ML20207K747
| ML20207K747 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/05/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8810170007 | |
| Download: ML20207K747 (2) | |
See also: IR 05000285/1988023
Text
__
_
_
_ _ _ _
__ _ . _ _ _ . _ _ _ . - ..
_ - .
.
_ _ _ _
_
. _ _ ,
.
,
,
- .
,
OCT 5W
.
In Reply Refer To:
Docket: 50-285/88-23
Omaha Public Power District
ATTN:
Kenneth J. Norris, Division Manager
Nuclear Operations
1623 Harney Street
Omaha, Nebraska 68102
Gentlemen:
Thank you for your letter of September 19, 1988, in response to our
letter and Nutice of Violation dated August 19,'1988. We have reviewed your
reply and find it responsive to the concerns raised in our Notice of
Violation. We will review the implementation of your corrective actions
during a future inspection to determine that full comp!nce has been
achieved and will be maintained.
Sincerely,
L. J. Callan, Director
Division of Reactor Pro,jects
cc:
Fort Calhoun Station
ATTh:
W. G. Gates, Manager
P.O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NW
Washington, D. C.
20036
Nebraska Radiation Control Program Director
bec:
(seenextpage)
RIV:5Rik
PSB h
C:PSB
D:D
6
PHHarrell/nc
RPMullikin
TFWesterman
LJCallan
09/29/88
10/y/88
10/g/88
10/i/88
f
m
l8A 488s 8t4886
'
I
PNU
_ _ _ _ _ - _ _
.
.
.
Omaha Public Power District
-2-
bec to DMB (IE01)
bec distrib. by RIV;
R. D. Martin, RA
RPB-DRSS
SectionChief(DRP/B)
MIS System
RIV File
RSTS Operator
Project Engineer. DRP/B
Lisa Shea, RM/ALF
P. Milano,flRR Project Manager
RRI
l
l
1
l
.
\\
.
-
.
. . .
.
._
__._ _ ---_ _ _ -
A';y
,,; y_
.
m. - -
- +
~ e L. -
31_
"' ':
y .' _
_
C,
,
.
Omaha Public Power District
1623 Harney Omaha. Nebraska 68102 2247
402/536 4000
p 'd ? $. IC: ','/*.' li &,
- .
7:,,...,
-
.i;
.
.
. _.
.
,
September 19, 1988
1
c
.
,
LIC-88-778
.
I..
V. S. Nuclear Regulatory Comission
1
Attn: Document Control Desk
Mail Station P1-137
l
Washington, DC 20555
l
References:
1.
Docket No. 50-285
2.
LetterfromNRC(L.J. Callan)toOPPD(K.J. Morris) dated
-
August 19, 1988
Gentlemen:
SUBJECT:
Response to Notice of Violation
NRC Inspection Report 50-285/88-23
l
Omaha Public Power District (0 PPD) received the subject inspection report which
identified two violations. The violations were cited on failure to properly
store unused ion exchange resins and the failure to provide adequate procedures
for the start-up of the Instrument Air System.
Please find attached OPP 0's re-
sponse to the Notice of Violation in accordance with 10 CFR Part 2.201.
If you have any questions concerning this matter, please contact us.
Sincerely,
Av /
K. J. Morris
,
Division Manager
Nuclear Operations
KJM/mc
c:
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Ave., N.W.
Washir.gton, DC 20036
A d . Martin, NRC Regional Administrator
P. D. Milano. NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
l
-
p
1
-s
i
45 5tN
tr croymem mm EQuel OPC01ufvty
V'
%4'e F ems;f
._!.
1
.
.
._
_
..
. _ .
-
.
- ..
.
ATTACHMENT
'
'
During an NRC inspection conducted on July 1-31, 1988, violations of NRC re-
quirements were identified.
The violations involved the failure to properly
store unused ion exchange resins and the failure to provide adequate procedures
for start up of the instrument air system.
