ML20236L466
| ML20236L466 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/04/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-87-680, NUDOCS 8711100355 | |
| Download: ML20236L466 (8) | |
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I ?l' s. 4 Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 402/536 4000 November 4, 1987 LIC-87-680 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
References:
1. Docket No. 50-285 2. Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated May 8, IS'7 3. Letter from NRC (R. E. Hall) to OPPD (R. L. Andrews) dated August 24, 1987 4. Letter OPPD (R. L. Andrews) to NRC (Document Control Desk) dated September 24, 1987 (LIC-87-248) Gentlemen:
SUBJECT:
Revised Response - Notice of Violation (NRC Inspection Report 50-285/87-05) Omaha Public Power District's (OPPD) response to the Notice of Violation as contained in Reference 4 has been revised. The revision pertains to tne response to Violation B(4) and is denoted by a vertical line in the right margin. If you have any questions concerning this matter, please contact us. Sincerely, flWU R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector /bO 8711100355 071104 /p POR ADOCK 0500 5 45 5124 Employmen h Equal Opportunity
Response to Notice of Violation During an NRC inspection conducted on April 6-10, 1987, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions, " 10 CFR Part 2, Appendix C (1987), the violations are listed below: A. 10 CFR Part 50, Appendix'B, Criterion III, requires, in part, that measures be established to a::nre that applicable tegulatory requirerr.ents and design I bases for those structures, systems, and components to which this appendix applies, are correctly translated. into specifications, drawings, j procedures, and instructions. These measures must include provisions to l assure that appropriate quality standards are specified and included in l design documents and that deviations from such standards are controlled. i The design control measures must provide for verifying.or checking the l adequacy of design, such as by the performance'of design reviews, by the. use of alternate or. simplified calculational methods,- or_ by the performance - q of a suitable testing program.- In addition, design changes, including field changes, must be subject to design control measures commensurate with 4 those applied to the original' design. 1 Section A.4, " Design Control," of the OPPD Quality Assurance Plan commits I to Regulatory Guide 1.64 and_ ANSI N45.2.11-1974, Section 6.0, " Design Verification," of. ANSI N45.2.ll-1974 specifies that design verification is ) to be performed by individuals or groups other than those who performed the j original design and that design activities are to be controlled. J Contrary to the above, in March 1983, the licensee performed Maintenance Order (MO) 16275, which covered the reinstallation of main steam safety l relief valves (MS SRV) 275, 276, 277, 278, 280, 281, 282, 291, and 292. l t 1. The M0 contained instructions to torque the subject. valves' in-line l flange bolts to 750 foot-pounds; however, there was no documentation that an independent design verification had been performed in 1 determining the specified torque value. 2. During MS SRV installation, the bolts were not stressed to the specified 750 foot-pounds but rather were stressed to unknown values I in an uncontrolled manner (the use of a slugging wrench), This is a Severity Level IV violation (Supplement II). (285/8705-01). OPPD's Resoonse Reason for the Violation. if Admitted During March 1983, the main steam safety valves (MSSV's) were installed as a result of Maintenance Order (MO) 16725. This M0 contained information con-l cerning torque values for the MSSV inlet flange studs. This information was deleted, without Plant Review Committee review, by the craft supervisor. The torque value of 750 foot-pounds was deleted because the craftsman could.not physically fit the torque wrench onto the stud due to-the' limited space adjacent to the MSSV's. The use of a slugging wrench was then employed ~to tighten the bolted joint. j m___.--__
=1 Violation' A (Continued)- OPPD's Response (Continued). Reason for the Violation. if Admitted (Continued) The deletion of the torque value from the_ maintenance order instructions was not a violation of plant standing orders as a PRC approved procedure was not required in order to perform the work. However,.this represents improper management attention to safety related bolted pressure boundary connections. This method of bolt-up was utilized until May 1987, when this violation was identified, q The Corrective Steos Which Have Been Taken and the Results Achieved i OPPD has developed and issued interim torquing guidelines'. These guidelines provided torque values for the following: COE and fire protection pressure-boundary bolted connections; seismic mounting or supports of mechanical and l electrical equipment; EE0 equipment where required to maintain q alification; I and NSSS threaded connections unless safety-wired or lock-nutted. These l l guidelines were implemented in May 1987. ] Upon issuance of these guidelines, specific attention was given to those maintenance orders which encompassed the above noted items to. ensure the ) requirements of the guidelines were being fulfilled. Additionally, a review was conducted of 1987 outage completed M0's and any "in-progress" M0's which l needed to adhere to the requirements of the guidelines. Corrective action was l taken as necessary to ensure compliance. The MSSV reinstallation during the 1987 refueling outage occurred in early June 1987. OPPD, in an effort to ensure that the reinstallation of the MSSVs did not involve the use of a possibly over-stressed stud due to previous slugging 1 operations, chose to purchase new studs for the MSSV inlet flanges. A new procedure was developed and received PRC approval for the. reinstallation. This procedure, MP-MS-4, provided a calculational method to ensure that the pre-load i l stress of the studs on the inlet flange to the MSSVs was at a value