ML20101H611
| ML20101H611 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/22/1992 |
| From: | Gates W OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-92-195R, NUDOCS 9206300063 | |
| Download: ML20101H611 (4) | |
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__u Omaha Public Power District 444 South 16th Street Mall Omaha Nebraska 681024247 402/636-2000 June 22, 1992 LIC-92-195R 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. C. Gates) dated May 22, 1992 Gentlemen:
SUBJECT:
NRC Inspection Report No. 50-285/92-10 Reply to a Notice of Violation (NOV)
Reference 2 +.ransmitted a NOV resulting from an NRC inspection of the Fort CalhounStat.onconductedApril27throughMay1,1992.
As requested, attached is Omaha Public Power District s (OPPD) response.
A description of OPPD's program for proceduralizing and maintaining NRC commitments was also requested, and is described below.
Commitments are proceduralized using the guidance of Nuclear Operations Division Quality Procedure, N00-QP-34, "0ngoing Commitment Program" and Fort Calhoun Station-Standing Order (S0) G-30, "Setpoint/ Procedure Changes And Generation."
Procedure'N00-QP-34, defines an ' ongoing commitment" as a commitment detailing a procedural or administrative corrective action or a statement of intended compliance with a scecific industry standard.
Ongoing commitments involve an action that is perfo'rmed periodically or continually. A procedure containing an
" ongoing" commitment is termed an " Implementing Document," which is a c ntrolled document that establishes a mechanism for maintaining continued compliance with an ongoing commitment.
When commitments must be incorporated into a station orocedure, S0-G-30 requires that ongoing commitments be identified, annotated and maintained in accordance with N00-QP-34.
To maintain and control commitments to the NRC and other regulatory agencies, OPPD utilizes a Coinmitment Tracking System, which is a database residing on a mainframe computer. Commitments in the database can be reviewed using a variety of search methods including keywords, Implementing Documents, etc.
Procedure N00-QP-23,
" Commitment Track:.ig System (CTS) Action Trackina," provides instructions for the assignment and tracking of tasks associated with identified commitments.
N00-QP-23 also includes instructione for the review of documentation justifying task closure.
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l U. S. Nuclear Regulatory Commission LIC 92-195R Page 2-
'If you should have any questions, ph ase contact me.
Sincerely,
/M 5 N4 W. G. Gates Division Manager Nuclear Operations WGG/sel Attachment c:
.LeBoeuf, Lamb, Leiby & MacRae
-R. D. Martin, NRC Regional Administrator, Region IV R. P. Mullikin, NRC Senior Re.ident inspector S. D. Bloom, NRC Acting Project Manager a
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Attachment LIC-92-195R Page '
REPLY TO A NOTICE OF VIOLATION VIOLATION During an NRC inspection conducted on April 27 through May 1,1992, 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, the violation is listed below:
Fort Calhoun Technical Specification 5.8, " Procedures," states, in part, that " Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANS1 N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33," and that, "Each procedure and changes thereto, shall be reviewed by the Plant Review Committee and approved by the Manager - Fort l
l Calhoun Station prior to implementation....
Contrary to the above, the licensee had failed to maintain procedures for the containment sump narrow range water level instruments, LT-599 and LT-600, which include the Technical Specification requirement of calibration of these instruments by "known signals applied to the sensors."
This is a Severity Level IV violation (285/9210-01) (Supplement 1).
OPPD Response The Reason for the Violation As documented in NRC Inspection Report 50-285/90-01, a similar NOV on failure to calibrate the containment sump narrow range water level instrument LT-599 and LT-600 sensors with "known signals..." occurred in January 1990.
As a result, on February 16, 1990, upgraded procedures IC-ST-WDL-0001 and IC-ST-WDL-0002 were issued.
The upgraded pro:edures required measurement uf the float position to verify actual sump-water l
level but did not clearly describe how this was to be accomplished.
During surveillance testing in May 1990 using procedures IC-ST-WDL-0001 and IC-ST-WDL-0002, test personnel chose to measure the float position with a ruler to verify actual sump water level.
Therefore, during the 1990 Refueling Outage, level instruments LT-599 and LT-600 were calibrated with a "known signal" in accordance with Technical Specification 3.1.
During the '992 Refueling Outage, changes to IC-ST-WDL-0001 and IC-ST-WDL-0002 o re implemented to facilitate performance of the procedures.
However, he procedures still did not clearly soecify the proper method of measuring the float position, i.e., with a ruler or other physical means.
l The revised procedures directed the operators and technicians to fill the sump based upon the level indicated on readouts located in the control room. As a result, it was not clear to the technicians that they were to physically measure the water level at the containment sump (i.e., with a l
ruler); thus, the calibrat. ion was performed improperly using control room l
instruments rather than the method required by Technical Specification 3.1.
l
Attachment LIC-92-195R Page 2 Although the potential for noncompliance with Technical Specification 3.1 should have been recognized by the procedure change initiator, the procedure change reviewer and the Plant Review Committee (PRC) lear Safety also failed to detect it.
Finally, the-10 CFR 50.59 review by the Nuc Review Group (NSRG), (which occurs approximately 30 days after procedures
-are approved for use by the PRC) did not detect the potential for noncompliance with Technical Specification 2.1.
The Corrective Steps That Have Been Taken And The Results Achieved 1.
Prccedures IC-ST-WDL-0001 and IC-ST-WDL-0002 were revised to Revisions 11 and 8 respectively on April 29, 1992 to incorporate ph.vsical measurement of the containment sump water level.
A caJtionary statement at the beginning of the section titled " Loop Vr d fication" was added.
In accordance with N00-QP-34, this s.atement requires review of Commitment Identification (CID) 900061 (include the containment sump narrow range level instrumentation sensors in the calibration process) before revisions are allowed to the " Loop Verification" section. This will insure that the section is not changed or deleted without PRC review and approval.
2.
On April 30, 1992, the revised PRC approved procedures were used to calibrate level instruments LT-599 and LT-600 by locally measuri_ng the containment sump water level.
The surveillance testing was completed within its Technical Specification required frequency (i.e., refueling outage).
3.
A Root Cause Analysis cf this event was completed.
The Corrective Steps Which Will Be Taken To Avoid Further Violations 1.
A memorandum to all members and alternates on the PRC and NSRG will be issued by July 17, 1992.
The memorandum will emphasize the necessity of performing a thorough review of procedure revisions to
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insure compliance with Technical Specifications.
2.
A revision to Procedure N00-QP-3, "10 CFR 50.59 Safety Evaluations,"
will be completed by August-31, 1992.
The revision will provide additional guidance in determining Technical Specification compliance for the proposed activity.
3.
A review of other float type level calibration procedures "cquired by the Technical Specifications will be completed by December 31,.
4 1992.
The review will determine i f procedure revisions are warranted to clarify the method of calibration required by Technical Specificatinns.
The Date When Full Compliance Will Be Achieved OPPD is currently in full compliance.
Implementation of the corrective actions noted above will provide additional assurance that this event does not recur.
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