ML20118B109
| ML20118B109 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/18/1992 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS926741, NUDOCS 9209300082 | |
| Download: ML20118B109 (2) | |
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- z. a - w CNSS926741 Septe.aber 18, 1992 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 Centlemen:
Subject:
NPPD Response to Inspection Raport 50-298/92-11 (Reply to a Notice of Violation)
During sa NRC Site inspection of plant procedures and concerns related to energency operaring procedures conducted July 20-24, 1992, a violation of NRC requirements was identified. The violation involved the failure to maintain appropriate plant procedures.
Following is a statement of the violation and ur response thereto in accordante with 10CFR2.201, liLelfim!Lnt_ of ViolaliOD Technical Specif' cation 6.3.2 states that, " Written procadures and in s t.ruc t ion s including applicable check off lists shall be established, implemented, end maintained for the following:
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Emergency conditions involving possible or ctual releases of radiation materials."
Emergency Support Procedure ESP-5.8.11. "RPV Venting During Pri: nary C rtainment Flooding," was written to address a plant emergency condition.
Contrary to.'ie abcve, Procedure ESP-5.8.11 was not maintained, in that, on April 1, 1992, the licensee identified three cases in which procedural steps would not have worked under certain accident conditions, and tne procedure was not revised to correct the discrepancies.
rhis is a Severity Level IV violation (298/9211-01) (Supplement I).
Etagga lgLylglellgIl Emergency Support Procedure ESP-5,8.11 was not maintained in that procedural deficiencies identified du: ing the EOP Support Procedura Verification process were not corrected in a timely manner.
This vac due to t.he CNS EOP Maintenance Program not providing a process for expediting either temporary or permanent procedure changes to individual Emergency Support Procedures.
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Nuclear Regulatory Commission September *17, 1992 Page 2 Corrective Steps Taken ar.d the Results Achieved Prior to this Inspection, the CNS E0P Maintenance Team was in the proces, of revising Procedure 0,22, " Emergency Operating Pro..edure Maintenance Program" to provide a means for expediting procedure changes to the E0Ps.
Subsequent to discussions with the NRC inspector who identified the procedural deficiency, this work was accelerated. On July 23, 1992 Procedures 0.22 (Revision 5) and 0.22.1, "EOP Temporary Procedure Changes" (Revision 0) were approved.
These revised procedures streamline the E0P revision process by allowing for both temporary and permanent revision of individual Emergency Support Procedures.
On July 24 an E0P Temporary Change was performed or. Procedure ESP-5.8.11 to correct the technical deficiencies.
Corr'ctive St.ep_s_Which Will Be Taken To Avoid Further Violations To ensure that EOPs and their support procedures are maintained. Procedure 0.22 will be revised to provide additional guidance for assigning priority for procedure revis,,n.
This guidance will identify Emergency Support Procedures that contain technical errors as requiring immediate revisien.
This change, in conjunction with existing Procedurn 0.22.1, will provide timely procedure revisions.
Date When Full Cornpliance Vill Be Achieved NPPD is currently in compliance with the requirements stated in the violation.
The follow-up action identified above will be completet by December 25, 1992.
Should you have any questions regarding this matter, ploase contact me.
Sin erely.
ln G.(
Ho'rn Nuc ear Power C oup Manager CRH:db:js cc:
mgional Administrator l'
S. NRC - Region IV NRC Resident Inspector Cooper Nuclear Station