ML20055G179

Ack Receipt of Advising NRC of Corrective Actions in Response to Violations Noted in Insp Rept 50-285/90-13. Implementation of Actions Will Be Reviewed During Future Insp

ML20055G179
Person / Time
Site:	Fort Calhoun
Issue date:	07/18/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gates W OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 9007200213
Download: ML20055G179 (2)

See also: IR 05000285/1990013

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D /In! Reply Refer To:

: Docket: 150-285/90-13

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'0maha hublic Power District

-ATTN: -W. G. Gates Division Manager t

Nuclear Operations-

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444 South-16th Street Mall

6 _ Mail Stop BE/EP4

60maha, Nebraska '68102-2247

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- Gentlemen:'

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Thank you for your letter of Julyz2,1990, in response to our letter and

Notice of Violation dated May 24,'1990. We have reviewed your reply and find-

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it responsive to the concerns raised in our Notice of Violation. We will

' " review the implementation of your corrective actions:during a future inspection-

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to' cermine that full compliance has been achieved and will be maintained.

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Sincerely,

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Original Signed By:

Samuel J. ColBR8

Samuel J. Collins, Director

Division of Reactor Projects

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LeBoeuf, Lamb,'Leiby & MacRae l

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ATTN: Harry H. Voigt. Esq. .l

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a :1333 New. Hampshire Avenue, NW ,

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-Washington, D.C. 20036

5 Washington Cou'nty Board ,

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_, -of Supervisors =

C ATTN:s Jack Jensen, Chairman

Blair, Nebraska -63008 i

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4 Combustion Engineering, Inc.

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ATTN:: Charles B. Brinkman, Manager '

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Washington Nuclear Operations

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12300 Twinbrook Parkway, Suite 330

. Rockville, Maryland 20852

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-Department of Health.

ATTN:: Harold Borchert. Director

Division of Radiological Health

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301 Centennial Mall,' South

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Pe0. Box 95007

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t.incoln, Nebraska 68509

~ Fort Calhoun Station

ATTN: G. R. Peterson, Manager.

P.O.: Box 399

Fort ~Calhoun, Nebraska 68023

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LU;S. Nuclear Regulatory Commission >

ATTN: Resident-Inspector-

P.O. Box 309

. Fort Calhoun, Nebraska' 68023

U.S.' Nuclear Regulatory Connission -

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Regional Administrator, Region IV

~611'Ryan Plaza Drive, Suite 1000

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Arlington, Texas - -76011

bect6-DMB(IE01)

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R. - D. Martin

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. Resident Inspector

'DRSS;FRPS: SectionChief(DRP/C);

MIS System, RIV File

DRP: RSTS-Operator .

ProjectEngineer(DRP/C) Lisa Shea,'RM/ALF

-A'. Bournia,1 NRRProjectManager(MS: 13-D-18) . DRS:

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Omaha Public Power District

1623 Harneu Omaha. Nebraska 68102 2247

402!536 4000

2, 1990:

LIC-90-0524

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JUL. - 51990

U. S. Nuclear Regulatory Commission .

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Attn: Document Control' Desk

Mail: Station PI-137

' Washington, DC'20555

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REFERENCES: 1.- Docket No. 50-285

2. Letter from NRC'(S. J. Collins) to OPPD (W.'G- Gates) dated- .

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May 24, 1990.

3. Letter from NRC (E. J. Butcher) to OPPD (R. L. Andrews)

' dated July 3, 1985

Gen'tlemen:

SUBJECT: Response to Notice of Violation (NRC Inspection Report

50-285/90-13)

Attached in accordance with_10 CFR Part 2.201 is Omaha Public Power District's

(0 PPD) response to_the subject inspection report (Reference 2), which

. identified three violations regarding separation criteria for inverters,

storage of contaminated filters and control of danger tags.

> , A extension of the required response date to July 2,1990 was discussed in:a

telephone conversation ~ between NRC (R. V.- Azua) and OPPD (T. G. Therkildsen) on

June 22,n1990.

If you should'have any questions on this response, please contact me.

. Sincerely,

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.W. G. Gates.

