ML20235P000
| ML20235P000 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/21/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-14, NUDOCS 8903020065 | |
| Download: ML20235P000 (15) | |
Text
_____
8 Omaha Public Power District l
1623 Harney Omaha, Nebraska 68102 ?247 i
402/536-4000 February 21, 1989 Docket No. 50-285 LIC-89-098 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 l
Washington, DC 20555
References:
Reference index begins on page 3 of this cover letter Gentlemen:
SUBJECT:
Response to Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety Related Equipment" dated August 8,1988 Omaha Public Power District (0 PPD) received Generic Letter 88-14 which requested licensees to review NUREG-1275, Volume 2 and perform a design and operations verification of the Instrument Air System. OPPD's response is enclosed as Attachment 1.
OPPD had previously committed to evaluate, test and install modifications on the Instrument Air System in response to a water intrusion event which occurred July 6, 1987. As a result of the water intrusion event, the Instrument Air Corrective Action Program was developed.
Major elements of the program included a System functional Inspection (SFI), a design review of the failure position of safety related air operated valves, reconstitution of the design basis of the air system, and functional testing of components.
The System Functional Inspection reviewed the maintenance and testing conducted on the Instrument Air System to verify the operability and design adequacy of the system.
In addition, a review of procedures and training which affect the operation of the system was completed.
An analysis was performed to verify the design requirements of the safety i
related accumulators and functional testing was completed using this criteria during the 1988 refueling outage. A design review was also conducted of the failure position of air operated safety related valves.
i, " Response to Notice of Violation and Imposition of Civil Penalty (NRC Inspection Report 50-285/87-27)," which presents the Instrument Air Corrective Action Program is enclosed. The references are grouped into three j
categories:
I.
Correspondence related to the July 6, 1987 water intrusion j
event, II.
Correspondence _related to the Instrument Air j
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Corrective Action Program, and III. Correspondence related to items discovered by 0 PPD during the review of the Instrument Air System. Those items identified by OPPD during the review concerning operability have been corrected.
Verification of the design of the Instrument Air System at the Fort Calhoun i
Station to ensure that the system will operate as required is complete. Those items of the program which were not completed prior to plant start-up following the 1988 refueling outage were presented in the " Instrument Air Corrective Action Program Status" enclosed as Attachment 3 and discussed with the NRC Senior Resident Inspector.
This response is being submitted under oath pursuant to the provisions of j
Section 182a of the Atomic Energy Act of 1954, as amended.
Should you have any questions concerning this matter, please contact us.
Sincerely, 34 K. J. Morris I
~ Division Manager Nuclear Operations KJM/sa Attachments:
1.
Response to Generic Letter 88-14 2.
Response to Notice of Violation and Proposed Imposition of Civil Penalty, (NRC Inspection Report 50-285/87-27 EA 87-210) dated April 27, 1988 3.
Instrument Air Corrective Action Program Status, dated November 15, 1988 c:
LeBoeuf, Lamb, Leiby & MacRae, w/o attachments R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager, w/o attachments P. H. Harrell, NRC Senior Resident Inspector, w/o attachments
i U. S. Nuclear Regulatory Commission LIC-89-098 i
l Page 3 REFERENCE INDEX I. Correspondence Related to July 6,1987 Water Intrusion Event I-1 Docket No. 50-285 I-2 Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated October 23, 1987, Inspection Report 50-285/87-27 I-3 Licensee Event Report 50-285/87-025 dated October 23, 1987, DG-2 Shutdown on Hiah Coolant Temperature (LIC-87-720)
I-4 Letter from OPPD (R. L. Andrews) to NRC (R. D. Martin) dated November 4, 1987, Instrument Air System at Fort Calhoun Station (LIC-87-744) 1-5 Letter from NRC (A. Bournia) to 0 PPD (R. L. Andrews) dated November 9, 1987, Meetina Summary of Meetina Held on November 5, 1987 in Bethesda.
Maryland I-6 Letter from NRC (R. D. Martin) to OPPD (R. L. Andrews) dated November 10, 1987, Meetina Summary of Enforcement Conference Held October 29. 1987 in Arlinaton. Texas I-7 Letter from NRC (A. Bournia) to 0 PPD (R. L. Andrews) dated November 13, 1987, Summary of Meetina Held November 13. 1987 in Bethesda. Maryland I-8 Letter from OPPD (R. L. Andrews) to NRC (J. A. Calvo) - dated November 20, 1987, Summary of Meetina with NRC Held November 13. 1987. Reaardina the Instrument Air System at Fort Calhoun Station (LIC-87-783)
I-9 Licensee Event Report 50-285/87-033 dated November 25, 1987, Water Intrusion into Air System (LIC-87-795)
I-10 Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated December 10, j
1987, Inspection Report 50-285/87-30 1-11 Licensee Event Report 50-285/87-025 Revision 1, dated December 15, 1987 (LIC-87-854)
I-12 Letter from NRC (J. A. Calvo) to OPPD (R. L. Andrews) dated December 15, 1987, Water Intrusion into the Instrument Air System I-13 Letter from NRC (R. D. Martin) to 0 PPD (R. L. Andrews) dated February 22, 1988, Notice of Violation and Proposed lmoosition of Civil Penalty (NRC Inspection Report 50-285/87-27)
(References continued on next page)
U. S. Nuclear Regulatory Commission LIC-89-098 Page 4 i
REFERENCE INDEX (Continued) l II.
Correspondence Related to the Instrument Air l
Corrective Action Program j
II-1 Letter from NRC (J. M. Taylor) to OPPD (B. W. Reznicek) dated March 19, 1986, Safety System Outaae Modification Inspection (Installation and Test) 50-285/85-29 II-2 Letter from OPPD (R. L. Andrews) to NRC (J. f. Taylor) dated April 10, 1987, Besponse to Notice of Violation and Proposed Imposition of Civil Penalty, (NRC Inspection Reports No. 50-285/85-22 and No. 50-285/85-29 (LIC-87-086)
II-3 Letter from 0 PPD (R. L. Andrews) to NRC (J. A. Calvo) dated November 20, 1987, Submittal of Seismic Qualification Calculations and Report for C0E (Safety Related) Air Accumulators (LIC-87-790)
II-4 Letter from OPPD (R. L. Andrews) to NRC (J. A. Calvo) dated November 25, 1987, Seismic Qualification Information for the Valves Associated with the Air Accumulators Discussed in LIC-87-790 dated November 20.1987(LIC-87-803)
II-5 Letter from 0 PPD (R. L. Andrews) to NRC (Document Control Desk) dated December 16, 1987, Review of Fort Calhoun's ISI Proaram (LIC-87-806)
II-6 Letter from 0 PPD (R. L. Andrews) to NRC (J. Lieberman) dated March 22, 1988, S_pbmittal of Civil Penalty (LIC-88-202)
II-7 Letter from 0 PPD (R. L. Andrews) to NRC (J. Lieberman) dated April 27, 1988, Response to Notice of Violation and Proposed Imoosition of Civil Penalty (NRC Inspection Report 50-285/87-27 EA 87-210) (LIC-88-165)
II-8 Letter from OPPD (K. J. Morris) to NRC (Document Control Desk) dated November 15, 1988, Instrument Air Corrective Action Procram Status (LIC-88-974) l (References continued on next page)
U. S. Nuclear Regulatory Comission LIC-89-098 Page 5 REFERENCE INDEX (Continued)
III. Correspondence Related to Findings During Review of the Instrument Air System III-1 Licensee Event Report 50-285/88-002 dated February 25, 1988, Inocerability of Isolation Valve on Hiah Pressure Safety In.iection (LIC-88-118)
{
III-2 Licensee Event Report 50-285/88-004 dated April 11, 1988, Instrument Air l
Valve PCV-1849 Outside Desian Basis for Containment Isolation Criteria
)
(LIC-88-209) i III-3 Licensee Event Report 50-285/88-009 dated May 6, 1988, Pneumatic Ooerated Valves Outside Desian Basis Durina Desian Basis Accident (LIC-88-276)
III-4 Licensee Event Report 50-285/88-010 dated May 16, 1988, Inocerable Check Valves on SIRWT Bubblers (LIC-88-346)
III-5 Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated June 1, 1988, NRC Inspection Report 50-285/88-15 III-6 Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated June 21, 1988, Enforcement Conference Concernino NRC Inspection Findinas, (Inspection Report 50-285/88-15 EA 88-145)
III-7 Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated July 28, 1988 Reouest for Status of Instrument Air System Thirty Days Prior to Plant Start-up III-8 Letter from NRC (R. D. Martin) to OPPD (R. L. Andrews) dated October 12, 1988, Notice of Violation and Proposed Imposition of Civil Penalty, (NRC Inspection Report 50-285/88-15 EA 88-145)
III-9 Licensee Event Report 50-285/88-028 dated November 22, 1988, Failure of YCV-1045A Instrument Air Check Valve (LIC-88-1010) 111-10 Letter from OPPD (K. J. Morris) to NRC (J. Lieberman) dated November 15, 1988, Response to Notice of Violation and Proposed Imoosition of Civil Penalty. (NRC Inspection Report 50-285/88-15 EA 88-145) (LIC-88-994)
III-11 Licensee Event Report 50-285/88-032 Revision 1, dated February 2, 1989 (LIC-89-094)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
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Omaha Public Power District
)
Docket No. 50-285 (Fort Calhoun Station
)
Unit No. 1)
)
AFFIDAVIT W. G. Gates, being duly sworn, hereby deposes and says that he is the Manager -
Fort Calhoun Station of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached information concerning the response to NRC Generic Letter 88-14; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information, and belief.
- 6 W. G. Gates Manager - Fort Calhoun Station STATE OF NEBRASKA)
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ss COUNTY OF DOUGLAS)
Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this alak day of February,1989.
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U. S. Nuclear Regulatory Commission LIC-89-098 ATTACHMENT 1 Response to Generic Letter 88-14 The NRC Generic Letter 88-14 " Instrument Air Supply System Problems Affecting i
Safety Related Equipment," addresses three specific concerns and requests information as to the licensee's actions or projected actions to address these concerns. The following is a summary of OPPD's actions to the concerns addressed in the Generic Letter.
Further details of actions taken may be i
obtained by review of the referenced correspondence.
Concern 1.
Verification by test that the actual instrument air quality is consistent with the manufacturer's recommendations for individual components served.
Resoonse The design basis for instrument tic ip ality at Fort Calhoun Station is based on the dewpoint.
In addition to verif Y _ tion that the recommended dewpoint is being met, OPPD has addressed other ereas where concerns could arise.
A.
Dew Point Samplina Proaram - This program was implemented in the third quarter of 1987 to provide a means to ensure that the instrument air dew point was maintained below the USAR design value of -20' F.
A Nse-line program was first established to verify that the overall system was being maintained at the required dew point. Upon completion of the base-line program, sampling at the outlet of the air dryer was initiated on a weekly basis on each dryer tower to ensure that the system continued to stay at the required dew point.
In addition, a humidity indicator, which is monitored each shift, has been installed on the dryer outlet to allow quick identification of dryer problems. The dryer normally maintains system dew point below -30' F.
This dew point fully meets the recommendations of ANSI /ISA S7.3-1975.
An on-line dew point analyzer is scheduled to be installed into the system during the 1989 operating cycle in conjunction with a new air drying system.
Reference II-7, page 1.15.
B.
Particulate Filterina - Prior to the 1988 refueling outage, the installed system particulate filters prevented particles any larger than 20 microns from entering the instrument air system from the air compressors or the air dryer.
The 20 micron filters on the outlet of the air dryer were replaced with 3 micron filter elements to meet the recommendations of ANSI /ISA S7.3-1975.
A review of the safety related valves has been conducted to ensure that Critical Quality Element (CQE) Valve operators are protected by locally installed filters or filter regulators nominally rated at 35 microns. A l
modification to install filters on safety related valves identified as lacking local filters was completed during the 1988 outage
]
(MR-FC-88-089).
Reference Il-7, Page 1.39.
1 1
U. S. Nuclear Regulatory Commission LIC-89-098 C.
Oil /0ther Contaminates - Extensive walkdowns of the Instrument Air System I
were completed in order to determine interfaces with other systems. No significant potential for contamination intrusion has been determined as a result of these walkdowns.
In addition, the air compressors at Fort l
Calhoun Station are " oil-less" type compressors which do not require oil in the cylinders for lubrication and therefore oil in the Instrument Air System is not a concern.
The previously discussed testing and upgrades ensure that the system meets the manufacturer recommendations and USAR design requirements for operation of the installed equipment.
2
U. S. Nuclear Regulatory Commission LIC-89-098 Concern 2.
Verification that maintenance practices, emergency procedures, and training are adequate to ensure that safety-related equipment will function as intended on loss of instrument air.
1
Response
l t
A.
Maintenance Practices and Inspections 1.
Uoarade of Preventive Maintenance (PM) Proaram - A review of the l
Instrument Air System was conducted by two independent consultants to evaluate the overall maintenance and operation of the system. As a I
result of this review, a number of changes to the existing PM progrtm have been initiated to provide an increased level of re' liability cf the system.
Examples of these changes include desiccant replacement every refueling outage, increased preventive maintenance on the air dryer, and the addition of air regulators on safety related air operated components to the PM program.
Reference Il-7, pages 1.10, 1.11, 1.12., 1.13.
2.
Inservice Insoection Proaram - An update to the Inservice Testing Program has been submitted to the NRC to include valves related to the Instrument Air System which were not previously considered to be within scope of the ISI Program.
This update included air check valves to safety related accumulators.
Surveillance tests for these valves have been developed, and testing is being conducted during the appropriate surveillance test period.
Functional testing of safety related air accumulators was conducted during the 1988 refueling outage.
Reference II-7, page 1.34.
3.
Valve Operator Teardown Proaram - A program to inspect and rebuild a sample set of air operators to determine damage from the July 1987 water intrusion event at Fort Calhoun Station was completed. The scope of the teardown effort examined air risers that were affected by the water intrusion event, and selected a representative sample of the various models of actuators installed. This program assessed the long term impact on the system as a consequence of the event.
It was determined that no long term detrimental impact occurred on system operability due to the water intrusion event.
In parallel with the teardown program was a program to stroke on a monthly basis, those air operated ISI valves which had a test frequency of quarterly, and to stroke a selected sample of water affected valves.
The addition of valves to the ISI program and the upgrade of the PM program will ensure the continued operability of air operated components.
Reference II-7, page 1.29.
3
U. S. Nuclear Regulatory Commission LIC-89-098 It is expected that the previously discussed enhancements to maintenance practices with regard to the Instrument Air System will ensure that air supplied equipment will continue to function as required.
B.
Emergency Procedures 1.
Abnormal Operatina Procedure (AOP) Review - A thorough review of AOP-17 " Loss of Instrument Air" was conducted to ensure that the procedure meets operator needs in the event of a loss of instrument air, This upgrade included the addition of valves that are required to function with accumulator air supplies, failure positions on important air supplied valves, and feedback from operators concerning their experience with previous revisions to ensure consistency between the installed system and the A0P.
Reference II-7, page 1.27.
2.
Emeraency Plan Imolementina Procedure (EPIP) Unarade - A review of EPIP-OSC-1 " Emergency Classification" and upgrade as necessary was completed to include consideration of common mode failures into the condition of a Notification of Unusual Event (NOVE) Classification.
A condition has been included in EPIP-0SC-1 to initiate a NOUE in the event of water intrusion into the instrument air.
Reference II-7, page 1.22.
3.
Development of Operatina Instructions (0I) for Hiah Dew Point -
Instructions to address specific operator actions required to correct a dew point reading greater than -20' F have been developed and incorporated into 01-CA-1 " Compressed Air System - Normal Operation."
Reference II-7, Page 1.8.
C.
Training Plant operating staff (licensed and non-licensed) have been trained on revisions to A0F-17 during requalification classes. Additional training has been provided to operators on the following items by classroom discussion and/or individual review to emphasize the importance of the instrument air system.
1.
LER-87-025, "DG-2 Shutdown on High Coolant Temperature," Reference I-3.
2.
LER-87-033, " Water Intrusion Into Air System," Reference I-9.
3.
NRC Inspection Reports 50-285/87-27 and 50-285/87-30 Additional training has been given to operating shifts (eg. operators, STA's) on the upgrade of EPIP-0SC-1.
4
U. S. Nuclear Regulatory Commission l
LIC-89-098 Concern 3.
Verification that the design of the entire instrument air system
'I including air or other pneumatic accumulators is in accordance with its intended function, including verification by test that l
air-operated safety related components will perform as expected in-accordance with all design-basis events, including a loss of the normal Instrument Air System. This design verification should include an analysis of current air operated component failure positions to verify that they are correct for assuring tafety functions.
A.
Air System Desian Review - A design review of the failure position of air operated safety related valves has been conducted to ensure that one of the following conditions are satisfied:
- 1. valves fail in the " safe" position in a design basis event, 2. are backed up by safety related accumulators, or 3. safety functions are satisfied.
Results of this design review are being evaluated and will be ccmplete by June 1,1989.
B.
System Functional Insoection - OPPD has completed an Instrument Air System Functional Inspection. The purpose of this review was to confirm operability and design adequacy of the Instrument Air System and safety related coinponents served by the Instrument Air System. This inspection included a review of maintenance, testing, and training that has been conducted on the Instrument Air System.
i Reference II-7, pages 1.16, 1.37.
C.
Desian Basis Reconstitution - Reconstitution of the Instrument Air System design basis has been included in the scope to the Fort Calhoun Design Basis Reconstitution Project. The development of the Design Basis Document for the Instrument Air System is complete.
4 Reference II-7, page 1.38.
D.
Air Accumulator Desian Review - In response to Reference 11-2, an analysis was conducted to verify the design requirements of safety related air accumulators.
These design requirements include time requirements for accumulator operability and valve operability requirements following a design basis event. This effort is complete, and functional requirements for safety related air accumulators have been established.
Reference II-7, page 5.1 E.
Functional Testino of Safety Related Air Accumulators - Functional testing of the safety related air accumulators was completed during the 1988 refueling outage. The purpose of this testing verified that the accumulators will meet their design requirements. This testing included
" fast" and " slow" loss of air testing as recommended in Regulatory Guide 1.68.
Reference II-7, page 5.1 5
U. S. Nuclear Regulatory Commission LIC-89-098 F.
Seismic Qualification of Safety Related Air Accumulators - Calculations to verify the seismic qualifications of CQE air accumulators were submitted in
]
references 11-3 and 11-4.
Several accumulators located inside of I
containment which could not be verified while the plant was in power j
operation were reviewed during the 1988 outage. A modification was i
I completed on these accumulators during the outage to complete their seismic qualifications.
Reference II-7, page 8.1 Verification of the design of the Instrument Air System at Fort Calhoun Station to ensure that the system will operate as required is complete.
Verification included a System Functional Inspection and system walkdowns to prove operability of the Instrument Air System following the water intrusion event.
