ML20199K829

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Submits Addl Info Supporting Commitment to Revise CPS Administrative Procedure 0.26, Surveillance Program to Eliminate Redundant Procedural Requirements Contained within Procedure 0.26 & Administrative Procedure 0.5
ML20199K829
Person / Time
Site: Cooper Entergy icon.png
Issue date: 11/24/1997
From: Graham P
NEBRASKA PUBLIC POWER DISTRICT
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-298-97-13, NLS970202, NUDOCS 9712010214
Download: ML20199K829 (3)


Text

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,mirOmura'a-Nebraska Public Power District T==""

_, ww wmeemm +====umm==wmmnw=~== mmm==s===ma NLS970202 November 24,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D C. 20555 0001 Gentlemen:

Subject:

Pcvision of Commitment Made in Reply to Notice of Violation Looper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

1. Letter to Document Control Desk (NRC) from Graham (NPPD) dated October 14,1997, " Reply to Notice of Violation"
2. Letter to G. R. Ilorn (NPPD) from A. T. Ilowell 111 (USNRC) dated September 12,1997,"NRC Inspection Report 50-298/9713 and Notice of Violation" 11y letter dated October 14,1997 (Reference 1), responding to a Notice of Violation (Reference 2), Nebraska Public Power District (District) committe to revise Cooper Nuclear Station d

Administrative Procedure 0.26," Surveillance Program to eliminate redundant procedural requirements contained within Procedure 0.26 and Administrative Procedure 0.5 " Problem identification and Resolution " The District instead, revised Procedure 0.26 to provide clear guidance for the use of the Discrepancy Sheet (Attachment 3 to Procedure 0.26) and reinforce that the use of the Discrepancy Sheet does not relieve the user from applying the requirements of Procedure 0.5, and generating a Problem Identification Report (PIR) when applicable. Additional information supporting this commitment change is provided below.

Procedure 0.26 contains a Discrepancy Sheet (Attachment 3) to document and link discrepancies

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and resolutions resulting from/during performance of a test. The marking of a procedural step as N/A without conditional direction within the procedure, and the discovery of failed equipment are p))

cach examples of a discrepancy. The Discrepancy Sheet provides a means to document each of 4

these conditions and their resolutions, and is intended to remain with the procedure to provide an y

auditable record of the performance of the procedure. The condition of failed equipment however, requires the generation of a PIR and further evaluation through the Corrective Action Program 9712010214 971124

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, NLS970202

'Novernber 24,1997 Page 2 of 2 With the revision of this commitment, in conjunction with the revision to Procedure 0.26, the District regards this issue as closed. Should you have any questions concerning this matter, please

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contact me.

Sincerely, hD $~

P. D Graham Vice President of Nuclear !!nergy

/rar cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate 1%1 Senior Resident inspector USNRC NPG Distribution

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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l

pqrrespondence No NLS970202 s..

The following table identifies those actions committed to by the District in this document.

Any other actions discussed in the submittal represent intended or planned actions by the District.

Tt.ey are described to the NRC for the NRC's information and are not regulatory commitments.

Please notif y the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory cortmit ments.

COMMITTED DATE COMMITMENT OR OUTAGE None gg i

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l PROCEDURE NUMBER 0.42 l

REVISION NUMBER 5 l

PAGE 9 OF 13 l

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