ML20246E696
| ML20246E696 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/23/1989 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8908290263 | |
| Download: ML20246E696 (2) | |
Text
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r iI GENERAL oFHCE -
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. Nebraska:Public' Power District
" 8 *' ice'a,u,e,ug.gEBRAS u
68601-0499 h.
s TAugust 23, fl989_
- U.S. Nuclear. Regulatory Commission-Attention: ~ Document Control' desk-'
Washington, DC 20555
Subject:
NPPD Response'to NRC Inspection Report No. 50-298/89-22'
. Gentlemen:
This : letter is written in response to your. 1stter dated. -July 24,~1989, transmitting Inspection ' Report No..50-298/89-22.
Therein you indicated that certain of our activities were in violation of NRC requirements.
Following; is the statement of the violation : and our response in. accordance with 10CFR2.201.
' Statement of Violation Inadequate Design Control 10CFR50, Appendix B, Criterion III, requires.that measures be established to assure that the design basis for structures, systems, and components
,are correctly translated into specifications, drawings, procedures, and instructions and that design changes, including ' field changes, shall be.
-subject to design control measures commensurate with those applied to the original design.
Engineering Procedure; 3.4,
" Station Modifications", and Engineering Procedure 3.4.11,
" Status Reports",
requires procedure-changes and training to be conducted as applicable.
Contrary to the above, procedures for on-the-spot changes (OSC) do not require an evaluation to determine if procedure changes or training is required due'to the OSC.
Design Change 88-036 was altered by OSC No. 8 on April 20, 1989, without training being conducted nor procedures affected by the OSC, such as System Operating Procedure' 2.2.28, "Feedwater System," being modified to reflect the change.
This.is a Severity Level IV violation.
(Supplement I) (298/8922-01)
' Reason for Violation The OSC pmcedure does not require an evaluation for procedure changes or training as stated in the Statement of Violation.
However, the Status Report
. procedure presently states that the Design Engineer is to review OSCs to ensure the resultant affect on procedure changes and training instructions is addressed.
8908290263 890823,e O[
gDn ao0cn osooo2 PDC l
August 23, 1989
. Page 2 The need for revision to Alarm Procedures 2. 3.2.27 and 2.3.2.28 due to OSC No. 8 was identified by the Design Engineer.
Draft revisions to the Alarm Procedures were submitted by the technical staff on June 14, 1989 for incorporation into the Station Operating Procedures. Howeser, these procedure changes and subsequent training instructions as a result of OSC No. 8 were not identified as a requirement for start-up, and were therefore not implemented prior to start up.
This concern will be addressed by reviewing and enhancing as necessary the existing methoda for ensuring the procedure changes and training instructions are completed when required.
The. subject inspection report references System Operating Procedure 2.2.28, "Feedwater System" as a procedure impacted by OSC NO.
8.
The required revision to this procedure was approved by plant management and implemented on June 20, 1989.
Corrective Steps Which Have Been Taken and the Results Achieved:
Revisions to Alarm Procedures 2.3.2.27 and 2.3.2.28 were approved by plant management and implemented on July 6, 1989.
The procedure revisions that resulted from this OSC were routed to all licensed operators for review.
Corrective Steps Which Will be Taken to Avoid Further Violations:
The existing methods of ensuring that procedure changes and training instructions for on-the-spot changes (OSC) to design changes are performed prior to required system operability will be reviewed and enhancements will be made as required, by December 1, 1989.
Date When Full Compliance will be Achieved The corrective steps noted will be implemented with full compliance by December 1, 1989.
If you have any questions regarding this response, please contact myself or G. R. Horn at the site.
Sincerely,
/
i
.A Trevors Division Manager of Nuclear Support i
GAT /LPK:dh79.1z j
l cc:
U.S. Nuclear Regulatory Commission Region IV Arlington, Texas NRC Resident Inspector Cooper Nuclear Station I
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