Valve operator teardowns, and monthly cycling of a selected sample of valves affected by the event found no evidence of adverse effects from either water exposure or the potential exposure to high humidity.
The reconstitution of the design basis of the Instrument Air System, along with the various design reviews which were conducted on the air system ensure that design requirements are being met. The functional testing which was conducted during the 1988 outage, along with the addition of valves to the ISI program and the PM program upgrade will ensure the continued operability of the system.
The items remaining to be completed, Quality Assurance Deficiency Reports generated in response to the System Functional Inspection and open items identified in the Design Basis Reconstitution, have been evaluated to determine their impact on plant safety and resolution of immediate concerns is complete.
6
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T Umaha Public Power District 1623 Harney Ornana. Nebraska 68102 2247 402/536 4000 i
q April 27,1988 LIC-88-165 Docket No.-50-285 Mr. James Lieberman, Director Office of Enforcement U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
- i
References:
See Index provided on Pages 3 and 4 of this cover letter
Dear Mr. Lieberman:
SUBJECT:
Response to Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Report 50-285/87-27 EA 87-210)
Omaha Public Power District (OPPD) received the Notice of Violation and Pro-posed Imposition of Civil Penalty, Reference 16, dated February 22, 1988.
The Notice of Violation involved three Level III violations resulting from the findings of.the Instrument Air System Inspections, References 2 and 12. As a result of these inspections an enforcement conference was held in Arlington, Texas-on October 29, 1987, and meetings were held in Bethesda,. Maryland on November 5 and 13, 1987.
OPPD acknowledged the violations and previously submitted payment of the civil penalty on March 22, 1988 (Reference 17). A three week extension for the response to the Notice of Violation was discussed with Region IV to address the' more general programmatic improvements being taken by 0 PPD. On April 8, 1988 Region IV personnel were briefed by OPPD on the status of the Instrument Air corrective actions.
During that meeting, OPPD requested and received a second extension to April 26 in order to update the response to Violation B.3 to address the clarification provided at the meeting and to verify information to be included in the response. A follow-up phone call between Mr. Jim Fisicaro of my staff and Mr. Tom Westerman of Region IV established the submittal date of April 27.
Accordingly, please find attached as Attachments 2, 3 and 4, OPPD's response to the Reference 2 violations pursuant to 10 CFR Part 2.201.
In addition to responding to these violations, a summary of the Status of Actions Related to Previous Commitments is presented in Attachment 1 to demonstrate that actions are completed or in progress which supplement the corrective actions presented in the violation responses. The status of air accumulator and check valve testing is presented in Attachment 5.
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James Lieberman LIC-88-165 Page 2 Based on all actions taken to date, as described in Attachments 1, 2, 3 and 4, the Omaha Public Power District is confident that the Instrument Air System at Fort Calhoun Station is being properly maintained and is operationally ready to meet design requirements in response to plant events.
Our procedures, person-nel, supporting evaluations, design and surveillance of the system support these conclusions.
Furthermore, management initiatives toward improvement in design evaluations, safety awareness, deportability and corrective action pro-grams are additional assurance that major concerns identified as a result of the July 6 water intrusion event have been resolved.
Planned and future actions will strengthen this confidence.
Also provided is the schedule for Instrument Air System modifications (Attach-ment 7). The modifications arise from the concerns associated with previously identified SS0MI instrument air concerns and water intrusion event corrective actions. Attachment 6 updates information on ISI testing of valve operators which was previously provided in Reference 8. provides additional seismic information to supplement information on HCV-238 and HCV-239 previously provided in Reference 9.
Status of Actions Related to Previous Commitments Response to Violation A - Design Evaluation Response to Violation B - Design Implementation and Classification / Reporting Response to Violation C - Corrective Action SSOMI Concerns Related to the Instrument Air System Update of the Inservice Inspection Program Plan -
Schedule for Instrument Air System Modifications Additional Seismic Information
)
Should you have any questions concerning this matter, please contact us.
l Sincerely, R. L. Andrews Division Manager Nuclear Production RLA/bjb c:
R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036
James Lieberman LIC-88-165 Page 3 REFERENCE INDEX
- 1. Docket No. 50-285
- 2. Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated October 23, 1987, Insoection Reoort 50-285/87-27
- 3. Licensee Event Report 50-285/87 025 dated October 23, 1987 (LIC-87-720)
- 4. Letter from 0 PPD (R. L. Andrews) to NRC (R. D. Martin) dated November 4, 1987, Instrument Air System at Fort Calhoun Station (LIC-87-744)
- 5. Letter from NRC (A. Bournia) to 0 PPD (R. L. Andrews) dated November 9, 1987, Summary of Meetina Held on November 5.1987 in Bethesda. Maryland
- 6. Letter from NRC (R. D. Martin) to OPPD (R. L. Andrews) dated November 10, 1987, Summary of Enforcement Conference Held October 29. 1987 in Arlinaton.
- 7. Letter from NRC (A. Bournia) to OPPD (R. L. Andrews) dated November 13, 1987, Summary of Meetina Held November 13. 1987 in Bethesda, Maryland
- 8. Letter from OPPD (R. L. Andrews) to NRC (J. A. Calvo) - dated November 20, 1987, Summary of Meetina with NRC Held November 13. 1987. Reaardina the Instrument Air System at Fort Calhoun Station (LIC-87-783)
- 9. Letter from OPPD (R. L. Andrews) to NRC (J. A. Calvo) dated November 20, 1987, Submittal of Seismic Qualification Calculations and Reoort for COE (Safety Related) Air Accumulators (LIC-87-790)
- 10. Letter from OPPD (R. L. Andrews) to NRC (J. A. Calvo) dated November 25, 1987, Seismic Qualification Information for the Valves Associated with the Air Accumulators Discussed in LIC-87-790 dated November 20. 1987 (LIC-87-803)
- 11. Licensee Event Report 50-285/87-033 dated November 25, 1987 (LIC-87-854)
- 12. Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated December 10, 1987, insoect_ ion Reoort 50-285/87-30
- 13. Licensee Event Report 87-025 Revision 1, dated December 15, 1987
- 14. Letter from NRC (J. A. Calvo) to OPPD (R. L. Andrews) dated December 15, 1987, Water Intrusion into Instrument Air System
- 15. Letter from OPPD (R. L. Andrews) to NRC (Document Control Desk) dated i
December 16, 1987, Review of Fort Calhoun's ISI Proaram (LIC-87-806)
I (references continued on next page) l l
l
James Lieberman LIC-88-165 Page 4
- 16. Letter from NRC (R. D. Martin) to OPPD (R. L. Andrews) dated February 22, 1988, Notice of Violation and Proposed Imoosition of Civil Penalty (NRC Inspection Report 50-285/87-27)
- 17. Letter from 0 PPD (R. L. Andrews) to NRC (J. Lieberman) dated March 22, I
1988, Submittal of Civil Penalty (LIC-88-202)
- 18. Letter from NRC (J. M. Taylor) to OPPD (B. W. Reznicek) dated January 21, 1986, Safety System Outaae Modification Insoection (Installation and Test) l 50-285/85-29 j
- 19. Letter from 0 PPD (R. L. Andrews) to NRC (J. T. Taylor) dated April 10, 1987, Resoonse to Notice of Violation and Proposed Imoosition of Civil Penalty, (NRC Inspection Reports No. 50-285/85-22 and No. 50-285/85-29 (LIC-87-086)
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' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.
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l In the Matter of
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)
Omaha Public Power District
)
Docket No. 50-285 (Fort Calhoun Sta ?n
)
Unit No. 1)
)
AFFIDAVIT R. L. Andrews, being duly sworn, hereby deposes and says that he is the Division Manager - Nuclear Production of the Omaha Public Power District; that as such he is duly authorized to sign and. file with the Nuclear Regulatory Commission the response to Notice of Violation and Proposed. Imposition of Civil Penalty (NRC Inspection Report 50-285/87-27) (EA 87-210); and that he.is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information, and belief.
R. L. Andrews Division Manager Nuclear Production STATE OF NEBRASKA)) 'ss COUNTY OF DOUGLAS)
Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this 11
- day of April,1988.
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AL Notary Public N
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STATUS OF ACTIONS RELATED TO PREVIOUS COMMITMENTS l
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ATTACIMENT 1 1
STATUS OF ACTIONS RELATED TO PREVIOUS COMITMENTS i
i The purpose of this section is to present the status of specific actions and update commitments made in Reference 8.
The actions summarized in this section are examples of improvements in the operation and management of the Instrument 1
Air System and Fort Calhoun Station.
These examples may not be directly related to the violation cited in Reference 16 or OPPD's responses in this sub-mittal, Attachments 2, 3 and 4.
These are additional actions which supplement
{
the corrective actions presented in the responses to the violation responses.
The results achieved by these actions provide high assurance of operability of the Instrument Air System.
A system functional inspection was conducted which confirmed the operational readiness and design adequacy.
This inspection included a review of mainten-ance, testing and training for the Instrument Air System components and safety related components served by the Instrument Air System.
Only one concern, as a result of this inspection, was safety significant.
It was subsequently report-ed and corrective action was taken.
Corrective actions are being taken on other non-safety related findings.
Instrument Air Operating and Abnormal Operating. procedures have been reviewed and upgraded to be more accurate and complete.
Instructions within 0I-CA-1 now provide operator action to be taken should dew point readings exceed specifications.
On-going surveillance of the Instrument Air System indicates there has been no degradation of components or system function.
Weekly readings of dew point temperatures consistently indicate approximately
-50*F.
Recent operator teardowns of components known to be wetted, have found no evi-dence of significant corrosion, even though water has been found in 25 percent of the valve operators surveyed.
Data is being collected and monitored to trend valve operator performance.
No significant degradation of stroke times has been observed.
Particulate monitoring has shown no noticeable increase in the quantity of particulate in the Instrument Air System.
Check valve testing verifies the operability and integrity of all testable instrument air check valves on accumulators serving a safety function. Check valves and accumulators which cannot be tested on-line have been evaluated for inoperable consequences considering existing additional design and operational factors which support continued safe operation.
An evaluation has been conducted which concludes that valves utilizing an internal diaphragm and tank level instruments using bubblers do not have a potential to cause water intrusion into the Instrument Air System.
1.1
1 The summaries in this section reflect the progress toward resolving concerns and implementing improvements as identified by OPPD and the NRC prior to the Notice of Civil Penalty (Reference 16).
These summaries include actions, complete or nearly completed.
Tasks listed under Section A, Instrument Air System Specific, provide further assurance that the Instrument Air System is today being properly maintained operational with procedures, personnel and supporting evaluations.
Initiatives which relate to aspects beyond the Instrument Air System are described under the heading of Section B, Managerial Improvements.
The status of other instrument air commitments related to the SSOMI findings (Reference 19) are summarized in Attachment 5.
The effectiveness of corrective actions has been and will continue to be assessed. This is evidenced by the fact that some completed items have hr.d initial corrective actions upgraded.
Further information and details on the breadth and scope of these actions is available if requested.
I.
ITEMS COMPLETE A.
INSTRUMENT AIR SYSTEM SPECIFIC 1.
Operational a.
Assignment of System Engineer 2.
Procedural Procedure Change to MP-FP-7 to Ensure Check Valve Operability a.
b.
Review of IAS Operating Procedures c.
Upgrade Incident Reporting Process d.
Development of Operating Instructions for High Dew Points e.
Instrument Air System Line-up/ Tag Out 3.
Maintenance a.
Preventive Maintenance Program Upgrade b.
Air Dryer Desiccant Replacement c.
Revise Air Dryer Preventive Maintenance Schedule 4.
Surveillance Preventive Maintenance / Surveillance Testing of Air Operated a.
Dampers b.
Particulate Monitoring Program c.
Dew Point Sampling Program l
l l
1.2 L________-__--_
5.
Evaluations a.
System Functional Inspection b.
Evaluation of Interface Valves and Bubblers Consideration of Check Valve Failures in the Safety Analysis c.
for Operability 6.
Engineering a.
Common Mode Failure Consideration B.
MANAGERIAL IMPROVEMENTS 1.
Evaluations a.
SARC Evaluation of the Water Intrusion Event b.
Event Investigative Team 2.
Reporting Emergency Plan Implementing Procedure (EPIP) Upgrade a.
b.
Safety Analysis for Operability (SAO) 3.
Personnel a.
Employee / Management Conferences 4.
Procedures Policy Statement Concerning Equipment Operation by a.
Non-Operators II.
ITEMS IN PROGRESS A.
INSTRUMENT AIR SYSTEM SPECIFIC
- 1. Operational Additional Walkdowns of Instrument Air System a.
j 2.
Procedures 1
a.
Abnormal Operating Procedure (AOP-17)
Upgrade in Accordance with Writers Guide 3.
Maintenance Clean / Flush the Instrument Air System a.
b.
Valve Teardown Program 1.3 1
4.'. Surveillance n.
Testing of CQE Non-ISI Valves
).
Monthly Valve Cycling for Inservics Test Program -
Cycling of Inservice Inspection (ISI) Valves c.
d.
Inservice Inspection Program 5.
Engineering a.
Diesel Generator Air Damper Replacement b.
Assessment of Instrument Air System Design to Current Industry Standards c.
System Functional Inspection - Follow-up d.
Development of Instrument Air System Design Basis Documentation Identification and Installation of Air Filter Additions for e.
Valve Operators and Air Dryer f.
Removal of Plant Air System and Fire Protection System Crosstie B.
MANAGERIAL IMPROVEMENTS 1.
Evaluations Nuclear Operations Plan Development and Appraisal a.
b.
Instrument Air Steering Committee 2.
Training General Employee Training (GET) Upgrade for Safety Awareness a.
b.
Additional Field Observation Training c.
Upgrade of Lesson Plans d.
'-Job Briefings for Surveillance Tests f
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l' TITLE:
Assignment of System Engineer DESCRIPTION:
Assign one experienced individual the responsibility for coordinating design changes, operations, maintenance, testing, performance trending and other aspects of the Instrument Air System.
l STATUS:
One individual was assigned as Instrument Air System Engineer in December 1987. Assignment responsibilities include, but are not limited to, coordination of operation, maintenance, testing, and modification of the Instrument Air System.
Additional enhancements are in progress, i.e. position descriptions, formalized system specific training and assignment of systems engineers to other systems.
RESULTS ACHIEVED: The individual assigned to the Instrument Air System is involved in daily and routine performance, operation, maintenance and testing of the Instrument Air System.
He is utilized as the coordinator of resources applied to the system and maintains an overview of planned enhancements.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.1.a Instrument Air Project No. I.C.13 I
I 1.5 j
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TITLE:
Procedure Change to MP-FP-7 to Ensure Check Valve Operability l
DESCRIPTION:
A change to MP-FP-7, Resettino of Diesel Ory Pioe Deluae Valve after Trio or Testina, was necessary to ensure that I
check valves in the compressed air system are inspected /re-1 paired after each actuation of the deluge valve. These l
check valves were previously the isolation devices between the Fire Protection and Instrument Air Systems, but were disconnected from the Instrument Air System in October 1987.
and reconnected to the plant air system.
STATUS:
A procedure change to MP-FP-7 was prepared, reviewed, approved and fully implemented to ensure proper reset of deluge valve after actuation.
RESULTS ACHIEVED:
Procedure now provides proper instructions for check valve reset after trip.
COMPLETION STATUS: This task is complete.
t Submittal Item Number I.A.2.a Instrument Air Project No. I.B.1 1.6
l TITLE:
Review of Instrument Air System Operating Procedures f
DESCRIPTION:
Initiate and complete a review and upgrade Instrument Air System operating procedures to assure that plant operators are provided with clear, concise procedures.
STATUS:
The Instrument Air System procedures, 01-CA-1, 2 and 3 were reviewed and upgraded as appropriate in accordance with existing procedure change requirements.
RESULTS ACHIEVED:
Procedures are accurate and complete.
Application of criteria from a Procedure Writers Guide will assure format uniformity (see Item II.A.2.a).
COMPLETION STATUS: This task is complete.
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l Submittal Item Number I. A.2.b 1
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Instrument Air Project No. I.A.16 l
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TITLE:
Upgrade Incident Reporting Process DESCRIPTION:
Review the operating incident reporting process and upgrade I
the plant incident reporting system to provide prompt determination of the safety significance of an incident.
STATUS:
Standing Order R-4, Station Incide,it Reports, was revised to reflect upgrades on shift safety assessment and evaluation of deportability of events and occurrences. Additionally, the responsibilities of the Shift Technical Advisor in per-forming analysis of off-normal events are explicitly defined in the revision.
Previously, this function was informally accomplished.
The majority of events and findings, e.g. discovery of situations where the design basis is exceeded, occur during normal working hours. These have been promptly evaluated for safety significance, operability and corrective actions by the plant management and staff and then reported under criteria of 10CFR 50.72 or 50.73.
These events and findings also initiate the provisions of Standing Order R-4 including safety assessment and evaluation.
RESULTS ACHIEVED:
Personnel have achieved an increased level of awareness concerning plant safety and the significance of events as evidenced in timely safety evaluations and a reduced threshold of deportability.
COMPLETION STATUS: This task is complete.
1 Submittal Item Number I.A.2.c Instrument Air Project No. I.C.3 1
1.8
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TITLE:
Development of Operating Instructions for High Dew Point l
DESCRIPTION:
Instructions were required to identify actions to be taken in the event of determination of high moisture content in the Instrument Air System.
STATUS:
Instructions, contained in 01-CA-1, have been developed and issued. These instructions address specific operator actions required to correct a dew point reading greater.than
-20*F.
Operator training is complete.
RESULTS ACHIEVED:
Guidance has been provided concerning operator actions required for out of specification dew point readings.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.2.d Instrument Air Project No. - None 1.9
TITLE:
Instrument Air System Line-up/ Tag Out DESCRIPTION:
Review existing administrative procedures related to In-strument Air System lineup and assure that the system-components are appropriately tagged with control tags to prevent inadvertent operation of a component causing' undesired results.
Review and upgrade the administrative procedure or field control tagging if required.
STATUS:
Based on a complete Instrument Air System walkdown outside of Containment in November 1987, the system was determined to be properly labeled.
Review of administrative procedures (Standing Order 0-20) indicated that the procedure was satisfactory as issued.
RESULTS ACHIEVED:
System component tagouts and administrative procedures have been verified as adequate.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.2.e Instrument Air Project No. I.A.19 i
1.10
' TITLE:
Preventive Maintenance Program Upgrade DESCRIPTION:
Conduct a review of the preventive maintenance program for the Instrument Air System to determine what additional Preventive Maintenance Surveillance are required.
STATUS:
A review of the existing Preventive Maintenance Procedures was conducted through inspections performed by experienced industry consultants.
Field observations were also made, and based on the recommendations made by the consultants, additional preventive maintenance activities have been incorporated into the Instrument Air Preventive Maintenance Program to assure adequate Preventive Maintenance Procedures are in place.
