ML20247D473
| ML20247D473 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/06/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8909140275 | |
| Download: ML20247D473 (1) | |
See also: IR 05000298/1989022
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= Docket: 50-298/89-22
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Nebraska Public Power District
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ATTN: George A. Trevors
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Division Manager - Nuclear Support
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P.O.-Box 499
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Columbus, Nebraska '68602-0499
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' Gentlemen:
Thank you for your letter of August 23, 1989, in response to our letter and
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' Notice of Violation dated July 24, 1989. 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 determine that full compliance has been achieved and will be maintained.
Sincerely.
Original Signed By:
James L Milhoan
James L. M11hoan, Director
Division of Reactor Projects
cc:
Cooper Nuclear Station
ATTN: Guy llorn, Division Manager
of Nuclear Operations
P.O. Box 98
~Brownville, Nebraska 68321
Kansas Radiation Control Program Director
Nebraska Radiation Contral Program Director
bectoDMB(IE01)
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August 23, 1989
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U.S. Nuclear Regulatory Commission
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Attention: Document Control desk
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Washington, DC 20555
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Subject: NPPD Response to NRC Inspection Report No. 50-298/89-22
Gentlemen.
This letter is written in response to your letter 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,
"Feeduater System," being modified to reflect the change.
3
This is a Severity Level IV violation.
(Supplement I) (298/8922-01)
Reason for Violation
The OSC procedure 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 reviev OSCs to
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ensure the resultant affect on procedure changes and training instructions is
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addressed.
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' August 23, 1989
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The need for revision to Alarm Procedures 2.3.2.27 and 2.3.2.28 due to OSC
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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. However, 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 methods 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 n.anagement 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. Born at the site.
Sincerely,
.A
Trevors
Division Manager of
Nuclear Support
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cc:
U.S. Nuclear Regulatory Commission
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Region IV
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Arlington, Texas
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NRC Resident Inspector
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Cooper Nuclear Station
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