ML20206E974

Responds to NRC Re Violations Noted in Insp Rept 50-298/87-06.Corrective Actions:Two Instruments Recalibr & Documented,Event Discussed W/Operations Dept Manager, Instrument & Control Supervisor,Foreman & Technicians

ML20206E974
Person / Time
Site:	Cooper
Issue date:	04/08/1987
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CNSS874167, NUDOCS 8704140035
Download: ML20206E974 (2)

Text

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GENERAL OFFICE Nebraska Public Power District "" * ""#Edo"~'e"S4'*"% '** *"

a CNSS874167 April 8, 1987 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Subject:

NPPD Response to IE Inspection Report No. 50-298/87-06 Gentlemen-This letter is written in response to your letter dated March 16, 1987, transmitting Inspection Report No. 50-298/87-06. Therein you indicated that one of our activities was in violation of NRC requirements.

The following is the statement of the violation and our response in accordance with 10 CFR 2.201:

Statement of Violation Failure to Follow a Maintenance and Test Equipment Procedure Appendix B Criterion V of 10 CFR Part 50 and the licensee's approved Quality Assurance Program require that activities affecting quality be accomplished in accordance with the drawings and procedural instructions.

CNS Procedure 0.4, " Preparation, Review, and Approval of Procedures,"

Revision 7, dated July 2, 1986, states that approved written station procedures shall be adhered to by all station personnel. Instrument and Control Procedure 7.5.4.2, " Pressure Test Gauge Calibration," Revision 19, dated May 1, 1986, requires that calibration data be recorded in the appropriate as-found and as-left data blank.

Contrary to the abeve, page 11 of Attachment "B" to Instrument and Control Procedure 7.5.4.2 performed on December 16, 1986, failed to have data for the zero calibration point recorded in the as-found and as-lef t data blank, and page 31 of the above named procedute for the same date also failed to have data for the zero calibration point recorded in the as-left data blank.

This is a Severity Level IV violation. (Supplement I) (298/8706-04) 8704140035 870408 PDR ADOCK 05000299 DI G PDR p

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_ LApril:8,-1987 P:ga 2 Reason For The~Violatidn Attachment."B" of Instrument and Control (I&C) Procedure.7.5.4.2, " Pressure

- Test Gauge Calibration," performed on December 16, 1986, failed to have-the as-found and as-left data recorded on.page 11 for the zero calibration

. point. _ In addition, page 31 of the- above named procedure and performance Ldata failed to : have the as-left data ' recorded - for the zero calibration point. The reason for :this violation is personnel error in completing and reviewing the data sheet in accordance with procedures.

Corrective Stepe Which Have'Been Taken And The Results Achieved The two instruments which were calibrated per page 11 and 31 of Attachment "B" of I&C Procedure 7.5.4.2 on December 16, 1986, have been re-calibrated

.and this calibration properly' documented.

' Additional corrective steps taken have been the discussion of the event by the Operations Department Manager and I&C Supervisor with the I&C-Foremen. The foremen were counseled on the importance of completing a thorough review and evaluation of those I&C procedures requiring a review subsequent to ~ the completion of the testing accomplished in the procedure. Further discussion of the event took place between I&C Foremen and I&C Technicians. During these discussions, the technicians were-counseled- on -the importance of recording data per _ station procedural requirements. Both of--these actions should ensure Ldata is recorded properly ~ by .I&C Technicians per station procedural requirements and that the required procedural review and evaluation takes- place to verify necessary data has_been recorded.

~ Corrective Steps Which Will Be Taken To Avoid Further Violations All I&C procedures requiring review subsequent to completion of the testing accomplished in the procedure will have the signoff space stating " Reviewed By",. changed to " Test Complete and Reviewed". This corrective step will require a review to - be performed and documented before the procedure is to be considered fully completed.

Date When Full Compliance Will Be Achieved Full compliance will-be achieved by August 1, 1987.

G. A. Trevors Division Manager Nuclear Support

/rg

.cc: U.S. Regional Office Region IV Resident Inspector Cooper Nuclear Station