IR 05000285/1987002

Ack Receipt of Informing NRC of Steps Taken to Correct Violation & Deviation Noted in Insp Rept 50-285/87-02

ML20215H503
Person / Time
Site:	Fort Calhoun
Issue date:	04/13/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8704200358
Download: ML20215H503 (2)

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j. In Reply Refer To:

Docket: 50-285/87-02 ,

Omaha Public Power District ATTN: R. L. Andrews, Division Manager-Nuclear Production 1623 Harney Street Omaha, Nebraska 68102 Gentlefren:

Thank you for your letter of March 23, 1987, in response to our letter, Notice of Violation, and Notice of Deviation dated February 19, 1987. We have reviewed your reply and find it resporisive to the concerns raised in our Notice of Violation and Notice of Deviation. 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, Oegir.at Staned D/

'J. J. E. Gagliardo, Chief Reactor Projects Branch CC:

W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, DC 20036 Kansas Radiation Control Progr'am Director Nebraska Radiation Control Program Director bcc: (see next page) g

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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/536-4000 March 23, 1987 LIC-87-169 M @ M Dg [e:

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Mr. J. E. Gagliardo, Chief !a U.

Reactor Projects Branch -

U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 References: 1. Docket No. 50-285 7 2. Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated February 19, 1987

Dear Mr. Gagliardo:

SUBJECT: Inspection Report 50-285/87-02 The subject inspection report identified one deviation and two violations. The deviation involved the administrative control of manual containment isolation valves. The violations involved failure to establish measures to prevent the

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misuse of outdated procedures and failure to maintain a procedure in an up-to- -

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date condition. Pursuant to the provisions of 10 CFR Part 2.201, please find attached the Omaha Public Power District's responses to these violations and deviation.

Sinfer.ely, p ,

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R. L. Andrews Division Manager

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Nuclear Production RLA/me

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cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W. ";

Washington, DC 20036 Mr. R. D. Martin, Regional Administrator Mr. P. H. Harrell, NRC Senior Resident Inspector -

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ATTACHMENT 1

During an NRC inspection conducted on January 1-31, 1987, violations of NRC requirements were identified. The violations involved (A) the failure to establish measures to prevent the misuse of outdated procedures and (B) the failure to maintain the procedure for operation of the onsite 480-volt distribution system in an up-to-date condition. In accordance with the 4 " General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

Violation A Failure to Establish Measures to Prevent the Misuse of Outdated Procedures.

Criterion VI of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality.

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Paragraph 4.1.1 of Section 2.1 of the licensee's Quality Assurance Plan

{ requires in part, that controls be provided to avoid the misuse of outdated or j :- inappropriate documents.

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. Contrary to the above, the licensee did not provide adequate controls to avoid

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the misuse of outdated documents in that out-of-date revisions of Procedure 01-EE-4,Section IV of the Technical Data Book, and the boric acid temperature readout Technical Specification reference sheet were posted in the plant as operator aids, in lieu of the current revisions of these documents.

This is a Severity Level V violation. (Supplement I)(285/8702-02)

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1 OPPD's Response The Reason for the Violation if Admitted OPPD has an administrative standing order (S.0. 0-41) to ensure procedures,

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figures, operations memos and piping and instrument drawings (P& ids) posted as operator aids throughout the plant are authorized. A quarterly review of the checklist is completed by the Shift Technical Advisor (STA) through the Fort Calhoun Station preventive maintenance program. The standing order provides a list of authorized aids and drawings posted. The presence

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and correct revision of the document is verified by initialling an'd dating i the checklist. The standing order, however, does not provide for the i update of any of the aids during the quarter. Hence, the possibility for a document to become outdated due to procedure changes becomes apparent.

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During tours of the plant, the NRC inspector noted that soms"hf the procedures posted in the plant were out of date in that the latest revision was not posted.

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,a *e Attachment 1 (Continu::d)

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The Corrective Steos Which Have Been Taken and the Results Achieved Upon notification by the NRC inspector, licensee personnel removed the outdated postings and replaced them with the correct revision. Shortly thereafter, the licensee personnel conducted the quarterly review and made updates and changes as necessary.

Standing Order 0-41 has been altered to provide a space for the STA to record the current revision of each document checked. This provides a record of the current document revision effective at the time of the review.

An additional duty was also added to the STA Shift Turnover Log (FC-163).

The duty requires that a list of the documents from S.0. 0-41 Appendix A, with the current posted revision, be checked against the list of the latest procedure changes made. The list of procedure changes is issued to the STA's each time changes are placed in the books. The STA on the afternoon shift is to check the lists and replace any document that is out of date.

The piping and instrument drawings in S.0. 0-41 Appendix B are already being updated by the Records Coordinator when any changes to the P&ID's are 7 made.

During the interim period an STA has been assigned the task of checking the

lists daily to ensure that documents listed in S.O. 0-41 remain up to date.

The Corrective Steos Which Will be Taken to Avoid Further Violations Full compliance with Criterion VI of Appendix B to 10 CFR Part 50 has been achieved by temporarily assigning an STA the task of checking daily, the list of documents in S.0. 0-41 Appendix A with the list of procedure

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changes. This temporary assignment will continue until issuance of the ,_.-

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changes to S.0. 0-41 and the STA Shift Turnover Log.

The Date When Full Comoliance Will be Achieved OPPD is presently in full compliance.