Division Manager

Nuclear Operations

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Attachment

c: LeBoeuf, Lamb, Leiby & MacRae

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A. Bournia, NRC Project Manager

TRED PMartin3 NRCYRegionalsAdministratoriq8tegiontlV W 2

P. H. Harrell, NRC Senior Resident inspector -

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Response to Notice of Violation

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During an NRC inspection conducted March 1 through April 14, 1990, violations

of NRC requirements were identified. In accordance with the " General Statement

of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C-

'(1989) (Enforcement Policy), the violations are listed below:

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A. Failure to Comoly with Separation Criteria for Safe Shutdown Systems

Section III.G.2 of Appendix R to 10CFR Part 50 states, in part, "Where

:i cables or equipment . . . of redundant trains.of systems necessary to

L( achieve and maintain hot shutdown conditions are located within the same

fire area outside of primary containment, one of the following means- of

ensuring that one of the redundant trains is free of fira damage shall be

provided:

1. Separation < of cables -, . . of redundant trains aarrier

having a 3-hour rating . . .,

2. Separation of cables . . . of redundant trains * v a b . .zu..tr?

distance of more than 20 feet with no intervening combustibl. .- fire

hazard . . ,, or

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3. Enc ~ lose the cable . . . of one redundant train in a fire barrier

having a 1-hour rating."

Contrary to the above, the installation of Inverters B, C, and D (redundant

trains)-failed to comply with the above requirements in that:-

1. The cables were not separated by a 3-hour fire barrier.

'2. The distance between the cables was less than 20 feet.

3. The cables of redundant trains were not enclosed in h fire barrier

having'a 1-hour rating.

This is a Severity Level IV Violation.- (Supplement I) (285/9013-01)

0 PPD'Resoonse:

31. The Reason for the Violation. If Admitted:

OPPD admits the violation occurred. OPPD reviewed the problem involving

Inverters B, C and D on an expeditious basis following OPPD's

self-initiated Safety System Functional Inspection (SSFI) of the 120 Vac

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vital; instrument power system. Based on this review, OPPD initially

concluded that an Appendix R' exemption for Fire Area 36,< granted by the NRC

on' July 3, 1985 (Reference 3), applied to this situation and that FCS was

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1 in compliance. The exemption is based on area wide fire detection and the-

automatic fire suppression system. These remote monitoring and automatic

suppression systems, along with fire brigade response, are expected to

minimize damage, preventing large scale equipment failures. With area wide

systems, the probability of a fire propagating to such an extent that it

would lead to failure of the cable from inverter C is expected to be

acceptably small, as would the failure of B and D inverters. Following

discussion with NRC on the intent of limiting exemption requests to

specifically defined scenarios, OPPD agreed to not consider the exemption

applicable and proceeded to expeditiously install fuse protection.

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As part of our initial evaluation, OPPD examined on a "what if" basis the

-loss of inverter C in addition to inverters B and D. -With the benefit of

infonnation on loads previously obtained through a Maintenance Work Order

(MWO 886773), OPPO was able to conclude, that A0P 16 could be used to

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crosstie the inverter C loads (Al-400) to inverter A.

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Subsequent analyses have corroborated the engineering judgements regarding

the transient effects of multiple inverter loss on safe shutdawn of FCS.

Accordingly, OPPD considers.that FCS was not outside its design basis nor

was it in an unanalyzed. condition that significantly compromised plant

safety during resolution of ..is issue.

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LX .The violation occurred as a: result of an inadequate review of the post fire

safe shutdown requirements for the west switchgear room.

2. The' Corrective Steps That'Have Been Taken and the Results Achieved:

a. A fuse (located in the east switchgear room) has been installed in the

' cable between Inverter.C and Breaker EE-6C, which will clear the fault

in the event of a fire induced fault in the west switchgear room.

This' will isolate Inverter C and allow it to maintain the loads in the

control room. Reference 2 paragraph 5.a indicates that this action is

acceptable to the NRC staff,

b. The Associated Circuit Analysis (EA-FC-89 05J) has been reverified and

updated. No other design deficiencies of this. nature were noted,

c. The modification rrocess has been revised to assure consideration of

cable separation with. respect to safe shutdown in the event of a

fire. General Engineering Instruction GEI-3 requires-a review of the

existing safe shutdown analysis if the modification' affects safe

. shutdown components.

3. .The Correcfive Stens That Will Be Taken to Avoid Further Violations:

No further actions are required; the action described in item 2.b. above is

considered to provide adequate assurance that this is'an unique incident,

and the current modification procedure discussed in item 2.c.-above will

prevent recurrence.

4. The Date-When Full Compliance Will Be Achieved:

. OPPD is presently in full compliance.

B. Failure to Follow Procedures

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Technical Specification 5.8.1 states, in part, " Written procedures shall

be established, implemented, and maintained that meet or exceed the

minimum requirements of. . . Appendix A of. US NRC Regulatory Guide 1.33."

Section 1.1 of Appendix A to Regulatory Guide 1.33 requires that

activities related to the plant fire protection program be covered by

written procedures.

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Section-3.3.5 of Procedure S0-G-6, " Housekeeping," states, in part, . "

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HEPA.(high efficiency particulate air) filters are sources of airborne

W -activity when ignited. These materials shall be transferred immediately 'i

to closed containers when removed from inservice use.'

