ML20198P315
| ML20198P315 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/13/1998 |
| From: | Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gambhir S OMAHA PUBLIC POWER DISTRICT |
| References | |
| 50-285-97-13, NUDOCS 9801220073 | |
| Download: ML20198P315 (4) | |
See also: IR 05000285/1997013
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NUCLEAR REGULATORY COMMISSION
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January 13, 1998
S. K. Gambhir, Division Manager
Engineering & Operations Support
Omaha Public Power District
Fort Calhoun Station FC 2-4 Adm.
P.O. Box 399
Hwy,75 - North of Fort Calhoun
Fort Calhoun, Nebraska 68023-0399
SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-285/9713
Dear Mr. Gambhir:
Thank you for your letter of November 3,1997, in response to our October 2,1997, letter
and Notice of Violation concerning the inadequate valve stroking test program and the failure to
issue condition reports We have reviewed your reply and find it responsive tothe concerns raised
in our Notice of Violation. We will review the implementation of your corrective actions duringa
future inspection to determine inat full compliance has been achieved and will be maintained.
Sincerely,
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&W
Thomas F. Stetka, Acting Chief
Engineering Branch
Division of Reactor Safety
Docket No.: 50 285
License No.: DPR-40
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James W. Tills, Manager
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Nuclear Licensing
Omaha Public Power District .
Fort Calhoun Station- FC 2-4 Adm.
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James W. Chase, Manager
Fort Calhoun Station
P.O. Box 399
Fort Calhoan, Nebraska 68023 '
Perry D. Robinson, Esq.
Wnston & Strewn
1400 L Street, N.W.
Washington, D.C. 20005-3502
Chairman
Washington County Board of Supervisors
Blair, Nebraska 68006
Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
Nebraska Department of Health
301 Centennial Mall, South
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November 3,1997
LIC 97 0169
U.S. Nuclear Regulatory Commission
A1TN: Document Control Desk
Mail Station PI 137
Washingten, D.C. 20555
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References:
1.
Docket No. 50 285
2.
letter from NRC (A. T. Ilowell) to OPPD (S. K. Gambhir) dated October 2,
1997
SUBJECT:
Reply to a Notice of Violation, NRC Inspection Report No. 50-285/97-13
The subject report (Reference 2) transmittcJ a Notice of Violation (NOV) resulting from an NRC
inspection conducted June 30 through July 15,1997, at the Fort Calhoun Station (FCS). Attached is the
Omaha Public Power District (OPPD) response to this NOV.
If you should have any questions, pie tse contact me.
Sin,cerely,
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S. h. Gambhir
Division Manager
Engineering & Operations Support
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Attachment
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Winston and Strawn -
E. W. Merschoff, NRC Regional Administrator, Red on IV
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L R. Wharton, NRC Project Manager
W. C. Walker, NRC Senior Resident inspector
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- Attachment
LIC-97 0169
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Omaha "ublic Power District
Docket No. 50-285
Fort Calhoun Station
License No. DPR-40
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During an NRC inspection conducted on June 30 through July 18,1997, three violations of NRC
requirements were identitled. In accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions," NUREG 1600, the violadons are listed below:
A. Technical Specincation 5.5.2.2 requires, in part, that the safety audit and review committee -
composition shall have a senior vice prwident as the chairperson. Contrary to the above, the licensee
was conducting safety audit and review committee meetings since January 17,1997, without the senior
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vice president as the chairperson.
This is a Severity Level IV violation (Supplement I) (285/97013 01).
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H. .10 CFR Part 50, Appendix B, Criterion XI, states, in part, that "[a] test program shall be established
to assure that all testing required to demonstrate that structures, systems, and components will
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perform satisfactorily inser vice is identined and performed in accordance with written test procedures,
which incorporate the requirements and acceptance limlfs contained in applicable design documents.
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Contrary to the above, the established test program did not demonstrate that the component cooling
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water outlet valves from the component cooling water / raw water heat exchanger (11C%4898/490B/
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491H/492B) would perform satisfactorily in service. The quarterly inservice test was performed in a
manner such that the outlet valve was always stroked open and closed immediately prior to the thned
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opening stroke test. Thb preconditioning of tl.c valve prior to its stroke test precluded an accurate
assessment of its initial opening capability.
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This is a Sev.rity Level IV violation (Supplemem I) (50 285/9713-02).
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C.
10 CFR Part 50, Appendix H, Criterion V, " Instructions, Procedures, and Drawings," states that
" activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,
of a type appropriate to the circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings."
