ML20063B908
| ML20063B908 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/28/1994 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS941049, NUDOCS 9402030159 | |
| Download: ML20063B908 (3) | |
Text
{{#Wiki_filter:~. - - l -{ l I ) .e { f ) COOPER NUCLEAR STATION ' Nebraska Public Power District " " "A*"PaE2 55.^i f" ""' 5 CNSS941049 January 28, 1994 U. S. Nuclear Regulatory Commission j Attention: Document Control Desk Washington, DC 20555
Subject:
NPPD Response to Inspection Repart 50-298/93-26 (Reply to e Notice j of Violation) Gentlemen: i A During an NRC inspection conducted October 10 through November 20, 1993, violations of NRC requirements were identified in that inadequate review of work documents associated with the repair of Fire Door H305 resulted in a breach of the control room isolation envelope. The following is a statement- !} of the violation and our response in accordance with 10CFR2.201. l STATEMENT OF VIOLATION l .f Criterion V to Appendix B-of 10CFR50 states, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with l these procedures. 1 l Maintenance Procedures 7.0.1.1, " Maintenance Work Requests'- Work Item l Tracking Form Initiation and Review", and 7.0.1.2, " Maintenance Work Request - MSR Generation and Review", were issued by the licensee to prescribe the licensee's expectations for activities affecting quality in the maintenance area. Step 4.12 of Procedure 7.0.1.2 describes the shift supervisor's general responsibilities for activities on his shift. Step 4.3 of Procedure 7.0.1.1 requires the shift supervisor to review all Work Item Tracking Forms for operability issues. i contrary to the above, the shift supervisors in charge of the shifts on i November 18 and 19, 1993, failed to adequately review the work documents.. involved in che repair and testing of Fire Door H-305 and did not identify that this work resulted in a breach of the control room isolation envelope. . I i This is a Severity Level IV violation (298/93026-02)-(Supplement I)- l i l \\ 0 [_: [h\\ ... ~ ~ l 9402030159 940128 PDR ADOCK 05000298 v Q PDR
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s U. S. Nuclear Regulatory Commission January 28, 1994 Page 2 REASON FOR VIOLATION The reason for this violation is failure of the involved personnel to recognize that removal of Fire Door H305 degraded the control room isolation envelope. The work being performed on this door was a part of a large scale effort to ensure fire door operability that encompassed all plant fire doors. Since the focus for the corrective action effort which was underway was associated with fire barrier integrity, the significance of this door with regard to control room isolation envelope integrity was missed. Licensee Event Report 93-037 described the cause of this error'as programmatic in nature due to the fact that the personnel involved were not provided the necessary controls to ensure recognition of the additional functions of this door. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Fire Door H305 has been returned to service and the control room isolation envelope satisfactorily tested for pressure integrity. Furthermore, CNS Procedure 6.4.5.2.12, " Fire Door Annual Inspection", was revised to specifically identify those doors which form either the control room isolation, or the secondary containment, envelope. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS CNS Procedure 0.16, " Control of Fire Doors", will be revised to ensure clear identification of any additional critical door functions, such as secondary containment or control room pressure boundary. The labelling of plant doors will also be upgraded to show the functions each door performs. This will 4 further aid in the field identification of all door functions prior to performing any activity which might impair its design requirements. The appropriate plant personnel will be specifically trained on the described procedure revisions and the labelling enhancements. DATE WHEN FULL COMPLIANCE VILL BE ACHIEVED The described procedure revision will be approved and upgraded labelling installed by April 1, 1994. The training will be completed by May 31, 1994. In response to the concerns expressed in the Inspection Report cover letter, management is also very concerned about the weaknesses the NRC has identified with our maintenance planning process that allowed' work to be performed on a door which serves more than one function. The root cause analysis identified a programmatic problem; therefore, we believe the described corrective action will resolve this concern. However, to further ensure resolution, specific
O ~ U. S. Nuclear Regulatory Commission January 28, 1994 Page 3 training will be provided to the personnel involved in the maintenance planning process. Should you have any questions concerning this matter, please contact me. Sin rel, e. os---- R. Horn ic President-Nuclear cc: Regior.nl Administrator i USNRC - Region IV l NRC Resident Inspector Cooper Nuclear Station 1 r a t F l ,.}}