RESULTS ACHIEVED:
These reviews and observations resulted in development of an accurate dew point measurement method and a dew point mea-surement procedure.
Further, the' frequency and thoroughness of Instrument Air System Preventive Maintenance has been subsequently improved.
The revision of the air. dryer Pre-ventive Maintenance Schedule (Item Number I.A.3.a in this section) is an outcome of this review.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.3.a Instrument Air Project No. I.A.4 1.11
TITLE:
Air Dryer' Desiccant Replacement DESCRIPTION:
Replace desiccant in~ air dryer.
. STATUS:
After the September 1987 diesel generator shutdown incident, the desiccant in the air dryers was replaced to insure reduced moisture content in the Instrument Air System.
Desiccant replacement will be performed each refueling outage by Preventive Maintenance procedure PM-TXDB.
RESULTS ACHIEVED:
Instrument air low moisture content is being verified by dew point sampling program.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.3.b Instrument Air Project No. - None l
1.12
TITLE:
Revise Air Dryer Preventive Maintenance Schedule DESCRIPTION:
Increase the frequency of preventive maintenance on the instrument air dryer in order to increase its reliability.
STATUS:
Preventive Maintenance procedure PM-UXHV now requires inspec-tion and lubrication if required of instrument air dryer
' components to be performed biweekly.
Prior to December 1987, this procedure was performed on a quarterly basis.
Preventive Maintenance procedure PM-TXDB has been revised to provide for desiccant replacement rather than inspection every refueling outage.
RESULTS ACHIEVED:
Increased emphasis on preventive maintenance on air dryer.
COMPLETION DATE:
This task is complete.
Item Number I.A.3.c Instrument Air Project No. - None 1.13
l TITLE:
Preventive Maintenance / Surveillance Testing of Air Operated Dampers DESCRIPTION:
Include in the preventive maintenance or surveillance test program eight air operated dampers or the diesel generators.
STATUS:
The eight diesel generator air dampers were evaluated regard-ing the need for preventive maintenance and/or cycling to maintain maximum reliability.
The radiator exhaust damper valves, YCV-871E and YCV-871F, are being cycled monthly and stroke times are being trended. A preventive maintenance procedure has been developed and implemented to blowdown the associated accumulators on a quarterly basis.
The six inlet air damper valves, YCV-871-A/B/C/D/G/H, are cycled moathly during the diesel generator surveillance test to verify operability.
RESULTS ACHIEVED:
Verification of satisfactory operation of all diesel gener-ator inlet and exhaust air dampers.
COMPLETION STATUS: Full implementation is complete.
Submittal Item Number I.A.4.a Instrument Air Project No. I.A.11, I.A.23 1.14
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- TITLE:
Particulate Monitoring Program DESCRIPTION:
Develop a program to analyze system particulate.
STATUS:
A particulate monitoring procedure was developed and imple-mented.
Based on an evaluation of samples taken and filter inspections conducted in October and November 1987, it has been concluded that a continuing program for further parti-culate monitoring is not necessary.
Samples and filters showed a low corrosion product concentrate resulting from 15 i
years of operation, including the period between July 6 and sample / inspection dates.
Since October 1987, dew points have been well within design limit and thereby minimizing or eliminating additional corrosion.
A particulate sample collected in March 1988 confirmed this conclusion.
Particu-l late quantity will continue to be observed by I&C techni-cians as they perform routine preventive maintenance on the Instrument Air System and replace filters on regulators.
RESULTS ACHIEVED:
No noticeable increase in the quantity of particulate in the Instrument Air System has been observed at a result of water intrusion.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.4.b Instrument Air Project No. I.A.7, I.A.8 l
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1.15 L__-__----------
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TITLE:
Dew Point Sampling Program l
DESCRIPTION:
Establish a sampling program to verify system dew points are j
within system tolerances.
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STATUS:
In November of 1987 a baseline program r.onsisting of eigh-teen sample points on risers affected by the water intrusion event was performed for a-period of three weeks to verify l
that the system was being maintained below -20*F. A contin-uing program of weekly sampling of the dryer outlet for each dryer tower has been established as part of the Chemistry Sampling Program.
In addition, a temporary gross dew point indicator, moni-tored each shift, has been installed at the dryer outlet to provide indication of a dryer failure.
A permanent, on-line dew point analyzer is being evaluated as part of a modifi-cation to upgrade the instrument air dryer to utilize current air dryer technology.
RESULTS ACHIEVED: An ongoing dew point sampling program is in place and will continue. Weekly readings taken to date indicate dryer out-let dew points of approximately -50*F and that the moisture resulting from the July 6 event has been eliminated from the air lines.
COMPLETION STATUS: The commitment to establish a sampling program is complete.
The program is ongoing and may change in the future subject to future monitoring equipment improvements and information gained as the program proceeds.
Submitt al Item Number I. A.4.c Instrurient Air Project No. I. A.5, I.A.6 1.lf
_ _ _ - _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
L TITLE:
System Functional Inspection DESCRIPTION:'
Initiate a system functional inspection to confirm oper-ational readiness and design adequacy including review of maintenance, testing and training for the Instrument Air System and safety related components served by the Instru-ment Air System.
STATUS:
OPPD has completed an Instrument Air System (IAS) System Functional Inspection.
Results have been issued and re-viewed. As a result of this inspection issues have been-identified and are currently under OPPD review and sche-duling for implementation. A number of these issues identified such concerns us dew point testing, periodic testing of air accumulators and the assignment of an Instrument Air Systems Engineer th;t have been implemented.
The remaining items are being reviewed and scheduled for implementation.
Deficiency / Quality Reports have been issued to track the completion of corrective actions resulting from the inspection.
Several of the issues identified by the inspections were incorporated into other tasks associated with the Instrument Air System.
RESULTS ACHIEVED:
The system functional inspection identified concerns which have been reviewed. Only one was determined to have safety significance. This item was the failure position of the con-tainment isolation valve for Instrument Air, PCV-1849.
This item was evaluated, reported under 10CFR 50.72 and correc-tive actions taken to assure continued safe operation.
COMPLETION STATUS: This task is complete.
Refer to Submittal Item II.A.5.c for follow-up of SFI concerns.
i Submittal Item Number I.A.5.a Instrument Air Project No. I.A.15 1
i 1.17 x
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TITLE:
Evaluation of Interface Valves and Bubblers DESCRIPTION:
An evaluation of interface valves (utilizing an internal diaphragm) and bubblers (tank level instruments) was necessary to determine their potential for allowing water intrusion into the Instrument Air System.
STATUS:
An evaluation was performed.
Results from this evaluation are presented in the response to Violation C in this submittal. The evaluation, based on records and filed, is complete, however, a future walkdown of the Instrument Air System is planned by the System Engineer to assure that all interface valves and bubblers have been identified in this evaluation (see Item II.A.1.a).
RESULTS ACHIEVED:
Interface valves and bubblers were determined to not be a concern with respect to water intrusion into the Instrument Air System. There have been no instrument air / water inter-faces identified which present a possibility of water intru-sion into the Instrument Air System.
Water intrusion is pre-vented by pressure differences, as is the case for bubbler monitors of tank level, or would require multiple failures to occur in conjunction with pressure differences, as in the case of diaphragm valves.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.5.b Instrument Air Project No. - None 1.18 i
l TITLE:
Consideration of Check Valve Failures in the Safety Analysis for Operability (SAO)
DESCRIPTION:
Consider check valve failure in the SAO for CQE valves that cannot be cycled during plant operation.
STATUS:
SAO developed and approved in October, 1987 based on the scope of valves identified at that time. A revised SAO, based on additional valve cycling, was approved in Novem-ber. An engineering evaluation (SAO) has been revised to include the. components identified-by Operations Support Analysis Report (0SAR) 87-10.
As of April 27, 1988, all safety related air accumulator check valves had been or are in the process of being tested or their accumulator / check valve function was fulfilled by a N2 jumper except for HCV-238, HCV-239, HCV-240, YCV-871E and YCV-871F. The check valve associated with these valves have been included in the-safety analysis for operability and will be modified and/or tested during the 1988 refueling outage.
RESULTS ACHIEVED:
SAO consideration of check valve failure was_ not required since the check valves were either tested to verify operability or a SA0 already existed which did not rely on check valve operability.
COMPLETION STATUS: This task is complete.
Submittal Item Number I.A.5.c Instrument Air Project No. I.A.26 1.19
TITLE:
Common Mode Failure Consideration DESCRIPTION:
. Revise and upgrade engineering procedures to assure that modifications formally address potential common mode failures including combined operator, procedural or equipment deficiencies.
l STATUS:
The GSE Engineering Manual, Section GEG-3, Preparation of I
Desian Packaces, was written to provide design engineers guidance for preparation of proposed design modification packages. This procedure is applicable to all propoced design change packages at Fort Calhoun Station.
Further
. status description of this action is described in response to Violation A in this submittal.
RESULTS ACHIEVED:
Procedures have been implemented so that proposed station design modifications now specifically include consideration for potential common mode failures.
COMPLETION STATUS: This task is complete.
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l Item Number I.A.6.a Instrument Air Project No. I.C.5 1.20 L-___--_------------_----------------
l TITLE:
'SARC Evaluation of the Water Intrusi6n Event' DESCRIPTION:
A special. working group of the Safety _ Audit' Review Comittee (SARC) conducted an independent' assessment'of the events and circumstances.before, during and after the July 6,1987
- water. intrusion event.
STATUS:
The Safety tudit and Review 'Comittee ' chairman ~ and two con-sultants, both previous Fort Calhoun Station plant managers, were assigned to'this working group.
This group developed observations and general' conclusions dealing with comuni-cation, training, procedure's and programs.
The' report was completed in December 1987.
OPPD's~ response to this report was completed in January 1988.
Both the report.and. response were discussed in the January 1988 SARC meeting.
RESULTS ACHIEVED:
OPPD's internal critique identified several. areas ~where longer term programmatic improvements are necessary.
There were no further violations or reportable events identified.
OPPD is taking action to enhance plant operation and further-eliminate causes related to the water intrusion event.
In response to this report, OPPD developed and. initiated action en specific action items.
COMPLETION STATUS: This task is complete.
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1 Submittal Item Number I.B.1.a Instrument Air Project No. - None i
1.21
TITLE:
Event Investigative Team DESCRIPTION:
Evaluate the feasibility and use of an event investigation team which.could be utilized to provide in-depth investi-gation of any event at the Fort Calhoun Station.
-STATUS:
A Nuclear Production. Division Quality Procedure, QP-18, to initiate a Management. Investigative Safety Team (MIST), has been issued.
The purpose of this policy is to charter a team, composed of key management personnel, to be respon-sible for collecting and preserving data, analyzing event significance and identifying root cause.
RESULTS ACHIEVED:' The Nuclear Production Quality Procedure was recently issued and has not had an occasion for implementation. The effec-tiveness of this procedure remains to be demonstrated.
COMPLETION STATUS: This task is complete.
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i Submittal Item Number I.B.1.b Instrument Air Project No. I.C.4 1.22
._____________-_L
1 TITLE:
Emergency Plan Implementing Procedure (EPIP) Upgrade l
DESCRIPTION:
Review the EPIP's and upgrade as necessary to include the consideration of common mode failures into the declaration of a Notification of an Unusual Event Classification.
The notification and activation of the Emergency Response Organization should be initiated if common mode failures or i
precursors to such failures occur during operation.
STATUS:
Upgraded EPIP has been prepared, approved and implemented.
Training is in progress with six operating shifts having completed training.
RESULTS ACHIEVED:
Upgraded EPIP now includes common mode failure consider-ations as part of the classification p*ocess.
OPPD now has a more effective program to ensure additional resources and support can be immediately applied to operational events.
COMPLETION STATUS: This task is complete.
Training will be completed in August 1988.
Item Number I.B.2.a Instrument Air Project No. I.C.14 1.23
TITLE:
Safety Analysis for Operability (SAO)
DESCRIPTION:
Provide formal guidance on development and issuance of SA0.
Guidance will cover development of SA0 content, safety analysis requirements, PRC and SARC approval requirements and development of LER for notification to the NRC.
STATUS:
Formal guidance has been developed, reviewed, approved and implemented. Additional enhancements to this procedure are.
planned.
Training is currently incomplete, however, enhancements and training will be completed by June 1,1988.
RESULTS ACHIEVED:
The issued Nuclear Production Division procedure has been utilized in recent 10CFR 50.72 reported discoveries where conditions outside the design bases have been found. Al-though the procedure has improved understanding and require-ments for safety evaluations in these situations, further enhancements are planned.
COMPLETION STATUS: This task is complete.
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Item Number I.B.2.b Instrument Air Project No. I.C.10, I.C.11 I
l 1.24
1 i
TITLE:-
, Employee /ManagementConferences DESCRIPTION:
Conduct small group meetings with all available workers to communicate management expectations and assess / ensure employ-ee commitments toward improvement of safety awareness and compliance.
(.
STATUS:
Two group sessions were scheduled for each station employ-Initial group meetings were scheduled for. January and ee.
February 1988.
All but five station personnel. of the nearly 335 in Nuclear Production Division have presently completed first meet-ings.
Second meetings were first held in March 1988. All but twenty station employees are complete as of April 8, 1988.
RESULTS ACHIEVEDi Although not a. measurable result, OPPD' feels an improvement in internal communications with respect to safety and com-pliance has resulted.
Procedural compliance and a mutual understanding of purpose and future direction is felt to be evident.
COMPLETION STATUS: Station employee meetings (initial and second) are expected to be completed by May 1988.
Item Number I.B.3.a Instrument Air Project No. I.C.8 1.25
I TITLE:
Policy Statement Concerning Equipment Operation by l
Non-Operators DESCRIPTION:
Develop a policy for use by station personnel, other than operators, who utilize plant equipment to perform certain assigned tasks.
STATUS:
A policy letter was issued to Station personnel on December 31, 1987 providing direction on operation of equipment /
valves by non-operations personnel.
This policy clarified previously unwritten,. general understandings of equipment operation by technicians.
In February, 1988 a procedure change to Standing Order 0-29 was incorporated to provide direction on valve / equipment operation to non-operations personnel.
This standing order allows only operations personnel to operate plant valves and equipment, with the following exceptions; (1) chemists performing sampling, (2)
I&C Technicians operating instrument root and manifold iso-lation valves, (3) pressure equipment personnel operating valves within boundaries of an applicable equipment tag out, and (4) work groups repositioning valves on hose bibs for potable water, demineralized water and service air. Manipu-lation of these valves does not alter a safety configuration or jeopardize safety. Other work groups can only position valves or operate equipment with specific operations permis-sion.
RESULTS ACHIEVED:
Station personnel, both operators and non-operators, now have specific written instructions which leads to an understanding of equipment operating limitations by non-operators.
COMPLETION STATUS: This task is complete.
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Item Number I.B.4.a Instrument Air Project No. 1.C.6, I.C.7 1.26
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TITLE:
Additional Walkdown of Instrument Air System DESCRIPTION:
Confirm the identification of items included in the eval-uation of interface valves and bubblers by a system wal kdown.
STATUS:
A walkdown of the Instrument Air System outside of containment was performed in Cctober, 1987 and the l
information included on the P&ID's.
This walkdown did not specifically identify all interface valves and bubblers. The evaluation of interface valves and bubblers (Item I.A.5.b) was completed in January,1988 based on records and files, however, a future walkdown of the Instrument Air System is planned by the System Engineer to assure that all interface valves and bubblers have been included in this evaluation.
RESULTS TO BE ACHIEVED: Interface valves and bubblers were determined to not be a concern with respect to water intrusion into the Instrument Air System.
There have been no instrument air / water interfaces identified which present a possibil-ity of water intrusion into the Instrument Air System.
Water intrusion is prevented by pressure differences, as is the case for bubbler monitors of tank level, or would require multiple failure to occur in conjunction with pressure differences, as in the case of diaphragm valves.
COMPLETION STATUS:
Since this task will include the Instrument Air System in Containment, it will be completed by the end of the 1988 outage.
Submittal Item Number II.A.I.a Instrument Air Project No. II.A.13 1.27
I TITLE:
Abnormal Operating Procedure (A0P) 17, Upgrade in
-Accordance with Writers Guide DESCRIPTION:
Upgrade A0P-17 in accordance with the Procedures Writers Guide within ninety days of issuance of the writers guide.
f STATUS:
A0P-17, the Abnormal Operating Procedure for loss of instrument air, has been upgraded to include; (1) feedback from operators concerning their experience with previous revisions, (2) concise and accurate information and (3) consistency between the installed system and the A0P.
The upgrade utilizing the Procedure Writers' Guide will be performed upon issuance of the guide to maintain consistency with the Guide's format.
(The Guide is a product of a project to upgrade all plant procedures within the next two years).
RESULTS TO BE ACHIEVED: Use of the Procedure Writers Guide will assure format uniformity and consistent development and content in procedures.
COMPLETION STATUS:
Task completion is scheduled for September 1988.
Submittal Item Number II.A.2.a Instrument Air Project No. I.A.12 1.28
r.--__-
TITLE:
Clean / Flush the Instrument Air System DESCRIPTION:
Evaluate the necessity to clean / flush the Instrument Air System during the 1988 Refueling Outage. Cleaning or flushing requirement will be based on an investigation of industry experience and results of operator teardowns i
l and valve cycling program (SP-STROKE-1).
STATUS:
Review of industry experience is in progress.
Operator teardown and valve cycling is underway. Based on infor-mation obtained from these programs, a decision will be made as to whether a system flush is warranted.
RESULTS ACHIEVED:
Based on information received to date and the results of our testing and teardown of operators, a flush does not appear to be necessary or desirable.
COMPLETION STATUS:
System cleaning, if required, will be performed during the 1988 refueling outage.
Submittal Item Number II.A.3.a Instrument Air Project No. I.A.27 1.29
TITLE:
Valve Teardown Program DESCRIPTION:
Develop and implement a valve operator teardown program to identify the existence of any long term consequences caused by the July 6, 1987 water intrusion event.
STATUS:
A total of forty-one valve operators out of forty-seven committed to in Reference 8 have been disassembled to date to detennine the effect, if any, of water on valve operator internals.
Thirty-three valve operators were disassembled prior to November 20, 1987.
Of the remain-l ing eight valve operators disassembled since November 20, 1987, two valve operators were found to contain water.
RESULTS ACHIEVED:
Two of the eight valve operators (HCV-7968 and HCV-797B, both Bettis type) disassembled since November 20, 1987 contained water in the amounts of one and two pints re-spectively.
Both operators had no evidence of signifi-cant corrosion damage. All operators, except for the YCV-871 damper operators on September 23, 1987, have remained operable since the water intrusion.
