ML20043B464
| ML20043B464 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/21/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gates W OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9005300062 | |
| Download: ML20043B464 (2) | |
See also: IR 05000285/1990002
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In Reply Refer To:
Docket:- 50-285/90-02
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' Omaha Public Power District.
ATTN:
W. G.' Gates, Division Manager
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. Nuclear Operations
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'444 South 16th Street Mall-
Mail Stop 8E/EP4
Omaha. Nebraska- 68102-2247
Gentlemen:
Thank you for your letter of May 7,1990, in response to our letter and Notices
- of' Violation and Deviation dated April 6,1990. We have reviewed your reply to
- the Notice of Violation and. find it responsive to the concerns raised. We will'
review the implementation of your corrective actions durin9 a future inspection
to determine that full compliance has been achieved and will be maintained.
In discussions with Ms. D. Matthews, Supervisor Station Licensing, on May 14,
1990, it was established that you desire to revise your response to the Notice
of Deviation due to a planned change in your response to the corrective action
steps which will be taken to avoid further deviations'. During the discussion,
it was determined that a revised response would be submitted on or before
Junei29, 1990.
We find that your proposal for resubmittal- of a response to the Notice'of
' Deviation is appropriate.
Sincerely.
Original Signed By:
Samuel'J. Collins
Samuel J. Collins, Director
Division of Reactor Projects
cc:
LeBoeuf, Lamb, Leiby & MacRae
ATTN: Harry H. Voigt, Esq.
1333 New Hampt. hire Avenue, NW
Washington, D.C.
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Washington County Board
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ATTN:: Jack Jensen, Chairman
Blair, Nebraska 68008
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U.S. Nuclear Regulatory Cobrnission
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Resident Inspector
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Fort Calhoun, Nebraska' 68023
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' ATTN:. Regional Administrator, Region IV.
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Omaha Public Power District
1623 Harney Omaha. Nebraska 68102 2247
402/536-4000
May 7, 1990
LIC-90-0366
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U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Station Pl-137
Washington, DC 20555
Reference:
1.
Docket No. 50-285
2.
Letter from NRC (S. J. Collins) to OPPD (W. G. Gates) dated
Aprii 6, 1990
Gentlemen:
SUBJECT:
Response to Notice of Violation and Notice of Deviation
(NRC Inspection Report 50-285/90-02)
Omaha Public Power District (0 PPD) received the subject inspection report
(Reference 2) which identified one violation regarding raw water pump discharge
check valves and one deviation regarding installation of cables.
Attached
please find OPPD's response to these items in accordance with 10 CFR Part 2.201.
If you should have any questions, please contact me.
Sincerely,
W
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W. G. Gates
Division Manager
Nuclear Operations
WGG/mc
Attachment
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LeBoeuf, Lamb, Leiby & MacRae
A. Bournia, NRC Project Manager
qR 8DL Martin;eNRC Regional. Administrator, Region IV '
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P. H. Harrell, NRC Senior Resident Inspector
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ATTACHMENT
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RESPONSE TO NOTICE OF VIOLATION
During an NRC inspection conducted on January 16 through February 28, 1990, a
violation of NRC requirements was identified.
In accordance with the " General
~ Statement of Policy-and Procedure for NRC Enforcement Actions", 10 CFR Part 2
Appendix _C (1989) (Enforcement Policy), the violation is listed below:.
Failure to Take Corrective Actions
' Criterion XVI of Appendix B to 10 CFR Part 50 and Lction A.17 of the
licensee's approved QA Program, Updated Safety Analysis Report, require that
measures be' established to assure that conditions adverse to quality be
promptly identified and corrected.
Contrary to the above, the corrective measures initiated by the licensee failed
to:
1.
Identify in Safety Analysis for Operability 89-10 the potential for
degradation of the raw water (RW) pump discharge check valves that could
have resulted in the operation of the RW system outside of its design basis -
following the failure of the RW pump AC-10A discharge check valve (Valve
RW-125) on June 24, 1989.
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2.
Provide for backflow testing of the RW pump discharge check valves to
determine that further degradation had not occurred from the first quarter
of January.1989 until January 1990.
This is a Severity Level IV violation. (Supplement I) (285/9002-04)
OPPD RESPONSE:
1.
The' Reason for Violation, if Admitted
.
OPPD admits to the failure to conduct RW pump discharge check valve
surveillance testing (to monitor the condition of the remaining check
.
valves) following issuance of Safety Analysis for Operability (SA0) 89-10.
The purpose of SA0 89-10 was to analyze the operability status of the raw
water system with -the internals removed from RW-125.
SA0 89-10 was not
issued to address potential further degradation of the raw water pump
discharge check valves.
When SA0 89-10 analysis was prepared, it
conservatively accounted for the degraded condition of RW-ll7 based on
backleakage data available at the time.
As noted in the NRC Inspection
Report, the SAO stated that if surveillance testing revealed further
degradation of RW-ll7, then the cot.dition should be assessed and the SA0
revised accordingly.
