NLS8600047, Responds to NRC Re Violations Noted in Insp Rept 50-298/85-30.Corrective Actions:All Discrepancies Noted in Future Site Tour Surveillances Will Be Reported & Documented Per Facility QA Program
| ML20141N220 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/06/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20141N218 | List: |
| References | |
| NLS8600047, NUDOCS 8603040509 | |
| Download: ML20141N220 (3) | |
Text
.
3m GENERAL OFFICE 3
Nebraska Public Power District
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NLS8600047 3@30W3 %
February 6, 1986 FEB I Oi986 h,!
Mr. J. E. Gagliardo, Chief Reactor Projects Branch U.S. Nuclear. Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011
Dear Mr. Gagliardo:
Subject:
NPPD Revised Response to IE Inspection Report No. 50-298/85-30 This revised response to Inspection Report 50-298/85-30 is being submitted in accordance with your letter of January' 27, 1986.
The section entitled "The Reason for the Violation if Admitted" has been added.
STATEMEN] OF VIOLATION -
10 CFR Part 50, Appendix B, Criterion V and the licensee's approved quality assurance program require that activities affecting quality be performed in accordance with approved procedures, instructions, or drawings.
Quality Assurance Instruction, " General Guidelines - Quality Assurance Surveillance," QAI-4, Revision 13, dated August 30,1985, paragraph 4.0 states, in part, " Findings will be identified on a QA Audit / Surveillance Report Form.
These reports shall be used : as soon as possible after completion of the surveillance with -the distribution being as follows:
Contrary to the above, findings were not always being identified on a "QA.; Audit / Surveillance Report Form." _It was observed that two' recent surveillances performed on August 4 and 30,- 1985, to checklist No. 800-31both noted discrepancies to the checklist requirements in that fire protection equipment was obstructed, blocked or otherwise had restricted access.
These results were not reported or identified as findings.
'0603040509 B60224-T PDR ADOCK 05000298:
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" Mr. J. E. Gagli rdo Page 2 February 6, 1986 The Reason for the Violation if Admitted NPPD is in agreement with the findings identified in this violation.
A review of the violation for determination of cause indicates that during the initial development of the site tour surveillances, observations such as those identified were handled on an immediate basis, where they were brought to the responsible individuals attention and taken care of immediately.
Later in the evolution of the site tour surveillances it was recognized that there was a need to assure management awareness of these observations and the practice of distributing the surveillances to the appropriate managers was implemented.
On the infrequent occasions when the disposition of an observation was felt to be inadequate or an observation was recognized as being recurring, a QA Observation / Finding Report was issued.
Through this development process of the site tour surveillances, issuance of QA Observation / Findings Reports for certain observations such as those identified, regardless of the promptness and effectiveness of actions taken, was overlooked.
It is recognized that, although adequate actions were taken on the observations, we were in viointion of our QA Program.
Corrective Steps Which Have Been Taken and the Results Achieved This violation has been reviewed with the CNS QA Staff along with the applicable criterion of-10 CFR 50 Appendix B, QAI-4 and the definition of findings and observations as defined in QAI-5, Revision 19.
All site tour surveillances conducted by the CNS QA Staff since July 1, 1985 were reviewed.
The results of that review found that all discrepancies which ha c' been identified durirg that time frame were appropriately dispositioned.
Corrective Steps Which Will be Taken to Avoid Further Violations All discrepancies noted in future site tour aurveillances will be reported and documented in accordance with the CNS Quality Assurance Program.
Date When Full Compliance Will be Achieved We are presently in full compliance.
M* '" 7 Mr. J. E. _ Gagli:rdo Page 3 February 6, 1986' If you have any questions regarding this response, please contact me.
Sincerely, M
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- 1. Pilant Technical Staff Manager Nuclear Power Group JMP/GMC/VLWidh4/5(14A) 3 I
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