ML20206H309
| ML20206H309 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/03/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| LIC-87-218, NUDOCS 8704150323 | |
| Download: ML20206H309 (8) | |
Text
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l Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/536 4000 April 3, 1987 LIC-87-218 APR - 8 887
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L Mr. J. E. Gagliardo l
Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
References:
1.
Docket No. 50-285 2.
Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated January 29, 1987 (IER 50-285/86-34) 3.
Letter 0 PPD (R. L. Andrews) to NRC (J. E. Gagliardo) dated March 2, 1987 (LIC-87-120)
SUBJECT:
Inspection Report 86-34
Dear Mr. Gagliardo:
The subject inspection report addressed two violations identified by the NRC Senior Resident Inspector during the month of December, 1986. OPPD responded in Reference 3 to the notices of violation identified in Reference 2.
Since that time, conversations have been held with the Senior Resident Inspector concerning the content of Reference 3.
In response to these discussions, OPPD believes a supplemental response would be in order.
Accordingly, please find attached an amended response to that submitted in Reference 3.
If you have any questions, please do not hesitate to contact us.
Sincerely, G1.h.1 b R. L. Andrews
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LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 R. D. Martin, Regional Administrator
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P. H. Harrell, NRC Senior Resident Inspector 0
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e Attachment i
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During an NRC inspection conducted December 1-31, 1986, two violations of NRC requirements were identified. One violation involved the incorrect valve line ups of the waste gas sampling system, and the second violation involved fire barrier / security doors not being installed in accordance with documented instructions.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1986), the violations are listed below:
Violation A Incorrect Valve Line Ups of the Waste Gas Samplina System I
i Technical Specification 5.8.1 requires that procedures, as listed in Appendix i
A to Regulatory Guide 1.33, be established and implemented.
Section 7.C of Appendix A to Regulatory Guide 1.33 includes procedures related to sampling and monitoring of the gaseous effluent system.
i Procedure 01-WDG-3 has been established in accordance with this Technical i
Specification requirement and requires that the waste gas sampling system will be placed in a standby mode upon completion of sampling.
i Contrary to the above, the waste gas sampling system was found, on three
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occasions.on December 4, 29 and 31, 1986, during this inspection period, not to have been placed in the specified standby mode after completion of i
sampling.
l This is a Severity Level IV violation.
(Supplement I.D.) (285/8634-03) j OPPD's Response j
Reason for the Violation. if Admitted Upon initial notification of the problem on December 4,1986, two actions were taken. The procedure for performing sampling was reviewed. The reviewer concluded that the procedure appeared reasonable and workable.
Secondly, the technician involved was retrained. The incident was also noted i
in the weekly chemistry group meeting. The problem was believed to have been corrected.
4 Upon the second instance, December 29, 1986, retraining was again undertaken i
and a more thorough root cause investigation conducted.
Based on the root i
cause findings, a decision was made that a procedural revision could lessen the probability of recurrence and the revision was initiated.
Before completion of the revisions, the third instance occurred. The root cause was determined to be lack of adequate training, which was complicated by i
procedural complexity.
Corrective Steos Which Have Been Taken and the Results Achieved The procedure in question, OI-WDG-3, and CMP-2.2 were revised January 7, 1987.
The changes included ensuring that the two procedures were consistent with each other. Additionally, required valve manipulations were included in
A Attachment (Continued) the body of the procedure, as well as calling out for the technician to return the valves to their original position. This change was made to eliminate the necessity of performing a detailed valve line up that included numerous valves never needing to be repositioned.
The revised procedures have been successfully used to perform both on-line and grab sample analyses.
Corrective Steos Which Will Be Taken Other procedures in use by the chemistry group were reviewed. The two procedures noted above_were among the most complicated procedures performed by the chemistry group.
It is believed that the revision to these procedures will make them easier to understand and will make compliance more attainable.
The importance of procedural compliance and actions to be taken if verbatim procedural compliance is not, for some reason, possible, will be emphasized further in upcoming chemistry group meetings. Additionally, chemistry personnel will, be reminded of steps to be taken if procedures appear con-fusing, unclear or unsafe. These actions should help preclude further occurrences of this type.
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Date When Full Comoliance Will Be Achieved OPPD is currently in full compliance.
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Attachment (Continued)
Violation B Fire barrier / security doors not installed in accordance with documented instructions.
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- Criterion V of Appendix B to 10 CFR 50 and Section A.6 of the licensee's quality assurance plan require that activities affecting quality be described in documented instructions, installed.in accordance with the instructions, and appropriate quantitative acceptance criteria be provided.
