IR 05000285/1989003
| ML20245F132 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/24/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8905020266 | |
| Download: ML20245F132 (2) | |
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In Reply Refer To:
.j Docket: 50-285/89-03 i
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Omaha Public Power District q
ATTN:
Kenneth J. Morris, Division Manager Nuclear Operations l
1623 Harney Street j
Omaha, Nebraska 68102
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Gentlemen:
Thank you for your letter of March 31,.1989,- in response to our letter J
and Notice of Violation dated March 1, 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.
Ow;ff O Cheber/Ain L. J. Callan Director Division of Reactor Projects CC:
I W. G. Gates, Manager i
Fort Calhoun Station
P.O. Box 399
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Fort Calhoun, Nebraska 68023 Harry'H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Wa'shington, DC 20036
Nebraska Radiation Control Program Director bectoDMB(IE01)
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March 31, 1989 i O,,'
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LIC-89-326
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U. S. Nuclear Regulatory Commission l
Attn: Document Control Desk l
Mail Station PI-137 l
Washington, DC 20555 l
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated March 1, 1989 Gentlemen:
SUBJECT:
Response to Notice of Violation NRC Inspection Report 50-285/89-03 Omaha Public Power District (0 PPD) received the Notice of Violation dated March 1, 1989.
The violation involved the lack of drawing control for temporary modifications.
Pursuant to the provisions of 10 CFR Part 2.201, please find attached, OPPD's response to the violation.
If you have any questions concerning this matter, please do not hesitate to contact us.
Sincerely,
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K. J. Morri Division Manager Nuclear Operations KJM/jak Attachment c:
LeBoeuf, Lamb, Leiby & MacRae
%;"D. Martin, NRC Regional Administrator l
P. D. Milano, NRC Project Manager
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P. H. Harrell, NRC Senior Resident Inspector QR-\\ 0
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RESPONSE TO NOTICE OF VIOLATION.
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During an NRC inspection conducted on January 1-31,-1989,- a violation of NRC requirements was identified. The violation involved.the failure to provide-appropriate drawing control for temporary modifications.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below.
Lack of Drawino Control for Temporary Modifications 10 CFR 50, Appendix B, Criterion III, requires that measures be established for the control of design changes, including field changes. Appendix A of the Fort Calhcun Station Updated Safety Analysis Report, Attachment 1, paragraph L states, in part, that the licensee's Quality Assurance (QA)
Program and QA Plan comply with the requirements' of ANSI N45.2.11-1974,.
" Quality Assurance Requirements for the Design of Nuclear Power Plant."
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ANSI N45.2.ll-1974 states, in part, that documented procedures shall be j
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provided for design changes, including field changes, which assure that
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information concerning the change is. transmitted to all affected persons and organizations.
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Contrary to the above, Procedure 50-0-25, " Temporary Modification j
Control," Revision 26 does not assure transmittal of design changes to the control room drawings utilized by the plant operations staff during the interim time from submittal of the drawing revision request to the actual issuance of a drawing revision incorporating the design change, b.
Contrary to the above, temporary modifications 88-M-011, which added a nitrogen bottle supply to supplement the instrument air accumulators associated with Safety Injection Water Refueling Tank Outlet Valves-
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LCV-383-1 and LCV-383-2 in April 1988, had not been incorporated into
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the control room drawings when reviewed by the NRC inspector on j
January 15, 1989.
This is a Severity Level IV violation.
(Supplement I) (285/8903-01)
OPPD RESPONSE I
1.
Admission or Denial of the Alleaed Violation l
0 PPD admits the violation occurred as stated.
2.
The Reasons For the Violation. If Admitted
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The reason for the violation can be attributed to the inadequacy of the procedure for temporary modifications.
The Standing Order S0-0-25 Rev. 26, I
which was in effect at the time of the violation, did not specify actions
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required to update the control room drawings when installing a temporary modification.
The Temporary Modification Control. Form associated with
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temporary' modifications were added to.the Shift Supervisors " Temporary Mod Log" in descriptive terms but not always with a drawing backup.
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- ~.# 3...The Corrective Steos That Have Been Taken and The Results Achieved l
l The immediate corrective action taken was the temporary modifications that
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were in effect at the time of the inspection were reviewed and the control j
room drawings were updated (red lined) to show temporary modifications. A i
revision change request to the Procedure 50-0-25, " Temporary Modification I
Control" was also initiated at that time.
4.
Corrective Steos Which Will Be Taken To Avoid Further Violations In order to prevent the violation from occurring in the future, Procedure l
S0-0-25 " Temporary Modification Control" Revision 28 was issued on February j
21, 1989.
Section' 7.2 (8); (9); and (10) of the procedure specifically
addresses actions to be taken during the evaluation and verification
l processing of the Temporary Modification Control form (FC-66A) to provide modification on the control room drawings when a temporary modification is l
to be installed in the field.
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Date When Full Comoliance Will Be Achieved
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OPPD is currently in full compliance with the corrective actions described above.
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