ML20141M527
| ML20141M527 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/27/1992 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9209010078 | |
| Download: ML20141M527 (2) | |
Text
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J-4 GENERAL OFFICE i
P.o. box 499 COLUMBUS, NEBRASKA 686024499 Nebraska Public Power District
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t August 27,1992 i
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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 i
l Gentlemen:
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Subject:
NPPD Response to Inspection Report 50-298/92-09 (Reply to a Notice of i
Violetion)
During an NRC Site inspection of training activities conducted June 22-26,1992, a violation was identified in that a CNS surveillance procedure did not fully meet the requirements for independent verification. Following is a statement of the violation and our response thereto in accordance with 10CFR2.201.
Statement of Violation l
Criterion V of Appendix B to 10CFR Part 50 requires that activities affecting quality shall be prescribed by documented. procedures, of a type appropriate to--the j
circumstances and shall be accomplished in accordance with these procedures.
Station Administrative Procedure 2.0.1, " Conduct of Operations,". Revision 14, Step I
8.14.1, required that independent verification shall be provided fbr main flow path i
valves in systems designed for accident mitigation.
t 3
Surveillance Procedure 6.2.2.3.4, "HPCI Suppression Chamber and ECST Water Level i
Calibration and Functional / Functional Test and Water Initiation," provided-instructions for aligning main flow path valves in the high pressure coolant injection j
system and the reactor core isolation cooling system.-
Contrary to the above, on June 11,1992, Procedure 6.2.2.3.4 was not appropriate in -
l that the procedure did not require independent verification:of the' position of the l-high; pressure coolant injection system and reactor core isolation. cooling system l
suction valves from the emergency condensate storage tank.-
F This is a Severity Level IV Violation (Supplement I) (298/9209-01).
Reason for Violation l
Surveilkmce Procedure 6.2.2.3.4 was deficient in that while the procedure addressed the opening _ of 'HPCI suction valve HPCI-MO and--RCICL suction valve -
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U.S. Nuclear Regulatory Commission Augyst 27,1992 Page 2 RCIC-MO 18, it did not require the position of either velve to be independently verified. Since both valves are in the main flow paths of their respective systems, the requirements for independent verification, as specified in Procedure 2.0.1, were not being met.
Corrective Steps and the Results Achieved Subsequent to discussions with the NRC inspectors who identified the procedural deficiency, a temporary change was made to Surveillance Procedure 6.2.2.3,4 to include steps for independent verification of valves HPCI-MO-17 and RCIC-MO-18.
A permanent change to Procedure 6.2.2.3.4 was also initiated.
Regularly scheduled (monthly) surveillance tests for July and August were conducted using the temporary procedure change. The permanent change was approved on August 6,1992.
Corrective Steps Which Will Be Taken To Avoid Further Violations Action is in progress to review CNS Surveillance Procedures, to verify that the required independent verification steps have been included. To date, the results of this review indicate that the situation described herein was an isolated occurrence.
Date Station Operator Compliance Will Be Achieved NPPD is currently in compliance with the requirements stated in the violation. The follow up action identified above will be completed by October 1992. In the interim, scheduled surveillance procedures will be checked prior to performing them to ensure that the proper independent verification steps are included.
Should you have any questions regarding this matter, please contact me.
Sinc > rely, t
GE Nuc ear Power Group Manager l
l GRH:js l
cc:
Regional Administrator U. S. NRC - Region IV i
l NRC Resident Inspector Cooper Nuclear Station
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