ML19256E824
| ML19256E824 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/06/1979 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7911150317 | |
| Download: ML19256E824 (5) | |
Text
..
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_I LJ bM Omaha Public Power District 1623 HARNEY OM AN A.
NESRASKA 68102 TELEPHONE S36-4000 AREA CODE 402 November 6, 1979
- L*. Darrell G. Eisenhut Acting Director Divisicn of Operating Eeactcrs Office of Iiuclear Reacter Eeralation U. S. Iluclear Regulatcry Cctuissicn Washingten, D. C.
20555
Reference:
Dceket No. 50-205 Gentlemen:
The Craha Public Fover District received the Cc=issicn's letter of September 21, 1979, requesting that the District ccnduct certain reviews of Fort Calhoun Stt.icn operations in regard to the potential fcr multiple equipment failures and surveillance testing errcrs.
Acccrdingly, the rwiews were conducted and are sunnariced in the attachnent to this letter. The attachment clearly dencnstrates that the Fcrt Calhcun Staticn is cperated safely and in accordance with the Occrissicn's reralaticns and, as cuch, nc just cause exists for scdifying, suspending, or reycking Operating License No. DPE LO.
Sincerely, W. C. Jones Division Manager Production Operations WCJ/FJM/3JH:J==
Attachment ec: LeSceuf, Lamb, leiby & MacEae 1333 New Hampshire Avenue, N. W.
Washingten, D. C.
20036 Sworn and subscribed to this - -
day of '
., 1979 Notary Public 1333034 Aool e sian= =amr-s,....,,,J S
J. T. GLEASON
_QQ My Conm f.o. My 28.1982
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7911150 317
g.
1.
- 1) Requested Review:
You and your plant supervisors should review the its described in this letter, to determine whether similar errors have occurred or could occur at your facility and whether the potential exists for a problem associ-sted with occurrences that you have not previously con-sidered.
Renly:
The operations incidents which vere reviewed indicate that only cne error to date has resulted in an' inadvertent challenge to the reactor trip or engineerei safeguards systems:
Date Incident Cc==ent 1/11/77 Inaivertent partial
?cver Oper3an centinued centainment spray after a ccntainment in-briefly initiated.
pectica chewed no sign of am jctential equipment degcr.daticn caused by vet-ting with berated centainment spray water.
Some limited pescibility fcr errors which challenge the reacter trip or engineered safeguards syste=n at Fort Calhoun always exists.
However, this potential for error is held to an acceptable level by well vritten surveillance test preccdures which have withstood the test of time and by trained, knowledgeable perscnnel per-f rming the procedures.
All procedure changes and engineering evaluation assis-tance requests (EZAR) prepared for the Fort Calhoun Station are reviewed for the potential of being an un-reviewed safety questien per 10 CFR 50 59 This review provides for a constant analysis of the operational methodology used at the Fort Calhoun Station.
- 2) Recuested Review:
In addition, it is requested that management policies and procedures be reviewed and strengthened as nece-ssary to assure that multiple equipment failures in safety-related systems vill be vigorously pursued and analyzed to identify potential failula modes not pre-vicusly considered that could lead to a significant reduction in the ability of safety systems to function as required.
1335 035
2.
Reuly:
A review of policies and procedures to ascertain that multiple equipment failures in safety-related systems vill be vigorously pursued and analyzed indicates that the District has sufficient methods and means to iden-tify multiple equipment failures, analyze their poten-tial significance, and pursue resolution of the pro-blem. Specific guidance concerning the evaluaticn of
" Incidents, Occurrences, Failures, Malfunctions, etc.,
to Frevent Recurrence" is provided in plant Special Order No. 25 The folleving discussion is a brief description of the method that the Cistrict uses to ascertain timely analysis and resciution of multiple safety-related equipment failures.
Within the District organizatien, two groups, the Plant Review Com it*-a f:CC' and the Safety Audit and Review Cc==ittee (SARC), have the pr'--"y responsibility of identifying and pursuing unreviewed safety questions.
