IR 05000285/1997019

Ack Receipt of Explaining Steps Taken to Correct Violations Noted in Insp Rept 50-285/97-19 on 971219.Finds Reply Responsive to Concerns Raised in Nov.Will Review Implementation of C/As During Future Insp

ML20199J081
Person / Time
Site:	Fort Calhoun
Issue date:	01/29/1998
From:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
References
50-285-97-19, NUDOCS 9802050209
Download: ML20199J081 (4)

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, , ARLINGTON, TEXAS 760114064 JM 2 91998 S. K. Gambhir, Division Manager Engineering & Operations Support Omaha Public Power District Fort Calhoun Station FC 2-4 Adm.

P.O. Box 399 Hwy. 75 North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 SUBJECT: NRC INSPECTION REPORT 50 285/97-19

Dear Mr. Gambhir:

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Thank you for your letter of January 16,1998, in response to our letter and Notice of i Violation dated becember 19,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We willi aw the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, h

Willia . Johnson, Chief Project Branch B-Division of Reactor Projects Docket No.: 50 285 License No.: DPR-40 cc:

James W. Tills, Manager Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399

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Omaha Pubib Power District 2 James W. Chase, Manager Fort Calhoun Station P.O. Box 399 Fort Calhoun, Nebraska 68023 Perry D. Robinson, Esq.

Winston & Strawn l 1400 L. Street, N.W.

Washington, D.C. 20005-3502 Chairman Washington County Beard of Supervisors i Blair, Nebraska 68008 I Cheryl Rogers, LLRW Program Manager Er vironmental Protection Section Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509 5007

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January 16,1998 "  ;

LIC-98 0004 e p$q Jid ? 6 ~ !

-lL t U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station Pl-137 REG g ~[~" ,

Washington, DC 20555 References: 1. Docket No. 50 285 2. Letter from NRC (W. D. Johnson) to OPPD (S. K. Gambhir) dated December 19,1997 SUBJECT: NRC Inspection Report No. 50-285/97-19, Reply to a Notice of Violation The subject report transmitted a Notice of Violation (NOV) resulting from a NRC inspection conducted October 26 through December 6,1997 at the Fort Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD) response to this NOV.

If you should have any questions, please contact me.

Sincerely, S. . Gambhir Division Manager Engineering and Operations Support SKG/ddd Attachment c: Winston and Strawn E. W. Merschoff, NRC Regional Administrator, Region IV L. R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector 99-66 @

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Attachmen.

!- LIC-98-0004 '

Page1 REPLY TO A NOTICE OF VIOLATION

Omaha Public Power District Docket No.: 50-285 Fort Calhoun Station - License No.: DPR-40

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During nu NRC inrpection conducted on October 26 through December 6,1997, three

. vloistions of NRC requirements wereidentifled. In accordance with the" General

' Statement of Polley and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

! A. Appendix B to 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 c with these instructions, procedures, or drawings.

Standing Order SO O-1," Conduct of Operations." Revision 36, Step 6.1.3, Section i C and G, requires, in part, that all necessary plent related technical / administrative control room business must be conducted at a location and in such a maurer that I neither licensed control room operator attentiveness nor the professional

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atmosphere will be compromised. It further requires that nonoperations personnel shall enter the control room only to discuss official business with the control room crew.

Contrary to the above, on November 21,1997, the control room crew failed to maintain a professional atmosphere in the control room in that breakfast was being cooked in the main control room area and nonoperations personnel were eating in

Control room.

This is a Severity Level IV violation (Supplement 1)(50-285/9719-01).

-B. Appendix B of 10 CFR Part 50, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instruction, procedures, or drawings of a type appropriate to the circumstances.

Revision 11 of Operating Instruction OI-CO-5," Containment Integrity," states, in part, that the purpose of this operating instruction is to establish containtrent lategrity.

Contrary to the above, on November 19,1997, the inspectors identified that the containment in_tegrity operating lustruction was inadequate because not all containment penetrations needed to establish containment integrity were included in the operating lustruction.

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i Attaclunent LIC 98 0004 Page 2 This is a Severity Level IV violation (Supplement 1)(50-285/9719-02).

C. 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 Gulde 1.33, Appendix A, Section Ic, states,in part, that procedures shall be written for equipment control (e.g., locking or tagging).

Standing Order SO-O-44," Administrative Controls for the Locking of Components," Revision 5d, Attachment 1," Locked Components Checklist,"

requires that Valve IICV-2812C, raw water inlet to SI-2C hearing cooler, he locked.

Step 7.1 of Standing Order 50-0-44 states that locking devices shall at the very least provide a ll.nited physical restraint on the operation of the compon at.

