ML20042A608

Responds to NRC 820204 Ltr Re Violations Noted in IE Insp Rept 50-298/81-25.Corrective Actions:Sorc Meeting on 820226 Stressed Thorough Reviews by Senior Operators Prior to Changes to Procedures

ML20042A608
Person / Time
Site:	Cooper
Issue date:	02/26/1982
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20042A607	List: ML20042A608
References
LQA8200025, NUDOCS 8203230608
Download: ML20042A608 (3)

Text

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LQA8200025 February 26, 1982 Mr. G. L. Madsen, Chief Reactor Projects Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to IE Inspection Report No. 50-298/81-25

Dear Mr. Madsen:

This letter is written in response to your letter dated February 4, 1982 in which you indicated certain of our activities were not being con-ducted in full compliance with NRC requirements.

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

Statement of Violation Failure to Follow Procedure for Making Temporary Changes to P_r_oc edure s Technical Specification 6.3.7 states, " Temporary changes to procedures which do not change the intent of tSe original procedure may be made, provided such changes are approved by two members of operating staff holding SRO licenses. Such changes shall be documented and subsequently reviewed by the Station Superintendent within one month."

CNS Administrative Procedure 1.3, Revision 6, Section 1.3.6, titled,

" Temporary Changes to Procedures," states, " Occasionally it may become necessary to make temporary changes to a procedure to fulfill the re-quirements of a special situation. If such a situation should arise, temporary changes may be made to procedures applicable to operation pertaining to volumes 2, 3, 4, 5, 6, 7, and 10 by written consent of two individuals holding senior Operators licenses. Changes may be made to any procedure by written consent of two SORC members. All temporary changes to procedures must be reviewed by the Station Superintendent within one month."

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Mr. G. L. Madsen February 26, 1982 Page 2.

Contrary to the above, on October 31, 1981, Surveillance Procedure 6.3.5.1, Revision 16, titled, "RHR Test Mode Surveillance Operation,"

was not performed as written, nor was a temporary procedure change written and approved to indicate the actual performed surveillance test valve lineup.

This constitutes a Severity Level V violation.

Discussion The violation occurred as an oversight on the part of the operating crew l conducting the procedure. During the test, the test engineer requested I that the crosstie valve be opened to help him evaluate the system per-formance after completion of the RHR test line modification. Two SORC members (both Senior Licensed Operators) reviewed the request and agreed to the change in procedure. However, the change and approval were not indicated on the procedure. Since this deviation from the procedure was not noted on the procedure, further reviews of the completed surveil-lance procedure did not identify the deviation from the procedure. This oversight was not intentional, nor is it considered to be a common problem at Cooper Nuclear Station.

Corrective Steps Which Have Been Taken and Results Achieved The temporary change was reviewed by SORC. The review identified no safety concerns with the change.

Corrective Steps Which Will Be Taken to Avoid Further Violations The failure to follow procedures was discussed in SORC Meeting on 2 82. It was stressed to all meeting attendees that thorough reviews must be conducted before changes to procedures are made and that those reviews and approvals must be documented.

This response will also be reviewed by licensed operators and test engineers to remind them of this requirement.

The Date When Full Compliance Will Be Achieved Full compliance will be achieved when the above review is completed prior to April 1, 1982.

Mr. G. L. Madsen February 26, 1982 Page 3.

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

Sincerely, W

. Pilant Division Manager of Licensing and Quality Assurance JMP:LCL:cg