COMPLETION STATUS:
Valve operator teardown will continue to substantiate that no significant problems exist. At the completion of the 1988 refueling outage, an evaluation will be made on the need to continue valve operator teardowns based on data gathered to that time.
l Submittal Item Number II.A.3.b Instrument Ai-D-oject No. I.A.1, I.A.2, I.A 3 I.30 i
I TITLE:
Testing of CQE Non-ISI Valves DESCRIPTION:
Determine the operability of cercain CQE valves that j
were potentially affected by water intrusion into the Instrument Air System but were not covered under the Inservice Testing program.
STATUS:
Special Procedure SP-STROKE-1 was implemented in November, 1987 to test thirty-eight air operated CQE and non-CQE valves that were not included in the valve testing portion of the ISI program. Trending of valve stroke times indicates no significant increases in valve stroke times.
RESULTS ACHIEVED:
Data is being collected and monitored to trend valve operator performance.
No significant deg,adation of stroke times for the population of valve operators as a whole or individual valve operators has been observed.
COMPLETION STATUS:
The procedure was in place in November 1987.
The test-ing is ongoing until the results of the trending can be used to substantiate the reduction and/or elimination of j
the testing.
An evaluation of trending results will be completed prior to the end of the 1988 refueling outage.
l l
i Submittal Item Number II.A.4.a j
Instrument Air Project No. - None 1.31 i
i TITLE:
Monthly Valve Cycling for Inservice Test Program DESCRIPTION:
Review Inservice Testing requirements of air. operated valves and establish cycling frequency of thirty days for those valves whose previous cycle period was ninety-days or greater.
i STATUS:
The cycling frequency for valves with quarterly or greater test period has been. changed to a monthly basis and a program was established to monitor cycling times for each valve.. Cycling times are being trended to ensure that an adverse increase in cycling times is not occurring due to the effects of water injection into the Instrument Air System.
Trending of valve stroke times indicates no significant increases in valve stroke times.
RESULTS ACHIEVED:
Data is being collected and monitored to trend valve operator performance. No significant degradation of stroke times for the population of valve operators as a whole or individual valve operators has been observed.
COMPLETION STATUS:
The procedure was in place in November 1987. The test-ing is ongoing until the results of the trending can be used to substantiate the reduction and/or elimination of the testing. An evaluation of trending results will be completed prior to the end of the 1988 refueling outage.
Submittal Item Number II.A.4.b Instrument Air Project No. I.A.9 1.32
1 i
TITLE:
Cycling of Inservice Inspection (ISI) Valves j
DESCRIPTION:
ISI valve operators which were potentially wetted and.
cannot be cycled and timed during power operation must be identified and scheduled for cycling during the next cold shutdown in excess of forty-eight hours.
STATUS:
A list of affected valves has been developed and valve cycling procedures have been issued.- These' valves are currently included in the SAO on wetted valve operators.
Valve cycling will be initiated at next cold shutdown in' excess of forty-eight hours.
RESULTS ACHIEVED:
Preparations for valve cycling are complete, however, until the testing can occur, there are no results to report.
COMPLETION STATUS:
List of affected valves and supporting cycling proce-dures were completed in December 1987.
Valve cycling will be completed no later than the end of the 1988 refueling outage.
i Submittal Item Number II.A.4.c l
Instrument Air Project No. I.A.20 i-1.33 1
TITLE:
Inservice Inspection Program l
l DESCRIPTION:-
Update the Inservice Testing Program to include valves related to the Instrument Air System that were previously not considered to be within the scope of the ISI program.
STATUS:
The Inservice Testing Program was wdated and submitted.
to the NRC in December 1987.
RESULTS ACHIEVED:
The update incorporates valves related to the Instrument Air System that were reclassified as having a specific function in shutting down the reactor or mitigating the consequences of an accident. An additional revision will be required to reflect the changes associated with the safety analysis on accumulator functions and sizing, OSAR 07-10, which concerns the possible addition of two.
accumulators associated with (HCV-438 8 and D) and deletion of the accumulators associated with HCV-864, HCV-865, HCV-344 and HCV-345.
NOTE:
Nitrogen backup to the air supply to the air accumulators on HCV-344 and HCV-345 will be provided prior to the end of the11988 outage to assure post-accident operability of the valves.
COMPLETION STATUS:
This task was completed in December 1987, however, is not considered complete due to the possible changes as a result of OSAR 87-10.
The revision will be submitted prior to the end of the 1988 refueling outage.
Submittal Item Number II.A.4.d Instrument Air Project No. - None 1.34
t l
TITLE:
Diesel Generator Air Damper Replacement DESCRIPTION:
Initiate a request for a modification to replace the J
Diesel Generator Air' Dampers with an air' damper utilizing a different type of operating ~ control mechanism which is not dependent on a small ported orifice.
Procure and install replacement dampers.
STATUS:
The request was initiated in December, 1987 and the design (MR-FC-87-63) is currently in progress.
RESULTS ACHIEVED:
The modification has been initiated and is currently-planned for-1988.
COMPLETION STATUS:
Installation is scheduled for completion by end of the 1988 subject to availability of materials.
I I
Submittal Item Number II.A.5.a Instrument Air Project No. I.A.24, I.A.25 1.35 e
.t TITLE:
Assessment of Instrument Air System Design to Current Industry Standards DESCRIPTION:
Assess the Fort Calhoun Instrument Air System design against the current industry standards and experience and initiate necessary upgrades.
STATUS:
An assessment of the Instrument Air System design is underway.
RESULTS ACHIEVED:
None as yet.
COMPLETION STATUS:
Complete evaluation of report recommendations by June 30, 1988 and initiate appropriate upgrades thereafter.
i I
l 1
i Submittal Item Number II.A.5.b Instrument Air Project No. I.A.14 1.36
TITLE:
System Functional Inspection - Follow-up DESCRIPTION:
Resolve the concerns generated _by-the System Functional Inspection
. STATUS:
Concerns from the SFI have been reviewed by the Quality Assurance and Regulatory Affairs Division, Instrument-Air Project Team, and OPPD Management. Deficiency / Qual-ity reports have been issued to track the completion of-corrective actions.
RESULTS ACHIEVED:
To be determined pending resolution of the concerns.
COMPLETION STATUS:
Review of these items has recently been initiated. One significant concern was the failure position of the Instrument Air pressure control valve to the contain-ment, PCV-1849.
This item was reported under 10CFR 50.72 and corrective actions initiated. Modification of the configuration is planned during the 1988 outage (see ).
A review of the other SFI' concerns shows there is currently no other item of this significance.
Submittal Item Number II.A.5.c Instrument Air Project No. I.A.28 1.37
l l
L L
I TITLE:
Development of the Instrument Air System Design Basis Documentation DESCRIPTION:
Assemble documentation of the design basis for the Instrument Air System.
STATUS:
The development.of Instrument Air System design basis documentation is being accomplished as part of the Fort Calhoun Design Basis Reconstitution Project.
Tne Design Basis Reconstitution Project is currently in progress with initial review of the Instrument Air System Design Basis Documentation scheduled for May 15, 1988.
RESULTS ACHIEVED:
None to report to date.
Awaiting Design Basis documentation review effort.
COMPLETION STATUS:
Final review and approval is scheduled for June 30, 1988.
Schedule for completion of items identified as open in this report will be dependent upon the item.
I l
l
)
i Submittal Item Number II.A.5.d Instrument Air Project No. I.A.13 1.38 i
TITLE:
Identification and Installation of Air Filter Additions for Valve Operators and Air Dryer DESCRIPTION:
Identify required locations for air filters.
Develop the design such that filters are installed upstream of all air operators that currently do not have in-line filters.
~
l STATUS:
Evaluation has been initiated.
Procurement and installation procedures will.be initiated to allow installation to be completed by the end of the 1988 refueling outage.
Required hardware has'been verified as commercially available.
I RESULTS ACHIEVED:
An estimate of the maxisnum number of additional filters has been made and determined to be manageable for 1988 outage installation.
COMPLETION STATUS:
Installation is presently planned to be completed by the end of the 1988 re"ueling outage.
i 1
Submittal Item Number II.A.5.e Instrument Air Project No. I.A.17, I.A.18, I.A.22 1.39
TITLE:
Removal 'of Plant Air System and Fire Protection System Crossties DESCRIPTION:.
Develop and implement a modification to allow permanent removal of the crossties between the Fire Protection System and the Plant Air System.
.i STATUS:
The Instrument Air System was isolated from the Fire i
Protection System in October 1987. As of April.15, 1988, the crosstie which initiated the July 6, 1987 event remains crosstied to the Plant Air. System. A
-modification'to eliminate the Plant Air System / Fire Protection System crosstie has been designed.
The final design and construction procedure have been developed and issued.
Required materials have been purchased.
'RESULTS ACHIEVED:
Instrument Air System is fully isolated from Fire Protection System.
Plant Air' System will be fully isolated from the Fire Protection System.
COMPLETION STATUS:
Completion date for construction is scheduled for June 1988.
l Submittal Item Number II.A 5.f Instrument Air Project No. I.A.21 l
1.40
r TITLE:
Nuclear Operations Plan Development and Appraisal DESCRIPTION:
An appraisal of OPPD's nuclear operations will be developed by a qualified independent firm. This appraisal will be directed toward improvements in safety of plant operations and compliance with NRC regulations, leading to excellence in operations.
STATUS:
Stone and Webster Engineering Corporation was selected to perform the independent appraisal and commenced plant development in December 1987.
Onsite and offsite interviews and appraisals are essentially complete with a draft report in preparation stages.
1 RESULTS ACHIEVED:
Awaiting submittal of evaluation report.
COMPLETION STATUS:
The evaluation report is scheduled for completion in June 1988.
Submittal Item Number II.B.I.a Instrument Air Project No. I.C.1, I.C.2 1.41
TITLE:
Instrument Air Steering Committee:
DESCRIPTION:
Establish a comittee dedicated to monitoring and coor-dinating resources, activities and information to enable-timely response and actions to commitments made as a re-sult of the Instrument. Air System water intrusion event.
STATUS:
The Instrument Air Steering Committee was established in; December 1987.
It reviews progress on all commitments; initiates and coordinates activities resources and information.
The Committee reports the status of: pro-ject tasks to management. This committee is composed of representatives from the plant staff, Engineering and Technical Support staff. Other representatives from these organizations; as well as Licensing, Training and Quality Assurance, assist this committee on related topics. Overdue milestones are identified and correc-tive action initiated to expedite completion of commit-ments on a timely basis. The scope of this committee's activities has recently expanded to include previously existing SSOMI items related to instrument air.
RESULTS ACHIEVED:
The Committee, meeting on a monthly basis, has provided I
overall guidance to responsible departments / individuals in achieving completion of assigned commitments.
COMPLETION STATUS:
The Steering Committee will continue to function until the majority of the primary commitments initiated by the water intrusion or SSOMI findings are resolved or clos-ed. Tasks and activities initiated as a result of satisfying primary commitments, e.g. SFI findings, SARC 1
concerns, etc., may continue to be tracked using other tracking processes.
]
Submittal Item Number II.B.I.c Instrument Air Project No. - None 1.42
~l 1
TITLE:
General Employee Training (GET) Upgrade for Safety Awareness
)
{
DESCRIPTION:
Upgrade GET to assure continual awareness of management requirements on safety and procedural compliance as a
{
follow-up to Employee / Management conferences, j
l STATUS:
Preparation of GET video tapes is in progress.
RESULTS ACHIEVED:
Awaiting completion of tapes and subsequent use in GET.
I COMPLETION STATUS:
This task is scheduled for completion in May 1988.
l l
Submittal Item Number II.B.2.a Instrument Air Project No. I.C.9 1.43 1
i
l
-TITLE:
Additional Field Observation Training.
DESCRIPTION:
Train additional 0 PPD personnel in the INPO developed i
methodology for field observations. The intention of this item is to assess the effectiveness of GET training and verify' that GET is resulting in improved safety consciousness and procedure compliance.
STATUS:
Individuals in the Training Department have received INPO instruction on the content and methods for a field observation training course. The lesson plan has been developed.
RESULTS ACHIEVED:
None until course is presented, however, members of the Quality Assurance Department who also have had this training are utilizing these observation skills.
COMPLETION DATE This will be an ongoing process..
Submittal Item Number II.B.2.b Instrument Air Project No. I.C.15 1.44
7 TITLE:
Upgrade of Lesson ^ Plans DESCRIPTION:
As part of the routine upgrade of lesson plans, empha-size the unique features of systems which have the potential for_ improving or detracting from the safety of the plant.. Training procedures will be revised to-include the identification and discussion of unique system features in lesson plans.
STATUS:
Lesson plan incorporation of unique feature is continu-ing on a routine basis.
Specific guidance'is being incorporated into the Training Administrative Manual.
Lesson plan review by the system engineer is.being considered.
RESULTS ACHIEVED:
Increased awareness of unique system features.
COMPLETION STATUS:
The upgrade of lesson plans is an ongoing process, such as when needed to describe unique features associated with modifications to the system.
l Submittal Item Number II.B.2.c Instrument Air Project No. I.C.12 1.45 1
1 TITLE:
Pre-Job Briefings for Surveillt.nce Tests DESCRIPTION:
Pre-Job briefings are to be held prior to performing a
]
surveillance test which has a frequency of less than quarterly.
i STATUS:
During the preparation of the surveillance schedules l
(prepared monthly), those tests with frequency of less I
than or equal to quarterly are identified as requiring pre-job briefings.
Currently, as the test procedures are routed to the personnel responsible for performing the test, a briefing sheet accompanies each copy of the procedure and briefings are conducted.
Further proce-dure changes will be made to formalize and proceduralize the pre-job briefings.
These changes are awaiting PRC approval.
RESULTS ACHIEVED:
Pre-job briefings are being conducted on surveillance tests which have a frequency of less than or equal to quarterly to improve the level of understanding of the test procedure and ensure successful test execution.
COMPLETION STATUS:
Incorporation of pre-job briefings is in progress and will be completed by September 1988.
Submittal Item Number II.B.2.d Instrument Air Project No. - None 1.46
l j
i ATTACHMENT 2 VIOLATION A DESIGN EVALUATION 1
1 i
ATTAC19 TENT 2 l
l VIOLATION A:
DESIGN EVALUATION i
l 10 CFR 50.59(a) allows the holder of a license to make a change in the facility as described in the safety analysis report (SAR) without prior Commission approval unless it involves a change in the technical specification or involves an unreviewed safety question. A proposed change involves an unreviewed safety question:
(1) if the probability of occurrence or the consequences of an acci-i dent or malfunction of equipment important to sefety previously evaluated in the SAR may be increased, (2) if a possibility for an accident or malfunction j
of a different type than any evaluated previously in the SAR may be created or j
(3) if the margin of safety as defined in the basis for any Technical Specifi-j cation is reduced.
l 10 CFR 50.59(b) requires, in part, that the licensee maintain records of changes in the facility to the extent that such changes constitute changes in 1
the facility as described in the SAR.
These records shall include a written i
safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
Section 9.12 of the Fort Calhoun Station Updated Safety Analysis Report (USAR) describes, in part, that the compressed air system provides compressed air to the instrument air header for pneumatic controls and the actuation of valves, dampers and similar devices, and states that the system has a design basis of a maximum instrument air dew point of -20*F.
Contrary to the abov9, the licensee failed to perform an adequate evaluation, i
as required by 10 Ch'. 50.59(a), to determine if an unreviewed safety question existed when Modification MR-FC-83-182 was installed on May 22, 1985 to connect the Instrument Air System to the Fire Protection System.
Although the licensee completed a 10 CFR 50.59 evaluation to determine the effect of the modification on the Fire Protection System, it failed to evaluate the effect of the modification on the Instrument Air System and the potential for introduction of water from the Fire Protection System into the Instrument Air System.
The introduction of water into the Instrument Air System could result in a common q
mode failure through flooding of the Instrument Air System, which supplies the i
motive force for equipment or components in redundant trains of safety-related
)
equipment. The intrusion increased the probability of the malfunction of l
safety-related equipment, and components because moisture caused the system to not meet the design bases for a dew point maximum limit of -20*F which is specified in Section 9.12 of the Fort Calhoun Station USAR.
The unreviewed safety question existed until the Instrument Air / Fire Protection System interface was disconnected in October 1987.
This is a Severity Level III violation (Supplement I).
Civil Penalty - 575,000 2.1 1
Resoonse to Violation A
- 2. THE REASONS FOR THE VIOLATION, IF ADMITTED The reasons for the violation are as follows:
When the design package for modification FC-83-182 was prepared in 1985, a safety analysis was not required during the design phase of the modifica-tion if the modification did not involve CQE (Nuclear Safety Related) equipment.
l
- The Fort Calhoun Station USAR, Section 9.12, Compressed Air, Par. 9.12.1 i
states:
" System operation is not required to initiate operation of engineered safeguards equipment since all air operated valves and dampers requir-ed to control the accident were designed to assume the accident -
controlling position on loss of air pressure.
Further, air is not required for the reactor protective system."
Also, Par. 9.12.5 states:
"All air operated valves which are required to operate in this case do so by spring actuation following removal of air pressure from their operators...the instrument air is also not required for any of the engineered safety features to operate properly.
In all cases, air operated valves fail upon loss of air pressure in a position for the engineered safeguards to function properly."
This discussion led the design engineer to the conclusion that instrument air system was not required for a safe plant shutdown. Due to inadequate design engineering procedures, a safety analysis was not performed as part of the design.
Conditions created as a consequence of the water intrusion were not formal-ly evaluated immediately because the significance and consequence of poten-tial common mode failure was not realized.
- 3. THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A.
Procedure Upgrades As a result of the SSOMI finding, the design engineering function for the Fort Calhoun Station was evaluated, and the procedures utilized for the preparation of design change packages were upgraded in December 1987 as described below.
The GSE Engineering Manual, Section GEG-3, Preparation of Desian Packaaes, was written to provide design engineers guidance for the preparation of proposed design modification packages.
This procedure is applicable to CQE and non-CQE proposed design change packages at Fort Calhoun. The following are examples of the applicable items that GEG-3 requires be considered for proposed design changes:
2.2
Depending upon the: safety significance of a given modification, discussion of some of the items listed below can be brief.
l 1
a.
Scone or Problem Evaluation
- 1. Modification Purpose
-Root Cause' Analysis.
-Impact on Unit
- 2. Alternative Analysis i
- 3. Performance Analysis
- 4. Cost / Benefit Analysis
- 5. Recommended Solution and Technical Description.
b.
Reaulatory Requirements
- 1. Codes and Standards
- 2. CQE Designation 3
3.. Code Classification 1 i
- 4. USAR Impact i
- 5. Technical Specification Impact
- 6. Licensing Commitments
- 7. Regulatory / Industry Notices c.
Desian Inout Requirements
- 1. System Functional Requirements
- 2. System Performance Requirements
- 3. System Design Conditions
-Environmental
-Seismic
-Loading
-Material s
-Electrical Power 1
- 4. Interfaces with Other Systems d.
Desian Analysis l
- 1. System Design Analysis
- 2. Procurement Specifications
- 3. Drawing List e.
