NLS8500256, Responds to NRC Re Violations Noted in Insp Rept 50-298/85-19.Corrective Actions:Cns Procedure 3.8, Drawing Control Procedure, Will Be Revised & Implemented to Control Use of safety-related Drawings

Responds to NRC Re Violations Noted in Insp Rept 50-298/85-19.Corrective Actions:Cns Procedure 3.8, Drawing Control Procedure, Will Be Revised & Implemented to Control Use of safety-related Drawings

ML20138H982
Person / Time
Site:	Cooper
Issue date:	09/20/1985
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20138H969	List: IR 05000298/1985019 NLS8500256, Responds to NRC Re Violations Noted in Insp Rept 50-298/85-19.Corrective Actions:Cns Procedure 3.8, Drawing Control Procedure, Will Be Revised & Implemented to Control Use of safety-related Drawings
References
NLS8500256, NUDOCS 8510290202
Download: ML20138H982 (3)

Text

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GENERAL OFFICE Nebraska Public Power District "" "%fe#oTAE*2M^""*"

NLS8500256 - -

Septabber 20, 1985 ,

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Mr. E. H. Johnson, Chief Reactor Project Branch I U.S. Nuclear Regulatory Commission Region IV Gil Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Subject:

Nebraska Public Power District Response to IE Inspection Report #50-298/85-19 This letter is written in response to your letter dated August 21, 1985, transmitting Inspection Report #50-298/85-19.

Therein you indicated that two of our activities were in violation of Nuclear Regulatory Commission requirements. The following are statements of the violations indicated and our response to each in accordance with 10CFR2.201:

1. STATEMENT OF VIOLATION Station Procedures to Prevent or Control the Use of Voided, Deleted , or Superseded Safety-Related Drawings and As-Built Drawings 10CFR Part 50, Appendix B, Criterion V requires that activities affecting quality be prescribed by documented instructions or procedures which shall include appropriate quantitative or qualitative acceptance criteria.

Contrary to the above, no CNS Procedure existed to prevent or control the use at CNS of safety-related drawings specified by the NPPD document control system as being voided, superseded, or deleted , or as being construction drawings which had not been certified as as-built drawings.

Corrective Steps Which Have Been Taken and the Results Achieved A review was conducted to identify the most appropriate way to incorporate control of safety-related drawings into the CNS Procedures. It was determined that CNS 8510290202 ADOCK OOh%-78

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Mr. E. H. J:hncon P:g2 2 September 20, 1985 Procedure 3.8 " Drawing Control Procedure" will be revised to control the use of safety-related drawings specified by the Records ' Administration Department (RAD) Drawing Control System.

Corrective Steps Which Will Be Taken To Avoid Further Violations CNS Procedure 3.8 " Drawing Control Procedure" will be revised and implemented.

Date When Full Compliance Will Be Achieved Procedure 3.8 will be revised and approved by November 15, 1985.

.2. STATEMENT OF VIOLATION Approved Lock for Safeguards Drawing Cabinet 10CFR73.21 (d) (2) states: "While unattended, Safeguards Information shall be stored in a locked security storage container. Knowledge of lock combinations protecting Safeguards Information shall be limited to a minimum number of personnel for operating purposes who have a 'need to know' and are otherwise authorized access to Safeguards Information in accordance with the provisions of this section."

The Atomic Energy Act, Section 147, states that guidcnce on protection of Safeguards Information shall be provided by the NRC.

NRC guidance for padlocks for Safeguards Information is contained in NUREG-0794 " Protection of Unclassified Safeguards Information," Section 4.1 Storage, which further requires padlocks to -be a "GL.i approved combination padlock."

~ Contrary to the above, a CNS storage cabinet for Safeguards drawings was secured with a key padlock.

l Corrective Steps Which Have Been Taken and the -Results Achieved

- The keylock was replaced with a GSA approved lock and the combination was set by security personnel the same day the violation was noted. The cabinet has been locked with this approved lock since that time with the exception of required access.

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S.,* Mr. E. H. J:hnson P:gs 3 September 20, 1985 Corrective Steps Which Will Be Taken to Avoid Further Violations The key padlock- has been removed from the CNS Engineering office and appropriate personnel reminded of Safeguards Procedures.

Date When Full Compliance Will Be Achieved Compliance was achieved the same day as the finding during the June 10-14, 1985, inspection period as noted by the inspector on page three of his report.

If you have any questions regarding this response, please contact me.

Sincerely, ,,

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.M. t Technical Staff Manager Nuclear Power Group JMP/GRH/JHF:km23/1(6A)

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