IR 05000285/1997007
| ML20149L450 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20149L228 | List: |
| References | |
| 50-285-97-07, 50-285-97-7, NUDOCS 9708010159 | |
| Download: ML20149L450 (4) | |
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ENCLOSURE 1 NOTICE OF VIOLATION Omaha Public Power District Docket No.: 50-285 Fort Calhoun Station License No.: DPR-40 During an NRC inspection conducted on March 23 through May 3,1997, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
Appendix B of 10 CFR Part 50 Criterion V, states, in part, that activities affecting
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quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Standing Order M-101, " Maintenance Work Control," Revision 43, Step 5.2.5, states, in part, that "A Work Request Tag should be completed whenever a MWR is initiated for an equipment deficiency."
Contrary to the above, the inspector identified that, on March 26,1997, licensee personnel did not complete a Work Request Tag following initiation of a Maintenance Work Request to document the identification of a body-to-bonnet steam leak on the steam trap inlet valve for the turbine-driven auxiliary feedwater pump steam supply line.
This is a Severity Level IV violation. (Supplement 1)(285/97007-01)
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Technical Specification 5.8.1 states, in part, that written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the minimum requirements of Regulatory Guide 1.33.
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Regulatory Guide 1.33, Appendix A, Section 9.a, states, in part, that maintenance that can affect the performance of safety-related equipment shall be performed in accordance with written procedures or documented instructions appropriate to the circumstances.
Standing Order SO-M-100, " Conduct of Maintenance," Step 4.6.2, directs maintenance personnel to perform maintenance in accordance with approved documents.
Preventive Maintenance Order 9701947 directed maintenance personnel to blow down the raw water supply header flow transmitter sensing lines by opening the drain valve to clear the lines. Step 6 of the preventive maintenance document stated that, if the sensing lines could not be cleared, initiate a maintenance work document to document the deficiency.
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9700010159 970725 PDR ADOCK 05000295
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-2-Contrary to the above, in addition to opening the drain valve to clear the t,ensing lines, the inspectors found that on April 7,1997, maintenance personnel used nitrogen to blow down the sensing lines without initiating a maintenance work
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document to document the deficiency.
This is a Severity Level IV violation. (Supplement 1)(285/97007-02)
The NRC has concluded that information reg -iv.g the reason for the violations, the
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corrective actions taken and planned to cony 5 the violation and prever t recurrence and
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the date wha' full compliance was achieved is already adequately addressed on the docket in Omaha Puuiic Power District letter dated June 17,1997. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does nc'i accurately refhm+ your corrective actions or your position. in that case, or if you choose to respond, clear., nark your response as a " Reply to a Notice of Violation,"
and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan
Plaza Drive, Suite 470, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this N itice, within 30 days of the date of the letter transmi'. ting this Notice of Violation (Nmh e).
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Dated at Arlington, Texas this 25th day of July 1997
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Omaha Public Power District-3-JUL 2 51997
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bec to DCD (IE01)
j bec distrib. by RIV:
Regional Administrator DRS-PSB DRP Director MIS System Branch Chief (DRP/B)
RIV File Project Engineer (DRP/B) -
Branch Chief (DRP/TSS)
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DOCUMENT NAME: R:\\_FCS\\FC707AK.WCW To receive copy of document, indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures "N" = No copy
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. OFFICIAL RECORD COPY
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444 South 16th Street Mall
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,.. !i June 19, 1997 l
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LIC-97-0099 Ji
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U.S. Nuclear Regulatory Commission AlI.Ui l
ATTN: Document Control Desk Mail Station P1-137 Washington. D.C.
20555 References: 1.
Docket No. 50-285 2.
Letter from NRC (T. P. Gwynn) to OPPD (S. K. Gambhir) dated May 19, 1997
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SUBJECT:
NRC Inspection Report No. 50-285/97-07. Reply to a Notice of Violation The subject report transmitted a Notice of Violation (NOV) resulting from an NRC inspection conducted March 23 through May 3.1997, at the Fort Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD) response to this NOV.
f OPPD disagrees with Violation A in Reference 2.
A response has been provided that does not deny the violation, but, places the violation where OPPD believes it should have been cited.
If you should have any questions, please contact me.
Sincerely
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K. Gambhir s.
Division Manager Engineering & Operations Support GRC/grc Attachment
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Winston and Strawn t
E. W. Merschoff. NRC Regional Administrator. Region IV L. R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector
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' Attachment, LIC-97-0099 Page 1 NOTICE OF VIOLATION Omaha Public Power District Doiet:
50-285
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Fort Calhoun Station License: DPR 40 During an NRC inspection conducted on March 23 through May 3,1997, two violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
A.
Appendix B of 10 CFR Part 50 Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Standing Order 50 R 2, " Corrective Action Program," Revision 3, Step 2.2, states, in part, that defective material and equipment, abnormal occurrences, and nonconformances affecting structures, systems or components require the initiation of a condition report.
Contrary to the above, the inspector identified that, on March 26, 1997, engineering personnel did not initiate a condition report when a body to-bonnet steam leak was identified on the steam trap inlet valve for the turbine driven auxiliary feedwater pump steam supply line.
This is a Severity Level IV violation. (Supplement 1)(285/97007 01)
B.
Technical Specification 5.8.1 states, in part, that written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the minimum requirements of Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix A, Section 9.a., states, in part, that maintenance that can affect the performance of safety related equipment shall be i
performed in accordance with written procedures or documented instructions appropriate to the circumstances.
