ML20212C309
| ML20212C309 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/24/1987 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS875611, NUDOCS 8703030755 | |
| Download: ML20212C309 (3) | |
Text
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g COOPER NUCLEAR STATION g
Nebraska Public Power District
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CNSS875611 February 24, 1987 a
U; S. Nuclear Regulatory Commission Document Control Desk Washington D. C.
20555 Subjectr NPPD Response to IE Inspection Report No. 50-298/86-36 Denr. 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 statements 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.
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 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 i
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 by'the NRC Res' dent Ittapector as an apparent violation.
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kDocument Control Dazk February 24, 1987 Page'2 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,
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this review was not corisidered 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 ISC 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 b
I for fuel handling operations, t
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CNS Nuclear Performance Procedurd (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 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.
This is a Severity Level IV violation.
(Supplement I.D.) (298/8636-03) t
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o Document Control D; k February 24, 1987 Page 3 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.
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 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 G. R. Horn at the site.
Sincerely, f
i re ors Division Manager of Nuclear Support GAT:EMM:RB:ya ec:
U. S. Nuclear Regulatory Commission Regional Office - Region IV Resident Inspector t
Cooper Nuclear Station i
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