ML20215A183
| ML20215A183 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/19/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| CNSS866095, NUDOCS 8612110196 | |
| Download: ML20215A183 (3) | |
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GENERAL OFFICE r
Nebraska Public Power District
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CNSS866095 November 19, 1986 Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Subject:
NPPD Response to IE Inspection Report No. 50-298/86-26
Dear Mr. Gagliardo:
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This letter is written in response to your letter dated October 24, 1986, transmitting Inspection Report No. 50-298/86-26.
Therein you indicated that certain of our activities were in violation of NRC requirements.
The following includes statements of the violations and our response in accordance with 10CFR2.201:
Statement of Violation A.
Failure to Follow 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 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. CNS Procedure 2.2.33, "High Pressure Coolant Injection System", Appendix A. " Valve Checklist", requires that valves HPCI-129 and HPCI-130 be sealed open and valve HPCI-26 to be shut.
Contrary to the above, during the performance of System Operating Procedure 2.2.33, "High Pressure Coolant Injection System", Appendix A, " Valve Checklist", and during the conduct of Operation Procedure 2.0.2, " Operations Logs and Report", Section H, " Sealed Valve Log",
valves HPCI-129 and HPCI-130 valves were found open but unsealed, and valve HPCI-26 valve was found open.
This is a Severity Level IV violation.
(Supplement I.D)
(298-8626-02)
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fy%h 8612110196 861119 PDR ADOCK 05000298 G
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7, E. G:glicrds Ja P:g3 2 November l19, 1986 Reason For the Violation-HPCI-129 and 130 valves were found in the open position and unsealed, but are required to be sealed per Station Procedure 2.0.2, " Operations Logs and Reports". HPCI-26 valve was found in the open position, but is required to be in the closed position per Station Procedure 2.2.33, Appendix "A", " Valve Checklist". An investigation into the improper valve positioning and lack of lead seals was conducted, but no determination could be made relating to the as found condition of the valves.
Corrective Steps Which Have Been Taken and the Results Achieved The aforementioned HPCI system valves were properly positioned and lead seals installed. The Operations Supervisor discussed this event with Operations personnel during weekly crew meetings. These meetings should ensure no further violations in this regard occur.
Corrective Steps Which Will Be Taken to Avoid Further Violations All valves requiring-lead seals will be verified before startup from the current refueling outage.
Date When Full Compliance Will Be Achieved Full compliance will be achieved prior to startup from the current refueling outage.
Statement of Violation B.
Inadequate Review of Surveillance Test Results Appendix B, Criterion XI, of 10 CFR Part 50, and the licensee's approved Quality Assurance plan, require that test results be documented and evaluated to assure that test requirements have been satisfied. CNS Procedure 6.2.4.1P, " Daily Surveillance Log (Technical Specification)", Revision 54, dated July 10, 1986, states, on page 12 of 15, that core spray differential pressure instrumentation be logged and compared to the given acceptable limits of approximately -3.5 psid during normal operation or approximately +3.0 psid in case of a line break.
Contrary to the above, the recorded and accepted values on September 19, 1986, were -28 psid and 9 psid for trains "A" and "B" respectively.
This is a Severity Level IV violation.
(Supplement I.D)
(298/8626-03)
- ,.pJ. E. G:glicrdo P:ga 3 November 19, 1986 Reason for the Violation Core spray header differential pressure instrumentation check readings were incorrectly transferred by a station operator from Station Procedure 2.1.11
" Station Operators Tour", to Surveillance Procedure 6.2.4.1P,
" Daily Surveillance Logs".
The incorrect entries were reviewed and accepted by a station operator, control room supervisor, and shift supervisor. The failure to adequately document, review, and evaluate the core spray log entries resulted from a lack of attention and human error.
Corrective Steps Which Have Been Taken and the Results Achieved The Operations personnel involved in the event have been counseled by the Operations Supervisor.
In addition, Surveillance Procedure 6.2.4.1P has been revised to require the control room supervisor or shif t supervisor to review log entries transferred from Station Procedure 2.1.11 for their correctness. All shift supervisors were informed of this revision.
These corrective steps should ensure no further violations in this regard occur.
Corrective Steps Which Will Be Taken to Avoid Further Violations All corrective action for this event has been taken.
Date When Full Compliance Will Be Achieved Full compliance has presently been achieved.
If you have any questions regarding this response, please contact me or G. R. Horn at the site.
Sincerely,
&g J.
. Pilant Technical Staff Manager Nuclear Power Group JMP/MLS:chl(COMM12)