ML20196E628
| ML20196E628 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/26/1988 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-137, NUDOCS 8803010212 | |
| Download: ML20196E628 (5) | |
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=8 Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536 d900 February 26, 1988 LIC-88-137 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 27, 1988 Gentlemen:
SUBJECT:
Response to Notice of Violation NRC Inspection Report 50-285/87-29 Omaha Public Power District (0 PPD) recently received Reference 2, Notice of Violation, issued as a result of the subject inspection report.
This report identified two violations. The violations involved the failure to have an adequate post-maintenance testing program for safety-related components and the I
failure to issue and implement a procedure for surveillance testing of the core exit thermocouple system.
Pursuant to the provisions of 10 CFR Part 2.201, please find attached, OPPD's response to the violations.
If you have any questions concerning this matter, please do not hesitate to contact us.
Sincerely, l
l R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBeeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator L. J. Callan, NRC Director, Division of Reactor Projects A. Bournia, NRC Project Manager 9{
P. H. Harrell, NRC Senior Resident Inspector 8003010212 880226 k
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RESPONSE TO NOTICE OF VIOLATION Duaing an NRC inspection conducted on November 1-30, 1987, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are listed below:
A.
Section 5.8.1 of the Technical Specifications states, in part, that written procedures shall be established, implemented, and maintained that meet or exceed the minimum requirements of Section 5.3 of ANSI 18.7-1972.
Section 5.3.5(3) of ANSI 18.7-1972, which is applicable to all safety-related equipment, requires that maintenance procedures provide instructions for post-maintenance checkout and return to service.
Section 6.2 of the licensee's Quality Assurance Plan states, in part, that post-maintenance testing shall be performed on CQE (safaty-related),
limited-CQE, and fire-protection equipment.
1.
Contrary to the above, Procedure S0-G-17 does not require the tech-nical supervisor to specify post maintenance testing requirements for all CQE, limited-CQE, and fire-protection equipment.
Paragraph 4.3 of this procedure requires post-maintenance testing only for safety-related equipment required to function during accident conditions.
2.
Contrary to the above, post-maintenance operability testing was not specified on Maintenance Orders 875166, 675167, and 875183 which were issued for repair of safety-related valves PCV-514A, FCV-532A, and LCV-Il73, respectively.
These are safety related valves not required to function during accident conditions.
This is a Severity Level IV violation.
(Supplement 1)(285/8729-01)
OPPD'S RESPONSE Le.ason for the Violation if Admitted Section 6.2 of the OPPD Quality Assurance Plan does not specifically state that post-maintenance testing shall be performed on CQE, limited-CQE, and fire-protection equipment. However, it could be interpreted to mean that because of the scope of Section 6.2.
The process for determining post maintenance testing requirements is contained in Section 4.3 of Standing Order G-17 (Maintenance Orders). At the time of the violation, G-17 required post-maintenance testing for only tha* safety-related equipment which performed an accident function.
Due to the aforementioned interpretation of the QA Plan, Standing Order G-17 was in conflict with Section 6.2 of the QA Plan.
Q.qtnective Steos Which Have Been Taken and the Results Achieved Upon notification of this concern by the Resident Inspector, personnel authorized to perform the technical reviews of Maintenance Orders (M0's) were immediately directed to specify post maintenance testing for all safety-related equipment. Testing was performed on valves PCV 514A, FCV-532A, and LCV-Il73, and a revision to Standing Order G-17 was also prepared and submitted to the Plant Review Committee.
This change was approved and implemented December 7, 1987.
b Attachment (Continued)
Corrective Steos Which Will Be Taken to Avoid Further Violations OPPD management will develop or revise existing procedures to ensure that future changes to the QAP are reviewed and appropriate changes to affected procedures are implemented.
The reviews will also ensure that affected proce-dures properly interpret the QA Plan and discrepancies will be resolved as appropriate.
This procedure will be completed and implemented by June 30, 1988.
Date When Full Comoliance Will Be Achieved OPPD is currently in full compliance.
+
B.
Section 5.8.1 of the Technical Specifications states, in par t, that procedures shall be established, implemented, and maintained that meet or exceed the requirements of Appendix A to Regulatory Guide' l.33.
Section 8.b of Appendix A to Regulatory Guide 1.33 states, in part, that specific procedures for surveillance tests should be written for each surveillance test listed the the Technical Specifications.
On October 30, 1987, Amendment 110 of the Technical Specifications became effective and established the surveillance requirements for the core exit and heated junction thermocouple instrumentation systems.
Contrary to the above, the Fort Calhoun Station failed to issue and imple-ment procedures for surveillance testing of the core exit and heated junction thermocouple instrumentation systems on October 30, 1987, the date that the Amendment 110 became effective. On November 10, 1987, the NRC inspector notified the licensee that surveillance test procedures had not been implemented.
On November 24, 1987, the licensee issued the core exit and heated junction thermocouple instrumentation surveillance procedure and performed testing to verify instrumentation operability.
This is a Severity Level IV violation.
(Supplement I)(285/8729 04)
OPPD's Resoonse The Reason for the Violation If Admitted Plant personnel were unaware that a Technical Specification amendment was issued until the date it became effective.
The amendment was not properly routed to the plant personnel due to an error in correspondence distribution.
Corrective Steos Taken and the Results On the November 24, 1987, Fort Calhoun Station issued the core exit and heated junction instrumentation surveillance procedures (ST-CET-1 F.1 and ST-HTJC-1 F.1) and performed testing to verify instrumentation operability. Alterations to the surveillance for calibration of the Subcooled Margin Monitors (ST-SMM-1) and to the Master Checklist for Start-up or Trip Recovery (OP-1) were also completed. The implementation and alteration of these procedures ensure full compliance with Technical Specification Amendment 110.
Corrective Steos Which Will Be Taken to Avoid Further Violations To resolve the generic problem of correspondence control and distribution a review is being performed. The Technical Specification amendment review process is a part of this. Several actions concerning the Technical Specif t-cation amendments have been implemented to date.
Attachment (Continued)
Within the first week after the issuance of an amendment to Technical Specif t-cations, the plant manager and the other supervisors are notified of the change and receive a copy of the amendment.
This provides each supervisor with the knowledge of a change to Technical Specifications that could potentially affect the various procedures used by his/her group.
Per Nuclear Production Division Policy / Procedure G-2, the amendment is placed on the Integrated Regulatory Requirement ActiSn Log (RRD).
This document is used by licensing to facilitate orderly handling and tracking of industry requirements and OPPD commitments.
The amendment is assigned to cognizant personnel who will ensure that the procedural changes required for an amendment to Technical Specifications will be implemented within 3 weeks of the date of issuance. This is within the 30 day time limit that is usually allowed to implement the amendment.
Date When Full Comoliance Will Be Achieved The new procedures and procedure changes that have been implemented ensure full compliance with Technical Specification Amendment 110.
The review of the generic problem of correspondence control and distribution will be completed by April 15, 1988.
Recommendations resulting from this review will be addressed as needed.
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