Systems Interaction Analysis
?. Fire Protection
- 2. Environmental Qualification Impact
- 3. High Energy Pipe Break
- 4. Seismic Interaction
- 5. Electrical System Interaction i
- 6. Human Factors Review
- 7. Security Review
- 8. Environmental Radiological Release
- 9. Materials Compatibility
- 10. Containment Integrity
- 11. Control Room Habitability 2.3 1
E_______._____.____.
512. Missile Protection
.)
- 13. Internal' Flooding l
14.. Separation Criteria j
- 15. Single Failure Criteria j
- 16. Possibility of Operator. Error J
- 17. Heavy Loads
-4
- 18. Impact on HVAC f.
10CFR50.59 Analysis
- 1. Design (Operating)
- 2. Construction 3: Testing g.
Ooeratina Imoact
- 1. ALARA Analysis
-Construction
-Operation
- 2. Constructability, Operability, Maintainability Review-
- 3. Special Training Requirements 4' Special Testing Requirements
- 5. Special Maintenance Requirements h.
Installation and Testina Requirements
- 1. Installation and Testing Summary
- 2. Installation and Testing Procedures i.
Document Revisions J.
Resource Requirements
- 1. Materials List
- 2. Materials Estimate -
- 3. Engineering and Design Estimate
- 4. Construction Labor Estimate
- 5. Work Order k.
Schedules
- 1. Design
- 2. Procurement
- 3. Construction NPD Quality Procedure QP-3 is OPPD's governing document for perform-ance and control of.the safety analysis process.
The GSE Engineering Manual, Section GEG-27, Frenaration of 10CFR50.59 Safety Evaluation, provides guidance to the design engineer on what is required to com-plete a safety analysis as required by 10CFR50.59.
Section 2.0 of GEG-27, states that a safety analysis is required for all proposed modifications to the Fort Calhoun Station.
This guideline meets the requirements of Quality Procedure QP-3.
2.4
=
s The Generating Station Engineering Procedures Manual,.Section B-11,.
Par.1.0 requires that " modification and design changes to Fort Cal-houn. Station involving CQE, Limited CQE, Non-CQE, and Fire Protection Systems and components" must have an independent multidisciplinary design verification. Section B-11 Checklist E,10CFR50.59 Analysis provides assurance, by independent verification, that an adequate safety analysis was performed.
i As.a result of these procedure changes and upgrades, design packages and their associated safety evaluations now include consideration of a-wider range.of topics and analytical requirements. An improvement in the quality and an increased level of detail has been noted in the development and documentation of modifications, independent of whether the modification is to a CQE or non-CQE system.
l B.
Instrument Air System Evaluation In order to assess the operational readiness of the Instrument Air System, an extensive evaluation of the Instrument Air. System was con-ducted. This evaluation, similar in content and format to the Safety System Functional Inspections (SSFI) included onsite and field reviews of design adequacy, testing, maintenance, operating instructions and training.
This evaluation was conducted in December, 1987.
The evaluation team referred to commitments documented in the USAR, Technical Specifications, correspondence to the NRC, etc., to deter-mine system design intent End then reviewed maintenance activities, modifications, equipment data and interfaces to verify conformance to this design intent.
Very little original design information was avail-able. to compare to the existing design as modified.= A site walkdown of selected parts of the Instrument Air System served as a basis for verifying the existing configuration.
The team determined that in general, the design intent has been attained and that the Instrument Air System is operable, however, several concerns were identified.
These concerns are currently under management review and corrective action planning. One concern identified a potential safety issue and was expedited, evaluated and reported to the NRC'on March 11, 1988 pursuant to 10 CFR 50.72. Corrective actions associated with the LER have been completed to' address-this concern.
This included interim actions, e.g. AOP-17 changes notifying the operator of special actions to be taken in the event of a-LOCA with~1oss of offsite power, Further, modification of valve PCV-1849 (Containment penetration M-73) is scheduled to be completed in the 1988 refueling outage to permanently eliminate this concern.
Based on this thorough evaluation of an Instrument Air System design and our review of the identified concerns, OPPD concludes that the design basis of the Instrument Air System is being met and that pre-vious modifications to the system reviewed as part of the SFI, with the exception noted and the modification identified in the violation, have not compromised the design basis of the system and, therefore, the system is considered operable.
2.5 l
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- C.-
Evaluation of the July 6 Event Consequences A safety evaluation'was completed in October 1987-to address the-l consequences of the water intrusion event. This evaluation was con-1 ducted by.a consultant using a draft of the procedure which was subse-l quently issued as NPD E-1.
The evaluation considered consequences on containment integrity, system performance, single failure criteria, high energy line break, accidents, control room habitability, design j
basis and environmental qualification.. Also considered, but not applicable, were. separation criteria, fire protection, radioactive i
releases, operator error, materials compatibility, potential conse-quences of procedural errors, missile protection, heavy loads and natural phenomena.
On November 15, 1987 the Nuclear Production Division. Policy No. E-1, 10CFR50.59 Safety Evaluations, was issued to provide guidelines in the safety evaluation process.
This policy was recently reissued as NPD Quality. Procedure QP-3 and is now used by the STA for assessing-the significance of an event in Standing Order R-4, Station Incident Reports.
The results achieved from this procedure development is to i
assure timely review and understanding of event consequences.
The connection between the Fire Protection System and the Instrument Air System was isolated / disconnected. The dry pipe valve was connected to the Plant Air System, making it unnecessary to update the safety evaluation for this modification.
4.
THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The above corrective steps will help eliminate the potential for future violations of. inadequate evaluations. To further enhance the quality of future evaluations and to assure that evaluations associated with a completed modification are adequate, OPPD will complete the following actions:
A.
Design Basis Reconstitution Reconstitution of the Fort Calhoun Station design basis including Design Basis Verification will be completed in accordance with the program plan and schedule provided in Reference 19.
Concurrent with the reconstitution project OPPD will review modification packages (for safety related modifications and non-safety related modifications which have potential to impact safety systems) installed after issuance of the license to confirm the adequacy of safety evaluations.
The above evaluation will be based on the information contained in the
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design packages and no new detailed packages will be created. This 1
effort will be part of design bases reconstitution project.
B.
Update the USAR Continuing updates of the USAR will reflect the conclusions of the results of the design basis reconstitution and evaluation upgrades.
2.6 l
1
The USAR statements on instrument air are vague and could lead the design engineer t-o conclude that the Instrument Air System was not required for safe actuation of valves or dampers important to safety.
These statements will be expanded to provide clarification and enhance i
the safety relationship and interactions of the Instrument Air System to other systems during future updates to the USAR.
C.
On-going Self Assessments of System Safety Functions OPPD will continue the practice of performing SSFI type inspections on a periodic basis after the Design Basis is reconstituted for i
significant systems.
t 5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is presently in full compliance regarding the specific violation based on corrective actions completed and the interim measures currently in place. Other actions planned will provide additional enhancements to the design process.
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ATTACHMENT 3 VIOLATION B DESIGN IMPLEMENTATION AND CLASSIFICATION / REPORTING
ATTAGMENT 3 VIOLATION B:
DESIGN IMPLEMENTATION AND CLASSIFICATION / REPORTING Violation B.1 10 CFR Part 50, Appendix B, Criterion XI and Section 8.4 of the OPPD Quality Assurance Plan requires, in part, that a test program be established to assure that all testing required to demonstrate that components will perform satisfac-torily in service is identified and performed in accordance with written test procedures.
Contrary to the above, on May 22, 1985 the licensee installed check valves in the Instrument Air System to ensure that water from the Fire Protection System did not enter the Instrument Air System, but failed to establish a test program that would assure that the check valves would perform satisfactorily in ser-vice. Subsequently, on July 6, 1987 the check valves failed to perform their intended function, resulting in the introduction of fire water into the Instrument Air System.
These violations (B.1-B.6) are considered in the aggregate tu be a Severity Level III problem (Supplement 1).
Civil Penalty - $50,000 (assessed equally among the violations).
OPPD RESPONSE 1.
ADMISSION OR DENTAL OF THE ALLEGED VIOLATION OPPD admits the violation occurred as stated.
2.
THE REASON FOR THE VIOLATION IF ADMITTED In 1985 OPPD procedures did not adequately address functional testing of modifications, and subsequent reviews related to modification adequacy were not sufficient to detect this situation.
Inservice testing of the check valves was not required or specified because they were being installed in a non-CQE system which is outside the scope of Section 8.4 of the OPPD QA Plan. As non-class valves, the check valves are also not within the scope of the ASME Section XI Inservice Test Program.
3.
THE CORREGILVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED 1
The Fire Protection System was isolated / disconnected from the Instrument Air System.
The dry-pipe valve was connected to the Plant Air System.
In addition procedure HP-FP-7, Resettino of Diesel Generator Dry Pioe Deluae Valve After Trio or Testino, has been revised to include steps to verify the functioning of the check valves (IA-575, IA-576).
New procedures were established to assure adequate functional testing of design changes after installation. The GSE Engineering Manual, Section GEG-3, was issued in December 1987.
3.1 o
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GSE Manual, Section GEG-3 states that " test procedures shall be included to test the system to assure its function in actual operation." This section i
in the GSE Engineering Manual is applicable to design changes, both CQE and non-CQE, at the Fort Calhoun Station. Also, to assure that the procedures are adequate, GSE Procedure B-11, Independent Desion Verification, upgraded on February 16, 1988, is required for modifications and design changes involving CQE, limited CQE, non-CQE and Fire Protection systems and inter-connections.
This verification process specifically addresses functional testing of modifications.
This procedure now requires an independent multi-disciplinary review.
Checklist F, Section 5.8, of Procedure B-11, Installation / Test Procedures, Item No. 21 asks, "Does testing demonstrate, as close as practical; that normal, abnormal and emergency functions can be accomplished?" This will assure that design changes are adequately functionally tested after installation.
CQE hardware has been functionally tested, maintained where necessary and verified to be operable.
In accordance with commitments made in Reference 8, Page VII-1, OPPD has enhanced the ISI/IST program.
Testing of the diesel generator air operated danipers has been accomplished with no degra-dation of operability detected to date.
A review was performed to identify components within the Instrument Air Sys-tem such as instrument air accumulators or instrument air check valves that must function in order to insure the safe operation of an existing critical quality component. The accumulator check valves were added to the valve test portion of the ISI/IST Program Plan.
The instrument air check valves added to the ISI/IST Program Plan are identified in OPPD's letter dated December 16, 1987 to the NRC (Reference 15).
The status of testing of these safety related accumulators and instrument air check valves is presented in Attachment 5.
All of these have been tested, supplemented by a nitrogen gas jumper to eliminate the functional need, or are addressed by safety evaluations which consider other opera-tional and design factors which justify continued safe operation.
During 1987, two activities were performed that resulted in the addition of valves to the ISI/IST Program Plan.
The first resulted from answering a series of questions transmitted to OPPD from the NRC on June 24, 1987. The second was a self assessment performed by OPPD during the instrument air review. Each of these activities added valves to the ISI Program Plan or placed additional test requirements on valves already covered by the program.
As a result of the above activities, existing Instrument Air System valves and equipment which provides a safety related function have been identified and are now included in the ISI/IST program. These components are now sche-duled for periodic testing and/or preventive maintenance. These components have been tested, supplemented by a nitrogen gas jumper, or are addressed by a safety evaluation.
Engineering procedures installing modifications to the existing system require testing of equipment when installed and a re-view of the need for addition to ongoing testing programs.
3.2 1
9
4.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Reconstitution of the Fort Calhoun Station design basis will involve an evaluation of the "as installed" system to verify consistency with the systems design requirements. Additional valves, if any, that arc identi-fied as serving a safety function will be incorporated into the ISI program as appropriate.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is presently in full compliance with regard to the specific violation.
i 3.3
Violation 0.2.a 10 CFR Part 50, Appendix B, Criterion V and the OPPD Quality Assurance Plan, Section 2.1 require, in part, that activities affecting quality be prescribed by documented instruct %ns of a type appropriate to the circumstances.
Procedure ST-FP-5, " Fire Protection-Auxiliary Building Sprinkler Systems a.
Testing," specifies how the licensee is to test the dry-pipe fire system in the emergency diesel generator rooms.
j Contrary to the above, Procedure ST-FP-5 failed to provide adequate instruc-tions for the performance of the surveillance testing activities on the dry-pipe system in the emergency diesel generator rooms.
Procedure ST-FP-5 did not provide specific step-by-step instructions for returning the drypipe system to the normal lineup after completion of the surveillance test. Con-sequently, water from the Fire Protection System was introduced into the Instrument Air System during the performance of the test on July 6,1987.
OPPD RESPONSE 1.
ADMISSION OR DENTAL OF THE ALLEGED VIOLATION OPPD admits the violation occurred as stated.
2.
THE REASONS FOR THE VIOLATION IF ADMITTED The reason for this violation was a combination of inadequate training in the unique features of this system and a procedure which contained poor human factors aspects.
The step-by-step instructions required to ~ return the dry pipe system to normal lineup are contained in a second procedure, MP-FP-7, Resettino of Diesel Generator Ory Pioe Deluce Valve After Trio or Testino, referenced by ST-FP-5.
The operator, in performing ST-FP-5, assumed that the dry pipe valve was similar to other deluge valves in the plant that are tested as part of ST-FP-5, and did not utilize MP-FP-7 to reset the clapper, as required by a step sign off in ST-FP-5.
This was due to inadequate train-ing on the unique features of this system.
MP-FP-7 was not listed in the reference section at the beginning of ST-FP-5, therefore, the operator would not have recognized the need for HP-FP-7 prior to performing this step. Additionally, MP-FP-7 did not con-tain steps to verify that the check valves which prevent fire main water from entering the Instrument Air System, were properly seated prior to returning the dry pipe valve to service.
Had the check valves been properly seated, the dry pipe valve could have remained open without water intrusion into the Instrument Air System.
This was the system configuration in the event of a fire in the diesel generator room.
The check valves were not tested because they were designated as non-class, non-CQE valves and as such, do not have test requirements under ASME Section XI or Section 8.4 of the QA Plan.
3.4
l-l 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 1
Procedure changes to the procedures (ST-FP-5, ST-FP-11, MP-FP-7) for per-formance of testing of the fire protection dry pipe system have been made and incorporated into the plant procedure manuals.
Tnese changes provide better direction for future performance of this surveillance test Since November _1987, surveillance tests performed on a frequency ist than J
or. equal to quarterly require a pre-job briefing prior to performance to ensure that personnel are thoroughly familiar with infrequently used procedures.
Surveillance Tests performed more frequently than quarterly are conducted often enough to prevent this problem.
Training has been conducted on performance of this particular Surveillance Test (ST-FP-5) and its implications.
1 Procedural compliance has been emphasized in small group meetings with available workers and by the plant manager's letter on procedural compliance.
GET has been appropriately upgraded to maintain continued awareness of management requirements.
These actions have resulted in improved procedures, better preparation of personnel conducting these procedures, and continued awareness and improvement in procedural compliance.
4.
THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Training lesson plans.will continue ta be upgraded for operator training so that unique system features are identified as.part of the normal lesson plan revision process. Refer to Attachment 1, Submittal Number Item II.B.2.c for additional information on this task.
OPPD has initiated a major procedures upgrade program.
This program will develop and implement a procedure writer's guide to provide better direction in the. writing of new procedures.
The program will also review and upgrade existing plant procedures.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED I
OPPD is currently in full compliance with regard to the specific violation.
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3.5
l Violation B.2.b l
Procedure A0P-17 " Loss of Instrument Air," Revision 2, dated July 2, 1986, requires the licensee to provide instructions to operations personnel for the mitigation of a plant transient due to the effect of the loss of instrument air on 14 different safety-related systems.
Contrary to the above, Procedure A0P-17 failed to provide adequate instructions to operations personnel in that the procedure did not adequately address the effect of loss of instrument air for each of the safety related systems specified.
For example, the procedure did not address the effect of the loss of instrument air of the radiator exhaust dampers on the emergency diesel generators.
Furthermore, it did not provide specific information regarding the backup capability of the accumulators installed on specific safety-related equipment (e.g., the procedure stated that level indication for the safety injection and refueling water tank would be lost, when in fact, the tank level indication is available up to four hours after the loss of instrument air).
OPPD RESPONSE 1.
ADMISSION OR DENIAL 0F THE ALLEGED VIOLATION OPPD admits the violation occurred as stated.
2.
THE REASONS FOR THE VIOLATION IF ADMITTED OPPD agrees that A0P-17, Revision 2, failed to adequately address the loss of instrument air on some of the safety-related valves, in that the procedure did not provide information about the backup capability of accumulators installed on some of the valves and pneumatic devices.
In 1986, the plant Emergency Procedures were apgraded to the Emergency Operating Procedures (EOP's) in response to NUREG 0737 Supplement 1, Item I.C.1.
Emergency Procedures previously existing which were not covered in the E0P's were converted to a new set of procedures designated Abnormal Operating Procedures (A0P's).
OPPD's basis fo: A0P's was to provide the operator with only the essential information necessary to assist in the recovery following an abnormal event. A0P's are not designed to address every possible situation. A0P-17, therefore, only addressed the ultimate failure mode of the pneumatic devices upon loss of all instrument air reserves.
This information reflects the assumptions made in OPPD's safety analyses which assumes complete loss of instrument air.
3.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The following corrective actions have been taken to revise A0P-17:
In accordance with Reference 8, Section VI-D, OPPD has reviewed and upgrad-ed the operating procedures and abnormal operating procedures on the Instrument Air System to assure that operators are provided with clear, concise information.
j 3.6 1
The Instrument Air System procedures, OI-CA-1, 2 and 3 were reviewed and upgraded.
Procedure changes initiated in October 1987 made necessary clarifications and corrected a minor error.found in AOP-17 related to the failure position of one valve litted in the procedure..The valves remaining operable due to backup air accumulators were listed in a separate attachment to the procedure.
An in-depth revision of A0P-17 was completed in December 1987.
The revi-f sion to the procedure resulted in the following changes:
o a)
Operator actions were divided into Initial and Follow-up Actions.
b)
Step-by-step instructions, for isolation of an air line break were I
provided.
l c)
Steps which were to be performed under the reactor trip immediate actions (EOP-1), were identified as such.
d)
A detailed list of the failure mode of the air operated valves sorted by location was provided in attachments.
j e)
A table containing the valves that remain remotely operable due to backup air accumulators, time duration that they remain operable and their ultimate failure mode has been appended to the procedure.
The plant management has recently initiated a program of verbatim procedure
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compliance.
This program has caused personnel to be more alert to proce-dural deficiencies and resulted in an increase in the number of corrections and clarifications. This effort will continue.
4 CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further action is required, however, programmatic actions are being taken by OPPD in the Procedures Upgrade Program to improve procedures in the future.
