IR 05000285/1989001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/89-01.NRC Will Withdraw Items 3 & 4 If Review of Safety Evaluation Documentation Found to Be Adequate

ML20248B771
Person / Time
Site:	Fort Calhoun
Issue date:	09/19/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Morris K OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8910030281
Download: ML20248B771 (2)

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SEP I 91999 In Reply Refer To:

Docket; 50-285/89-01 Omaha Public Power District ATTN: Kenneth J. Morris, Division Manager Nuclear Operations 444 South 16th Street Mall Omaha, Nebraska 68102-2247 Gentlemen:

Thank you for your letter of August 28, 1989, in response to our letter and Notice of Violation dated July 14, 1989. We are pleased that you have located the documented safety evaluations for the modifications addressed in Items (3)

and (4) of Violation A. We note that you have admitted to Violation A with regard to Items (1) and (2).

We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the safety evaluation documentation for Items (3) and (4) of Violation A and the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained. If based on this review, we find the safety evaluations to be adequate, we are prepared to withdraw Items (3) and (4) as examples of Violation

Sincerely, Driginal Signed By g, L. Idilhoan James L. Milhoan, Director Division of Peactor Prcjects cc:

Jort Calhoun Station ATTN: G. R. Peterson, Manager P.O. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt, Es LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, DC 20036 Nebraska Radiation Control Program Director l $0l

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R. D. Martin, RA RPB-DRSS SectionChief(DRP/B) MIS System RIV File DRF RSTS Operator ProjectEngineer(DRP/B)

Lisa Shea, RM/ALF DRS D. Kelley J. E. Gagliardo A. Bairnia, NRR Project Manager (MS: 13-D-18)

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Omaha Public Power District ,...

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1623 Harnetj Omaha. Nebraska 68102 2247

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August 28, 1989 LIC-89-763 SEP - l 1989 j

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U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555 References: Docket No. 50-285 Letter July 14,from 1989NRC (J. L. Milhoan) to OPPD (K. J. Morris) dated Gentlemen:

SUBJECT:

Response to Notice of Violation - Inspection Report 50-285/89-01 Omaha Public Power District (OPPD) received Reference 2 which identified two violations. A two week extension was granted by the NRC in order for OPPD to obtain further information on the subject violations. Attached please find OPPD's response to these items in accordance with 10 CFR Part 2.20 If you have any questions concerning this matter of require additional information, please contact me or members of my staf

Sincerely,

. Morris Division Manager Nuclear Operations KJM/pjc Attachment c: LeBoeuf, Lamb, Leiby 1 MacRae R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC fenior Resident Inspector jff 930'N$

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ATTACHMENT Response to Notice of Violation During an NRC inspection conducted June 1-30, 1989, a violation of NRC requirements was identified. The violation involved the failure to report a deficient condition. In accordance with failure.to take prompt corrective action of conditions adverse to quality. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below: Violations Involvina Chances in the Facility 10 CFR Part 50.59, requires that the licensee shall maintain records of changes in the facility. These records must include a written safety evaluation, which provides the bases- for the determination that the change does not constitute an unreviewed safety questio Contrary to the above, Omaha Public Power District failed to have a safety a evaluation for each of the modifications listed below: { A spray shield was installed in the switchgear room over Load Center 1848. The spray shield was attached to a safety-related cable tray on one end with the other end being supported by a conduit from the load cente l The diesel generator exciter brush housing inspection covers had been replaced with plexiglass cover . Installations of a temperature inversion switch in Radiation Monitoring Panel AI-33 . Unsupported wiring with no redundant channel separation in the RCS hot leg and cold leg temperature and steam generator pressure control room instrument This is a Severity Level IV violatio (Supplement I) (285/8901/05)

OPPD Response Reason for the Violation, if Admitted l OPPD admits the violation for failing to provide a written safety evaluation for the modifications listed in items one (1) and two (2)

above. Subsequent to this inspection, OPPD located documented safety evaluations for modifications listed in items three (3) and four (4)

above. With respect to the modification listed in item three (3) above, Engineering Evaluation and Assistance Request (EEAR) No. 80-68, completed July 3,1980, documents, with a written safety evaluation, the installation of the temperature inversion switch-in radiation monitoring panel AI-33 With respect to the modification listed in item four (4) above, modification request MR-FC-85-132, completed January 13, 1989, documents, with a written safe.ty. evaluation, the instrument installation activities for control room panel CB- Both safety evaluations noted above are available for NRC review.

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The spray shield modification (Item 1 above) was installed due to a water leak (since repaired) in the compartment above the switchgear room. A search of historical maintenance records and verbal discussions with cognizant personnel failed to identify the required source documentatio It was determined that the installation of this shield occurred between 1977 and 1979. The reason for the absence of required documentation cannot oe determine The plexiglass cover modification (No. 2 above) was installed under maintenance order M0 2734, dated October 23, 1973. This maintenance order was reviewed and approved by the Plant Review Committee (PRC). At this time, there was no formal documentation for the evaluation of an unreviewed safety question. This practice was changed in 1976 with the introduction of Form FC-154 which required the evaluation of an unreviewed safety question tc be formally documented. This requirement for written documentation is currently in place at Fort Calhou . Corrective SteDs That Have Been Taken and the Results Achieved The spray shield modification was removed under Maintenance Order 892046, dated March 30, 1989, therefore this plant condition no longer exist The plexiglass cover modification has been reanalyzed as two temporary modifications (there are two diesels with the plexiglass covers), under temporary modification requests TM-89-M-021 and TM-89-M-022, including documented safety evaluations. Therefore, these installations are now documented as temporary modifications which include safety evaluation A long term resolution has been approved to include these temporary modifications into the scope of a permanent modification, FCS-MR-FC-83-133, to be completed during the 1990 refueling outag . Corrective Steps That Will be Taken to Avoid Further Violations OPPD believes that procedure N0D-QP-3 "10 CFR 50.59 Safety Evaluations",

