ML20028A944

Responds to NRC 820813 Ltr Re Violations Noted in IE Insp Rept 50-298/82-23.Corrective Actions:Power Restored to HPCI Isolation Valves & Supervisors Advised That Prior Written Approvals of Completion Required on Modified Safety Sys

ML20028A944
Person / Time
Site:	Cooper
Issue date:	09/23/1982
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20028A939	List: ML20028A944
References
LQA8200020, NUDOCS 8211290236
Download: ML20028A944 (3)

Text

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. ..- 4 COOPER NUCLEAR ST ATioN Nebraska Public Power District " ' " * "A"E *X#MR"M'" "

l LQA8200020 September 23, 1982 ___

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,h 'L l SEP 2 71982 ,

Mr. G. L. Madsen, Chief )

Reactor Project Branch 1 l {

U.S. Nuclear Regulatory Commission 3- l Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 l

Subject:

NPPD Response to IE Inspection Report No. 50-298/82-23

Dear Mr. Madsen:

1 This letter is written in response to your letter dated August 13, 1982, transmitting Inspection Report No. 50-298/82-23. You indicated certain of our activities were in violation of NRC requirements.

Following is the statement of the reported violation and our response in accordance with 10CFR2.201.

Statement of Violation CNS Technical Specification, Section 6.3.1, states, " Station personnel shall be provided detailed written procedures to be used for operation and maintenance of system components and systems that could have an affect on nuclear safety."

Contrary to the above, on August 13, 1982, the high pressure coolant injection (HPCI) pump turbine steam supply line isolation valves were failed as-is, e.g.; in the "open" position. The affected motor operated valves (MOV's), HPCI-MOV-15 and HPCI-MOV-16, provide automatic primary containment isolation capability upon receipt of any one of three in-dependent diverse isolation closure signals due to thu opening of their respective power supply breakers. Maintenance activities were in prog-ress wLich affected the HPCI steam line high temperature automatic isolation signal cables; therefore, MOV-15 and MOV-16 power supply breakers were opened to prevent inadvertent HPCI steam line isolation.

An approved procedure was not written to prescribe documented instruc-tions to be used for the performance of this specific safety-related maintenance activity.

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0211290236 821117 i PDR ADOCK 05000298 r Q PDR

4 Mr. . L. Mad.w a Septa- :82 Page 2.

Discussion This incident u.s dise n ned with the shift supervisor involved. He indicated the vn.ck war- sttherized without a specific written procedure in view of the 'c31owing onsiderations:

1. His desire to expedit.oualy complete the work with power secured to these valves the  :=st amount of time.

2. The HPCI isolation valves in question are not required for auto-matic' primary containment isolation by technical specifications (as indicated in Table 3.7.1 of Technical Specifications).

3. The isolation valves were better failed open than shut as this permitted the HPCI system to remain operable during the mainten-ance.

4. During the monthly conduct of Surveillance Procedure 6.2.2.3.2, power to these same HPCI isolation valves is regularly secured (with the shift supervisor's permission) in order to complete the required surveillance procedures on the HPCI steam line space temperature switches.

Immediate Corrective Steps Which Have Been Taken and Results Achieved The power was restored to the HPCI isolation valves and the appropriate portions of Surveillance Procedure 6.2.2.3.2 was performed on the same shift which proved operability of the isolation circuitry. Shift super-visors were also made aware that portions of routine surveillance pro-cedures cannot be directly applied to alleviate conflicts between plant operation and plant maintenance. They were further advised that prior written approvals and documentation of satisfactory completion would be required on safety systems if a procedure was to be modified to accom-modate completing maintenance.

Long Term Corrective Steps Which Will Be Taken to Avoid Future Violations Subsequently a procedure was devised and implemented the following day which accomplished the maintenance and retained the capability for HPCI isolation. The inspection report and its description of the violation were routed to all shift supervisors.

) .' .

e Mr. G. L. Madsen September 23, 1982-Page 3.

The Date When Full Compliance Will Be Achieved Cooper Nuclear Station is presently in full compliance.

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

Sincerely, J. M. Pilant Director of Licensing and Quality Assurance JMP:KRW:cg