Contrary to the above, on December 3,1997, the inspectors identified that the locking device on Valve IICV-2812C was improperly installed and would not have provided the physical restraint to prevent operation of the valve.

This is a Severity Level IV violation (Supplement 1)(50-285/9719-03).

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OEPAResponse These violations wm cited separately as Violation A (9719-01), Violation B (9719-02), and Violation C (9719 03) respectively. OPPD is p:oviding a separate response to violations B and C. Per the cover letter from reference 1, the NRC has concluded that information regarding the reason for violation A, and the corrective actions taken to correct the violation and prevent its recurrence, have already been addressed. Therefore, a response to this violation is not provided.

Violation"B" Response 1. Reason for the violation

- Revision 10 of OI-CO-5," Containment Integrity," and OI-CO-5-CL-D, the

" Containment Integrity Checklist," were in the process of being refonnatted. Afler approval by the responsible department head, the hard copy of OI-CO-5-CL-D was forwarded by the Procedure Maintenance Group (PMG) to Document Control for issuance. This procedure was also made available to Document Control in an electronic format so that procedure change bars, issue date and revision date could be added before being routed for typing review, proofreading, reproduction and issuance. The electronic file made available by the PMG and retrieved by Document Control did not contain five of the electrical penetrations that were present on the hard copy of OI-CO-5 that was routed for approval. During the Qualified Reviewer approval process, the reformatted

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O Attachment LIC-98-0004 Page 3 draft of OI CO 5 CL D contained the five electrical penetrations that were subseli uently found missing. Neither the typing review, which is intended to be a detailed comprehensive review, nor the proofreading review which is intended to be a format adherence review, identified the missing data. OI CO 5 was ultimately issued on May 2, 1997 with five electrical containment penetrations missing from OI CO-5 CL D.

The failure of the procedure review process to identify the discrepancy and the lack of proceduralized guidance for the handling of electronic files during the procedure change process were the two contributing factors in * '.s event.

2.' Corrective Steps Taken and Results Achieved a. Afler the discovery of the missing penetrations from OI CO 5, these penetrations were added to the procedure. These penetrations were then checked and found to be intact and operable.

b. A sampling of other procedures revised as part of the 'me reformatting program were compared to their previous revisions to ensure no information was inadvertently omitted or added. No problems were noted.

t c. As an interim measure new er revised station procedures will be manually copied afler approval.

3. Corrective Steps That Will Be Taken To Avold Further Violations A new Nuclear Administrative Instruction NAl 20, Control of Electronic Copies, will address control of electronic files. This procedure will be issued by February 27,1998.

4. The date when full compliance will be achieved Fort Calhoun Station is currently in full compliance.

' Ylolation."C" Response 1. Reason for the Violation HCV-2812C is the raw water interface inlet valve to high pressure safety injection pump SI 2C bearing cooler. HCV-2812C is normally closed and can supply backup cooling water to SI 2C ifits primary cooling water, component cooling water, is lost. Because of the physical orientation and proximity of HCV-2812C to the SI 2C mini recin:ulation line, its manual operator is a lever inst:ad of a handwheel. Thus, the normal practice c,f mnning the locking chain through the valve bonnet and handwheel to provide a secure lock cannot be used for this valve. HCV-2812C did have a chain and lock installed but

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o Attaciunent LIC 98 0004 Page 4

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the chain was not secured in such a fashion as to ensure limited physical restraint of the manual lever as required by SO O 44. This occurred due to the unique physical arrangement as previously noted and the operator's belief that the valve was adequately secured. It should be noted that with the chain and lock installed, although inadequate to -

prevent operation wi'.h malicious intent, did provide administrative control of the valve.

2. Corrective Steps Taken and Results Achieved a. The Auxiliary Building operator reinstalled the locking device (chain and lock) ;

for llCV 2812C in a manner that provides limited physical restraint.

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b. The SO O-44 locked component checklist was completed for locked valves, i

except those in very high and restricted high radiation areas, to ensure that locking ;

devices provided limited physical restraint.

3.. Corrective Steps That Will Be Taken To Avoid Further Violations i a. Training, that discusses locking of unique valves such as 11CV 2812C, will be conducted on this event. This will be completed by March 31,1998. I b, OPPD will evaluate if a better locking mechanism can be used on 11CV 2812C.

This evaluation will be completed bv February 27,1998.

4. The date when full compilance will be achieved Fort Calhoun Station is currently in full compliance.

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Regional Administrator DRS PSB DRP Director MIS System Branch Chief (DRP/B) RIV File Project Engineer (DRP/B)

Resident inspecto.- Branch Chief (DRP/TSS)

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DOCUMENT NAME: R:\_FCS\FC719AK WCW lo receive copy of document. Indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures *N" = No copy RIV:PE:DRP/B, C:DRP/B / /

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