Installation package MR-FC-85-38 A/B was established in accordance with the i
requirements specifying that the installation requirements for the fire barrier / security doors (1025-4,1011-28, and 1036-2) be installed in accordance with the Underwriter Laboratory (UL) standards.
Contrary to the above,. fire barrier / security doors were not installed in accordance with documented instructions and the instructions did not provide appropriate quantitative acceptance criteria as related to the UL standards, 4
in that:
1 1.
Work proceeded past the specified QC hold points during installation of doors 1036-2 and 1011-28.
2.
The installation packages for doors 1025-4, 1036-2, and 1011-28 were i
signed off as " work complete," when in fact steps were not complete.
3.
The installation package step for painting door 1025-4 was signed off as
" work complete," however, door 1025-4 was not painted.
4.
The gap at the bottom of door 1025-4 was excessive.
j 5.
Six holes were left unplugged in door 1036-2, which exposed the door Core.
This is a Severity Level IV violation.
(Supplement I.D.) (285/8634-02)
OPPD's Response Reason for the Violation, if Admitted The violation occurred in part because the individual signing off steps did i J1 not adequately verify completion prior to steps being signed off.
The indi-ls vidual believed that problems associated with-QC signoffs had been corrected-separately under a maintenance order.~ The individual was unaware that all 4
probler: had not been remedied. This accounted for11tems 3, 4 and 5.
Steps in the package signed beyond Q.C. hold points were signed because the pro-i l
cedure specified that steps may be performed out of sequence, and the Q.C.
j signoffs could be completed at the end of the job. However, a separate indi-vidual from the Central Maintenance group signed off the " work completed"-
step.
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Attachment (Continued)
Corrective Steos Which Have Been Taken and the Results Achieved Two Operations Incident Reports (0I's) were written as a result of this violation. GSE personnel involved were interviewed to ascertain the reasons the violation occurred. The individuals from Engineering and Central Maintenance have been reinstructed.
Corrective maintenance on doors identified in the report was initiated under Maintenance Order (M.O.) 864475 (door 1025-4) and 870028 (door 1036-2).
Corrective maintenance on door 1025-4 has been completed and the door has been painted. The remaining necessary maintenance on door 1036-2 was completed consistent with the commitment in Reference 3.
In Reference 3, it was noted that a " continuous fire watch" was being maintained.
Clarification to that statement is believed to be necessary. At the time of discovery of the potential problem with door 1036-2, the appropriate Technical Specification compensatory measures were taken. The internal Operations Incident contained an evaluation of the consequences of the signoff of the fire door before Q.C. verification took place. The evaluation concluded that since the control room is continuously occupied, no fire could have started without being detected even though there was no hourly fire patrol. The author of the Operations Incident Report and the author of the violation response did not communicate clearly, resulting in a misrepresentation of the intent of the firewatch activities and the role played by control room personnel in Reference 3.
There were no safety implications from this misunderstanding.
A memorandum was written and circulated to Generating Station Engineering personnel describing the violation and detailing the reasons for the violation. The memo stressed the importance of procedural compliance, of verification of work prior to signature, and of insuring that steps were within one's field of qualification prior to signature. The memo to GSE personnel stressed that care should be taken when citing a manufacturer or industry standard especially if specific information such as tolerances or other data are required.
It was also noted that whenever possible, reference to a drawing with specific criteria should be provided. This should help 4
eliminate the lack of quantitative acceptance criteria in future installation packages. The other guidance provided in the memo includes reminders of ensuring that if an installation package involves a different discipline than the signer's, the step is clearly understood and well verified prior to signature.
Before the beginning of the 1987 refueling outage, the memo was distributed again, this time requiring a signoff that the memo had been read. This also raised the level of awareness of GSE personnel prior to the refueling outage.
The Generating Station Engineering-Civil personnel have been instructed in the fire door installation criteria of MP-FIRED 00R-1. Additionally, walkdowns of fire doors have been conducted by plant engineering, ensuring that other fire doors have been properly installed.
Attachment (Continued)
Violation B Fire barrier / security doors not installed in accordance with documented instructions.
Criterion V of Appendix B to 10 CFR 50 and Section A.6 of the licensee's quality assurance plan require that activities affecting quality be described in documented instructions, installed in accordance with the instructions, and appropriate quantitative acceptance criteria be provided.
