ML20044B831
| ML20044B831 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/05/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NSD930292, NUDOCS 9303100062 | |
| Download: ML20044B831 (3) | |
Text
4 GENERAL OFFICE
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P O. BOX 499. COLUMBUS. NEBRASKA 6B6024499
{n._di Nebraska Public Power District "Exi@$%'"
3 Sy NSD930292 March 5, 1993 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Centlemen:
Subject:
NPPD Response to Inspection Report 50-298/93-03 (Reply to Notice of Violation)
This letter is written in response to your letter dated February 4, 1993, that transmitted a Notice of Violation containing two violations.
Following are the statements of violation and our responses in accordance with 10 CFR 2.201.
Statement of Violation Section 8.6 of the licensee's Emergency Plan, " Maintenance and Inventory of Emergency Equipment and Supplies," requires, in part, + hat quarterly inspections of the operational readiness of items of emergency equipment and supplies are departmental basis.
The use of inventory procedures in conducted on a conjunction with the licenso 's Preventive Maintenance Tracking System and follow up actions ensures that equipment is ready for use.
Preventive Maintenance Tracking System Work Item 4634 specifies that monthly tests of the licensee's Emergency Response Organizat on pager system will be conducted to ensure the capability and readiness of this emergency equipm:nt.
Contrary to the above, as of January 22, 1993, tests of the licensee's Emergency Response Organization pager system had not been performed monthly in accordance with Preventive Maintenance 4634 since April 1992. During this period of time, only one other test to ensure that the licensee's pager system was ready for use had been conducted, and this test was conducted by a different test procedure than that outlined in Preventive Maintenance 4634.
This is a Severity Level IV violation (Supplement VIII) (298/9303-01).
RE/\\ SON FOR VIOLATION The Emergency Preparedness (EP) Superviser and the EP Coordinator had a communications breakdown in determining the correct procedure to be issued for conducting the monthly testing of the pager system.
In May, 1992 the EP Supervisor advised the EP Coordinator to discontinue testing the paging system pending clarification of the paging system test protocol. However, the personnel involved failed to place the necessary emphasis on this issue to cause it to be resolved in a timely manner.
In the interim, reports of failure to complete Preventive Maintenance (PM) 4634 were being issued to the EP Coordinator who continued to hold the pager system testing in abeyance. The FM feedback failed to reach a level of management appropriate to assure resolution of the test protocol issue.
W mnnthly tests lapsed as a result.
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4 Document Control Desk March 5, 1993 Page 2 l
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The pagers and the paging system were immediately tested following completion of Inspection No.
50-298/93-03 with satisfactory results and were also satisfactorily tested in January and February 1993 in accordance with Preventive
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Maintenance 46?..
I CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIO1ATIONS A formal procedure for the conduct of monthly operational testing of the pagers and paging system is under development and will be implemented in March, 1993.
The procedure will include a monthly report to the Division Manager of Nuclear Support of ptger testi:
completed and the assignment of corrective actions if any are required.
i DATE WHEN PULL COMPLTANCE WILL BE ACHIEVED The Nebraska Public Power District is currently in full compliance with the requirements identified in Section 8.6 of the Cooper Nuclear Station Emergency Plan.
Statement of Violation Section 8.2 of the licensee's Emergency Plan, " Drills and Exercises," requires, in part, that drill performance will be critiqued by personnel acting as drill observers.
Based on the results of these critiques, follow up action is then recommended by the Emergency Preparedness Supervisor with action items assigned by the appropriate level of management.
Contrary to the above, no critique was performed following a June 2,1992, mini-drill.
In addition, no follow up action was recommended or assigned for three weaknesses identified during an emergency exercise dress rehearsal conducted on September 1, 1992.
This is a Severity Level IV violation (Supplement VIII) (298/9303-02).
REASON FOR VIDIATION The drill conducted on June 2, 1992 was intended to train Control Room and Technical Support Center (TSC) personnel.
Due to scenario inadequacies, the drill did not allow the TSC to fully demonstrate the desired objectives. This drill was in fact, informally critiqued, however the critique was not documented
.l in accordance with CNS Station Procedure 6.3.11.1.
Corrective actions from the critique were verbally assigned to the EP Coordinator by the EP Supervisor, j
immediately following the drill.
j
. Action assignments from the September 1, 1992 dress rehearsal critique were not assigned.
The procedures used for assigning follow up action on the critique were incomplete and did not desi nate "the appropriate level of management to 5
assign action." As a result, appropriate action assignments were not made.
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a Document control Desk March 5, 1993 Page 3 E 3ECTIVE STEPS TAKEN AND RESULTS ACHIEVED The June 2,1992 mini-drill critique has been formally documented, and follow up l
action items formally assigned. Followup action items on the September 1, 1992 dress rehearsal critique have also been formally assigned.
Action. items from both critiques are being tracked on the Nuclear Action Item Tracking System.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS CNS Procedure 6.3.11.1 will be revised, identifying the appropriate level of management to assign follow up corrective actions on emergency preparedness drill and exercise critiques. This revision will be approved in March, 1993.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i'
The Nebraska Public Power District is currently in full compliance with the requirements identified in Section 8.2 of the Cooper Nuclear Station Emergency l
Plan; t
Your letter of February 4,1993 also contained a concern related to our selection of operating crews to participate in emergency drills and exercises..
The operating crew in three drills as well as the 1992 participation of the same graded exercise was the unintended result of a drill schedule established several -
i months prior to the exercise.
No crew was intentionally given preference' for drill participation. In the future however, the participation of operating crews
'in drills and exercises will be. closely monitored to. achieve a more even distribution, i
Should you have any questions concerning this matter, please contact me.
. Sincerely, 7
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/s g~
iorn N c1' ear Power Group Manager
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Regional Administrator USNRC - Region IV NRC Resident Inspector Cooper Nuclear Station i
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