Standing Order 50-M 100,
" Conduct of Maintenance," Step 4.6.2, directs maintenance personnel to perform maintenance in accordance with approved document.
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U.S. Nuclear Regulatory Commission
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Attachment. LIC-97-0099 Page 2 Preventive Maintenance Order 9701947 directed maintenance personnel to blow down the raw water supply header flow transmitter sensing lines by opening the drain valve to clear the lines. Step 6 of the preventive maintenance document stated that, if the sensing lines could not be cleared, initiate a maintenance work s
document to document the deficiency.
Contrary to the above, in addition to opening the drain valve to clear the sensing lines, the inspector found that on April 7,1997, maintenance personnel used nitrogen to blow down the sensing line without initiating a maintenance work document to document the deficiency.
This is a Severity Level IV violation (Supplement 1)(285/97007 02).
OPPD Resoonse to Violation A A.
The Reason for the Violation OPPD disagrees that a violation of Standing Order S0-R-2. " Condition Reporting and Corrective Action," occurred.
Instead, there exists a misunderstanding of the requirements of S0-R-2. Step 2.2.
Step 2.2 states. "This procedure applies to and requires origination of a Condition Report for any of the following:
Failures, malfunctions, deficiencies, or deviations affecting Structures,
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systems, or components that are considered sudden or unexpected and outside the anticipated performance history of the structure, system, or component, or Defective materials and equipment, abnormal occurrences, and
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nonconformances affecting structures, systems, or components, or Equipment related events, documentation deficiencies, non-routine outside
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agency notifications, operational events, testing deficiencies, security infractions, human performance errors, personnel safety issues, radiological occurrences, or other circumstances which impact or potentially impact safe and/or reliable operation of the Fort Calhoun Station, or Events identified which are, or are suspected of being, adverse to
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quality"
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Attachment; LIC-97-0099 l-Page 3'
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The event in question was a body-to-bonnet gasket leak on MS-234. " Steam Trap ST-
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i 15 Inlet VO ve." This valve. Which tees off the steam supply line to FW-10. the
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' turbine-dr'ven auxiliary feedwater pump, is a Dresser Industries, one inch, i
manual globe valve, with a 2000 psig pressure rating. While body-to-bonnet steam
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'i leaks are not desirable. it is not uncommon in the industry for small globe
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valves to develop steam leaks ov'er time.
Therefore, it is unreasonable to say that this steam leak was sudden _ or~ unexpected and outside the anticipated
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performance history of the structure, system, or component-(SSCs), or that the
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leak was due to defective materials and equipment, abnormal occurrences, and 2 -
nonconformances affecting SSCs.
In fact. the leak was not adverse to quality.
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and did not affect the performance of FW-10. Therefore, no violation of Standing _
Order R-2 occurred.
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However. OPPD does admit that this event did involve a violation of Standing Order.M-101. " Maintenance Work Control." This steam leak was identified by a
l Design Engineer on March 26. 1997. The System Engineer, following notification
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of the problem by the Design Engineer, wrote a Maintenance Work Request (MWR).
Step 5.2.5 of M-101 states, in part. "A Work. Request Tag should be completed i
whenever a MWR is initiated for an equipment deficiency." A Work Request Tag was subsequently completed and, attached to the valve.
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As a result. OPPD is taking corrective actions associated with Standing Order M-101 an opposed to Standing Order R-2.
B.
Corrective Steos Which Have Been Taken and the Results Achieved 1.
Valve MS-234 was repaired under Maintenance Work Order 970142 on April 4
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1997, within four working days after the Design Engineer identified the
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leak.
2.
OPPD maintains that the failure to attach a work request tag was an isolated case. The System Engineer involved in this incMent is aware of the requirement for installing these tags.
However, the System Engineer
involved in the event has been counseled on the need to attach Work
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Request Tags on equipment whenever a Maintenance Work Request has been written.
Additionally.. the engineer was counseled on management's
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expectations on attention to detail and equipment walk-downs.
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Attachment, LIC-97-0099-Page.4 C.
Corrective Steos Which~Will'Be Taken
.This. event will be covered during an Engineering and Operations Support
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continuing training session to review management' expectations with the Engineering Staff. This will be completed by September 30, 1997.
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Date When Full Comoliance Will Be Achieved OPPD is currently-in full compliance.
j OPPD Resoonse to Violation B
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The Reason' for the Violation
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'l OPPD admits the violation occurred. The reason for this violation was failure j
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to comply with the procedure verbatim.
The technicians interpreted the. term'
" blowdown" to include the use of low pressure nitrogen to remove the obstpuction :
in the sensing line as a skill of the craft. This was performed at the direction of the craft supervisor.
B.
Corrective Steos Which-Have Been Taken and the Results Achieved On' April 30, 1997, the work instructions of the Preventive Maintenance' Order (PMO) were chano'd to allow the use of a nitrogen bottle.to clear sensing lines of obstructions. The change also included instructions-for notification of the System Engineer when use'of nitrogen was required.-
C.
Corrective Steos Which Will Be Taken A' briefing of maintenance personnel assigned to Fort Calhoun Station and the System Engineering Department will be conducted to emphasize the requirements of-S0-G-7, " Operating Manual." S0-M-100, " Conduct of Maintenance," and S0-M-101.
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Date When Full Comoliance Will Be Achieved
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OPPD is currently in full compliance.
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