The draft cf the Writer's Guide from the Procedures Upgrade Program contains specific provisions and steps for verification and validat%n of a procedure change by the group directly responsible for perforr.dn; the procedure. AOP-17 will be reviewed again by September 1988
?
to ensure its compliance with the Writer's Guide.
5.
THE DATE WHEN FULL COMPLIANCE'WILL BE ACHIEVED OPPD is currently in full compliance with regard to the specific violation.
Other actions planned will provide additional enhancements to A0P-17.
3.7
Violation B.3 Technical Specification 2.7 states, in part, that the reactor shall not be heat-ed up or maintained at temperatures above 300*F unless both diesel generators are operable. Additionally, Technical Specification 2.7 states that if one diesel generator becomes inoperable, it may remain inoperable for up to seven days provided the other diesel is started to verify operability, shutdown and controls are left in automatic mode and there are no inoperable safeguards components associated with the operable diesel generator.
The Definitions section of the Technical Specification states, in part, that a component shall be operable "when it is capable of performing its specified function (s).
Implicit in this definition shall be the assumption that all necessary... auxiliary equipment that are required for the component...to perform its function (s) are also capable of performing their related support function (s)..."
Contrary to the above, the reactor was maintained at temperatures above 300*F for greater than seven days while Emergency Diesel Generator (EDG) 2 was inoperable. On July 6 and August 25, 1987, water entered the Instrument Air System rendering the air accumulator associated with air driven motor for the i
EDG 2 radiator exhaust damper inoperable, thus rendering EDG 2 inoperable.
EDG 1 was not started to verify operability.
This condition existed until discover-ed during a surveillance test on EDG 2 performed September 23, 1987.
OPPD RESPONSE 1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION The alleged violation is denied as r,tated.
The alleged violation is denied as stated, however, OPPD acknowledges the automatic shutdown of Diesel Generator No. 2 (DG-2) at 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br />, Septem-ber 23, 1987.
This shutdown occurred due to high coolant temperatures as a result of partial opening of the exhaust dampers and was acknowledged in Licensee Event Report 87-25. DG-2 had been removed from service for planned maintenance of the exhaust system.
The inability of the equipment to operate was identified during the post maintenance testing of DG-2.
Although OPPD denies the violation as stated, OPPD admits DG-2 inoperabil-ity as identified on September 23 through September 24, 1987.
The following response addresses the admitted inoperability.
2.
THE REASONS FOR THE DENIAL On July 6, 1987 water entered the Instrument Air System and the air accumu-lators associated with the air driven motors for the radiator exhaust dampers. Actions taken by station personnel on July 6 to blow down water in the air lines restored air service to the diesel generators. Water in j
the August 25, 1987 event did not affect any safety related components serviced by the Instrument Air Systam.
Diesel Generator No. 1 (DG-1) suc-cessfully completed its surveillance test on July 8, 1987.
Both diesel generators successfully completed their surveillance tests in August of 1987.
The surveillance test verifies operability and requires the diesel to be loaded for at least one hour.
DG-1 was started to demonstrate operability, but not loaded, on September 22, 1987.
3.8
s 3.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED At 0644 hours0.00745 days <br />0.179 hours <br />0.00106 weeks <br />2.45042e-4 months <br /> on September 22, 1987, when Fort Calhoun Station was operat-ing at full power, DG-1 was started to prove operability prior to perform-ing maintenance on the exhaust pipe for DG-2. At this time, a seven-day Limiting condition for Operation was entered per Technical Specification 2.7.
On September 23, 1987, at 0906 hours0.0105 days <br />0.252 hours <br />0.0015 weeks <br />3.44733e-4 months <br /> CDT, DG-2 was manually started, followed by synchronization and loading at 0911 hours0.0105 days <br />0.253 hours <br />0.00151 weeks <br />3.466355e-4 months <br /> per Operating Instruc-tion 01-DG-2 as required by Surveillance Test ST-ESF-6. At 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br />, DG-2 automatically shut down due to high coolant temperature.
Personnel were immediately dispatched to determine the cause of the overheating.
Investigations revealed that the air operated radiator exhaust air damper YCV-871F may.not have automatically fully opened when the diesel was run-ning, thus restricting the required air flow through the radiator, and subsequently overheating the diesel coolant.
The air to operate the damper is supplied via a pilot valve. As shown on Figure 1, the air to the pilot valve is provided by either the Instrument Air System or an accumulator.
The damper is normally closed to limit the diesel's exposure to cold outside air and it is designed to be open when the diesel is running.
Investigations. revealed that the pilot valve internals had a white, " lime like" residue and the accumulator was partially filled with water. The pilot valve was cleaned, other associated valves and solenoids were inspect-ed and no problems.were found. The accumulator was drained.
The amount of water in the accumulator for DG-2 was not measured.
It was approximately one-half full which represents two quarts of water.
The cause of the damp-er malfunction was postulated to be the presence of the residue causing the I
pilot valve to sometimes stick.
Since the potential existed for.DG-1 to be similarly affected, the DG-1 exhaust dampers were cycled open using the normal air supply from the Instrument Air System and left open to ensure that if DG-1 was required to operate, adequate radiator cooling would be available.
In accordance with the requirements of 50.73(a)(2)(vii), this event was determined to be reportable.
DG-2 was successfully tested and returned to service at 1805 hours0.0209 days <br />0.501 hours <br />0.00298 weeks <br />6.868025e-4 months <br /> on September 24, 1987. At this time, the Technical Specification 2.7 seven-day Limiting Condition for Operation was exited.
Subsequently, DG-1 was removed from service and the instrument air valves associated with the radiator exhaust damper were inspected.
Residue was likewise cleaned from the pilot valve.
Other associated valves and solenoids were inspected and no problems were found. Approximately twelve ounces of water was drained from the accumulated 3.9
FIGURE 1 hf l
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1
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WA F7 f
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alfmotor
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closen I
f damcer j
open 1
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/
j
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Pilot valve sw l
&#flRO leaded Olston l
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During the week of November 7,1987. the internals of the pilot valves were reinspected to investigate if additional residue had built up in the orifice. Minor and insignificant buildup was found. in both valve orifices and the residue was removed. Since. December, 1987 the eight air operated dampers with safety functions have been specifically tested for operability either under a Maintenance Order or a Surveillance Test.
It was determined that DG-1 and DG-2 dampers differ from other valve-component installations at the Fort Calhoun Station.
These operators use a pilot valve with a very small pinhole orifice without a prefilter.
Throughout September, October and November of 1987, other inspections.of equipment serviced by the Instrument Air System were conducted.
In Novem-ber of 1987 an inspection of HCV-385 and 386, SI pump recirculation isola-tion valves, was conducted.
Both valve operators were wetted in July. A regulator and filter installed during May 1987 was disassembled and inspect-ed. No residue was found in the bowls of either regulator, supporting the conclusion that the residue found in September in the air operators, was the product of fifteen years of operation and not material carried into. or created in the Instrument Air System during or since the July 6,~1987 water intrusion.
Following the diesel generator shutdown on September 23, 1987, many eval-uations and investigations were conducted.
In addition, corrective actions have been taken. These evaluations and actions were summarized throughout Reference 8 and the LER 87-025.
Completed actions are summarized in Section I of Attachment I of this submittal.
These evaluations and actions address specific concerns of the Instrument Air System and the programmatic improvements in the areas of design evaluation, design implementation, event evaluation / classification and reporting and corrective actions.
As a result of these and other actions taken to enhance and maintain diesel generator reliability, there have been no failures of the diesel generator to start or complete their surveillance test since September 23, 1987. Air damper operators have functioned properly upon demand.
4.
THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS OPPD is continuing.the many actions presented in Reference 8.
Actions cur-rently in progress are summarized in Section II of Attachment 1 of this sub-mittal. OPPD's implementation of actions and programs is being coordinated
-)
and scheduled so that actions directly resulting from the July 6, 1987
)
event, described in Reference 8, are completed this year. Modi fications and tests which require outage conditions will be completed prior to power operation after the 1988 outage. All instrument air components currently addressed by a safety evaluation to justify operation will be modified or tested prior to power ascension from the 1988 outage.
Likewise, concerns related to the Instrument Air System that resulted from the Safety System Outage and Maintenance Inspection (SSOMI) (status is summarized in ), are also anticipated to be completed this year.
It is anticipated that additional derivative actions to enhance the Instrument Air System will continue to be identified as a result of these direct actions and may not be complete by the end of 1988, but will be completed as soon as material availability and plant conditions allow.
3.11
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED' j
OPPD was in full-compliance with regards to the specific violation on September 24, 1987. Other actions taken as a result of the water intrusion
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event are discussed throughout this submittal and are scheduled to be complete by December 31, 1988.
l 3.12
Violation B.4 Fort Calhoun Station Technical Specification 5.8.1 requires that procedures be established, implemented and maintained that meet or exceed the minimum require-ments of ANSI N18.7-1972 (Sections 5.1 and 5.3).
ANSI N18.7-1972, Section 5.1.6.1 states that maintenance which can affect the performance of safety-related equipment shall be in accordance with w"itten procedures and Section 5.3.5(3) states that instructions shall be 1.. 4d (or referenced) for returning equipment to normal operating status, giving special attention to systems that can be defeated by leaving valves, breakers or switch-es mispositioned.
Contrary to the above, at the time of the NRC inspections, even though misposi-tioning of an instrument air isolation valve led to the August 25, 1987 water intrusion event, the licensee had not provided a procedure or instruction to ensure proper positioning of valves, breakers or switches prior to returning the Instrument Air System to normal operating status.
I OPPD RESPONSE 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLAjj,QH OPPD admits the violation occurred as stated.
2.
THE REASONS FOR THE VIOLATION IF ADMITTED The August 25, 1987 water intrusion event was caused by the mispositioning of a valve (DW-CV-86) following maintenance by non-Operations personnel.
No specific procedural guidance was given to plant personnel regarding the operation of equipment and/or valves by non-Operations personnel.
Guidance was only given in existing procedures to Operations personnel for returning equipment to normal operating status following maintenance or testing.
3.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Actions were taken to ensure that there was no further water intrusion into the Instrument Air System.
This ultimately included physically discon-1 necting and capping the tagged closed isolation valve, thereby leaving the Instrument Air System physically separated from DW-CV-86.
A memorandum was written and distributed to plant staff as a policy state-l ment.
Subsequently, Standing Order 0-29, Conduct of Ooerations, was modi-fled in February 1988 to incorporate this guidance into plant procedures.
Training has been provided to personnel.
Station personnel, both operators and non-operators, now have specific written instructions which leads to an understanding of equipment operating limitations by non-Operations personnel.
4.
THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are planned.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is currently in full compliance.
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3.13 l
Violation B.5 10 CFR 50.47(b)(4) states, in part, that the onsite emergency response plan for nuclear power reactors must contain a standard emergency classification and action level scheme.
The licensee's Procedure EPIP-OSC-1, " Emergency Classifi-cation," implements the requirements of 10 CFR 50.47(b)(4).
Section IV.2 of EPIP-0SC-1 states, in part, the the shift supervisor shall eval-uate the condition and determine the applicable emergency classification.
Note 1.a of Section IV.d defines a notification of unusual event (NOVE) as events in progress or which have occurred which indicate a potential degradation of the level of safety of the plant.
1 Contrary to the above, the shift supervisor failed to determine the applicable emergency classification and declare a NOVE when an event occurred which indi-cated a potential degradation of the level of safety of the plant.
On July 6, 1987 an unknown amount of water from the Fire Protection System was introduced into the Instrument Air System and resulted in a potential common mode failure condition.
OPPD RESPONSE 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION OPPD admits the violation occurred as stated.
2.
THE REASONS FOR THE VIOLATION. IF ADMITTED The violation is attributed to insufficient guidance in Emergency Plan Im-plementing Procedure, EPIP-0SC-1, Emergency Classification. Although the procedure contains classification instructions and descript 1ns as present-ed in NUREG 0654; Figure OSC-1.1 of the EPIP, EAL Criteria for Emeraency Classification, is normally referenced for performing accident classifi-cation.
The chart of Figure OSC-1.1 did not contain or repeat the classi-fication description found in the text of the procedure.
In addition, the condition for " common mode failure" was not expressed in the classification scheme.
l 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED In accordance with Reference 8, Page IX-10, a revision to EPIP-OSC-1, Figure OSC-1.1 has been completed.
The chart now presents a description of each emergency classification. A definition of a common mode failure was I
added, together with identification of four additional plant systems which l
might initiate a potential for a common mode failure, thus, resulting in a i
" Notification of Unusual Event."
Control room table top drill sessions were added to the 1988 emergency pre-(
i l
paredness drill schedule. These drills are designed to optimize operator abilities to perform recognition, evaluation, classification and notifica-i tion of emergency responsibilities.
The student handbook provides the materials for the use of EPIP-0SC-1 in classifying emergencies.
Trair'a l
examination questions have been developed to emphasize common mode f.ure l
as a criteria for emergency classification.
Six operating shifts have i
completed this training, j
3.14 i
As a result, the upgraded EPIP now includes common mode failure considera--
tions as part of the classification process.
OPPD now has a more effective program to ensure additional resources and support can be immediately applied to operational events.
Shift personnel, who are the initial responders to events, are trained and prepared to recognize significant common mode failure situations.
4.
CORRECTIVE STEPS WilICH WILL-BE TAKEN TO AVOID FURTHER VIOLATIONS The'. emergency preparedness training will continue and is scheduled to be complete in August 1988.
5.-
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is currently'in full compliance with regard to the specific violation.
Six operating shifts have completed training on common mode
-failure as a possible criterion for deportability and are the individuals
. assigned the responsibility to evaluate incidents.
Other individuals will receive this training with scheduled completion in August 1988..
3.15
Violation B.6 10 CFR 50.72 states, in part, that each nuclear power reactor licensee shall notify the NRC Operations Center via the Emergency Notification System, within one hour, of any event or condition during operation that results in the condi-tion of the nuclear power plant being in an unanalyzed condition that signifi-cantly compromises plant safety.
10 CFR 50.73 states, in part, that the holder of an operating license for a nuclear power plant shall submit a Licensee Event Report (LER) within thirty days after the discovery of any event where the plant is in an unanalyzed condition that significantly compromises plant safety.
Contrary to the above, the licensee failed to notify the NRC Operations Center within one hour and failed to submit an LER within thirty days, of an event that resulted in an unanalyzed condition that significantly compromised plant safety. On July 6, 1987, an undetermined amount of water was introduced into the Instrument Air System and resulted in a potential common mode failure condi-tion.
The plant was in an unanalyzed condition in that the licensee did not determine the capability of the Instrument Air System to provide the motive force for operation of redundant safety-related equipment and components for at least two days after the water from the Fire Protection System was introduced into the Instrument Air System.
OPPD RESPONSE 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION OPPD admits the violation occurred as stated.
2.
THE REASONS FOR THE VIOLATION IF ADMITTED Station personnel were not cognizant of the potential failure condition caused by the water intrusion event because of inadequate guidance and training with regard to common mode failures.
Therefore, the reporting process to satisfy requirements of 10 CFR 50.72 and 50.73 were not initiated.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Licensee Event Report 50-285/87-033 was submitted to address the July 6 water intrusion event.
To resolve the issue concerning OPPD's failure to adequately determine the one hour reporting requirement for the July 6, 1987 event, changes to Fort Calhoun Station Standing Order G-43, Shift Technical Advisor, and Standing Order R-4, Station Incident Reports have been completed.
The revised procedures instruct the Shift Technical Advisor to perform a safety assessment (10 CFR 50.59 evaluation) for any event that places the plant in an abnormal situation or for any plant parameter that affects or reflects an abnormal indication of a safety-related system.
Upon completion of this assessment, the Shift Technical Advisor is instructed to initiate an Incident Report in conjunction with assisting the Shift Supervisor in determining one and four hour reportable events.
3.16
i The. Incident Report is:the primary mechanism to ensure that incidents are properly classified as one hour,:four hour or thirty day LER reportable events. By the completion of the safety. assessment, the Shift Technical Advisor, the Shift Supervisor and plant management have the tools and information available to correctly assess the correct status of the plant.
Further,-the safety analysis procedure, NPD Quality Procedure QP-3 was revised November 15,1987-to better improve the quality of safety evaluation of events, modifications and procedure changes.
With data available, plant management can determine the appropriate course of action. Additionally, this information can be vital to ensure that the NRC Operation Center is appropriately advised of the situation in progress.
To resolve the issue concerning OPPD's failure to adequately determine the thirty day reporting requirement for the July 6, 1987 event, a change to Fort Calhoun Station Standing Order R-4, Station Incident Reports, has been implemented.
According to R-4, as soon as any abnormal operational. occur-l rence, Technical Specification or Licensee violation, nuclear material j
accountability anomaly, design deficiency, or radiological hazard is iden-tified, station personnel are directed to initiate a Station Incident Report. Upon completion of the Incident Report,.the initiator is respon-l sible for notification of the Shift Technical Advisor to start reportabil-1 ity determination.
Subsequent to this, to ensure that no Station Incident Reports go unprocessed for longer than eight hours, Standing Order G-43, l
Shift Technical Advisor, and Standing Order R-4, require the Shift j
j Technical Advisor at the beginning of each shift (when the Reactor Coolant System temperature is above 210*F) to access the computer to perform a review of unreviewed Station Incident Reports which may be present on the system.
[ Note:
Below a Reactor Coolant System temperature of 210*F, STA's are not required to be on shift and a designated Incident Report reviewer will be appointed by the Incident Evaluation Coordinator.]
The Shift Technical Advisor, in consultation with the Shift Supervisor, will determine the deportability requirements. The Shift Technical Advisor will inform the Incident Evaluation Coordinator concerning any event which has been determined reportable.
The Incident Evaluation Coordinator will verify that the determination of deportability is applicable.
After the Incident Evaluation Coordinator substantiates the discovery, a recommendation is made to the Plant Review Committee concerning the dispo-sition of incident. Concurrently, the Incident Evaluation Coordinator assigns an Action Addressee to investigate the circumstances surrounding the incident, determine and institute appropriate corrective actions, and write the LER.
Prior to the July 6, 1987 event, the thirty day LER reporting decision was made per Standing Order R-4.
This Standing Order required the PRC to review all Incident Reports for thirty day deportability.
The above described changes were instituted to focus attention on deportability. The Shift Technical Advisor performs an initial investigation of the event using NUREG-1022 as a guideline for deportability.
The Incident Evaluation Coordinator reviews all events for deportability.
The Incident Evaluation Coordinator takes all events to the PRC and directs discussion on reportable and potentially reportable events.
This focuses questions, comments and LER criteria. The focus and directed responsibility for recommending deportability ensures the PRC of a clearer description of the event and its consequences.
3.17
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9
In order to provide in-depth investigation of any event at the Fort Calhoun Station, a Nuclear Production Division Quality Procedure, QP-18, to initiate a Management Investigative Safety Team (MIST), has been issued. The purpose of this policy is to charter a team, composed of key management personnel, to be responsible for collecting and preserving data, analyzing event significance and identifying root cause.
