ML20199J119

Responds to NRC Re Violations Noted in Insp Rept 50-298/86-13.Corrective Actions:Work Item 83-2112 Revised, Document List Will Be Added to Design Change 80-84 & Engineering Procedure 3.4 Will Be Revised

ML20199J119
Person / Time
Site:	Cooper
Issue date:	06/12/1986
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20199J105	List: IR 05000298/1986013 ML20199J119
References
CNSS867506, NUDOCS 8607080126
Download: ML20199J119 (4)

Text

--

g*.

h Nebraska Public Power District """faidhk%hbM"**"""

CNSS867506 June 12,1986 3@ 3 0W/2 V Mr. J. E. Gagliardo, Chief dM l b M Reactor Projects Branch ~ y U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to Inspection Report 50-298/86-13

Dear Mr. Gagliardo:

This letter is written in response to your letter dated May 13, 1986, transmitting Inspection Report 50-298/86-13. Therein you indicated that one of our activities was in violation of NRC requirements.

Following is a statement of the violation and our response in accordance with 10CFR2.201.

STATEMENT OF VIOLATION Failure to Fully Implement the Design Change Procedure 10CFR Part 50, Appendix B, Criterion III and the licensee's approved quality assurance program require that measures be established to assure that plant changes are properly controlled.

Procedure E.P. 3.4, " Station Design Changes". Revision 3, dated December 26, 1985, implements design change control and requires that:

any changes to equipment and systems be documented in a design change package (paragraphs I. A and II.F.1.a),

the design change package identify the documents required to be changed as a result of the particular design change (paragraph IV. A.11.a).

a final review by the design engineer be performed prior to implementation of the change (paragraph III. A.2.d.4)a), and a " Status Report" be submitted following installation, for turnover to the Operations Department (paragraph IV. A).

8607080126 860624 0 k PDR ADOCK 0000

r

=,

• J. E. Gaglicrdo Page 2 June 12, 1986 Contrary to the above, it was found that:

a plant change was made under Work Item No. 83-2112 which was not documented in a design change package, an open design change package, No.80-084, did not identify the procedures that would be required to be changed, a design change package, No.80-084, did not have a final review by the design engineer although it was implemented, and no " Status Report" was issued folicwing installation of Design Change No. 85-44, for turnover to the Operations Department.

This is a Severity Level IV violation (Supplement I.D.)(50-298/8613-01).

Reason for the Violation The statement of violation correctly describes the dwign change control deficiencies identified during the inspection.

The District attributes the deficiencies to a lack of explicit procedural guidance and to personnel failing to strictly adhere to the procedural guidance that was provided.

Corrective Steps Taken and Results Achieved The following correspond to the items in the Statement of Violation.

a. When discovered, Design Change (DC) 83-23 and Work Item (WI) 83-2112 were reviewed by a design engineer and, per Engineering Procedure 3.4, a change was generated to properly reflect the action taken in the Work Item. Although not formally documented, management and Operations were aware of the open status of this Design Change and that completion of the activity was scheduled during the October, 1986 plant refueling outage. It was pointed out to the inspector that management was previously made aware that the Updated Safety Analysis Report (USAR) revision to reflect this change had been made prematurely and that a correction would be made in the 1986 USAR submittal.

b. As identified by the inspector, DC 80-84 referenced drawing additions and delettone as the only document changes. Discussions with the system engineer have since pointed out that this u

c

• J. E. Gaglicrdo Page 3 June 12, 1986 was an installation of new equipment to the plant.

Consequently, new operating and surveillance procedures could not be readily identified when the DC was generated. These procedures were developed and incorporated in DC 80-84, Amendment 1, on April 9,1985. However, the changes to existing procedures for the original equipment should have been identified by the Design Change documents. The affected documents and procedures are presently being identified by the system engineer and will be added to the design document in accordance with Engineering Procedure 3.4.

c. As identified by the inspector, the " design engineer signature prior to implementation" had not been signed for DC 80-84. The system engineer immediately generated Nonconformance Report 5034 to document the problem. After reviewing the DC and work performed to date, the system engineer signed the checklist.

d. As identified by the inspector, no status report was issued for DC 85-44. Engineering Procedure 3.4 did not provide explicit direction that a status report be submitted for all design changes. A status report provides interim progress of a design change until a completion report is generated. Since the DC 85-44 Completion Report was closed out December 2, 1985, no further action is necessary for this specific design change.

Corrective Steps Which Will Be Taken to Avoid Further Vlointions The following correspond to the items in the Statement of Violation.

a. An on-the-spot change was generated to DC 83-23 to properly document the work performed on W1 83-2112 No further corrective action is necessary for this specific design change,

b. The system engineer is identifying a document list which will be added to DC 80-84. The current revision of Engineering Procedure 3.4 provides a more detailed list of documents the design engineer should consider than was previorsly available when DC 80-84 was originally written.

Following incorporation of the document list to DC 80-84, no further corrective action is necessary for this specific design change.

E .. .

J. E. Gagligrdo Page 4 June 12, 1986 .

c. In addition to the disposition of DC 80-84, Nonconformance Report 5034 also requires a review of all other work-in-progress design changes to ensure these design changes are reviewed and properly dispositioned. It should be noted that since September,1985, the design engineer signature has been administratively controlled on all design changes without incident.

Consequently, no further corrective action is considered necessary for this specific design change.

d. Engineering Procedure 3.4 is being revised to clearly state that a status report will be submitted for all completed design changes within ten working days or prior to plant startup, whichever occurs first.

In summary, the findings in this violation were the result of a dated design change program that has since undergone many revisions to alleviate the deficiencies noted by inspection Report 50-298/86-13. This more definitive design change program provides more specific programmatic controls for the design change process, particularly in the document listing and administrative control areas.

Although the design engineers were involved with and were knowledgeable of the design change procedure revision that incorporated the specific programm9 tic improvements, to further enforce their knowledge of the design change process, the current revision will again be routed and formally documented.

Date When Full Compliance Will Be Achieved The present CNS design change program is in full compliance with 10CFR Part 50, Appendix U, Criterion III.

Additionally, the DC 80-84 document listing, review of work-in progress design changes, and the 3.4 procedure revision will be completed by July 31, 1986.

Should you have any questions regarding this response, please contact me.

Sincerely, a

J. M. Pflant Technical Staf Manager Nuclear Power Group JMP:JRF:lk12/4(COMM10)

_ _ _ _ _ _ _ _ . _ _ ___