of less than 50 percent of the yield strength of the particular stud material. This was verified by measuring actual stud elongation using vernier calipers. Slugging of MSSVs, as in the past at Fort-Calhoun Station, has proven to be a reliablo leak-free method of bolting up the inlet flanges of _the MSSVs. On July 2.,1986, when the Fort Calhoun Station tripped from full power operation, the MSSVs operated as designed to prevent overpressurization of the Main Steam piping. The inlet flange, after experiencing a higher than normal pressure during the transient, remained leak-free throughout the remainder of the operating cycle. OPPD reviewed the method for performing the slugging. Based on the access in l the area, the longest wrench that could have been used was a one-foot wrench. l If a craftsman were to use a one-foot long slugging wrench in order to " slug-l up" the.MSSV studs, he would have to exhibit a force of 2085' foot-pounds at.the very end of the slugging wrench. This would require a large' swing of the i l sledge hammer and subsequently, a lot of room to swing it in. Very little' room l exists to perform this operation. OPPD therefore ' believes that previous slug-ging operation, even though uncontrolled, did not cause the stud material to be I overstressed. l
Violation A (Continued) The Corrective Steos Which Will be Taken to Avoid Further Violations OPPD has expanded upon the interim torquing guidelines program and has: developed a new procedure concerning bolting. This procedure requires either vendor supplied torque values or torque values that have been independently verified. This procedure is currently under review and awaiting PRC concurrence. This procedure will provide written instruction for selecting torque values for any bolted joint and will be used when updating or issuing procedures which require torquing. I The Date When Full Compliance Will be Achieved OPPD is presently in full compliance. I i i i
,1 j i B. 10 CFR Part 50, Appendix B,. Criterion'V, requires, in part, that activities that affect quality shall be prescribed by documented instructions, pro-cedures, or drawings of a type appropriate to the circumstancesLand shall 3 be accomplished in accordance with these instructions, procedures, and l drawings. Instructions, procedures,'or drawings shall include appropriate 1 quantitative or qualitative acceptance cr'teria. Section A.6, " Instruction, Procedures, anc Drawings," of the OPPD Quality Assurance Plan implements this requirement, and specifies, in part, that quality-related activities for plant operations, fabrication, processing, assembly, inspection, and test be accomplished in accordance.with the instructions, procedures, or drawings, and that such documentation ade-quately reflects all applicable quality requirements and contain the appropriate quantitative acceptance criteria (such as-dimensions, toler-ances, and samples) for determining that.important activities have been 4 satisfactorily accomplished 1 Contrary to the above: 1 1. The licensee's procedure MP-MS-1, Revision 13,~" Main Steam Safety' Valve Inspection and Repair," dated March 19, 1987, which was used to reinstall MS SRV 275, 276, 277, 278, 280, 281, 282, 291, and 292 did' i not specify torque values to assure that design bolt stress was 1 achieved. l 2. The initial M0 16275 specified a bolt torque value; however, the parameter was marked through with the comment "cannot be torqued." l Later M0s did not specify torque values. Therefore, a design require-ment was deleted without a proper review and' acceptance of the revised i work instruction. 4 3. The licensee failed to establish procedures for assuring that the accuracy of instruments used to calibrate (a) the wide range level indicators for steam generators A and B, and (b) the temperature detectors for reactor coolant hot and cold legs were within the accuracy constraints required by the design bases. 4. The licensee failed to specify equipment, acceptance criteria, or procedure for meggering. Examples of such failures include the following: a. Procedures PM-EE-VA-3/7, Revision 0, and PM-MOV-1, Revision 3, indicated that meggering was to be accomplished, however, neither I the instrument nor the voltage of the instrument was provided. b. Procedures PM-EE-VA-3/7, Revision 0; PM-EE-1-13, Revision 5; and PM-EE-3.0, Revision 0, do not specify meggering acceptance criteria. l c. No procedure specified meggering controls to be applied to containment ventilation and cooling fan motors. This is a Severity Level IV violation (Supplement II) (285/8705-02) l I
3 Violation B (Continued)' OPPD's Resoonse Reason for the Violation. if Admitted 1. MP-MS-1, Revision 13, " Main Steam Safety Valve Inspection and Repair," dated March 19, 1987, did not specify torque. values:for' reinstallation of' the Main Steam Safety Valves-(MSSVs). Past practice for installation of the MSSVs has utilized the practice of " slugging."'.This was due to the-fact that it was, and still is, impossible to physically fit to the ~ torque - wrench onto the. flange' stud nuts due to the limited space adjacent to the-MSSVs. This method of bolt-up was discontinued in May 1987 when this. violation was: identified. 2. MO 16275 was issued to reinstall.the main steam safety valves..The work; was completed in March 1983. The-M0 contained instructions toutorque thes MSSVs to 750. foot-pounds. These instructionsLwere marked through'with a comment "cannot be torqued.",Because a PRC approved l procedure'was,not' required, the fact that utilizing a torque wrench was not possible was not-noted'by the group which supplied the; values. This failure:to feed back information resulted in the violation. 3. In the area of instrument accuracy, OPPD was found to be deficient of-procedures for assuring.the accuracy of ' instruments used.to calibrate (a) the wide range level indicators for steam generators A and B, and (b) the: I temperature detectors for reactor coolant hot and cold legs were'within the accuracy constraints required by the design bases. OPPD did not have a specific procedure assuring instrument accuracies during calibration of the 1 specified instrumentation. -However, an investigation into thisLaccuracy question has demonstrated that'0 PPD currently meets appropriate acceptance criteria for accuracies between test and measuring equipment and precess equipment. 