ML20149M941
| ML20149M941 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/24/1988 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-120, NUDOCS 8802290300 | |
| Download: ML20149M941 (8) | |
Text
i 4
Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 402/536 4000 February 24, 1938 LIC-88-120 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated January 25, 1988 Gentlemen:
SUBJECT:
Response to Notice of Violation NRC Inspection Report 50-285/87-24 Omaha Public Power District (OPPD) recerstly received Reference 2, Notice of Violation, issued as a result of the subject inspection report.
This report identified three violations.
The violations involved the failure to properly store gas cylin.Mrs in the Auxiliary Building; the failure to establish a procedure for controlling the erection of temporary scaffolding in areas containing safety-related equipment; and the failure to post up-to-date 10 CFR Part 21 documentation. This report also identified one devietion, relating te the failure to issue a memo to establish interim measures related to nonfunctional fire barriers.
Pursuant to the provisions of 10 CFR Part 2.201, please find attached, OPPD's response to the violations and deviation.
If you have any questions concerning this matter, please do not hesitate to contact us.
Sincerely, N07desut R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector 8802290300 080224
/
gDR ADOCK 050 3
Tl 4s w4 i mpkwmen ngom<tung
RESPONSE TO NOTICE OF VIOLATION During an NRC inspection conducted on September 1-30, 1987, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actius," 10 CFR Part 2, Appendix C (1987), the violations are listed below:
A.
Criterion V of Appendix B to 10 CFR Part 50 states, in part, that activi-ties affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.
Paragraph 1.0 of Section 6.4, "Housekeeping," of the licensee's Quality Assurance Plan (QAP) states, in part, that this plan section specifies the quality assurance requirements for housekeeping controls for protection of equipment.
Paragraph 4.5 of QAP Section 6.4 states, in part, that instruc-tions which implement this plan section shall be contained in the station standing orders.
Standing Order (S0) G 6, "Housekeeping," was issued to implement the requirements of QAP Section 6.4.
Paragraph 3.3.5 of S0 G-6 states, in part, that gas cylinders shall be properly stored in the auxiliary suilding, with caps installed, unless in use or use is intended within a short period of time.
Contrary to the above, the licensee failed to properly store gas cylinders in the auxiliary building in that cylinders were secured to a safety-related seismic support; cylinders were secured in an unapproved storage method using a 3/8-inch nylon rope and cylinders were left unsecured in the auxiliary building.
This is a Severity Level IV violation.
(Supplement I)(285/8724 04)
OPPD'S RESPONSE Reason for the Violation. If Admitted 1
The procedural guidance provided at the time of this violation was Standing Order G-6, "Housekeeping," which stated that "gas cylinders shall be properly i
stored in the Auxiliary Building, with caps installed, unless in use or use is intended within a short period." Standing Order G-6 does not define the phrase "properly storeJ" and does not contain a discussion of bottle position, securing devices or locations, nor does it define the phrase "short,seriod". A memorandum was issued to clarify Standing Order G-6 however its guidelines were not followed for the placement of the subject gas cylinders.
f Corrective Steos Which Have Been Taken and the Results Achieved l
l The failure to properly store gas cylinders on September 21, 1987 was followed by the following actions: management attention was increased with respect to field conditions and station supervisors increa wd the frequency of their plant tours. These tours became more sensitive to the issue of the storage of 1
compressed gas cylinders.
There have been no instances of improperly stored compressed gas cylinders since the time of this violation.
i l
Attachment (Continued) h Corrective Steos Which Will be Taken to Avoid Further Violations Standing Order G-6 will be revised to provide detailed guidance with respect to gas bottle storage and initial training will be provided for gas bottle users by May 1, 1988, Date When Full Comoliance will be Achieved OPPD is currently in full compliance.
I W
1 1
Attachment (Continued) 8.
Criterion V of Appendix B to 10 CFR Part 50 states, in part, that activities affecting quality shall a prescribed by procedures of a type appropriate to the circumstances.
Paragraph 4.7.2 of Section 5.1, "Control of Plant Design and Modification,"
of the licensee's QAP states, in part, that appropriate procedures shall be used for modification activities.
Contrary to the above, the licensee failed to establish a procedure for control of the erection of temporary scaffolding in areas containing safety-related equipment; therefore, no evaluation was performed to tMdress the potential affect of nonseismically installed scaffolding on safety-related equipment during a seismic event.
This is a Severity Level IV violation.
(Supplement I)(283/872.!-05)
OPPD'S RESPONSE Ep.ason for the Violation. If Admitted Under modification MR-FC-86-56, for,.ie installation of a nitrogen supply line to the Emergency Feedwater Storage Tank, a temporary scaffold was constructed on and near the tank to facilitate installation work.
Scaffolding was addressed only in generic terms in the construction package, and neither a safety evaluation nor notification of the Shift Supervisor was required prior to the construction of the scaffolding.
Maintenance craft and skill training and apprenticeship programs were relied upon to provide assurance that the scaffolding was structurally sound and did not pose a threat to nearbv safety-related equipment.
This did not adequately address the seismic consequences of the scaffolding installation.
Corrective Steos Which Have Been Taken and the Results Achieved In response to this event, OPPD issued a memo to Plant Staff which st:ted that all modification packages need to address scaffolding installation.
Addition-ally, this memo stressed the need for prior review and approval of scaffolding installed in safety-related areas for maintenance or any other activities.
2 Scaffolding has been installed in one safety-related ares since the occurrence of this violation, and its installation was properly reviewed and approved in accordance with the issued memo.
Corrective Steos Which Will be Taken to Avoid Further Violations 0 PPD is preparing guidelines for the safe erection of scaffolding.
