ML20153H381
| ML20153H381 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/02/1988 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-294, NUDOCS 8805120291 | |
| Download: ML20153H381 (5) | |
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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 May 2, 1988 LIC-88-294 V. 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 March 25, 1988 Gentlemen:
SUBJECT:
Response to Notica of Violation - NRC Inspection Report 50-285/88-07 0maha Public Power District (0 PPD) recently received Reference 2, Notice of Violation, issued as a result of the subject inspection report.
Pursuant to 10 CFR Part 2.201, please find attached OPPD's response to the violations. A one week extension for this submittal was discussed between J. J. Fisicaro of OPPD and Tom Westerman of Region IV.
If you have any questions concerning this matter, please contact us.
Sincerely, R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector I
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8803120291 880502 PDR ADOCK 05000205 Q
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el IV violation (Supplement 1) (285/8807-02)
OPPD'S RESPONSE Reason for Violation if Admitted The five-man fire brigade is staffed utilizing operators and security officers.
In the event of a fire in the control room requiring implementation of Abnormal Operating Procedure 6 (A0P-6), three operators and two security officers are l
required to man the fire brigade. Due to manning requirements for a compensatory security station, and other duties procedurally assigned to the l
control room security officer, only one of two security officers needed for the fire brigade were immediately available.
l The violation occurred due to a failure to integrate all requirements and/or l
commitments related to the fire protection, emergency planning and security areas.
This resulted in procedural conflicts related to security officer responsibilities for fires in conjunction with valid security contingencies.
Corrective Steos Taken and Results Achieved A procedure change was immediately implemented to revise A0P-6 to reassign certain security officer's non-fire fighting duties to an operator; thus, freeing him for immediate assignment to the fire brigade.
With this change and the existing minimum staffing levels for operators and security officers, adequate trained personnel are available to meet fire brigade, operational, armed responder and emergency planning commitments for a fire requiring evacuation of the control room with a concurrent valid security contingency.
l
t Violation A (Continued)
Additionally, a modification was expedited to upgrade the vital area barrier which had required a long term compensatory station; this modification is complete and the officer that was stationed at the compensatory post is now available for regular shift duties including fire brigade membership.
The plant's management has a heightened awareness of the need to ensure that adequate staff exists at all times to meet fire brigade, security, emergency planning and operational requirements.
Controls have been implemented to ensure that when a compensatory post is required, additional officers are called in as necessary to meet staffing commitments.
Corrective Steos That Will be Taken to Avoid Further Violations The security plan commitments, existing NRC guidance documents and plant pro-cedures will be reviewed relative to staffing concerns.
Revisions. if necessary, will be made to procedures and/or the Security Plan, lo ensure that commitments related to fire brigade and security manning are correctly identified and documented. The review will be completed by May 31, 1988, with necessary procedure changes being promptly initiated.
OPPD has recently completed a reevaluation of the Fort Calhoun Fire Hazards Analysis (FHA) and is using the FHA as the basis for a reevaluation of the Safe Shutdown Analysis (SSA).
The SSA will identify operator action response re-quirements for fire in any fire area. The results of this analysis will be used to establish formal controlled pre-fire plans that will clearly define manning requirements.
This effort is currently scheduled for completion by September 30, 1988.
Date When Full Como11ance Will be Achieved OPP 0 is currently in full compliance with fire brigade manning commitments.
Other efforts to enhance complianco with fire brigade staffing requirements will be completed in accordance with the above noted schedules.
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Violation B 1
B.
Section 5.8.1 of the Technical Specifications stater. in part, that written procedures shall be established, implemented, and rWtained that meet or exceed the minimum recuirements of ANSI 18.7-1972.
Section 5.1.2 of ANSI 18.7-1972 states, in part, that pro odures shall be followed and the requirements for use of procedures shall be prescribed in writing.
Procedure 50-G-7 states, in part, that it is the responsibility of every individual performing activities to follow procedures exactly as written and it further states that strict adherence to all procedures is absolutely required.