The Nuclear Production Quality Procedure was-recently issued and has not had an occasion for implementation. The effectiveness of this procedure remains to be demonstrated.
The above actions have resulted in an upgrade in on-shift capability to assess and report events and unusual plant conditions.
This process has been demonstrated as effective.
Further, if a significant event occurs, an investigative effort can now be implemented.
4.
THE CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Additional training on common mode failure will be included as part of the emergency preparedness training as discussed in the response to Violation B.S.
Scheduled completion for training is August 1988.
5.
THE DATE WHEN Full COMPLIANCE WILL BE ACHIEVED OPPD is currently in full compliance with regard to the specific viola-tion.
Six operating shifts have completed training on common mode failure as'a possible criterion for deportability and are the individuals assigned the responsibility to evaluate incidents. Other individuals will receive this training with scheduled completion in August 1988.
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4 3.18 l
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i ATTACHMENT 4 VIOLATION C CORRECTIVE ACTION l
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ATTACHMEhT 4 VIOLATION C: CORRECTIVE ACTION 10 CFR Part 50, Appendix B, Criterion XVI and Sectio'n 10.4 of the OPPD Quality Assurance Plan requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, these measure must assure that the cause of the condition is determined and corrective action is taken to preclude repetition.
Contrary to the above, water from the Fire Protection System was introduced into the Instrument Air System on July 6,1987 the licensee failed to determine the cause of the condition adverse to quality and failed to take corrective action to preclude repetition such that:
1.
After introduction of water into the Instrument Air System on July 6, 1987, the licensee did not perform dew point measurements of air in the system to verify that the system complied with the design bases for the dew point maximum limit.
2.
Even after water was introduced into the Instrument Air System through tne connection that maintained the portion of the Fire Protection System in the emergency diesel generator rooms as a dry-pipe system, the licensee cleaned and inspected the associated check valves to verify proper operation and reinstalled the interconnection between the Fire Protection and Instrument Air Systems.
By reinstalling the interconnection, the licensee reesta-blished, in its original configuration, the condition that had led to the introduction of water into the Instrument Air System.
3.
After the introduction of water into the Instrument Air System, the licensee did not perform a review to determine whether other instrument air / pressurized water interfaces existed in the system.
Subsequently, on August 25, 1987, another event occurred in whic:, water was introduced into the Instrument Air System through an interface with a plant water system.
4.
After the introduction of water into the Instrument Air System, the licensee commenced a formal program for performing blowdowns to remove the water and/or moisture from the Instrument Air System.
However, the licensee failed to blowdown some accumulators to verify that water and/or moisture was not present.
For example, water was found in the accumulator for the Emergency Diesel Generator (EDG) 2 radiator exhaust damper during an investigation performed after EDG 2 failed its surveillance test on September 23, 1987.
This is a Severity Level III violation (Supplement I) 1 Civil Penalty - 550,000 l
l 4.1
i RESPONSE TO VIOLATION C 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION OPPD sdaits the violation occurred as stated.
2.
THE s iSONS FOR THE VIOLATION IF ADMITTED The reason for the violation was that a formal systematic event evaluation program did not exist to identify safety impact, potential for recurrence, generic implications and root cause. As a result, corrective actions that were taken in July and August of 1987 were limited to only the identified 1
concerns /causes and did not correct concerns /causes of importance which '
were not' identified. The first three specific examples cited in the violation occurred as a consequence of inadequate determination of cause.
The fourth specific example occurred because the information on drawings L
was not sufficient for the purpose for which the drawings were.being used.
i 3.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 1
In order to promptly evaluate events for safety impact, potential for re-currence, generic implications and human error causes, the Fort Calhoun f
Station Standing Order on Station Incident Reports, R-4, was revised on November 6 1987 and February 25, 1988. The revisions provide a systematic approach to the initiation of the processes associated with an effective j
corrective action system, e.g. identification, evaluation and correction of i
problems. The safety significance and deportability of an event occurring on a shift _ are being evaluated by the Shift Supervisor and the Shift Techni-cal Advisor.
Subsequently, the Incident Evaluation Coordinator tracks the Station Incident Report through closeout.
He determines and assigns relative significance, assigns the action addressee, verifies supervisor i
approval and corrective action completion and ensures that industry signficant events have been promulgated. He also coordinates the Incident Evaluation Committee for data, root cause, Human Performance Evaluation and trend analysis and has trend and summary evaluation and reports prepared for submittal to the PRC. He incorporates applicable PRC comments into the analysis in preparation for forwarding the reports to NPD management and SARC.
l In addition, NPD Quality Procedure QP-18 was initiated in April 1988 to establish a mechanism for formally mobilizing a Management Investigative Safety Team (MIST) to organize and direct the evaluation of an event.
This includes the efforts to collect and document pertinent information and performance of event evaluation.
These reviews and evaluations are currently adequate to meet regulatory compliance, however, further improvements have been planned to augment the process of identification, evaluation and correction as stated in Standing Order R-4.
These improvements are described in Section 4, Steos that Will Be Taken to Avoid Further Violations.
Further details of the Station Incident Report process are enclosed in this response in Attachment 3 under Item B.6.
Actions to correct the specific examples cited in this violation are stated after Item 5 of this violation response.
4.2
As a result of revising Standing Order R-4 and issuing NPD Policy / Procedure E-1,10CFR50.59 Safety. Evaluations, in November 1987 the systematic process for identification and appropriate evaluation of routine events has been initiated.
A significant event has not occurred which would necessitate a management investigation.
This has resulted in documentation and review of events experienced by or reported to the Shift Supervisor or STA.
- 4. THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS As part of OPPD's effort to achieve Excellence in Operations at the Fort Calhoun Station. a Special Projects team titled Project 1991 was esta-blished in the fall of 1987. One project managed by Project 1991 is the Trending and Root Cause Analysis program development project.
The objec-tive of this project is to establish a formal methodology which will in-clude the rigorous application of a program by which unplanned or recurring incidents at the station are systematically tracked and evaluated for poss-ible entry into a root cause determination process.
The project includes policy and procedural development and revision in various areas including maintenance history trending, station incident reporting, human performance evaluation and quality assurance with the overall goal of improving station safety, reliability and availability.
Several organizational revisions have been proposed at the Fort Calhoun Station as part of this project.
This includes the implementation of the Systems Engineering concept, a Safety Review Group, and enhanced role and responsibilities for the computerized equipment and maintenance. history data management group.
One of the elements of the root cause program will be the establishment of a Safety Review Group (SRG).
The purpose of this group will be to perform independent review of selected activities in the areas of operations, main-tenance, chemistry, radiation protection, engineering, emergency planning, security and training. The SGR will be responsible for reviewing selected operating abnormalities, violations, LER's, NRC and industry issuances relating to significant safety issues.
The group will be responsible to develop recommendations to prevent the occurrence of incidents with poten-tial nuclear safety consequences.
The SRG will be a permanent organization at the station and will not be under the direction of the line management organization of the station.
l The group, as a minimum, will consist of experienced personnel with exper-l tise in various operational, administrative, technical and maintenance related activities at the station.
The SRG may, at times request personnel with special expertise to assist with a specific incident evaluation.
Also in development is the establishment and implementation of the Human I
Performance Evaluation System (HPES) patterned after INP0 Guidelines.
The Coordinator of HPES will direct all HPES activities.
They will provide HPES input and support to the SRG.
The ultimate goal of HPES is to improve overall station performance through the identification and correction of human performance related problems as it relates to inappropriate actions, near misses or potential problems.
The HPES program evaluates human perfor-mance situations using proven techniques to identify the root cause(s) and recommends appropriate corrective action to prevent recurrence of the evalu-l 4.3 l
1
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1 ated situation.
To the fullest extent possible, the HPES program will be nonpunitive with emphasis placed on the identification and correction of the factors affecting human performance. Through the HPES Coordinator, reporters of situations will remain anonymous if they desire.
i A third organization, currently being planned, is the establishment of the System Engineer.
Qualified personnel will be assigned the overall respon-sibility for selected station systems.
Their duties and responsibilities will be clearly defined and by other station support groups and the lines of communication with other departments clearly delineated. The Systems Engineers will be involved with such duties as evaluating system perform-ance, trending significant system parameters and initiating action to correct equipment problems.
The Systems Engineers will be responsible for trending system component failures and will assist with the root cause of failure analysis of the system.
Therefore, the Systems Engineers will provide input for operating and maintenance procedure development. Addi-tionally, they will review updates to the Computerized History and Mainten-ance Planning System data base for their system. This will include not I
only the equipment record, but also associated changes to the preventive I
maintenance schedule, vendor manual, surveillance test schedule and applicable procedures.
The root cause program is currently in development and will be initiated by July 1988.
The SRG and System Engineer group will be developed and staffed in conjunc-tion with the implementation of changes resulting from the Independent Appraisal of the Nuclear Operations functions at OPPD.
This appraisal is currently underway and is to be completed by June 1, 1988 in accordance with Reference 8,Section VI.A.
In addition to the establishment of the new groups and functions described above, a review of the PRC's tasks and functions will be initiated to assure that PRC members are formally trained to perform their safety func-tions. A job analysis of PRC functions will be performed.
The results of the analysis will serve as a basis for developing a PRC training program.
The PRC members would then be scheduled to complete the appropriate train-ing. A schedule for performing the job analysis, development of a training program and completion of training will be provided by July 1989.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is currently in full compliance with regard to the specific violations stated. Other actions planned will provide additional enhancements.
Note: The preceding information is OPPD's response to the overall violation on corrective actions.
The following information is OPPD's response to the specific examples cited supporting the overall violation.
4.4 l
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Comments / Status of Soecific Examoles Example 1: After introduction of water into the Instrument Air System on July 6, 1987, the Licensee did not perform dew point measurements of air in the system to verify that the system complied with the design bases for the dew point maximum limit.
Response
At the time of the July and August events, no formal program existed for monitoring of the dew point of the Instrument Air System. As a result, no immediate actions were taken to ascertain the effect of the water intrusion event on system dew point.
In accordance with Reference 8, Page V-1, a baseline dew point sampling program was established and dew point readings were taken at eighteen selected sample locations throughout the plant to establish that a dew point better than (i.e. less than) -20'F was being maintained.
The results of l
this program were that all points were found to be below the -20*F limit.
j Also, in accordance with Reference 8, Page V-1, a sampling program for Instrument air was established to sample the system weekly, monitoring both dryer towers.
Instrument air dew point is being maintained at approximately
-50*F dew point. An on-line moisture indicator has been installed on the dryer outlet to provide warning of a gross failure of the instrument air dryer.
l Changes to Operating Instructions (OI-CA-1) to provide operator actions, in the event of high moisture content of instrument air, have been implement-ed. These instructions provide specific operator actions to correct a dew point greater than -20*F.
A modification to upgrade the instrument dryer, including installation of an on-line dew point analyzer, is planned to be completed by March 31, 1989.
)
An on-going program of dew point sampling and analysis has been established.
Two points requiring generic action are raised by this example:
1.
The evaluation of events must also identify transient parameters' relationship to design maximum limits for both during and after the event.
This will be incorporated into the methodology of the event evaluation or root cause determination programs to be established by July 30, 1988.
2.
The USAR may contain other references to system parameters and design l
limitations on nonsafety grade systems which may not be included in formal monitoring programs. As a result, the USAR will be reviewed to identify which system performance parameters with design limitation l
should be monitored.
This review will be completed by December 1988.
Additional monitoring, if required, will be initiated during 1989.
4.5
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Example 2: Even after water was introduced into the Instrument Air System i
through the connection that maintained the portion of the Fire Protection System in the emergency diesel generator rooms as a dry-pipe system, the licensee clean-ed and inspected the associated check valves to verify proper operation and rein-stalled the interconnection between the Fire Protection System and Instrument Air System.
By reinstalling the interconnection, the licensee reestablished, in its original configuration, the condition that had led to the introduction of water into the Instrument Air System.
Response
Plant personnel-utilized procedural improvements to ST-FP-5 to minimize the water intrusion possibility. A modification was requested to eliminate this connection, however, no specific instructions to expedite the performance of this work were given because Station personnel believed that procedural im-provements were sufficient to prevent recurrence.
In accordance with Reference 8, Page VI-3, the Instrument Air System was isolated and disconnected from the Fire Protection System on October 2, 1987. The dry pipe system was subsequently connected to the compressed air system and the procedure for testing was upgraded to ensure proper functioning of the check valves.
Completion of the modification by the end of June, 1988 to permanently pro-vide an independent air source for the Fire Protection System previously connected to the Instrument Air System will prevent recurrence.
Example 3: After the introduction of water into the Instrument Air System, the licensee did not perform a review to determine whether other instrument air / pres-surized water interfaces existed in the system.
Subsequently, on August 25, 1987 another event occurred in which water was introduced into the Instrument Air System through an interface with a plant water system.
At the time of the July event, as stated above, the event was not properly evaluated and therefore, the ramifications of the event were not fully understood.
Corrective actions utilized procedural improvements to ST-FP-5 to minimize the water intrusion possibility.
No other dry pipe valves with a similar connection to the Instrument Air System existed.
l In December, 1987 a study was conducted to identify other interfaces between instrument air and fluid systems with a potential for introduction of fluid into the Instrument Air System.
The interface with bubblers was evaluated.
Bubblers were identified to exist for monitoring the level on the safety injection and refueling monitor tanks, and the diesel fuel oil tank.
These tanks are maintained at atmos-pheric pressure.
In the event of a loss of Instrument Air pressure, tank pressure would be insufficient to pass any significant quantity of liquid through the line from the tank, the bubbler and regulator, and the Instru-ment Air line.
Bubblers, therefore, do not present a concern regarding liquid intrusion into the Instrument Air System.
4.6 1
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l Diaphragm valves, another type of interface, were also evaluated. This l
interface could occur when a diaphragm is used within a valve structure for process liquid control and the valve actuator is physically connected to the valve body such that an uninterrupted flow path exists between the body and actuator.
In the event of a diaphragm failure and loss of instrument air pressure, water could travel into the air system. Multiple failures are i
required to have intrusion through diaphragm valves. Those valves for which this internal interface is applicable have been identified. Analyses were made of the potential for these internal interfaces to introduce water into I
the Instrument Air System. Analysis has concluded that no hazard to the Instrument Air System with respect to a water intrusion event exists from these valves.
Water Plant Valves Numerous Grinnell-Saunders diaphragm control valves are used in the water plant due to the caustic nature of the liquids processed.
In these type of valves, a rubber diaphragm is used for control.
This diaphragm is connected by a valve stem to the valve actuator.
In order for process liquid to enter the air system, a diaphragm failure must occur, the liquid must pass a seal 2
on the stem and a loss of instrument air must occur.
For liquid to leave the water plant it would have to travel through a minimum of 10 ft. of 3/8 inch tubing (for most valves this distance is much farther, 50-60 ft.).
It must then pass backwards through an air pressure regulator, fill up the water plant air receiver, and finally pass through a check valve. The water plant requires instrument air to operate, therefore, it is unlikely that a pressure would exist during the instrument air loss to cause such an event.
Therefore, these valves present no hazard to the instrument air system with respect to a water intrusion event.
LCV-533A. LCV-5338. LCV-534A. LCV-5348. WD-PCV-1. WD-PCV-2. WD-PCV-3.
WD-PCV-4 These valves are Grinnell-Saunders valves utilizing an internal diaphragm installed on the waste gas compressors WD-28A and WD-288. All valves except WD-5338 and WD-534B are interfaced with the waste gas system across the dia-phragm and, therefore, no water intrusion possibility exists. Also, the compressors would be shut down during a loss of instrument air event and no j
waste gas pressure would exist to push this gas into the Instrument Air 1
System. WD-5338 and WD-5348 are interfaced with the demineralized water l
system.
For this water to enter the instrument air system would require a diaphragm failure, a seal failure on the valve stem, and a loss of instru-ment air. Water would then have to pass backwards through a regulator, and j
through 3/8 inch tubing greater than 20 ft. long to the main air header.
l This is a very low probability event and therefore, these valves do not present any concern with regard to water intrusion into the instrument air system.
HCV-2805A. HCV-28058 These valves are Galigher style pinch valves which consist of a rubber boot inside of the valve body pressurized by instrument air.
They are the back-wash control valves for the raw water pump strainers.
The potential for a diaphragm rupture to result in water intrusion into the instrument air sys-tem was considered in their design.
A check valve was placed on the instru-ment air supply line to prevent water flow up the line.
A water intrusion 4.7 J
event would require a ruptured diaphragm, a failed check valve, and a loss of instrument air pressure. Raw water would have to pass through the ruptur-ed diaphragm, through the ASCO solenoid valve (open only for one minute out of five, backwash cycle), backwards through the check valve, through a regu-lator, through a filter assembly, and through approximately 10 ft. of 3/8 inch tubing to reach the instrument air header. A ruptured diaphragm would be quickly detected since the strainer would go into continuous backwash.
Water intrusion from these valves is, therefore, not a concern.
PASS System Valves The post accident sampling system utilizes a large number of internal dia-phragm style valves which were evaluated for their potential for water intrusion into instrument air.
The large majority of the valves are Auto-clave Engineers diaphragm valves.
The diaphragm in these valves does not have a direct water-instrument air interface, therefore, there is no poten-tial for water intrusion. HCV-6746 is a Grinnell valve with the potential for an interface, however, the construction of this valve is such that two diaphragms exist between Instrument Air and the sampled fluid.
HCV-6741 and HCV-6743 are Grinnell valves which utilize an internal diaphragm which is a potential interface.
For sampled fluid to reach the Instrument Air System, it would require a ruptured diaphragm, a failure of the stem seal, and a loss of instrument air.
The entire PASS system is protected by a check valve on the air inlet line. None of the PASS valves, therefore, represent a concern with regard to water intrusion.
LCV-1984 LCV-1984 is the drain valve for the cyclone separator on the screen wash pumps.
This is a Saunders valve with an internal diaphragm. Water intru-sion would require diaphragm failure, packing failure on the valve stem, and a loss of instrument air.
Since this valve is on a drain the water would i
take the path of least resistance to the drains and not flow through the flow restrictions between the water and instrument air.
This valve, there-
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fore, is not a concern with regard to water intrusion.
It is expected that any other diaphragm valves not identified by this search will also have an extremely limited potential for introduction of water into the Instrument Air System due to the design of these valves.
A further walkdown is planned to ensure that all such internal interfaces are identified.
In accordance with Reference 8,Section VI.M, a system engineer has been assigned responsibility for the Instrument Air System.
In conjunction with the revision to design procedures, this individual will remain cognizant of all maintenance and modifications regarding instrument air, and prevent the possibility of installation of new interfaces.
Example 4: After the introduction of water into the Instrument Air System, the licensee commenced a formal program for performing blowdowns to remove the water and/or moisture from the Instrument Air System.