Installation package MR-FC-85-38 A/B was established in accordance with the requirements specifying that the installation requirements for the fire barrier / security doors (1025-4,1011-28, and 1036-2) be installed in accordance with the Underwriter Laboratory (UL) standards.
Contrary to the above, fire barrier / security doors were not installed in accordance with documented instructions and the instructions did not provide appropriate quantitative acceptance criteria as related to the UL standards, in that:
1.
Work proceeded past the specified QC hold points during installation of doors 1036-2 and 1011-28.
2.
The installation packages for doors 1025-4, 1036-2, and 1011-28 were signed off as " work complete," when in fact steps were not complete.
3.
The installation package step for painting door 1025-4 was signed off as
" work complete," however, door 1025-4 was not painted.
4.
The gap at the bottom of door 1025-4 was excessive.
5.
Six holes were left unplugged in door 1036-2, which exposed the door core.
This is a Severity Level IV violation.
(Supplement I.D.) (285/8634-02)
OPPD's Response Reason for the Violation. if Admitted The violation occurred in part because the individual signing off steps did not adequately verify completion prior to steps being signed off.
The indi-vidual believed that problems associated with QC signoffs had been corrected separately under a maintenance order. The individual was unaware that all problems had not been remedied. This accounted for items 3, 4 and 5.
Steps in the package signed beyond Q.C. hold points were signed because the pro-cedure specified that steps may be performed out of sequence, and the Q.C.
signoffs could be completed at the end of the job. However, a separate indi-vidual from the Central Maintenance group signed off the " work completed" step.
Corrective Steos Which Have Been Taken and the Results Achieved l
1
O Attachment (Continued)
Two Operations Incident Reports (0I's) were written as a result of this violation. GSE personnel involved were interviewed to ascertain the reasons the violation occurred. The individuals from Engineering and Central Maintenance have been reinstructed.
Corrective maintenance on doors identified in the report was initiated under Maintenance Order (M.O.) 864475 (door 1025-4) and 870028 (door 1036-2).
Corrective maintenance on door 1025-4 has been completed and the door has been painted. The remaining r.ecessary maintenance on door 1036-2 was complated consistent with the commitment in Reference 3.
In Reference 3, it was noted that a " continuous fire watch" was being maintained. Clarification to that statement is believed to be necessary. At 4
the time of discovery of the potential problem with door 1036-2, the appropriate Technical Specification compensatory measures were taken.
The internal Operations Incident contained an evaluation of the consequences of the signoff of the fire door before Q.C. verification took place. The evaluation concluded that since the control room is continuously occupied, no fire could have started without being detected even though there was no hourly fire patrol.
The author of the Operations Incident Report and the author of the violation response did not communicate clearly, resulting in a misrepresentation of the intent of the firewatch activities and the role played by control room personnel in Reference 3.
There were no safety implications from this misunderstanding.
A memorandum was written and circulated to Generating Station Engineering personnel describing the violation and detailing the reasons for the violation. The memo stresad the importance of procedural compliance, of verification of work prior.o signature, and of insuring that steps were within one's field of qualification prior to signature. The memo to GSE personnel stressed that care should be taken when citing a manufacturer or industry standard especially if specific information such as tolerances or other data are required.
It was also noted that whenever possible, reference to a drawing with specific criteria should be provided. This should help eliminate the lack of quantitative acceptance criteria in future installation packages. The other guidance provided in the memo includes reminders of ensuring that if an installation package involves a different discipline than the signer's, the step is clearly understood and well verified prior to signature.
Before the beginning of the 1987 refueling outage, the memo was distributed again, this time requiring a signoff that the memo had been read. This also raised the level of awareness of GSE personnel prior to the refueling outage.
The Generating Station Engineering-Civil personnel have been instructed in the fire door installation criteria of MP-FIRED 00R-1. Additienally, walkdowns of fire doors have been conducted by plant engineering, ensuring that other fire doors have been properly installed.
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Attachment (Continued)
Corrective Steos Which Will Be Taken The memo to GSE personnel stressed that care should be taken when citing a manufacturer or industry standard especially if specific information such as tolerances or other data are required.
It was also noted that whenever possible, reference to a drawing with specific criteria should be provided.
This should help eliminate the lack of quantitative acceptance criteria in future installation packages. The other guidance provided in the memo includes reminders of ensuring that if an installation package involves a different-discipline than the signer's, the step is clearly understood and well verified prior to signature. These actions should help preclude further occurrences.
Procedural compliance continues to be stressed.
Date When Full Comoliance Will Be Achieved OPPD is currently in full compliance.
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