ML20247D473

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/89-22

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

Text

r.

9

,

-il

f '

y. .

.. .)

,j SEP 6W j

,In Reply Refer To:

= Docket: 50-298/89-22 ]q

I

'i

l

Nebraska Public Power District l

ATTN: George A. Trevors 6 g

Division Manager - Nuclear Support 1

P.O.-Box 499 j

Columbus, Nebraska '68602-0499 j

' Gentlemen:

Thank you for your letter of August 23, 1989, in response to our letter and  !

' 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)

bec distrib.-by RIV:

RRI R. D. Martin, RA

SectionChief(DRP/C) Lisa Shea, RM/ALF

RPB-DRSS MIS System

RIV File Project Engineer ,(DRP/C)

RSTS Operator DRP

P. O'Connor, NRR Project Manager (MS: 13- ) DRS

RIV:DRP/C C: D: d j k

~GLMadsen;[f,,

9///89 B77

GL pnstable

9/T /89

JLMilhoan

9/ /89 [t/,b

V

s\\

s909140275 890906 7 \

PDR ADOCK 05000298

Iq__ _ _ _ _ PDC

.

_ _____ _ _ _

4 . . ..

se -

,

a~*

"

GENERAL OFFICE

"-

Nebraska Public Power District "'

" "" &#0uE%#80^!n'"**"

E

~ '- . . . . .

__ .

August 23, 1989 h@}[

1

I.UG 2 81989

U.S. Nuclear Regulatory Commission ['

-

[

lP

'

Attention: Document Control desk -

l

'

Washington, DC 20555

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 i

ensure the resultant affect on procedure changes and training instructions is j

addressed.

i

& W (9 0 Q hkh~N

ammmwaza.mmamnm.mmmas;mman

w _ w - n w ~ = = ~= = ===w= m =a ===w+=-=~====

, . . . . . . . . . _ - _ _ _

. . .

'

' August 23, 1989

'

, Pass 2

.

.

The need for revision to Alarm Procedures 2.3.2.27 and 2.3.2.28 due to OSC t

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

GAT /LPK:dh79.1z

cc:

/U.S. Nuclear Regulatory Commission

l Region IV

i Arlington, Texas

l

--

l NRC Resident Inspector

( Cooper Nuclear Station

.

.