ML20082L226
| ML20082L226 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/17/1995 |
| From: | Mueller J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS950088, NUDOCS 9504210053 | |
| Download: ML20082L226 (4) | |
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COOPER NUCLEAR STATON P.o. DOX 98, BRoWNVILLE. NEBRASKA 68321 Nsbraska Public Power District
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NLS950088 March 17, 1995 U. S. Nuclear Reguic*ory Cmumission Attention: Document Control Desk Washington, DC 20555
Subject:
Reply to Notice of Violation NRC Inspection Report No. 50-298/95-01 Gentleaen:
The Nebraska Public Power District (District) hereby submits its response to the Notice of Violation (NOV) transmitted with NRC Inspection Report No. 50-298/95-01. This inspection report documents the results of the NRC inspection conducted by Mr. Elmo E. Collins from January 16 through February 1, 1995, on activities authorized at Cooper Nuclear Station (CNS).
The NRC identified one violation during its inspection of CNS.
An explanation of the violation and corrective actions taken and planned in response to the violation is presented below.
Statement of Violation (50-298/9501-02)
Criteria V of Appendix B to 10CFR50 states, in part, activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures.
1.
Procedure 3.7, ' Drawing Change Notice, " Revision 8, dated October 11, 1994, Step 8.4.3, requires an engineering justification for drawing changes when a modification is not listed.
The engineering justification is to be written in Section III of the drawing change notice form. Step 2.7 defines an engineering justification as a technical explanation why a change was not the result of a modification document.
Contrary to the above, the engineering justifications for Drawing Change Notices C94-1671, dated December 2, 1994, and C94-1669, dated December 2, 1994, were not documented in Section III of the drawing change notice form; the engineering justification for Drawing Change Notice C94-1587, dated October 28, 1994, listed only a condition report number; and the engineering justification of Drawing Change Notice C91-1712, dated December 18, 1994, did not discuss why the change was not the result of a modification document. No modifications were listed for these drawing change notices.
2.
Procedure 3.4.7, ' Design Calculations, " Revision 7, dated November 23, 1994, Attachment 2, requires that affected calculations be listed and indicated as C - Change, A - Addition or D - Deletion.
Contrary to the above, Calculation NEDC 92-050BA, 9002 XX Disch Hin Flow Control Setpoint Calculation, RHR-DPIS-125A, RHR DPIS 125B, " Revision 0, dated December 30, 1994, and Calculation NEDC 94-258, Tech. Spec.
Acceptance Criteria of LPCI Pumps Flowing at 7,800 GPH, " Revision 0, dated December 13, 1994, listed affected calculations but did not indicate if they were a C - Change, A = Addition, or D - Deletion.
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N[S950088 March 17, 1995 Page 2 Admission or Denial of the Violation The District Admits the violation.
Reason for the Violation The reason for the violation was management's failure to clearly communicate and enforce expectations regarding the improvements in configuration control of Drawing Change Notices (DCNs) and calculations.
An investigation to determine the cause of the failure to follow Procedure 3.7 found that:
1)
Between October ll, 1994 (the effective date of Revision 8 to Procedure
- 3. 7), and January 31, 1995, there were 645 DCNs approved; approximately 30% of these, which amounted to about 194, were DCNs that required Engineering Justifications.
2) 55 out of those 194 DCNs (approximately 28%) did not adequately address Engineering Justifications per Section 8.4.3 of Revision 8 to Procedure 3.7; these 55 DCNs encompass the five (5) cited in the violation.
3)
On January 31, 1995, the NED Manager discussed with the NED Supervisors the importance and method of providing Engineering Justifications for DCNs.
In addition, the NED Manager issued a memorandum reminding them of the need to properly document the Engineering Justification on the DCN form.
4)
Since January 31, 1995, there have been 380 DCNs approved, all of which provided an Engineering Justification when required.
Procedure 3.7, Revision 8 was reviewed to determine its adequacy and clarity in providing guidance with respect to the Engineering Justification process for DCNs The review showed that the guidance prescribed in Section 8.1.4 regarding Engineering Justification contradicted the requirement provided in Section 8.4.3 of the procedure.