The respencibilities of each Ccnnittee is delineated in section 5 cf the plant's Technical Specifications.
Any and all equipment failures in safety-related systems, whether found during operation er testing, are documented on the plant's Operati;ns' Incident (OI) for=.
Provi-sien is made on this form to identify previous related incidents, if any.
In addition, a determination is made per 10 CFR 50.59 for eac'. OI as to whether or not the incident constitutes an unreviewed safety questien.
All completed O! forms sre revic sed by the PRC and Quality Assurance, with the tore significant OI's also being re-viewed by the SARC.
In additicn, the SARC periodically audits the OI files to ensure that all recc== ended correc-tive action is accc=plished in a timely =anner.
The SARC also reviews all OI's, LER's, and GIE Inspection Reports to determine' any trends in the nature of incidents, equip-ment =alfunctions, or operator errors relating to safety related systems. The use of Operations Incidents is out--
lined in the plant's Standing Orders.
.so require Scre equipment fcilures are sericus enough to 4
the submittal of a Licensee Event Report (LER) as defined in section 5 of the plant's Technical Specificatior.c. As with Operations Incidents, LER's a:e also acec=panied with an unreviewed safety question analysis per 10 CFR 50.59 and a description of the equipment failure history. The use of Licensee Event Reports is outlined in the plant's Tech-nical Specifications and Standing Orders.
1335 036
.s 3.
Renly (Continued)
Equipment failures, whether single or =ultiple, whose analysis appear to be beycnd the secpe of plant personnel, are submitted to the District's Technical / Engineering Departments as an Engineering Evaluation Assistance Re-quest (EEAR) for analysis and resolution. EIAR's are given attention in accordance with priorities established by District management. The use of EEAR's is outlined in the plant's Scanding Orders, in addition to the adminis-trative manuals of the Technical / Engineering Departments.
Safety-related equipment failures or potential failures may also be censidered in accordance with the requirements of 10 CFR Part 21, if applicable. The applicability and implementation of the Part 21 requirements are delineated in the District's Quality Assurance Manual (Quality Assur-ance Procedure #21), and the plant's Special Orders (No. 26) and Standing Orders.
Safety-related equipment failurea reported to the District in CIE Bulletins, Circulars, and/cr Infer =ation Notices, are usually analyzed and resolved in accordance with the schedule of tne given dccu=ent.
Scre itens are handled by the plant staff and sc=e are handled by the District's Technical / Engineering staff.
There may be an cccasion when a safety-related equipment failure is also carried as a Quality Assurance " Deficiency Report" or "Nonecnformity Report".
The use of these re-porting methods is outlined in the District's Quality Assur-ance Manual and in the plm. 's Standing Orders. Prc=pt followup is provided by the District's Quality Assurance group.
Frc= the above discussion it is apparent that the District has the mechanic: to ensure that multiple equipment fail-urea in safety-related systems will be pursued and analyzed in a timely manner.
In addition to the mechanism, the Dis-trict personnel associated with the operation of the Fort Calhoun Station are well trained, ec=petent, conscientious individuals who take their jobs and responsibilities seriously.
1335 037 O
e
4 h.
- 3) Reauested Review:
Finally, you are requested to reviev your engineered safety syste= surveillance procedures to determine whether appro-e cautions are included and to ensure that plant oper-s d supervisors are aware of the i=portance of avoid-ine
?h'_ lenges to the prctective features of your facility.
Paol.v :
~~
All engineered safety feature (ESF) surveillance tests have been reviewed in sn effort to determine that adequate pre-cautions are incorporated to avoid any challenges to the plant's protective features.
This review has shown that the existing s~ rveillance test procedures presently contain u
appropriate precautions to ensure that plant operators, tech-nicians,' and superviscrs are aware of thoce iters which ecull cauce challenges to the plant'c protective features during the performance of a test.
)
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