Inspection Report 50-298/89 28 Cooper Nuclear Station NRC Docket No. 50 298, DPR 46

Reference:

Letter, G. A. Trevors to USNRC dated September 25, 1989, "NPPD Response to NRC Inspection Report 50 298/89 28" Centlemen:

This is written in response to the letter from Mr. James L. Milhoan dated October 10, 1989, requesting additional information concerning the District's response- to the violation discussed in NRC Inspection Report 50 298/89 28.

Additional information is supplied below to supplement the response contained in the reference.

Corrective Steos Which Have Been Taken and the Results Achieved l .A random sample (10%) of the design changes, classified as Essential, that l, were implemented during the 1988 and 1989 Refueling Outages, was selected for i

a detailed review. For each of these design changes, the ' associated On The-Spot Changes (OSC's) were evaluated to ensure that the design basis or design- criteria of the design change was not altered. No discrepancies were noted as a result of this review.

l. In addition to the above, design changes that implemented activities described L in. a NRC Safety Evaluation Report on the Cooper Nuclear Station Docket were reviewed. These design changes, dating back to 1984, involved the following.

Primary Containment Purge and Vent Valve Orientation c.nd Actuators Primary Containment Purge and Vent Debris Strainers Reactor Vessel Water Level Reference Leg Fill IRM/SRM Loss of Negative Voltages Sensing Relays Automatic Depressurization System Actuation Logic Again, the associated OSC's were reviewed for any impact or alteration to the design criteria or basis of the design change and additionally, for any effect on the SER. This review also revealed no discrepancies.

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.- Do;ument Contr:1 Desk i s November 9, 1989

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l Accordingly, based on a lack of any additional discrepancies from the above two reviews of desi5 n changes, it is the District's position that the situation noted in the violation was an isolated instance of misapplication of an OSC and that no programmatic deficiencies ex1.st in the implementation of OSC's in the District's design change process, l- Corrective Steos Which Will Be Taken To Avoid Further Viointions To avoid further violations, Engineering Procedure 3.4.10, " Revision, Amendments and On The Spot Changes" will be revised to require the Design Engineers to verify that proposed OSC's will not modify the design basis or

design criteria of the design change package. If the answer is yes, the revised procedure will indicate that an OSC is not allowed. Documentation of this review will also be required by the revised procedure along with the Design Engineer's signature. This procedure change will be implemented in lieu of changing Engineering Procedure 3.3, " Station Safety Evaluations" as discussed in the reference.

Date When Full Comoliance Vil' Be Achieved TQ Revision to Engineering f rocedure 3.4.10 will be implemented by December 1, 1989.

If you have any questions regarding this information, please contact my office.

Sincerely, C. K. Trevors i Division Manager Nuclear Support ,

/rg cc: Regional Administrator USNRC - Region IV NRC Resident Inspector Cooper Nuclear Station

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