Contrary.to the above,;on February 17, 1990, the licensee failed to place

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contaminated HEPA filters, ren'oved from inservice use, innediately into

closed containers in that 40 HCPA filters were stored in Room 69 (a

safety-related area) for approximately 4 days in polyethylene bags.

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U.is. is a Severity Level IV violation. (Supplement I) (285/9013-02) ,

1. The Reason for the Violation. if Admitted:

OPPD admits the violation occurred. The cause of the violation was-

that the Maintenance Procedure used for removal 1of the HEPA filters

did not contain guidance on storage of~the filters after removal.

This is an infrequently performed activity and the craftsmen .

involved were not cognizant of the requirement of Standing Order-  :

G-6, " Housekeeping," to immediately transfer the filters to closed

containers. #

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j 2 .- The Corrective Steos That H' ave Been Taken and the Results Achieved:

The'HEPA filters were placed in containers meeting the requirements

of. Standing Order G-6. Additionally, the requirement for

"immediate" transfer of HEPA filters;to closed containers was-

reviewed. As a result of this'rev_iew, Standing Order G-6 was t

changed to allow a maximun of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> = between removal and storage.

A Training " Hotline" (HL 90-306) was issued March 21, 1990 which

addressed requirements for storage of:HEPA filters. ,

L 3. The Corrective Stens-That Will Be Taken to-Avoid Further Violation:

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Maintenance procedures which require removal or installation of HEPA'

filters and/or charcoal; filters will be reviewed and revised as

, necessary to provide guidance to the craftsmen on storage of filters T

L during the removal and installation process.  !

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4. The Date When Full Comoliance Will Be Achieved:

0 PPD is currently in full compliance with Standing Order G-6.

Revisions to.the Maintenance Procedures will be completed by October

15, 1990.

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I' - C. InadeauatLLmp.)ementation of Corrective Actions

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Criterion XVI of Appendix B to 10 CFR Part 50 and Section A.17 of the

icensee's NRC-approved quality assurance program (Appendix A to the

allpdated Safety Mnal.ysis Report) require that measures shall be

established to accure that nonconformances are promptly identified and

r.ot rected. In the 1:ase of significant conditions adverse to quality, the

L . measures shall ensure that the -cause of the condition is determined and.

corrective action taken to-preclude repetition.

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[' [~ ' Contrary to the'above, on March 20 and 21, 1990, the licensee's quality

assurance organization identified problems with the control of danger

tags-and plant management implemented corrective actions. The corrective

actions were inadequate in that, on March 23,-1990, NRC identified

similar' types of problems with the control of danger tags. In addition,

on . March 24 and 25,1990,- the 1icensee. during a follow-up review of the.

identified danger tag control problems, identified four. additional

instances where danger tags were not being controlled in accordance _with

licensee requirements. -.

This'is'a Severity Level IV violation. (Supplement I) (285/9013-03)

'1. The Reason 'for the Violation-if Admitted

OPPD admits the violation occurred as stated. The reasons for the

violation were _ inadequate training of maintenance and construction

personnel prior to the 1990 refueling outage and inadequate

verification of equipment tagging.

Training was provided on Standing Order-0-20, " Equipment Tagging

Procedure", from the Conduct of Maintenance lesson plan (1219-01)

and the Maintenance Crafts Administrative Handbook (1219-07),~to @l

craftspersons at the start of the refueling outage. Following the

cited procedural non-compliances, it was determined that the

pre-outage training did not adequately cover those areas that were

found' deficient.

2. The Corrective Steos that have been taken and the Results-Achieved

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When procedural non-compliances to Standing Order 0-20 occurred

during the outage, a special tagging briefing was conducted for

badged personnel. In addition, Standing. Order 0-20 has been revised

to require independent verification, by a qualified operator, of

equipment tagging in preparation'for equipment / component outages for

maintenance. This independent verification insures that the-tags

have been. hung in accordance with the Tag Out Sheet and that the

components have been placed in the required position prior to the

initiation of maintenance activities. This requirement was'added to

the Equipment Tagging Procedure on April 26, 1990. .A Training

" Hotline" (HL 90-047).was issued June 6, 1990 which addressed-

c changes to-the Equipment Tagging Procedure. To date, no additional

incidents involving equipment mispositioning or inappropriate tag

placement have been identified Fort Calhoun.

3. The Corrective Steos That Will Be Taken to Avoid Further Violations

Corrective steps described above are considered adequate.

4. The Date when Full Comoliance will be tchieved

OPPD is currently in full compliance based on the changes made to

Standing Order 0-20 and the training which has been provided.

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