ML20206P964

Responds to NRC Re Violations Noted in Insp Rept 50-298/86-21.Corrective Actions:Procedures 10.1 & 6.2.4.1 Revised

ML20206P964
Person / Time
Site:	Cooper
Issue date:	08/18/1986
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
CNSS860632, NUDOCS 8608270404
Download: ML20206P964 (2)

Text

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COOPER NUCLEAR STATION g " "

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_ Nebraska Public Power District _

CNSS860632 August 18, 1986 D$ $ b b7'hlj AUG 2 21986 '

b 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 Inspection Report 50-298/86-21,

Dear Mr. Gagliardo:

This letter is written in response to your letter dated July 24, 1986 transmit-ting Inspection Report 50-298/86-21. Therein you indicated that one of our activities was in violation of NRC requirements.

Following is a statement of the violation and our response in accordance with 10CFR2.201.

Statement of Violation Failure to Have a Procedure for Controlling Activities Affecting Quality 10 CFR Part 50, Appendix B, Criterion V, and the licensee's Quality Assurance Program require that activities affecting quality shall be prescribed by documented procedures.

Contrary to the above, the licensee did not have a procedure to provide necessary guidance and controls for ensuring that amendments to license documents such as the Technical Specification and Updated Safety Analysis Report.resulted in the identification, approval, and implementation of revisions to affected station procedures. Specifically, Surveillance Procedure 6.2.4.1, " Daily Surveillance (Technical Specifications)" and Nuclear Performance Evaluation Procedure 10.1, "APRM Calibration", were not revised to meet the requirements found in the CNS Technical Specifica-tion, Amendment 94, dated September 24, 1985. As a result, licensee x personnel did not accurately calculate APRM gain adjustment factors that are used to calibrate the APRM flux scram and rod block trip setpoints'.

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, C' M. or. J. E. G glicrdo August 18, 1986 Page 2 Reason for tie Violation The statement of violation is correct, in that a p'ocedure r does not exist to provide for the incorporation of amendments to license documents into station procedures. However, it should be noted that the procedures identified in the inspection report had been revised to implement the Technical Specification change authorized on September 20, 1985. These '

procedures were, unfortunately, incorrectly revised. The error was identified during our re-review of the implementation of this Technical Specification amendment and was reported to the NRC in accordance with 10CFR50.73.

Corrective Steps Which Have Been Taken and the Results Achieved As stated in LER 85-014 and in the " Details" section of Inspection Report 50-298/86-21, NPPD personnel determined that an error had been made during the revision of Procedures 10.1 and 6.2.4.1 to implement the single loop operation Technical Specification amendment. These errors were identified during our re-review of this Technical Specification amendment implementation and resulted in the revising of these procedures to include appropriate corrections. These corrected revisions were implemented on September 21, 1985 and December 19, 1985, respectively.

Corrective Steps Which Will Be Taken to Avoid Further Violations A procedure to provide guidance and control for the incorporation of license amendments into station procedures will be written, approved and implemented by October 31, 1986. The implementation of this procedure should preclude any further violations in this area.

Date When Full Compliance Will Be Achieved Cooper Nuclear Station is in full compliance at the present time. The implementation of the procedure to avoid further discrepancies in the area will be completed by October 31, 1986.

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

Sincerely,

. M. Pilant Technical Staff Manager Nuclear Power Group JMP:JVS:lb