In accordance with the "General
Statement of /alicy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1988), the violations are listed below,
a.
Section !!.A of Appendix R to 10 CFR Part 50 states, in part, that a fire
protection program shall be established at each nuclear power plant and the
i
program shall establish procedures required to implement the program.
j
Section 3.3 of the Updated Fire Hazards Analysis and Section 3.3.1 of Pro-
i
cedure 50-G-6, "Housekeeping," state, in part, that unused ion exchange
resins should be stored in an area protected by an automatic detection /
,
sprinkler ir,stellation.
,
Contrary to the above, the licensee stored eight barrels of unused ion ex-
change resins in Room 69 which does not have a sprinkler system installed.
i
-
?
This is a Severity Level IV violation.
(SupplementI)(285/8823-03)
i
OPPD'S RESPONSE
'
The Reason iGr tie V 41ation if Admitted
!
I
The violation is admitted as stated.
The resin was put into Room 69 to conduct
'
a resin addition procedure.
The procedure was not completed until several days
1
.
later. Resins have normally been brought into Room 69 to be available when the
I
-
appropriate personnel can conduct the procedure.
It was not the intent to
,
l
store the resin other than for this short period of time. Also, Operations
personnel were unfamiliar with statements contained in the UFHA regarding resin
'
'
'
storage.
I
The Corrective Steos That Have Been Taken, and the Results Achieved
I
i
Upon notification cf the condition on the date of the occurrence, the initial
response by Plant Engineering was based on a review of the UFHA for fire
,
j
area / zone 20.7.
Section 5.2 of the UFHA for fire area 20.7 contains a list of
'
allowable combustion levels for Room 69 which includes 1000 lbs, of unused
l
$
resin.
The individual responding personally inspected the storage area with
the intent of assessing the condition which was "analyzed" versus what
presentiy existed.
Since the analyzed condition (1000 lbs of ion exchange
resins) is considered adequate for the fire area / zone boundaries, it was
,
believed that returning to this baseline condition would ensure compliance.
His recomendation was, therefore, to remove four barrels of resins at 217 lbs,
1
per barrel, leaving 868 total lbs. of resins.
Furthermore, the individual re-
l
sponding, unaware of the inconsistency within the UFHA, believed that good
i
housekeeping practices were being maintained, and that adequate spatial separ-
ation from safety-related equipment existed.
)
i
i
i
I
)
.
Attachment (Continued)
'
A follow-up conversation, which took place the following day, uncovered the
.
statement made in Section 3.3 of the UFHA, and requirement 3.3.1 of Standu
Order G-6, which conflict with Section 5.2 of the UFHA.
Upon discovery of this
inconsistency, the remaining resins were removed from the area, and stored in a
non safety related area protected by automatic detection and sprinkler systems.
The Corrective Steos That Will be Taken to Avoid Further Violations
1.
A procedure change to Standing Order G-6, "Housekeeping", will be made to
change the wording of Section 3.3.1 to reflect that unused ion exchange
resins shall be stored in an area protected by an automatic detection /
sprinkler installation.
2.
The Updated Fire Hazards Analysis will be revised to resolve the
discrepancy between Sections 5.2 and 3.3.
This will be performed by
stating that unused ion resins are to be stored in an area with automatic
detection / suppression unless the presence of the resin is analyzed.
3.
Standing Order G-6, "Housekeeping", will De revised as necessary to include
a mechanism for identification of special requirements pertaining to
combustible materials storage and use, and to resolve any cunflicts with
the Updated Fire Hazards Analysis.
4.
A controlled copy of the Updated Fire Hazards Analysis will be maintained
in the control room. Operations personnel will be trained on the
document's content by April 1, 1989.
The Date When Full Compliance Will be Achieved
The change to Standing 01 der G-6 will serve as an interim control until items
2, 3, and 4 are comaleted.
Item 1 will be completed by September 23, 1988.
Items 2 and 3 will rae completed by February 1989, and Item 4 will be completed
by April 1989.