Section 8.4.3 (which references Section 8.1.4) prescribes a requirement for the NED Engineering Supervisor to provide an Engineering Justification in Section III of the DCN form when a modification is not listed; however, Section 8.1.4 of the procedure implies that an Engineering Justification is required only if the drawing change reflects a change in the configuration of the plant.
Conflicting requirements in Sections 8.1.4 and 8.4.3 of the procedure may have misled the engineers as j
to when an Engineering Justification was required. Also,Section III of the DCN form (Attachment 1 to Procedure 3.7) was not clear in providing the conditions under which an Engineering Justification would be required.
Regardless, management's expectations regarding the outcome of the revised procedure were not clearly communicated, followed up, and reinforced.
An investigation to determine the cause of the failure to follow Procedure 3.4.7 and adequately address calculation control activities found that:
1)
Between November 23, 1994 (the effective date of Revision 7 to Procedure 3.4.7), and January 31, 1995, there were 67 calculations issued; approximately 13% of these, which amounted to nine (9), did not contain the appropriate data entry codes. These nine (9) calculations encompass those two cited in the violation.
2)
On January 31, 1995, the NED Manager personally add _., sed the NED Supervisors on the importance and method of filling out Cross Reference Index forms.
i 3)
Since January 31, 1995, there have been 104 calculations issued all with proper data entry codes.
Procedure 3.4.7 was reviewed for adequacy.
The Cross Reference Index form in the procedure contained a single column to provide both the document identification and the appropriate data entry code.
The review indicated that
t NLS950088 March 17, 1995 Page 3 the. Cross Reference Index Form in the procedure lacked proper human factoring by its absence of a separate column for the entry of data entry codes (A, C, or D) for both the " Source Documents" and the "Affected Documents." A separate column would prompt the engineer to provide the data entry codes. As in the previous example, management did not clearly communicate, follow up, and reinforce its expectations regarding improvements to calculation configuration control.
Immediate Corrective Actions and Results Achieved The following immediate actions have been taken:
1)
Sections 2.7, 8.1.4, 8.1.5 and 8.4.3 of Procedure 3.7 were revised to eliminate contradictions with respect to the Engineering Justification process for DCNs.
In addition, the DCN Form in Procedure 3.7 has been revised to clarify the conditions under which an Engineering Justification is required.
2)
A total of 1025 DCNs approved since October 11, 1994 have been reviewed per Procedure 3.7.
This review revealed no concerns with design basis violations.
3)
The Nuclear Engineering Department (NED) Manager issued a memorandum on January 31, 1995 reminding the NED supervisors of the need to properly document the Engineering Justification review on the DCN Form per Procedure 3.7.
4)
Separate columns for data entry codes have been added on the Cross Reference Index Form of Procedure 3.4.7.
5)
The Cross Reference Index forms for the nine (9) calculations have been corrected by filling in the appropriate data entry codes.
Actions Taken to Prevent Recurrence The District's Nuclear Power Group is continuing to focus on management expectations in its daily routine, development and implementation of Phase II and III plans, and specifically in the Engineering Reorganization effort.
Date When Full Comoliance Will Be Achieved Presently CNS is in full compliance with 10CFR, Part 50, Appendix B, Criteria V.
I Additionally, it is our understanding that, at the February 1, 1995, exit, we stated that we would provide a presentation on the District's plans for improvements to the CNS technical specifications.
This presentation is currently scheduled for the first week in May.
If there are any questions regarding the information presented on these matters, please contact me.
}h=b J ohn H. Mueller Site Manager
/nr cc:
Regional Administrator USNRC - Region IV Arlington, Texas NRC Resident Inspector Cooper Nuclear Station NPG Distribution
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LIST OF NRC COMMITMENTS l ATTACHMENT '
l Cor'respondence No: NLS 950088 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITME!!T OR OUTAGE l
None l
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l PROCEDURE NUMBER 0.42 l
l PAGE 10 OF 16 l
REVISION NUMBER 0
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