These guidelines, which will be issued as a plant procedure, will be utilized for cases of Scaffolding installed in safety-related areas and will include seismic evaluation, compensatory measures, and Shift Supervisor notification.
Date When Full Comoliance will be Achieved OPPD is currently in full compliance, i
Attachment (Continued)
^
C.
Section 21.6 of 10 CFR Part 21 states, in part, that each entity subject to the regulations of this part, shall post current copies of the following documents where activities subject to this part are conducted.
The documents include the regulations in this part, Section 206 of the Energy Reorganization Act (ERA) of 1974, and procedures adopted pursuant to the regulations in this part.
Section 7.6.2 of Procedure H-2, "Reporting of Defects and Noncompliance to t'a Nuclear Regulatory Commission," states, in part, that the following documents shall be posted in conspicuous places at the Fort Calhoun Station, Jones Street Station, and Generating Station Engineering offices:
10 CFR Part 21, Section 206 of the ERA of 1974, and Procedure H-2.
Contrary to the above, the licensee failed to post the latest revision of the Part 21 regulations and the licensee's implementing procedure, and failed to post Section 206 of the ERA at the Brandeis building (the Generating Station Engineering offices).
This is a Severity Level V violation.
(285/8724-06)
OPPD'S RESPONSE Reason for the Violation if Admitted Investigation into the alleged violation revealed that a signed transmittal sheet acknowledging the receipt of the March 1987 Revision of 10 CFR Part 21, Section 206 of the Energy Reorganization Act of 1974, and Nuclear Production Procedure H-2, Revision I was received by Generating Station Engineering (GSE),
and the receipt acknowledgment form was returned to the Supervisor-Nuclear Regulatory & Industry Affairs on June 30, 1987. However, the actual posting of the material never took place. Also discovered, was that there were two postings of 10 CFR Part 21 documents at the GSE offices, and only one copy of the revisions was being sent. This made it necessary for GSE to xerox the revisions to nake the two posting complete. An investigation of all postings of 10 CFR Part 21 documents revealed that this was an isolated case and that the overall procedure is effective.
Corrective Steos That Have Been Taken and the Results Achieved The postings at GSE were updated on February 11, 1988 and are now in full compliance with 10 CFR Part 21 Section 21.6 and Section 7.6.2 of Nuclear Production Procedure H-2.
A review of all authorized posting areas of 10 CFR Part 21 documents was conducted on February 12, 1988 and all posting were found to be in compliance.
The list of designees responsible for posting 10 CFR Part 21, Section 206 of the Energy Reorganization Act of 1974, and Nuclear Production Division Policy / Procedure H 2 was reviewed and revised. Also, added to the list was an additional controlled copy for posting at GSE.
l
Attachment (Continued)
Corrective Steos That Will be Taken to Avoid Further Violations OPPD is drafting a new procedure regarding th2 posting of NRC required docu-ments:
10 CFR Part 21, Section 206 of ERA, NPD Policy / Procedure H 2,10 CFR Part 10, and Form NRC 3.
This procedure will require a periodic review to assure that all documents are posted with the latest revision.
The review will of the documents and how to obtain a,ittal sheet that lists the latest revision be documented by a signed off transm copy if any are found not to be in compliance.
Date When Full comoliance Will be Achievad OPPD is currently in full compliance.
3 i
l l
I, l
k Attachment (Continued)
Resoonse to Notice of Deviation During an NRC inspection conducted on September 1-30, 1987, a deviation from commitments made to the NRC was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1987), the deviation is listed below.
In a letter dated June 26, 1987, in response to Violation 285/8710-01,the licensee stated that a memo would be issued to all personnel with unescorted site access to establish interim measures for control of fire barriers.
The interim measures were to be established until the appropriate procedures were revised and a permanent program implemented.
In deviation from the above, the licensee failed to issue the memo establishing the committed interim measures. (284/8724 01)
OPPD'S RESPONSE Reason for the Deviation. If Admitigd in response to Violation 285/8710-01, _ OPPD committed to issuing a memo to all personnel with unescorted access to the Fort Calhoun Station.
This memo was intended to ensure that all personnel were aware of their responsibility related to the control of fire barriers. This commitment was made in an OPPD letter dated June 26, 1987, however, the memo was not issued until October 1, 1987.
The failure to issue the memo within a reasonable time frame was caused by lack of adequate administrative controls and management awareness of the urgency of the issue. In fact, a memo was prepared and forwarded to the Plant Manager within about a week of the commitment; however, revisions of the memo were required as a result of his review. Although the revisions were prepared by July 10, 1987, the memo was not signed until October 1, 1987.
Corrective Steos That Have Been Taken and Results Achieved The memo, FC-1473-87, was signed and issued to all personnel with unescorted access on October 1, 1988.
Since the occurrence of this event two other measures have been established to ensure more timely follow up on commitments.
First, the Plant Manager has established a formal weekly staff meeting process that focuses on open commitments and provided a forum for ensuring management awareness of problems associated with completing these tasks. As a second measure, OPPD has set up a program of formal monthly meetings between the resident inspector and the Supervisor-Nuclear Regulation and Industry Affairs for a regular review of NRC commitment status.
Corrective Steos That Will Be Taken to Avoid Recurrence A number of initiatives are in place that are aimed at improved management effectiveness at the fort Calhoun Station. There has been a concern for some time that the administrative demands placed upon the Department Heads and the
t Attachment (Continued)
Plant Manager have affected the responsiveness of the plant staff the NRC and l
other commitments; accordingly, an independent management assessment is currently in progress. This assessment is specifically intended to focus on areas of improvement related to management issues and to recommend specific-corrective actions.
The President of OPPD will be the recipient of the i
assessment report which is currently scheduled for completion in June 1988.
Date When Full Como11ance Will Be Achieved OPPD is currently in full compliance.
p t
f r
i r
i i