Violation B Failure to Maintain the Procedure for Ooeration of the Onsite 480-volt Distribution System in an Vo-to-Date Condition Technical Specification 5.8.1 requires, in part, that written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33 be maintained. .

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Appendix A to Regulatory Guide 1.33 includes procedures for operation of the onsite 480-volt electrical distribution system. Checklist EE-2-CL-E of Procedure OI-EE-2, " Normal Operation of the 480-Volt System," has.been established in accordance with this Technical Specification requirement, to provide instructions to operations personnel for reestablishing electrical loads in the plant in the event that all electrical power is lost to the 480-volt electrical distribution system.

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Attachment I (Continued)

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Contrary to the above, Checklist EE-2-CL-E of Procedure 01-EE-2 was not maintained in that approximately 40 discrepancies ricre identified by the NRC inspector where Checklist EE-2-CL-E listed breakers that were not installed on the motor control centers and where loads installed on the motor control centers were not listed on Checklist EE-2-CL-3.

i This is a Severity Level IV violation. (Supplement I)(285/8702-03)

OPPD's Response The Reason for the Violation The licensee failed to adequately review the procedure in question to ensure that it was accurate.

The checklist in question, EE-2-CL-E of Operating Instruction 01-EE-2, is used to completely strip a dead motor control center (MCC) before reenergizing the MCC. Because this evolution happens so infrequently, this particular checklist is very seldom needed. Thus, infrequent use of the T checklist contributed to its being in error.

. The Corrective Steos Which Have Been Taken and the Results Achieved An in-depth review of the electrical distribution procedures is being conducted to determine where the procedures are deficient. The following items are being considered as part of this review:

A. Procedure accuracy versus the as built plant, and vice versa.

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_ B. P&ID drawing accuracy versus the operating procedures. e- -

C. P&ID drawing accuracy versus the as built plant.

As a result of this review, procedure changes have been submitted for 01-EE-1, 01-EE-2 and 01-EE-4 to update and correct the procedures.

In addition to the procedure changes that have been submitted so far, a marked up copy of the electrical distribution elementary P&ID has been submitted to the District's print update department to correct several minor discrepancies.

The Corrective Steos Which Will be Taken to Avoid Further Violations A. Short term steps that remain to be taken are a review of electrical distribution operating instructions 01-EE-3 and 01-EE-TSC-1.~ -

B. Plant operating procedures will continue to be reviewed In accordance with current plant administrative procedures. In addition, the importance of performing proper procedure reviews will, "be reemphasized to the Operations staff.  :

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Attachment 1 (Continued)

The Date When Full Compliance Will be Achieved The above referenced procedure changes will be approved and incorporated in the operating instructions by April 15, 1987.

The review of operating instructions 01-EE-3 and 01-EE-TSC-1 will be completed, and any resulting procedure changes incorporated by June 30, 1987.

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ATTACHMENT 2 Based on the results of an NRC inspection conducted on January 1-31, 1987, a deviation of your commitments made to the NRC was identified. The deviation consisted of the failure to place all manual containment isolation valves under administrative control. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986),

the deviation is listed below:

Deviation Failure to Place all Manual Containment Isolation Valves Under Administrative Control Section 5.9.5 of the Updated Safety Analysis Report states that where a system penetrates containment and the system is inactive during reactor operation, operation of manual isolation valves is under administrative controls. Section 5.9.5 also states that branch line connections between the containment and the outside containment isolation valves are equipped with valves to provide isolation integrity equal to at least that of the

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main system.

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In deviation from the above, manual isolation valves in branch lines between the containment and the outside containment isolation valve were I not placed under administrative controls. The affected branch lines identified by the NRC SRI with manual valves were in the chemical and volume control system (Valves CH-517, CH-518, and CH-535), main steam system (Valves MS-101 and MS-103), low-pressure safety injection system (Valve SI-375), and component cooling water system (Valves AC-1133, AC-1134, AC-857, and AC-858). (285/8702-01)

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- OPPD's Response The Reason for the Deviation If Admitted Since plant startup in 1973, OPPD has traditionally used a variety of-means to provide administrative control to manual isolation valves. In some cases, the valve was included on a checklist and designated as

" closed", but was not locked or seal-wired. In some cases, the valve was closed and credit assumed for routine operator tours, in that an operator would detect an abnormal position (e.g., leaking steam would be such an indicator.) In other cases, a locking device was used, sometimes without a checklist reference.

l It has now been recognized that without a combination of procedural i

checklist control, in conjunction with physical locking device cdntrol, an effective administrative control program is difficult to implement and more difficult to demonstrate from an auditability standpoint.

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Attachment 2 (Continued)

The Corrective Steos Which have been Taken and the Results Achieved All of the valves in question have been either locked or seal wired. The OPPD technical support staff has performed walkdowns of the ' containment penetrations to determine if any additional valves were in need of

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attention. Three additional valves were identified and attended to.

Additionally, the administrative changes to checklists have been either implemented or have been proposed for implementation.

The Corrective Steos Which will be Taken to Avoid Further Deviations In addition to updating the operating instruction checklists, the appropriate P&ID drawings will be updated to reflect the desired status of the valves in question, (i.e., locked, or seal wired).

The Date When Full Compliance will be Achieved

'The valves listed in the deviation and the three additional identified valves have been either locked or seal wired. OPPD is presently in full

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The necessary procedure changes to the operating instruction checklists

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will be prepared and implemented, and the appropriate P&ID drawings will be updated, prior to leaving cold shutdown after the 1987 refueling outage.

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