ML19352A202

Responds to NRC Re Violations Noted in IE Insp Rept 50-298/80-17.Corrective Actions:Equipment Control Procedure Will Be Revised to Provide for Independent Control of Equipment Tagging

ML19352A202
Person / Time
Site:	Cooper
Issue date:	02/06/1981
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19352A200	List: ML19352A202
References
LQA8100054, NUDOCS 8103110782
Download: ML19352A202 (3)

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COOPER NUCLEAR STATION

':'jk-Nebraska Public Power District

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.a b LQA8100054 February 6, 1981 Mr. Karl V. Seyfrit, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement

-Region ~1V 611 Ryan Plaza Drive Suite 1000 Arlington, Texas-76011

Subject:

NPPD Response to IE Inspection Report 50-298/80-17

Dear Mr. Seyfrit:

This letter is written in response to IE Inspection Report No. 50-298/80-17.

Statement of Violation Criterion-II of 10 CFR 50, Appendix B, states that the licensee's quality assurance program shall be documented by written policies, procedures, or; instructions and shall be carried out in accordance with these policies, procedures, or instructions.

The licensee's Quality' Assurance Program for Operations, Section 8.15, states that the operational QA Program for Cooper Nuclear Station con-forms to the guidance.provided by ANSI N18.7 - 1972 and the associated

- Regulatory Guide 1.33.

A.

Section 5.1.5 of ANSI N18.7 - 1972 states:

" Equipment Control Procedures.

Procedures shall be provided

.for control of equipment, as necessary, to maintain rear. tor and personnel safety and co avoid unauthorized operation of equipment. _ These procedures shall require ~ control measures such as locking or tagging to secure and identify equipment in

-a' controlled status.

The procedures shall require independent verification, where appropriate, to ensure that necessary measures, such as tagging equipment, have been implemented

' correctly."

810.8.11o W A

~

Mr. Karl V. Seyfrit February 6, 1981 Page 2.

Contrary to the above, the licensee's Eculpment Control Procedure 1.6 did not provide administrative controls for an independent verification to ensure the tagging procedure 3ad been implemented correctly.

B.

Section 5.3.5.3 of ANSI N18.7 - 1972 states:

" Post-Maintenance Check Out and Return to Service.

Instruc-tions shall be included, or referenced, for returning the equipment to its normal operating status. Operating personnel shall place the ecuipment in operation and verify and document

~its functional acceptability.

Special attention shall be given to restoration of normal conditions, such as removal of signals used in maintenance or testing, and to systems that can be defeated by leaving valves or breakers mispositioned or by leaving switches in " Test" or " Manual" positions.

All jumpers shall be controlled. When placed into service, the equipment should receive special surveillance until a run-in period has ended."

Contrary to the above, the licensee's Administration Maintenance and Equipment Control Procedures did not provide administrative controls for returning safety-related equipment to its normal operating status.

~~C Section 5.1.6.1 of ANSI N18.7.-_1972' requires administrative con-trol prcedures for-evaluating failures by virtue of the statement:

"When failures occur, the cause shall be evaluated. Exper-ience with the' failed equipment and similiar components shall

.be reviewed to determine whether a replacement' component of

~

~

the same type can.be expected to. perform its function re-liably."

Contrary to the above, the licensee's Maintenance Program control

~

procedures do not provide Administrative Controls for evaluating failure. experiences.

This" constit'utes a Severity Level V Violation (Supplement I.E)

_ ~ Discussion-of Violation - Items A-and C

-ANSI N18.7 -11972' states that independent. verification of tagging 5

A.

.of equipment be. required where appropriate. We have been of the Jopinion!that-independent verification of itagging was not -approp-riate'at thisisite,:therefore,qit wasinot_ discussed in the pro-

-cedure. To: discuss'this would have' unnecessarily 1 complicated the

~

jprocedure.

/

w

Mr. Karl V. Seyfrit February 6, 1981 Page 3.

C.

Procedure 1.10, Non-Conformance and Corrective Action, is used to provide the Administrative Controls for evaluating failure exper-iences.

We believe the evaluations performed with the non-con-formance report (NCR) satisfies the intent of ANSI N18.7 - 1972.

Corrective Steps Which Have Been Taken and Results Achieved The~ corrective steps.taken on Items A, 3, & C have been to evaluate the steps needed to avoid further non-compliance as stated below.

- Corrective Steps Taken to Avoid Further Violation A.

The Equipment Control procedure will be revised to provide for independent control of equipment tagging where appropriate.

B.

The appropriate Maintenance and Equipment Control Procedures will be revised to provide for more explicit control and post =ainten-ance testing of safety related equipment.

C.

A statement will be added in procedura 1.7.1, Station Maintenance, to clarify how fcilure evaluation is being performed.

Date When-Full Compliance Will Be Achieved Compilance on all items will be achieved'by March 15,.1981.

Should you have any questions regarding this response, please contact me.

Sincerely,-

M J... Pilant-Director of - Licensing and Quality Assurance JMP:PJB:cg 1