ML20100K944

Responds to NRC Re Violations Noted in Insp Rept 50-285/84-12.Corrective Actions:Procedures Written for Tagging Equipment in Controlled Status & Shift Supervisors Directed to Document Review of Maint Orders

ML20100K944
Person / Time
Site:	Fort Calhoun
Issue date:	09/27/1984
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20100K918	List: ML20100K944
References
LIC-84-329, NUDOCS 8412110351
Download: ML20100K944 (4)

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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536 4000 September 27, 1984 LIC-84-329 Mr. Richard P. Denise, Director Division of Resident, Reactor Project and Engineering Programs U.S. Nuclear Regulatory Commission $@$ON$

Region IV 611 Ryan Plaza Drive, Suite 1000 ,n l g Arlington, Texas 76011 uu7

Reference:

Cocket No. 50-285

Dear Mr. Denise:

Notice of Violation Inspection Report 84-12 The Omaha Public Power District received the Commission's letter dated August 28, 1984 which forwarded two Notices of Violation: Item 285/8412-01, " Equip-ment Control," and Item 285/8412-02, " Quality Assurance Records." Pursuant to 10 CFR 2.201, please find attached the District's response to these Notices of Violation.

Sincerely, d

R. L. Andrews Division Manager Nuclear Production RLA/JJF/rh-E

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Attachment I cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 i

Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, Senior Resident Inspector I

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Attachment Based on the results of an NRC inspection conducted during the period of May 7-11, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2,

; Appendix C), 49 FR 8583, dated March 8,1984, the following violations were identified

i VIOLATION l Equipment Control j Technical Specification 5.8.1 states, " Written procedures and adminis-trative policies shall be established, implemented, and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI.

N18.7-1982."

ANSI N18-7-1982, Section 5.1.5, states, " Procedures shall be provided

for control of equipment, as necessary, to maintain reactor and person-nel safety and to avoid unauthorized operation of equipment. Tnese. pro-

cedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status. The procedures i shall require independent verification, where appropriate, to ensure that necessary measures, such as tagging equipment, have been imple-mented correctly."

Contrary to the above, the licensee's procedures did not require inde-  ;

pendent verificatien of tagouts to ensure that equipment was properly i sola ted. Standing Order 0-20, Equipment Tagging Procedure, Revision 13, reutred the craftsman to verify that the equipment was properly l '

i sola ted. This verification could.take the fom of at least one of the following: contacting the operator responsible for the tagout to ensure ,

that he had completed the tagout; personally checking the adequacy of the component tagout to ensure that it was safe for maintenance to proceed; or personally verifying that tags had been hung in accordance with the tagout sheet and that the tagged components were in their re- l

! quired position. Interviews with licensee management indicated that the i-first two options were regularly used. The third option was used only l when the craf tsman wanted to ensure his own personal safety but was not

, procedurally required.

This is a Severity Level IV Violation. (Supplement 1) (285/84-12-01)

DISTRICT'S RESPONSE l

(1) The corrective steps which have been taken and the results achieved.

Written procedures and administrative policies have been established, i

are implemented and are being maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI-N18.7-1972. The District

. believes that its procedures are adequate, however, additional clari-fication is necessary.

1 l As noted in the statenent of the violation, plant tagging procedures  !

j require the craftsman to verify that equipment to be worked on is l isolated properly. This verification could take the fom of at least one of the following: contacting the operator responsible for the  ;

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• tagout to ensure that he had completed the tagout; personally checking the adequacy of the component tagout to ensure that it was-safe for r maintenance to proceed; or personally tierifying that tags had been hung in accordance with the tagout sheet and that the tagged components were in their required position. It should be no*.ed that this procedure is consistent with the general District tagging policy in use at all of the

- District's power generation facilities and has. achieved desired safety results for many years.

Draft changes to the tagging procedure, Standing Order 0-20, have been written incorporating various degrees of independent verification to

. provide the necessary clarification. In addition, a cemittee comprised of personnel from each of the District's power generation facilities has met to discuss District wide tagging procedures.

(2) Corrective steps which will b_ee taken _to avoid future violations.

Plant Standing Orders will be revised, as necessary, to clarify independent verification requirments.

(3) The date when full compliance will ,be achieved.

The revised procedures will be implemented by January 1,1985.

VIOLATION Quality Assurance Records 10 CFR 50, Appendix B, Section XVII, states that sufficient records shall be maintained to furnish evidence of activities affecting quality and that these records shall include the results of reviews.

Standing Order G-17, Maintenance Order, Appendix A, Revision 27, Section 4 4.8.3, stated that whenever Technical Specification applicability was referenced on a maintenance order, approval of these items was to be made by the shift supervisor. This section further stated that if no Technical Specification or redundant equipment was required, an "NA" was to be placed in the approval blank.

Contrary to the above requirements, there was no record of shift super-visor review on the following maintenance orders, all of which involved

) safety-related equipment and specifically referenced Technical Specifi-cation applicability:

Maintenance Order No. Description 840045 Reset PORY Setpoints 840621 HCV-481 Inoperable 840514 Containment Purge Valves Inoperable Additionally, an "NA" was recorded in the shift supervisar approval blank for each of the above maintenance orders.

This is a Severity Level IV Violation. (Supplement 1) (285/8412-02)

DISTRICT'S RESPONSE (1)- The corrective steps which have been taken and the results achieved.

The District believes that the Shift Supervisor did conduct the neces-sary reviews for Technical Spectficatioa applicability in the three (3) instances cited in the inspection report. Each of the three (3) exam-ples cited involved a maintenance order on safety-related equipment, but the Shift Supervisor did not initial the applicable maintenance order to document his review. The existing maintenance order fom does not pre-sently. provide 'a means for documenting the Shif t Supervisor's review as stated in the Standing Order.' In the interim, the Shift Supervisors have been directed to document their review to ensure compliance with the Standing Order.

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

The District will clarify Standing Order G-17 and the maintenance order fom to ensure compliance with documentation requirements.

(3) The date when full compliance will b_ee achieved.

Standing Order G-17 and the maintenance order will be revised and

' f aplemented by January 1,1985.

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