ML20054M453

Responds to NRC Re Violations Noted in IE Insp Rept 50-285/82-03.Corrective Actions:Operating Instruction Revised to Include Precaution Against Draining Vent Header While Gas Sample Being Drawn from Vol Control Tank

ML20054M453
Person / Time
Site:	Fort Calhoun
Issue date:	04/19/1982
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20054M451	List: IR 05000285/1982003 ML20054M453
References
LIC-82-160, NUDOCS 8207130253
Download: ML20054M453 (5)

Text

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Omaha Public Power District 1623 MARNEY e OMAHA, NEBRASMA 68102 e TELEPHONE S36 4000 AREA CODE 402 April 19, 1982 LIC-82-160 .

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Y p 211982 Mr. J. T. Collins, Administrator h./

U. S. Nuclear Regulatory Commission Region IV M -

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611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

References:

Docket No. 50-285 IE Inspection Report 82-03

Dear Mr. Collins:

The subject inspection report identified one violation regarding the adequacy of certain instructions and procedures at the Fort Calhoun Station. The Omaha Public Power District's response to this violation is attached.

Sincerely, l^detCJ g W. C. Jones Division Manager Production Operations cc: U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D. C. 20555 LeBoeuf, Lamb, Leiby & MccRae 1333 New Hampshire Avenue, N. W.

Washington, D. C. 20036 8207130253 020702

{DRADOCK 05000285 PDR h

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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Omaha Public Power District ) Docket No. 50-285 (Fort Calhoun Station, )

Unit No.1) )

i AFFIDAVIT

. . . . . being duly sworn, hereby deposes and says that he is Section Manager - Operations of Omaha Public Power District; that he is duly I authorized to sign and file with the Nuclear Regulatory Commission the attached response to the Notice of Violation identified in IE Inspection Report 82-03; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his know-ledge, information and belief, a/ya R. L. Andrews Section Manager Operations

, STATE OF NEBRASKA ss COUNTY OF DOUGLAS)

Subscribed and sworn to befgye me, a Notary Public in and for the State of Nebraska on this /fN day of April,1982.

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OMAHA PUBLIC POWER DISTRICT Response to Inspection Report 82-03 Violation Technical Specification 5.8.1 requires that, " written procedures...

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..."

Section 5.1 of ANSI N18.7-1972 states that the licensee, " establish rules and instructions pertaining to personnel conduct and control (and) method of conducting operations. .. ," and that, " guidance should be provided to identify the manner in which procedures are to be implemented."

A. Section 5.3.3 of ANSI N18.7-1972 requires that instructions be provided, "for energizing, filling, venting, draining, starting up, shutting down, changing modes of operation, and other ,

instructions appropriate for operations of systems related to the safety of the plant..."

Contrary to the above, the licensee's instructions and procedures failed to adequately address the circumstances of February 3, 1982, in that two separate system evolutions (sampling of the Volume Control Tank gas space and draining of the vent header) in combination allowed radioactive gas to enter a system vented to atmosphere, causing an unplanned off-site release.

Response to Part A:

1) Corrective steps which have been taken and the results achieved.

Operating Instruction 01-WDG-1, " Waste Gas System Normal Operation" has been revised to include a precaution against draining the Vent Header while a gas sample is being drawn from the Volume Control Tank (VCT). The subject drain valves to the Waste Gas System have been CAUTION tagged to warn plant personnel that opening the valves is prohibited while a VCT gas space sample is being drawne Additionally, Chemistry and Radiation Protection (C/RP) Group Order No. 82-2 has been issued to remind all C/RP technicians that the control room operators must be informed prior to commencing sampling of the Reactor Coolant System. The District believes these actions are sufficient to prevent the circumstances leading to the unplanned release on February 3,1982 from occurring again.

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2) Corrective steps which will be taken to avoid further violations.

The District believes the actions identified in (1) above are sufficient to preclude future unplanned releases during VCT sampling.

However, an Engineering Evaluation and Assistance Report (EEAR) has been initiated to investigate the possibility of rerouting _the discharge lines of the subject Waste Gas System drain valves from the Spent Regenerant Tank to the Auxiliary Building Sump Tank.

This modification would prevent radioactive gases from the VCT from reaching the Auxiliary Building Ventilation System through the Vent Header.

3) The date when full compliance will be achieved.

The Omaha Public Power District is presently in full compliance.

B. Section 8b of Appendix A of USNRC Regulatory Guide 1.33 states that, " specific procedures for surveillance tests, inspections, and calibrations should be written (implementing procedures are required for each surveillance test, inspection' or calibra-tion listed in the Technical Specifications)." Standing Order G-23 establishes the Surveillance Test Program which requires-that, " safety-related equipment be tested on a periodic basis to verify its operational readiness to perfonn its design function."

Contrary to the above, Surveillance Test ST-ISI-CC-1, Section F.3, failed to ensure that Relief Valve AC-341 was properly returned to service af ter a bench test of the relief set point on October 28, 1981, in that the gag plug was missing, allow-ing radioactive waste gas to escape from the vent header in an unplanned release into the Auxiliary Building.

Response to Part B:

1) Corrective steps which have been taken and the results achieved.

The missing gag plug has been replaced in relief valve AC-341. The District carefully reviewed Surveillance Test ST-ISI-CC-1, Section F.3, and detennined it provided adequate instruction to ensure that relief valve AC-341 will be properly reinstalled and returned to service after performance of the subject surveillance test. The District believes it is impractical to address all possible con-tingencies that may arise in the removal, testing, and reinstalla-tion of each relief valve tested at Fort Calhoun under the Survell-lance Test Program. ' Additionally, the District will ensure that only qualified craf tsmen will be allowed to perform maintenance and surveillance tests on relief valves in the future. . The District presently has a program that permits only qualified craftsmen to work on specific safety-related components and safety-related relief valves have subsequently been incorporated into this pro-gram. The determination of whether a craf tsman is qualified to work on a specific type of component is made by the craftsman's

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- - immediate supervisor, based upon previous _ training and/or experience.

The Quality Control Department maintains documentation that identi- '

fies which safety-related components the craftsman is qualified to work on. This program will ensure that.only competent personnel perform the removal, testing, and reinstallation of important plant components. Plant craftsmen have been instructed to be alert for installation discrepancies such as the one addressed in this

. violation. The craftsmen involved in this violation were also verbally reinstructed on their responsibilities in performing such maintenance.

2) Corrective steos which will be taken to avoid further violation.

The District will only permit qualified craftsmen to work on safety-related equipment per the craftsman certification program described in (1) above.

3) The date when full compliance will be achieved.

With the installation of the missing gag plug in valve AC-341 and the implementation of the craftsman certification program, the Omaha Public Power District is presently in full compliance.

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