provides strong guidance for personnel on the requirements of 10 CFR 50.59. This procedure requires documentation be provided prior to the approval of any known temporary or permanent modification to Fort Calhoun Station. Personnel who perform safety evaluations at Fort Calhoun receive training on N0D-QP-3. OPPD believes the present procedures and training constitute a strong 50.59 program that will minimize the potential for further violations in this are OPPD is currently evaluating the impact of this violation on events that occurred early in the operating history of Fort Calhoun Station. The results of this evaluation and a subsequent plan of action will be complete by December 1, 198 . Date When Full ComDliance Will be Achieved OPPD is currently in full compliance with the requirements of 10 CFR 50.59 as it pertains to this violation. OPPD will inform the NRC of the results of the evaluation of p&st practices by December 15, 198 m e

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'. '+ Failure to Take Prompt Corrective Action Criterion XVI of Appendix B to 10 CFR 50 requires that, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."

This requirement is implemented by Section 10.4 of the licensee's quality j assurance plan, which states in Section 4.1.1 that, " Conditions adverse to I quality, such as failures, malfunctions, deficiencies, daviations, defective material and equipment, and nonconformances, shall be promptly identified and L corrected as soon as practicable." j Contrary to the above, the NRC inspectors found on April 19, 1939, an energized lighting circuit in the No. I diesel generator room which was routed outside of conduit with the energized wiring hanging on the valves on the air start receivers. This problem had been identified by the licensee in 1987 and  ;

Maintenance Order 874799 was issued on October 14, 1987, to correct the

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problem. The MO was subsequently lost or misplaced. The condition was-again addressed in January 1989. Maintenance Order 890297 was issued on January 10, 1989, to repair the wiring, but the problem had not been corrected at the time of this inspectio This is a Severity Level IV violatio (Supplement I)(285/8901-06)

OPPD Response Reason for the Violation, if Admitted OPPD admits the violation occurred as state The untimeliness of completion of this task can be attributed to assignment of a low priority for this task. The wiring temporarily routed outside of conduit can be attributed to a diesel generator turbocharger modification j performed during the 1987 refueling outage. The modification required i removal of a light fixture and two sections of conduit to accommodate  :

installation of temporary lifting eyes to remove and install I arbocharger It has been determined the conduit work should have been included in the scope of the turbocharger modification. Because of late preparation of modification work packages, pre-modification work and subsequent post modification work was accomplished with the use of maintenance orders. Maintenance Order 874799 was written to reinstall the light fixture and conduit as a post-modification work item. This practice was allowed at the time (late 1986), but is no longer allowed at Fort l Calhoun Station. Standing Order M-101, " Maintenance Work Control",

l approved May 23, 1989, now requires the system engineer to review l maintenance work orders to ensure the maintenance work order does not fall within the scope of the modification progra .

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. . Corrective Steps That Have Been Taken and the Results Achieved To address End correct the identified condition, the wiring was placed back in conduit on May 4, 1989 under maintenance work order 89029 Subsequent investigations indicate that an unauthorized modification was performed in that the light fixture was not reinstalled, and the conduit was not placed along its original route. No modification package was prepared for this work and the use of a maintenance order to perform the work was inappropriate. A Quality Assurance Deficiency Report, FCl-89-252, was issued on this unauthorized modification on August 9,1989 which requires this work to be documented as a modification or the installation returned to its original configuration. The NRC will be appraised of the outcome of the investigation of this separate issue by September 30, 198 The problem of inadequate control over modification related work has been addressed by a revision to Standing Order G-21, " Station Modification Control". This revision, dated December 14, 1988, requires a field walkdown (after work completion) to verify conformance with the design package and identify any other discrepancies discovered (e.g. wiring outside of conduit).

To address the timeliness of maintenance activities, the Safety Enhancement Program (SEP) goal of reducing the corrective, nonoutage maintenance order backlog to less than 600 items was achieved by the end of April,198 This has resulted in more manageable control over wor . Corrective Steos That Will Be Taken to Avoid Further Violations OPPD believes the steps taken above are effective for ensuring promot corrective actions. The recommendation from Quality Assurance Deficiency Report FCl-89-252 will be reviewed and corrective actions taken based on that review. It should also be noted that a significant enhancement to the Fort Calhoun maintenance program is planned which includes a program reorganization and personnel additions to both planning and scheduling groups to ensure proper task prioritization and timely execution of maintenance activities. The implementation of this program enhancement is expected by September 30, 198 Engineering procedures will be reviewed and revised as necessary to ensure that the removal and reinstallation of interfering plant equipment or other activities that could alter the configuration of FCS are controlled by the modification package only and without the utilization of maintenance orders. This task will be completed by December 1, 1989. OPPD intends to continue monitorin enhancements and take corrective actions, as necessary, to gensure the above program effective and timely maintenance actions remain in place at Fort Calhoun Statio . Date When Full Comoliance Will Be Achieved OPPD is currently in full compliance with Criterion XVI of Appendix B to 10 CFR 50 and Section 10.4 of OPPDs Quality Assurance Plan as it pertains to this violation. The NRC will be appraised when full compliance will be achieved with respect to the OPPD identified deficiency by September 30, 198 .