4. OPPD uses meggering as a gross indication of cable and/or; equipment. inte-grity. The' measurements taken have been used as a qualitative. measurement, not quantitative. Surveillance testing also ensures proper operability of equipment. The Corrective Steos Which Have Been Taken and the Results Achieved, 1. OPPD has developed and issued interim torquing guidelines. With these i guidelines in place, a'new' procedure was written and issued covering the reinstallation of the MSSVs, including necessary quantitative acceptance criteria. 2. Increased attention has been given to maintenance of safety-related systems and detailed attention has been given to the areas of procedures and torquing requirements. In this new environment, the. reinstallation.of the MSSVs requires the use of a PRC approved procedure (MP-MS-4). As noted in Violation A,1987 refueling outage maintenance orders were also. reviewed for torquing considerations. 1 I l O
1 Violation B (Continued) i I The Corrective Steps Which Have Been Taken and the Results Achieved. 1 (Continued) ) l 3. Safety related calibration procedures performed during the 1987 refueling l outage were evaluated for compliance with calibration accuracy requirements j stated in Standing Order M-28, " Calibration'of Test Equipment and Plant t Process Equipment.used to Support the 'In-Service Inspection of Nuclear Plant Components' Program." Those procedures examined complied with the requirements of Standing Order M-28. In the interim period, prior to i safety related calibration procedure upgrading, a policy has been imple- ] mented requiring engineering to identify safety-related accuracies prior to -] performance of any safety related calibration procedure. i 4. OPPD has reviewed these areas of concern and will investigate the j applicability of quantitative rather than qualitative acceptance' criteria for incorporation into applicable procedures. The Corrective Steos Which Will be Taken to Avoid Further Violations k l l l. OPPD has expanded upon the interim torquing guidelines and is currently awaiting PRC approval of the new procedure concerning bolting. This pro- ] cedure will provide written instructions for selecting torque values for l any bolted joint and will be used when updating or issuing procedures which I require torquing. 2. Heightened management attention to the use of PRC approved procedures for maintenance on safety-related equipment has resulted in the development of -{ a new bolting procedure. As with item 1, this procedure will provide the necessary written guidance to ensure bolted joints are formed to the proper written acceptance criteria. 3. OPPD uses generic test instruments rather than job specific test instru-ments to perform calibrations on process equipment. In order to ensure' that appropriate quantitative acceptance criteria exists between process equipment and its test equipment, QPPD will review and update safety re-lated calibration procedures following an evaluation of all safety related process equipment versus appropriate test equipment accuracies. 4. Heightened management attention to this matter is being given and will result in the development of a generic procedure to identify proper meg-i gering techniques. This procedure will identify applicable acceptance criteria (either qualitative or quantitative) to be used during the l meggering process and will be used when updating or issuing procedures which require meggering. Also, OPPD is currently developing a procedure writer's guide which will be I used as guidance to prepare and update specific procedures. Requirements for such items as torquing, test equipment accuracy,'and meggering will be addressed and reviewed for inclusion into the appropriate procedures. 1 The Date When Full Compliance will be Achieved ') PPD is currently in full compliance relative to the applicable interim policies and programs. 1 j .) i i
1 C. Technical Specification 5.8.1 requires that written procedures and. administrative policies shall be established, implemented and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of u ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33. l Tie Breaker Calibration Procedure, Revision 3, satisfies the above requirements for AC circuit breaker testing. Contrary to the above, the licensee failed to implement the appropriate I procedure and instead, an incorrect procedure for CP-main breakers was used for testing the CP-tie breakers. I l This is a Severity Level IV violation (Supplement I) I l OPPD's Resoonse l The Reason for the Violation if Admitted ) OPPD admits the violation occurred. Investigation into the reason for the use of the incorrect calibration procedure revealed that the preventive maintenance (PM) sheet for the tie breaker did not specify which calibration procedure to use. As a result, the foreman in charge of the task obtained what he felt was the correct precedure and assigned the task to.an electrician. The electrician, assuming he had the correct procedure, commenced performance of the procedure until trouble occurred during overcurrent testing. At that time i the electrician determined that the incorrect procedure was being used. The Correct.ve Steos That Have Been Taken and the Results Achieved The correct calibration procedure was obtained and performed satisfactorily on i the tie breaker. Additionally, main and tie breakers'previously calibrated during the 1987 refueling outage were verified to be calibrated using the l correct procedures. Ih3 Corrective Steos Which Have Been Taken to Avoid Further Violations The PM sheets associated with the main breakers and tie breakers.were revised on April 21, 1987, to list the specific calibration procedures to be used. The Date When Full Compliance will be Achieved OPPD is now in full compliance. l l}}