ML20207R201
| ML20207R201 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/11/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8703160104 | |
| Download: ML20207R201 (1) | |
See also: IR 05000298/1986036
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In Reply Refer To:
Docket: 50-298/86-36
Nebraska Public Power District
ATTN: George A. Trevors
Division Manager - Nuclear Support
P. O. Box 499
Columbus, NE
68601
Gentlemen:
Thank you for your letter of February 24, 1987, in response to our letter
and Notice of Viction dated January 28, 1987. We have reviewed your reply
and find it responsive to the concerns raised in our Notice of Violation. We
will review the implementation of your corrective actions during a future
inspection to detennine that full compliance has been achieved and will be
maintained.
Sincerely,
Orl;;!nd Signed By
J. E. Gagilardo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Guy Horn, Division Manager
of Nuclear Operations
Cooper Nuclear Station
P. O. Box 98
Brownville, Nebraska
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February 24, 1987
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Subject: NPPD Response to IE Inspection Report No. 50-298/86-36
Dear Sir:
This letter is written in response to your letter dated January 28, 1987,
transmitting IE Inspection Report No. 50-298/86-36. Therein you indicated
that certain of our activities were in violation of NRC requirements.
Following are the statementa of the violations and our responses in accordance
with 10 CFR 20.201:
Statement Of Violation
Failure to Have Documented Procedure Evaluation
Appendix B, Criterion XI, of 10 CFR Part 50, and the Licensee's approved
Quality Assurance Plan require that test results shall be documented and
evaluated to assure that test requirements have been satisfied.
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Contrary to the above, test results contained in Instrument and Control
Procedure 7.5.2.1, Attachment "A" were not reviewed in four instances,
and test results in Instrument and Control Procedure 7.5.2.4, were not
documented as reviewed in two instances during the time frame from
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September 1985 to December 1986.
This is a Severity Level IV violation.
(Supplement I.D.)(298/8636-02)
Reason For The Violation
Attachment "A" of Instrument and Control (I&C) Procedure 7.5.2.1, "SRM
Quarterly Calibration Procedure", Revision 13, dated October 30, 1986, and
Attachment "A" of I&C Procedure 7.5.2.4, "APRM Calibration Procedure",
Revision 12, dated June 19, 1986, failed to have the " reviewed by" signature
block and "date" block completed. The failure to document the review of
Attachments "A" of these procedures per the requirements of Appendix B,
Criterion XI, of 10 CFR 50, and the NPPD Quality Assurance Plan was identified
bv 'the NRC Resident Inspector as an apparent violation.
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This violation was due to a procedural inadequacy in that the test results
were meant to be reviewed after the test procedure was completed. Therefore,
this review was not considered to be an integral part of the test procedure.
An additional factor in the instance cited, was the fact that these procedures
were performed as an integral part of yet another CNS procedure and the
appropriate technical specification data was transferred to this procedure,
reviewed and signed by the Shift Supervisor.
Corrective Steps Which Have Been Taken And The Results Achieved
The Operations Department Manager and the I&C Supervisor discussed the
occurrence with I&C Department Foremen.
The foremen were counseled on the
importance of completing a thorough review and evaluation of those I&C
procedures requiring review subsequent to completion of the testing
accomplished in the procedure.
It was stressed that these I&C procedures are
not to be considered fully completed until a review is completed and
documented. The foremen were also advised of Appendix B, Criterion XI to 10 CFR 50 requirements and NPPD Quality Assurance Plan requirements regarding
documentation and evaluation of test results. These corrective steps will
ensure that reviews involving I&C procedures are completed and properly
documented.
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 existing " Reviewed By" signoff
space 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 October 1,1987.
Statement Of Violation
Failure to Follow Procedure
Technical Specifications, paragraph 6.3.2.A. requires that written
procedures and instructions be established, implemented, and maintained
for fuel handling operations.
CNS Nuclear Performance Procedure (NPP) 10.25, " Refueling", Revision 7,
dated December 10, 1986, requires in Section VII.A.2 that the licensee
verify that the procedures in the operations refueling floor procedure
book are of the latest revision and update as necessary.
Contrary to the above, on December 16, 1986, four days after the start of
refueling operations, the licensee had NPP 10.25, Revision 6, dated
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August 7, 1986, in the operations refueling floor procedure book during
refueling operations when the required revision should have been
Revision 7, dated December 10, 1986.
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This is a Severity Level IV violation.
(Supplement I.D.) (298/8636-03)
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Reason For The Violation
CNS Nuclear Performance Procedure (NPP) 10.25 in Section VII.A.2 requires the
procedures in the operations refueling floor procedure book be of the latest
. revision and that they be updated, as necessary. On December 16, 1986, a
review of procedures being used on the refueling floor revealed that NPP
10.25, " Refueling", was Revision 6, dated August 7, 1986, while the latest
~ issued revision of NPP 10.25 was Revision 7, dated December 10, 1986. The
failure to verify that NPP 10.25 in the operations refueling floor procedure
book was of-the latest revision as required by NPP 10.25 has been identified
as a procedural violation in that the personnel involved did not follow the
guidelines in Section VII.A.2.
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Corrective Steps Which Have Been Taken And The Results Achieved
Revision 7 to NPP 10.25, " Refueling", was immediately placed in the' operations
refueling floor procedure book. A subsequent review was conducted of the
changes made to NPP 10.25 by Revision 7 and it was determined that failure to
have the correct revision on the refueling floor.had no impact on the fuel
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moves that had been completed.
Corrective Steps Which Will Be Taken To Avoid Further Violations
The Control Room Procedure Distribution List has been changed to require that
the refueling floor procedure book also be included for updates. This method
has worked well for control and distribution of procedures for the control
room procedure books and will ensure that the refueling floor procedure book
is also kept up to date.
Date When Full Compliance Will Be Achieved
Cooper Nuclear Station is currently in full compliance.
If you have any questions regarding this response, please contact me or
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G. R. Horn at the site.
Sincerely,
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Division Manager of
Nuclear Support
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cc: U
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Regional Office - Region IV
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Resident Inspector
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Cooper Nuclear Station
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