Surveillance testing on these check valves, however, had been suspended
prior to the failure of RW-125 and had not been resumed with the issuance
- of SA0-89-10.
The apparent cause of this violation, therefore, was a lack
of communication regarding surveillance testing of the RW pump discharge
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(Response to Notice of Violation (Continued)
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The Corrective Steos That. dave Been Taken and the Results Achieved
2.
The four RW pump discharge check valves have been replaced and SA0 89-10
has-been closed.
Quarterly backleakage testing on these valves has been
re-instated.
OPPD has reviewed the other SA0s which are in force to determine if there
are other SAO mandated surveillance requirements or compensatory measures
which have been overlooked. This review revealed no similar situation with
other SA0s.
3.
The Corrective Steos Which Will be Taken to Avoid Further Violations
O
Based on the results of the review of other SA0s, OPPD considers the
violation to be an/ isolated incident.
However, OPPD intends to revise the
procedure for preparation of SA0s (N00-QP-22).
In the event an SA0's
requirements are more limiting than a surveillance test's. acceptance
criteria, the revision to N00-QP-22 will require that a caution statement
be added to the affected surveillance test (s) which precludes changing
affected sections of the test procedure without review of the impact on the
SAO conclusions. The caution statement would remain in the affected
test (s) for the duration of the SA0.
The revision to N0D-QP-22 will also
clarify the.need for the SA0 to identify actions required to maintain the
validity of the SA0. N00-QP-22 will be revised by July 1,1990.
4.
The Date When Full Comoliance will be Achieved
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OPPD is presently in full-compliance.
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RESPONSE TO NOTICE OF DEVIATION
Based on- the results of an NRC inspection conducted January 16 through February
28, 1990, a deviation of- your commitments made to the NRC was identified.
In
accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions," 10 CFR Part 2, Appendix C (1989) (Enforcement Policy),.
the deviation is listed below:
Jnadeauate Installation of Cables
Figure 8.5-1, " Cable and Conduit Schedule Notes," of the Updated Safety
Analysis Report states, in part, that the installation of electrical cables-
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shall meet the following requirements:
Paragraph 20.c states, in-part, that the fill in trays for 125-Vdc and
a
120-Vac cables shall generally not exceed a maximum of 50 percent.
-Paragraph 22 states, in part, that prefixed (sufety-related) cables
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may be routed in raceways containing nonprefixed (nonsafety-related)
. cables provided the cables are separated by a metallic barrier.
Paragraph 18 states, in part, that control and instrument cables shall
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be tied down in a neat configuration after installation in trays.
In deviation from the above, the licensee failed to properly install cables in
Trays 5-4A and 5-4B in that examples of improperly installed cables were
identified by the inspector that did not meet the installation criteria
identified above. (285/9002-03)
_0 PPD RESPONSE:
1.
The Reason for the Deviation if Admitted
OPPD admits the Deviation occurred as stated. The deviation. occurred for-
two reasons:
Inadequate instructions in the standard construction procedure to the
a.
Craftsmen and Quality Control Inspectors during the installation of-
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cables, resulting in cables not being tied down,
b.
Inadequate procedures for the preparation of modification packages to
address and analyze the impact of tray loading (percent fill) and
safety and non-safety related cable separation using a metallic
barrier. This resulted in tray overfills which render some of the
existing metallic barriers ineffective.
2. . The Corrective Steps Which Have Been Taken and the Results Achieved
Available computerized data on cable tray fill has been reviewed against
USAR criteria to identify potentially overfilled cable trays. An
inspection has been initiated of readily accessible safety related tray
subsections where fill in excess of the criteria has been identified.
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- Response'to Notice of Deviation.(Continued)
3.
Jhe Corrective Action Steos Which Will be Taken to Avoid Further Deviations
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OPPD plans to take the following' actions to prevent recurrence of the
deviation:
Prepare a. Safety Analysis for Operability (SAO) to justify operation
a.
under the current configuration, and complete a walkdown of-identified
safety related tray sections (which are accessible without construc-
tion of scaffolding) to verify existing conditions are appropriately
addressed by the SAO.
This is to be completed before startup from the -
1990 refueling outage (currently in progress),
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b.
Prepare an Engineering Analysis addressing the tray overfill and lack
of a metallic barrier. This analysis will discuss- updated criteria-
for determination of acceptable cable tray loading which will be
incorporated into a future revision to the USAR.
This Engineering
Analysis is to be completed by June 15, 1990.
Update the OPPD Engineering Instruction dealing with-cable separation
c.
and-tray loading to require specific analysis for each modification
which involves the installation or change in routing of cables in the
Fort Calhoun Station. This is to be completed by August 24, 1990,
d.
Update the construction procedure dealing with cable installation to
provide better : instructions to the craftsmen and Quality Control
Inspectors on cable installation in the cable tray system. This will
'be completed by June 29, 1990.
4.
The Date When Full Comoliance Will be Achieved
'0 PPD expects to be in full compliance by August 24, 1990.
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