ML20012C430

Responds to Violations Noted in Insp Rept 50-285/90-01. Corrective Actions:Util Issued Upgraded Version of Calibr Procedures Including,Steps to Verify Actual Measured Float Positions Against Instrument Indications

ML20012C430
Person / Time
Site:	Fort Calhoun
Issue date:	03/12/1990
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-90-0175, LIC-90-175, NUDOCS 9003210275
Download: ML20012C430 (5)

Text

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l Omaha Public Power District  ;

1623 Harney Omaha. Nebraska 68102 2247 l 402/536 4000  !

March 12, 1990 LIC-90-0175 i U. S.' Nuclear Regulatory Commission Attn: Document Control' Desk Mail Station PI-137 Washington, DC 20555

References:

1. Docket No. 50-285 4

2. Letter from NRC (S. J._ Collins) to OPPD (K. J. Morris) dated February 1, 1990

3. Letter from 0 PPD (W. G. Gates) to NRC (R. D. Martin) dated-February 15, 1990 (LIC-90-0142) s Gentlemen:-

SUBJECT:

Response to Notice of Violation (NRC Inspection Report 50-285/90-01)

Omaha Public Power District (0 PPD) received the subject inspection report (Reference 2) which identified two violations regarding' calibration of level i' transmitters and 480 VAC instrumentation. Attached please find OPPD's response to this item in accordance with 10 CFR Part 2.201.

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An extension of the required response date to March 12, 1990 was discussed in a_ e telephone conversation between NRC and OPPD on March 5, 1990.

If you should have any questions, please contact me.

Sincerely, w

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n. 2. As

$@ W. G. Gates Division Manager Nuclear Operations M((o Ed WGG/pjc ca o 3@ . Attachment

f. N om c: LeBoeuf, Lamb, Leiby & MacRae

@@c R. D. Martin, NRC Regional Administrator, Region IV A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector go/

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. ATTACHMENT RESPONSE TO NOTICE OF VIOLATION During an NRC inspection conducted January 8-12, 1990, violations of NRC requirements were identified. The violations involved the failure to properly implement Technical Specification (TS) surveillance requirements and procedure requirements. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989)  !

(Enforcement Policy), the violations are listed below: 1 A. Failure to Properly Calibrate Level Transmitters '

Technical Specification 3.1, " Instrumentation and Control Surveillance Requirements" requires that: " Calibration, testing and checking of instrument channels, reactor protective system and engineered safeguards system logic channels and miscellaneous instrument systems and controls shall be performed as specified in Tables 3-1 to 3-3."

1 Item 27 of Table 3-3, " Containment Water Level Narrow Range (LT-599 and i LT-600)" requires that calibration of the instruments on a refueling  !

frequency by "Known signals applied to sensors."

Contrary to the above, the licensee had failed to include the sensors for the containment sump narrow-range level instrumentation in the calibration process.

This is a Severity Level IV violation. (Supplement I) (285/9001-04)  :

OPPD RESPONSE:  !

1. The Reason for the Violation, if Admitted OPPD admits the violation occurred as stated.

The procedures in place at the time of the inspection were intended to meet  !

Technical Specification requirements for calibration of the Containment Sump Narrow Range Level Instruments (LT-599 and LT-600). The procedures were consistent with the appropriate vendor manuals and were therefore believed to meet the Technical Specifications based on the following:

a Loop calibrations of L-599 and L-600, performed every 18 months, included the use of a " float simulator" potentiometer. This potentiometer was used to apply a known signal current across the sensors to verify channel calibration.

e I.4 e ' An additional calibration check was performed monthly by testing the " FULL REF" switch. The vendor manual describes this as a means of checking the integrity of the system with no other test equipment or program being needed. The vendor manual further indicates that this switch connects the indicating meter across the entire transmitter and cabling, a Proper float operation was considered to be addressed by the daily verification of proper operation of level recorders LR-599 and LR-600. As these instruments are independent, an improperly operating float or a discrepancy between a float level and the ,

recorder indication would be evidenced by a difference in displayed level between the two recorders.

1 Prior to the inspection, OPPD had initiated an upgrade of containment sump level calibration procedures as part of the safety-related procedures upgrade program. This upgrade identified the issue addressed by the violation and initiated a change; however, the procedure in place at the time of the inspection was not recognized as failing to satisfy the Technical Specification requirement.

2. The Corrective Steos Which Have Been Taken and the Results Achigy_qd As indicated above, OPPD had initiated an upgrade of containment sump level calibration procedures prior to the inspection. The upgraded version of this procedure has been approved and issued. The revision includes steps to verify actual measured float positions against instrument indications.

3. The Corrective Steos Which Will Be Taken to Avoid Further Violation OPPD's safety related procedures upgrade program will be completed in accordance with the existing schedule (Reference 3).

4. The Date When Full Como11ance Will Be Achieved OPPD is currently in full compliance.

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B. ' failure to Calibrate the 480 VAC Instrumentation Technical Specification 5.8.1, " Administrative Controls - Procedures,"

requires that, " Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the minimum requirements of sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 . . . ."

Appendix A of Regu'latory Guide 1.33, " Quality Assurance Program Requirements," paragraph 8.a, requires the establishment and implementation of procedures for the calibration of readout instruments used for plant operation including postaccident monitoring.

Contrary to the above, the licensee failed to establish and implement procedures for the calibration of the 480 VAC bus voltage and amperage instruments utilized for postaccident monitoring. -

This is a Severity Level IV violation. (Supplement I) (285/9001-05)

OPPD RESPONSE:

1. The Reason for the Violation, if Admitted OPPD admits the violation occurred as stated. At the time of the NRC l inspection no calibration procedures existed for the 480 VAC bus voltage and amperage instruments. The requirement to routinely calibrate these instruments to meet Regulatory Guide 1.97 requirements had not been identified by OPPD.

2. The Corrective Steos Which Have Been Taken and the Results Achieved At the time of the NRC inspection, Procedure MS-CP-07-0002 " Calibration of

' Type 180 Indicating Instrument", was in the draft stage. This procedure was prepared to address concerns associated with VAC bus-tie ammeters in

! response to a previously identified issue. The procedure was written as a i- generic procedure for General Electric Type 180 meters. The applicability j list included the bus-tie ammeters and the 480 volt bus voltmeters and i

ammeters, 1

l Calibration Procedure MS-CP-07-0002 was issued January 25, 1990. This procedure provides calibration instructions for the 480 VAC bus voltmeters and ammeters.

Calibration procedures for other power sources for post-accident monitoring instrumentation (4160 VAC, 120 VAC and 125 VDC) were reviewed and found to be adequate to ensure proper calibration of readout instrumentation.

3. The Corrective Steos Which Will Be Taken to Avoid Further Violation Calibration testing is being scheduled for the 480 VAC bus voltage and amperage instrumentation on a refueling outage frequency.

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4. , The Date When Full Como11ance Will' Be Achieved Full' compliance will be- achieved prior to startup from the 1990 refueling -

outage when the 480 VAC bus ammeters and voltmeters will be calibrated.

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