Procedare SO R-2, " Condition Report and Corrective Action," Revision 4, requ'res origination of a
condition report for the following'
"... equipment related events, documentation deficiencies, non-routine outside agency notificutfons,
operational events, testing denciencies, security infractions, human performance errors, personnel
safety issues, radiological occurrences, or other circumstances which impact or potentially impact
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safe /or refleble operation of Fort Calhoun Station .... "
Contrary to the above, the licensee failed to originate a condition report for the following liccusce-
identined deficiencies'
(1)
Procedures S0-G-21, "Modincation Control," Revision 62, and PED GEI 56, " Configuration
Change Closecut," P.evision 4. contained deficiencies that could potentially impact the safe
operation of the plant. These procedures allowed design documentation to be inconsistent with
- Held installatloas for an extended period of time.
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1.lC-97 0169
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(2)
The 4 way solenoid for Valve FC%1904C had been repleted wkh a different model valve during
or after the original plant startup, but no engineering change notice or drawing change had been
procemed to document the change.
This is a Severity Level IV violation (Supplement I) (50-285/9713 04).
QW Public Power District (OPPD) Resoonse
As requested by Reference 2 only responses to violations B and C are being provided.
Violation B
I. - Reason for the violatiett
The cause of this violation is that the Inservice Inspection (ISI) program did not perceive the test
toethodology twing used as being preconditioning. Preconditioning was perceived as some action that is taken
intentionally to ensure that a component would pass its Inservice Test (IST). That is, some action tlat would
likely mask the effects of likely modes of component degradation. Since these valves are ganged together so
that both valves operate when one switch is wetivated and since these valves are frequently repositioned
during normal plant operation, it seemed appropriate to test the valves by consistently measuring the stroke
time of the "A valve" first and the "B valve" second. It is likely that consistent performance of the test and
obsetvation of the resultant trended data would detect deterioration of valve performance caused by any
credible mode of valve degradation, even on the valves that are consistently stroke timed on their second
stroke. nus, the present test methodology was considered adequate to provide reasonable assurance that the
valves would be able to perform their safety function.
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11. Corrective Steps Which Have Been Taken and the Results Achieved
1.
A review of category B valves tested under the IST Program was performed to identify valves that are
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ganged together and to rr
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that are tested under five uirierent surveillance tests. Thes: valves were tested in t. fashion similar to the
valves identified in this violation notice. That is, the valves were stroke timed one at a time and one of
the valves was always stroked once by the test procedure before the timing stroke was performed.
2. - FCS Operations Management has communicated their concerns about the issue of preconditioning of
components prior to testing to heighten the awareness of the persons responsible for test performance.
This has resulted in a critical evaluation of the test procedures and maintenance practices being
perfonned at FCS to identify situations or actions that could be defined as preconditioning. As a result,
six condition reports and numerous procedure changes are being processed to correct preconditioning
issues.
III. Corrective Steos Which Will Be Taken -
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The five procedures identified above are being revised to eliminate preconditioning of the ganged valves
by requiring simultaneous stroke timing of the ganged valves or splitting the test procedure so that the A
-valve and the B valve of the ganged pair are tested tit different times by different test procedures. These
procedure changes will be implemented prior to the next scheduled performance of each of the
Surveillance Tests,;
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LIC 97-0169
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A portion of the fourth quarter 1997 Engineering Support Personnel Generic Continuing Training will be
devoted to the subject of preconditioning of components prior to testing. This will heighten the
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awareness of the entire FCS engineering staff to the need to prevent proceduralizing any activities that
could result in preconditioning of components prior to testits This training will be completed by
December 31,1997,
IV.' Date When Full Camnllance Will Be Achieved
OPPD is currently in full compliance.
Violation C
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I.
Reason for the Violation
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Contrary to the requirements of SO R 2, in the two examples cited the individuals responsible for
determining if a Condition Report should be written judged that the conditions did not " impact or potentially
impact safe and/or reliable operation of Fort Calhoun Station" and therefore did not generate the required
condition repora.
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While the decision not to initiate the appropriate Condition Reports was consistent with management
expectations at the time, OPPD recognizes that it was not in strict compliance wPh the cited codes and
. procedures.
II. Corrective Stens Which Have Been Taken and the Results Achieved
1,
A Condition Report was generated to encompass the issues noted in the two examples cited in the
Violadon.
2.
Management expectations regarding Condition Report initiation have been conveyed through training,
meetings and one-on-one conversations. This has resulted in an increase in the number of Level 6
Condition Reports since the time of these events.
3.
Management's expectation that "A condition report shall be written as adverse conditions and
weaknesses are identified during self assessments." is included in Fort Calhoun Station Guideline
- (FCSG) 4. " Performance of Self Assessments " FCSG-4 clarifies that identified adverse conditions and
weaknesses are to be documented in Condi; ion Reports. Self assessments conducted since the issuance of
this guideline in August 1997 have incorporated this guidance.
'III, Corrective Steps Which Will Be Taken
' None
IV. Date When Full Compliance Will Be Achieved
OPPD is currently in full compliance.
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