ML20085D652
| ML20085D652 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/11/1991 |
| From: | Gates W OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-91-250R, NUDOCS 9110170038 | |
| Download: ML20085D652 (3) | |
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-e Omaha Public Power District 444 South 16th Street Mall Omaha. Ne"aska 68102-2247 402/636 20(X)
October 11, 1991 LIC-91 250R U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (A. B. Beach) to OPPD (W. G. Gates) dated September 9, 1991 (LIC-91-255)
Gentlemen:
SUBJECT:
NRC Inspection Report No. 50-265/91-19 Reply to a flotice of Violation The subject report transmitted a Notice of Violation resulting from an NRC ins)ection conducted July J-12, 1991 at Fort Calhoun Station.
Attached is the 0 mala Public Power District response to this violation.
If you should have any questions, please ccntact me.
Sincerely, b-f W. G. Gates Division Ma ager Nuclear Operations WGG/sel Attachment c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator, Region IV W. C. Walker, NRC Project Manager R, P. Mullikin, NRC Senior Resident inspettor i
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- d. S. Nuclear Regulatory Commission LIC 91-250R Attachment Y10LAIl0B 10 CFR 50.7)(e)(3)(i) states, in part, that the original Final Safety Analysis July 22(FSAR1 shalI be updated and replacement pages filed within 24 months of Report
, 1980, and maintained up-to-date. Chapter 11.2.3.7 of the updated FSAR states, in part that the waste disposal system concentrates Radiation Monitor RM-058isinstalled.
Contrary to the above, HRC inspectors determined at the time of this inspection that the waste disposal system concentrates monitor (RM 058) detector and existing / power supply elements were removed and not replaced in 1977, and the ratemeter connecting cable was used for Radiation Monitor RM 055A in 1979 therefore, RM-058 can not be considered installed. The FSAR, therefore, was not updated and replacement pages filed within 24 months of July 22, 1980, and was not maintained up-to-date.
This is a Severity Level "V" violation (Supplement VII) (285/9119-01).
3if1P_0RK 1.
Jhe Renan for the Violation This violation was primarily due to inadequate maintenance ot design records prior to the initial required update of the final Safety Analysis Report.
This inadequacy was a finding of the Safety Systems Outage Modification Inspection SSOMI) 50-285/85-22.
In response, Omaha Public Power District (OPPD) has r(econstituted the design bases of the fort Calhoun Station for 33 t
l systems and 16 plant level issues.
Because OPPD planned to upgrade the Process Radiation Monitoring System, it was deferred from the final scope of the Desion Basis Reconstitution aroject.
Development of the Design Basis Document (DBD) for the Waste
)isposal System included review of Design Change Request DCR-74A-04, which removed RM-058 from service by abandonment in place.
This review, however, failed to identify the need to revise the status of RM 050 in the Updated Safety Analysis Report, because the review focused on the functions of the Waste Disposal System.
It was expected that the details relating to the Process Radiation Monitoring System would be identified during ifie subsequent preparation of the DBD for that system.
2.
Jhe. Corradhe_1lenLRttkh HayL.fleen laken_anLLtte_JtelulLLattdered Since the implementation of DCR-74A-04. OPPD has improved the procedures which control the plant design change process.
The procedures specifically address various aspects of the documentation process, including the revision of the Updated Safety Analysis Report (USAR).
USAR Section 11.2.3.7 has been revised to accurately state tnal Radiation Monitor RM 058 was abandoned in place under Design Change Request 74A 04.
This revision was included in the annual USAR update submitted to the f4RC on July 22, 1991.
The Piping and Instrumentation Diagram (P&lD) ll405 M-8 referenced in this USAR section was updated in July 1982 and adequately indicated that the monitor was abandoned.
i 6
U. S. Nuclear Regulatory Commission LIC 91-250R Attachment 3.. The Corrective Steps Whij;h Will Be TakmLts_Arcid.Arther Viqlationi Modification MR fC-84-155 has been approved to collectively resolve outstanding problams with the Process Radiation Monitoring System.
This modification will include an evaluation of the system design. Appropriate updating of the USAR will be included in the modification documentation process.
The implementation of MR fC 84-155 is scheduled to begin during 1992, with completion during the 1993 refueling outage.
To address generic concerns, OPPD is developing a aroject which will verify the accuracy of USAR design information using the Jasign Basis Documents as bases.
Review and ap31, 1991. proval of the p!oject plan is expected to be complete by December OPPD will nottfy the NRC of the project content and schedule by January 31, 1992.
4.
D3te When full CoJ!$113Act.Will Be Atktfyv_td
.The cited discrepancy was resolved on July 22, 1991 with issuance of the 1991 revision of the USAR, which included the required change.
Completion of the USAR verification project noted above should ensure full compliance.
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