,
<-
.
Attachment (Continued)
..-
.
b,
TS'5.8.1 states, in part, that written procedures shall be established that
,
meet the minimum requirement of Regulatory Guide 1.33.
Section 3 of Regulatory Guide 1.33 states, in part, that instructions for
start-up should be prepared, as appropriate, for the Instrument Air System.
Contrary to the above, the licensee did not provide adequate instructions
for start-up of the Instrument Air System in that position verification for
all instrument air supply valves to safety-related components and equipment
was not included in operating instructions for plant systems. For example,
instructions were not provided for verification of the air supply valves in
the containment spray and Safety injection Systems.
This is a Severity Level IV violation.
(SuppluentI)(285/8823-04)
,0 PPD RESPONSE
The Reason for the Violation if Admitted
.
CPPD admits the violation as stated.
The Instrument Air System was originally
developed and designated as a non-safety related system.
Since the system was
so designated, not all instrument air valves have identifying tag numbers nor
are all instrument air valves located on Piping & Instrumentation Diagrams
(P& ids).
The Corrective Steos That Have Been Takea, and the Results Achieved
As a part of OPPD's corrective actions to address the SSOMI report, various
generic activities related to air accumulators were undertaken. One of these
activitiesinvolvedOperationsSuppcrtAnalysisRequest(0SAR)87-10,whichwas
completed on April 6, 1988 to identify "safety related" valves which utilize
accumulators to perform their design function. A walkdown of these safety
related accumulators outside containment has been performed to identify
associated air supply valves. A request for drawing revision has been
initiated to provide for proper drawing updates and tagging of these supply
valves.
i
The Corrective Steos That Will be Taken to Avoid Further Violations
-
Addition of the valves which supply safety related accumulators to the start-up
checklists will be initiated when drawing revisions are complete. Procedure
changes to the check lists will be performed to provide for lineup of the sup-
ply valves associated with the "safety related" accumulators. A further walk-
down of the three rew ining "safety related" accumulators, HCV-238, HCV-239,
and HCV-240 will be performed during the 1988 outage to verify P&!D's and tag
associated supply valves.
These valves will then also be added tc the proper
'
start-up valve lineup.
i
j
. _ _ _ _
__ _
_
._
. .
, ' . ' -
'
Attachment (Continued)
,
f
.
9
In addition, a start-u) checklist will be developed to line-up Instrument Air
riser valves and main leader valves and will include doubic verification. Tnis
checklist will be completed and performed prior to restart following the 1988
refueling outage.
'
A system walkdown of valves lined-up in the start-up check lists which have
handwheels will also be performed prior to the end of the 1988 outage. Those
l
handwheels which might affect valve operation if positioned incorrectly will be
added to the start-up check lists.
.
I
The completion of these actions will ensure that the air supply route to valves
!
with safety related accumulators are correctly identified and lined-up.
This
is considered to be the critical portion of the air system and these actions
'
1
will be complete prior to the end of the 1988 outage.
The remainder of the instrument air valves will be given identifying tag
'
numbers and p! acted on the P&lDs as part of Project 1991.
Those associated with
safety-related air operated valves will then be added to the startup checklist
as appropriate. These root valves are not a safety concern because system
'
design is such that safety related air operated valves go to the fail-safe
position in the event the instrument air is isolated.
The Date When Full C moliance Will be Achieved
i
Full compliance will be achieved by addition of the affected valves to the
start-up check lists for the safety related velves which utilize accumulators
i
prior to the end of the 1988 outage. The instrument air root valves to safety
i
related valves wiil be added to the P&lDs in accordance with the Project 1991
)
schedules.
-
I
l
I
!
I
I
'
2
.
i
l
I
1
4
i
i
.
- - - -
-
-
--
_-
. , - _ -
_.
, - - -
- ----, -
,----y--#
,m
,
cwe
y---r
---w
y,-w
e
-e--=-wa