However, the licensee failed to blowdown some accumulators to verify that water and/or moisture was not present.
For example, water was found in the accumulator for the Emergency Diesel Gener-ator (EDG) two radiator exhaust damper during an investigation performed after EDG two failed its surveillance test on September 23, 1987.
4.8
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. Response:
In development of'the formal program for blowdowns'of the Instrument Air System, the plant P&ID's were:used to trace the path of the water intrusion and develop the plan for accumulator and valve blowdown.
The Instrument Air System P&ID did not show the accumulators, therefore,.
they were not blown down in any of.the blowdown efforts. - Walkdowns of other systems and revision of drawings is planned as each System Engineer studies their assigned system.
A complete walkdown of the Instrument Air System was completed October 16, 1987 to verify the accuracy of the P&ID's.
As a result of this walkdown, additional valves were blown down to remove water from the system.
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ATTACHMENT 5 SS0MI CONCERNS RELATED TO THE INSTRUMENT AIR SYSTEM STATUS OF THE SAFETY.RELATED AIR' ACCUMULATOR TESTING
________._______.__._._____z__.
ATTACm ENT 5 SSOMI CONCERNS RELATED TO THE INSTRUMENT AIR SYSTEM Status of Safety Related Air Accumulator and Check Valve Testing In response to the SSOMI audit (Reference 18), OPPD has committed to identify all CQE air operators which are equipped with air accumulators, and determine the operating criteria for each of these valves (Reference 19).
OSAR 87-10 was developed to evaluate the safety function of all air accumu-lators.
Independent review of the OSAR was completed on April 6, 1988.
Follow-i ing is a summary of the findings:
Of the ninety-six air accumulators, fifty-eight are associated with valves that do not perform a post accident function and are not required to be repositioned following a DBA.
Thirty-eight air accumulators are relied upon to perform a specific post DBA function.
Of the thirty-eight air accumulators, thirty-four service thirty-five valves (LCV-383-1 and LCV-383-2 share an accumulator) that are required to perform a 4
post accident function and the remaining four provide air to the Safety i
Injection and Refueling Water Tank (SIRWT) level indicators (bubbler).
Six of the thirty-five valves (HCV-238, HCV-239, HCV-240, HCV-712A, HCV-385 and HCV-386) were tested during the 1987 outage. Two air accumulators were tested during the 1985 outage (YCV-1045A and YCV-1045B).
Sixteen air accumulators (HCV-400 A/B/C/D, HCV-401A/8/C/D, HCV-402A/B/C/D and HCV-403A/B/C/D) were func-tionally tested on line between November 1987 and April 1988.
The OSAR was recently revised and as a result, it was determined that the tests performed on HCV-238, HCV-239 and HCV-240 did not ensure operability of these valves for the required length of time.
The operability requirement for HCV-385 and HCV-386 increased from four hours to twelve hours.
A total of seventeen air accumulators remain to be tested or modified in order to ensure that they perform their design function as defined in the 0SAR.
Two accumulators (HCV-385 and HCV-386) need to be retested to satisfy the twelve hour operability requirement.
Pending this testing, a safety evaluation has been prepared to assess the potential safety impact of continued operation.
The attached tables summarize the testing of the air accumulators and check valves and show the air accumulators included in the safety evaluation.
Of the thirty-eight air accumulators, twenty had the check valves tested for leakage in October 1987 to verify that they remain operable as a result of the water intrusion event of July 6,1987. The SIRWT bubbler check valves (A-D/FIC-383) were replaced with new, leak tested valves on April 15, 1988.
Seven other check valves were tested in April 1988.
Modifications scheduled to be completed prior to power operation following the 1988 refueling outage, subject to availability of material are as follows:
1.
Modification of LCV-383-1 and LCV-383-2 to allow valve to remain closed for approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> after a DBA (EEAR FC-88-33).
5.1
2.
Evaluate the design basis for HCV-438B and HCV-438D and modify if necessary (EEAR FC-88-36).
3.
Modification to insure a single failure proof path for hot leg injection indefinitely (EEAR FC-88-35l.
4.
Modification to instrument air isolation valses to the SIRWT bubblers, to allow check valve testing during power operation (EEAR FC-88-39).
5.
Nitrogen backup to the air supply to the air accumulators on HCV-344 and HCV-345 will be provided to assure post accident operability of the valves.
Note:
The air accumulators serving HCV-344 and HCV-345 are not safety relat-ed, however, a backup to the air supply will be provided to ensure indefinite operability of the valves in both the open and closed position. (EEAR-FC-88-40) i i
i 5.2 L - -
I TABLE I SAFETY RELATED ACCUMULATOR TESTING AND OPERATIONAL STATUS SAFETY VALVE TAG ACCUMULATOR FUNCTIONAL ANALYSIS FOR t
NO.
NO.
TEST OPERABILITY REMARKS 1 HCV-238 M0 No. 872293, 5/87 FC-703-88 Modification of the hot leg injection path EEAR-FC-88-35.
2 HCV-239 M0 No. 872293 5/87 FC-703-88 Modification of the hot leg injection path EEAR-FC-88-35.
3 HCV-240 M0 No. 872293 5/87 FC-703-88 Modification of the hot leg injection path i
EEAR-FC-88-35.
i 4 HCV-304 MR-FC-82-132 4/87 FC-703-88 i
5 HCV-305 MR-FC-82-132 4/87 FC-703-88 i
i 6 HCV-306 MR-FC-82-132 4/87 FC-703-88 7 HCV-307 MR-FC-82-132 4/87 FC-703-88 8 HCV-438B No FC-703-88 Evaluation and modi-fication if nece sary EEAR-FC-88-34 9 HCV-4380 No FC-703-88 Evaluation and modi-fication if necessary s
EEAR-FC-88-34
)
i 10 LCV-E3-1 No FC-703-88 Mechanical jumper for N, back-up on 4-6-88, EEAR-FC-88-33 issued j
for modification
)
11 LCV-383-2 No FC-703-88 Mechanical jumper for Np back-up on 4-6-88, EEAR-FC-88-33 issued for modification 12 A/FIC-383 Ne FC-703-88 Modification EFAR-FC-88-39 to allow check valve testing during power operation 13 B/FIC-383 No FC-613-88 Modification EEAR-FC-88-39 to allow check valve testing during power operation 5.3
l SAFETY RELATED ACCUMULATOR TESTING AND OPERATIONAL STATUS SAFETY VALVE TAG ACCUMULATOR FUN ^TIONAL ANALYSIS FOR-NO, NO.
TEST OPERABILITY REMARKS 14 C/.FIC-383 No FC-703-88 Modification EEAR-FC-88-39 to allow check valve testing i
l during power operation i
15 D/FIC-383 No FC-703-88 Modification EEAR-FC-88-39 to allow check valve testing during power operation 16 HCV-385 MR-FC-87-24, 5/87 FC-703-88 Functional re-test for twelve hours, 1988 refueling outage 17 HCV-386 MR-FC-87-24, 5/87 FC-703-88 Functional re-test for twelve hours, 1988 refueling outage 18 HCV-400A M0 No. 875213 FC-703-88 19 HCV-4008 M0 No. 875213 FC-703-88 20 HCV-400C N0 No. 875T13 FC-703-88 21 HCV-4000 M0 No. 875213 FC-703-88 22 HCV-401A M0 No. 875213 FC-703-88 23 HCV-4018 M0 No. 875213 FC-703-88 24 HCV-401C H0 No. 875213 FC-703-88 25 HCV-401D M0 No. 875213 FC-703-88 26 HCV-402A M0 No. 875213 FC-703-88 27 HCV-4028 M0 No. 875213 FC-703-88 28 HCV-402C M0 No. 875213 FC-703-88 29 HCV-402D M0 No. 875213 FC-703-88 30 HCV-403A M0 No. 875213 FC-703-88 31 HCV-4038 M0 No. 875213 FC-703-88 32 HCV-403C M0 No. 875213 FC-703-88 33 HCV-403D M0 No. 875213 FC-703-88 5.4
SAFETY RELATED ACCUMULATOR TESTING AND OPERATIONAL STATUS SAFETY VALVE TAG
-ACCUMULATOR FUNCTIONAL ANALYSIS FOR
___NO.
NO.
TEST OPERABILITY REMARKS
(
34 HCV-712A M0 No. 872487, 5/87 35 YCV-1045A'
.MR-FC-83-~185, 1/86 FC-703-88 36 YCV-10458 MR-FC-83 -185, 1/86 FC-703-88 37 YCV-871E M0 No. 874570, 10/87 FC-703-88 38 YCV-871F M0 No. 874509, 9/87 FC-703-88 39 HCV-2987 No' FC-703-88 Nitrogen back-up-provided by mechanical jumper-NOTE: All safety related air accumulators will have been tested to verify their function with a " slow leak" of the instrument air supply by the end of the 1988 refueling outage.
The " slow leak" testing will be performed in accordance with the guidelines of NUREG 1275, Volume 2.
5.5
TABLE 2 SAFETY RELATED CHECK VALVE TESTING AND OPERATIONAL STATUS I
VALVE TAG CHECK VALVE SAFETY ANALYSIS NO.
NO.
TESTING FOR OPERABILITY REMARKS 1
HCV-238 No (See Note)
HCV-239 No (See Note)
HCV-240 No (See Note)
HCV-304 M0 No. 875106, 10/87 5
HCV-305 M0 No. 875106, 10/87 6
HCV-306 M0 No. 875106, 10/87 7
HCV-307 M0 No. 875106, 10/87 8
HCV-438B M0 No. 875106, 10/87 9
HCV-4380 M0 No. 875106, 10/87 10 LCV-383-1 No Mechanical jumper with nitrogen back-up since 4/6/88 11 LCV-383-2 No Mechanical jumper with nitrogen back-up since 4/6/88 12 A/FIC-383 M0 Nc. 881460, 4/88 13 B/FIC-383 M0 No. 881460, 4/88 14 C/FIC-383 M0 No. 881460, 4/88 15 D/FIC-383 MO No. 881460, 4/88 16 HCV-385 N0 No. 875106, 10/87 17 HCV-386 M0 No. 875106, 10/87 18 HCV-400A M0 No. 875213 19 HCV-4008 M0 No. 875213 20 HCV-400C M0 No. 875213 21 HCV-4000 M0 No. 875213 22 HCV-401A M0 No. 875213 5.6
7 L,
' SAFETY RELATED CHECK VALVE TESTING AND OPERATIONAL STATUS VALVE TAG CHECK VALVE SAFETY ANALYSIS NO.
NO.
TESTING FOR OPERABILITY REMARKS 23 HCV-4018 M0 No. 875213 24 HCV-401C M0 No. 875213 25 HCV-4010 M0 No. 875213 26 HCV-402A M0 No. 875213 4
27 HCV-4028 M0 No. 875213 28 HCV-402C M0 No. 875213 29 HCV-402D M0 No. 875213 30 HCV-403A M0 No. 875213 31 HCV-403B M0 No. 875213 32 HCV-403C M0 No. 875213 33 HCV-403D M0 No. 875213 34 HCV-712A M0 No. 875106, 10/87 35 YCV-1045A M0 No. 875106, 10/87 36 YCV-1045B M0 No. 875106, 10/87 37 YCV-871E No (See Note)
FC-703-88 Modification EEAR-FC-87-63 to replace damper I
operators 38 YCV-871F No (See Note)
FC-703-88 Modification EEAR-FC-87-63 to replace damper operators 1
39 HCV-2987 No Nitrogen back-up provided to valve NOTE: Accumulator functional testing implicitly verified check valves 5.7
ATTACHMENT 6 UPDATE OF THE INSERVICE INSPECTION PROGRAM PLAN I
I i
l ATTACIMENT 6 UPDATE OF THE INSERVICE INSPECTION PROGRAM PLAN In the November 20, 1987 submittal to the NRC (Reference 8, Table IX-1), OPPD included a list of 164 valves which were evaluated as necessary for performing a safe plant shutdown or to mitigate the consequences of an accident.
The list also included the testing frequency of the valves which were included in the ISI program.
The IST inspection conducted by the NRC on October 14-15, 1987 and the instrument air problems, resulted in reviews of the safety function of air operated valves, and led to the addition of approximately forty-five valves and/or check valves to the IST testing program.
These valves are included in the list of 164 valves.
A further update of the plan is necessary to be consistent with the safety related accumulator list developed as a result of OSAR 87-10.
The update will consist of adding to the ISI valve program the check valves on accumulators HCV-438B and HCV-4380 and deleting the check valves for the accumulators HCV-864, HCV-865, HCV-344 and HCV-345.
NOTE: Nitrogen backup to the air supply to the air accumulators on HCV-344 and HCV-345 will be provided prior to the end of the 1988 outage to assure post-accident operability of the valves.
The proposed Inservice Inspection Program Plan will be revised and reissued prior to the 1988 refueling outage.
Attached is the updated list of CQE air operated valves and/or check valves serving air accumulators, reflecting the ISI testing frequency as it is now planned to be reissued.
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ATTACHMENT 7 SCHEDULE FOR INSTRUMENT AIR SYSTEM MODIFICATIONS l
l f
ATTADOENT 7 SCHEDULE FOR INSTRIMENT AIR SYSTEM MODIFICATIONS l
A.
Modifications scheduled to be completed before the end of 1988.
(Subject to availability of material)-
1.
Replacement of D/G Damper Operators - MR-FC-87-63 2.
Replacement or redesign of. water plant valve DW-CV MR-FC-87 3.
Installation of dedicated air compressors for fire protection systems
- MR-FC-87-32 B.
Modifications scheduled to be completed before the end 1988 outage. subject to availability of material.
1.
Modifications or evaluations that may be closed to eliminate Instrument Air System components under existing JCO's.
a.
A modification to LCV-383-1 and 2 to allow valve to be closed for approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> after D8A (LOCA) (EEAR-FC-88-33) b.
Evaluate the design basis for HCV-438 B and D and modify if-necessary (EEAR FC-88-34)
A modification to ensure a single failure. proof path for hot leg c.
injection indefinitely (EEAR FC-88-35) (HCV-238, 239, and 240) d.
Investigate the air accumulators tubing and check valves install-ed for HCV-238 and HCV-239 and modify if ne'essary.
e.
Redesigr. of Instrument Air Penetration M-73 and PCV-1849-
-(MR-FC-88-11) f.
Addition of isolation valves to allow surveillance testing of check valves.
g.
Nitrogen backup to the air supply to the air accumulators on HCV-344 and HCV-345 will be provided to assure post accident operability of the valves.
2.
Addition of filters up stream of critical valve operators.
(See note below) l C.
Modification to the Air Dryer.
Note on addition of filters: The current schedule to determine if filters are required and the type of filter needed is scheduled to be completed by the end of June.
Since the modifications will involve non-CQE portions of the Instru-ment Air System, procurement delays are not expected to occur.
Based on the information available at this time, OPPD is planning to schedule the work to be completed by the end of the 1988 outage.
7.1
m-----,-~,------,--,
ATTACHMENT 8 ADDITIONAL SEISMIC INFORMATION l
1
ATTACIMENT 8 ADDITIONAL SEISMIC INFORMATION Information on the seismic qualification of HCV-238 and HCV-239 was not prev-iously provided in Reference 9.
This attachment provides additional discus-sions on their seismicity.
Valves HCV-238 and HCV-239 and associated accumulators are located behind the biological shield wall inside of containment.
These accumulators were installed under the modification package DCR 75A-52.
The documentation of the design package is not detailed enough to determine the seismicity of the accumulators and associated tubing.
However, a large number of previously installed accumulators were seismically analyzed as part of the Engineering Study ES-87-40 and were found to be seismically anchored.
Based on this study, it is our belief that the air accumulators for HCV-238 and HCV-239 are similar to the accumulators which were analyzed, and they are seismically anchored also.
Based upon what is known of the tubing routing and assuming that the piping and accumulators are seismically supported, which will prevent unacceptable rela-tive movements between the piping and the accumulator, the tubing should remain intact.
Since the tubing is constructed of copper, which is very flexible, small displacements are judged to cause the tubing to bend rather than crack or break.
In addition, provisions have been made to insure a backup path by which to implement hot leg injection; therefore, operability of the valves HCV-238 and HCV-239, although highly desirable, is no longer critical.
8.I
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Novemoer 15, 1988 I
LIC-88-974 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter OPPD (R. L. Andrews) to NRC (J. Lieberman) dated April 27, 1988 Gentlemen:
Subject:
Instrument Air Corrective Action Program Status In Referenca 2 above, a number of commitments were made to the NRC concerning corrective actions expected to be completed on the Instrument Air System.
It was requested in your letter dated July 28, 1988, that a list of items not expected to be completed prior to startup (prior to leaving Mode 2-Hot Standby Condition) be submitted for review.
The majority of the commitments made are in progress or complete. Close out of these items is being pursued with the NRC Senior Resident Inspector.
The following is a list of Instrument Air associated items which will not be completed by the end of our current outage. These items are required for improving reliability and availability of the Instrument Air System at fort Calhoun 5tation (FCS) and are not deemed by OPPD as required for a safe restart of FCS.
1.
Replace / Redesign OW-CV-86 valve in Water Plant.
Present Status:
Modification is currently scheduled for 1989 on-line. No modification is required prior to startup as the valve has been disconnected from the Instrument Air System and there is no possibility of water intrusion into the Instrument Air System.
2.
Installation of new Air Dryer on the Instrument Air System to include an on-line Oew Point Analyzer.
Present Status:
A modification to the piping on the Instrument Air System will be completed during the current refueling outage to facilitate the installation of the new Air Dryer and on-line Oew Point Analyzer during normal power operation in 1989.
The materials required to accomplish the installation of the new Air Dryer and the
/
V Document Control Desk LIC-88-974 Page 2 on-line Dew Point Analyzer were not available on a timely basis to facilitate installation during this refueling outage.
Therefore, the provisions necessary for the later installation are being provided.
The present air dryer and dew point monitoring programs are adequate to ensure compliance with the design basis requirements for Instrument Air quality.
Additionally, during the current refueling outage, the Instrument Air System filtration components are being upgraded to provide 3 micron filters in lieu of the present 20 micron filters.
3.
USAR updates for the modifications installed during the upcoming refueling outage to include 0SAR 87-10.
Present Status:
The updates to the USAR are scheduled for incorporation into the USAR during the normal annual update in July of 1989.
In addition, Quality Assurance Deficiency Reports (QA/0R's) generated in response to the System functional Inspection and open items identified in the Design Basis Reconstitution have been evaluated to determine their impact on plant safety. Resolution of immediate concerns (short term) is complete.
Resolution of generic concerns from the SFI and Design Basis Reconstitution will be an ongoing project and will not be completed prior to the end of the i
1988 Outage.
If you have any questions concerning this matter, please contact us.
Sincerely, f
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K/M. Morris D'ivision Manager Nuclear Operations KJM/js c:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.
Washington, DC 20036 R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _