NLS8500194, Responds to NRC Re Violations Noted in Insp Rept 50-298/85-16.Corrective Actions:Qa Instructions QAI-4,QAI-5 & QAI-10 Will Be Revised to Identify Proper Distribution & Contractor Will Rereview NDE Documentation
| ML20133E171 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/31/1985 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20133E165 | List: |
| References | |
| NLS8500194, NUDOCS 8510090300 | |
| Download: ML20133E171 (3) | |
Text
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GENERAL OFFICE Nebraska Public Power District
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NLS8500194 July 31,1985 Y $ D [j' 'R D
f 3 l AUG - 5 995 L' I Mr. E.11. Johnson, Chief
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Reactor Project Branch I U. S. Nuclear Regulatory Commission Region IV
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611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Dear Mr. Johnson:
Subject:
Nebraska Public Power District Response to IE Inspection Report No. 50-298/85-16 This letter is written in response to your letter dated July 2,
- 1985, transmitting Inspection Report No. 50-208/85-16.
Therein you indicated that two of our activities were in violation of Nuclear Regulatory Commission requirements.
The following are statements of the violations and our response to each in accordance with 10CFR2.201:
1.
Statement of Violation Failure to Follow Procedure 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by and accomplished in accordance with appropriate documented instructions, procedures, or drawings.
The "CNS Quality Assurance Policy Document," Section 2.15, requires that the Nonconformance Report form, which is Attachment "A" to CNS Administrative Procedure 0.5, shall be used by all station personnel to record and report nonconforming conditions.
Contrary to the above, licensee QA department personnel did not record and report " Findings" (e.g., nonconformances) using Attachment "A" to l
CNS Administrative Procedure 0.5 This is a Severity Level V Violation.
(Supplement I.E.)
(208/8516-01)
Corrective Steps Which IIave Been Taken and the Results Achieved The CNS Quality Assurance Policy Document Rev. 2 Section 2.15 states, "the NCR form identified in CNS Administrative Procedure 0.5 shall be used by all persons performing operation, maintenance, and quality control functions...".
This statement does not indicato nor is it l
intended to indicate that the Nonconformance Report (NCR) form i
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PDR ADOCK 05000298 G
Bir>. E.11. Johnson, Chief Page 2 July 31, 1985 identified in CNS Administrative Procedure 0.5 is to be used by Quality Assurance to identify findings resulting from QA Audits and Surveillances.
As identified within the body of IE Inspection Report #85-16, findings identified by QA Audits and Surveillances are reported on a "QA Audit / Surveillance Report" form.
It is recognized,
- however, that the distribution of "QA Audit / Surveillance Report" forms identified in Quality Assurance Instructions QAl-4, Rev. 12 and QAI-5, Rev. 18 is inadequate for compliance with CNS Technical Specifications.
Quality Assurance Instructions QAI-4, QAI-5 and QAl-10 will be revised to identify proper distribution to ensure that CNS Technical Specification violations identified in QA audit and surveillance findings receive the same level of management review (including SORC) as do nonconformance reports issued in accordance with CNS Administrative Procedure 0.5.
Corrective Steps Which Will be Taken to Avoid Further Violation No further corrective actions beyond those discussed above are planned at this time.
Date When Full Compliance Will be Achieved Full compliance will be achieved by September 1,1985.
2.
Statement of Violation incomplete Test Records 10 CFR Part 50, Appendix B, Criterion XVII, requires that inspection and test records identify the inspecto, acceptability of test results, and corrective actions taken to correct deficiencies.
Contrary to the above, the licensee failed to provide all required information on, and the acceptability status of, radiographic reader sheets.
This is a Severity Level V Violation.
(Supplement 1.E.)
(298/8516-02)
Corrective Steps Which IInve Been Taken and the Results Achieved The inadequacy of the nondestructive documentation provided by our IGSCC pipe replacement and inspecting contractor, as disclosed during the on-site audit, has been acknowledged and immediate corrective action was taken to correct current inadequacies and to prevent recurrence on future radiograph reports.
The contractor's Quality Assurance Department was instructed and did perform a complete detailed review of all nondestructive examination records, including radiographic film and Task Work Traveler documents, to correct and/or incorporate all incorrect or incomplete items.
This review included the radiographic film, records and travelers associated with the NRC audited documents.
The items corrected during said review include; welder I.D., traveler sequences, rarliographic film reshot i
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,, 31c. E.11. Johnson, Chief Page 3 July 31, 1985 and repair labeling, number of films per report, verifict. tion that all location intervals were addressed on radiographic reports, verification that all areas were evaluated (acceptable or reject) on radiographic reports, maintenance of exact copies of reports with film and the associated traveler, and clerical corrections as required.
In addition to the contractor's re-review of the nondestructive documentation the District established an independent review group to review all contractor Task Work package documentation, including nondestructive examination reports, to insure the as received documents were complete and accurate.
It is believed that the two additional reviews of the nondestructive documentation discussed in this response has provided the necessary corrective action to assure the adequacy of exist'ag records and eliminate recurrence of the identified discrepancies with future nondestructive examination test records.
Corrective Steps Which Will be Taken to Avoid Further Violations No further corrective actions beyond those discussed above are planned at this time.
Date When Full Compliance Will be Achieved The District is currently in full compliance.
If you have any questions regarding this response, please contact me.
Sincerely, A. # h
. M. Plant Technical Staff Manager Nuclear Power Group JMP/GHH/ GAT:mh31/2 (15)