Contrary to the above, during witnessing of the performance of Surveillance Tests ST-ISI-RW-1, ST-ESF-6, and ST-DC-2, the NRC inspectors noted that the individual performing the test did not adhere to the written procedure in that steps were not performed as required by the procedure, or steps were not performed in the order specified by the procedure.
This is a Severity Level IV violation.
(Supplement I)(285/8807-03)
OPPD'S RESPONSE Reason for the Violation if Admitted Surveillance test ST-DC-2 verifies the proper operation of the spare battery l
charger #3. There is a thirty minute waiting period before taking final j
readings off battery charger #3.
The next step is to place battery charger #1 i
in service. The electrician performing ST-DC-2, knowing that it would be good operating practice to let battery charger #1 warm up prior to being placed back in service, started battery charger #1 before completing the readings on battery charger #3 in the previous step.
Surveillance test ST-ISI-RW-1 verifies the operability of raw water valves by recording and trending the stroke times.
The special equipment designated by this procedure is a stop watch. The operator performing the timing in the field was observed using a wrist watch to time the valves.
The operator used the wrist watch assuming that the timing would be accurate enough for the i
results needed.
Surveillance test ST-ESF-6 verifies the emergency diesel generator start circuits and operability of the fuel oil transfer pumps.
The resident inspector stated that a step to observe the proper operation of the fuel oil transfer pumps had been forgotten by the control room operator performing the test, but the control room operator had already dispatched an equipment operator to perform that step in the test.
ST-ESF-6 had been performed as l
specified by the procedure.
The two cases of procedural noncompliance were violations of S.0. G-7 which presently states that procedures will be followed exactly as written.
In both cases, the intent of the procedure was followed to obtain acceptable results, but the procedure was not followed verbatim.
The manner in which the tests i
were performed did not affect the safe operation of the plant.
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Violation B (Continued)
Corrective Steos Which Have Been_Taken and the Sgsults Achieved l
The items noted in the violation, and as detailed in the inspection repcet were addressed.
Specifically, there was no safety significance to ST-DC-2 teing performed in the manner witnessed; no corrective action was necessary.
The valve timing vitnessed in Surveillance test ST-ISI-RW-1 was repeated using a stop watch.
'a,1ves timed during this test using a wrist watch were retimed with a stopwatch.
Results of the test were satisfactory.
As noted in The Reason for the Violation, ST-ESF-6 was performed according to procedure; no additional action was required.
The inspection report notes these as examples of inattention to detail and procedural non-compliance. To address this concern a memo from the Plant Manager to department heads was issued on February 16, 1988. This memo stressed the importance of compliance with procedures. Occumented meetings with plant personnel were held to reiterate the Station policy and to reaffirm the need to follow and comply with procedures exactly as written.
The awareness of this issue is evidenced by an increase in on-the-sr" procedure changes for clarifying and correcting procedures.
In add) co the efforts made to heighten awareness of Station personnel, OPPD recogn*:es that a portion of this violation is attributable to procedures which are ambiguous or misleading. The ambiguity allows for interpretation by personnel in the field, resulting in the type of incidents cited in the violation.
The potential for interpretations of this sort will be reduced through the Procadures Upgrade Project, discussed below.
Corrective Steos Which Will be Taken to Avoid Further V121ations The Procedures Upgrade Project includes the development of a Procedure Writer's Guide to provide guidance from a human factor's perspective.
The Procedure Writer's Guide, currently in development, will provide guidance in identifying optional steps or those steps that may be performed in optional sequences, making procedures more acceptable from a human factors perspective.
This should reduce the occurrence of violations of this sort.
Date When Full Comoliance Will be Achieved OPPD is in full compliance with respect to the three examples noted in the violation. The Procedures Writer's Guide will be in effect by September 1988.
To enhance compliance with procedures, guidance contained in the Procedures Writer's Guide will be incorporated into procedures as part of the Procedures Upgrade Program.
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