ML20237K845

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Notice of Violation from Insp on 870406-10.Violation Noted: Lack of Documentation That Independent Design Verification Performed in Determining Specific Torque Value to Be Attained in Performance of Maint Order
ML20237K845
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 08/21/1987
From: Randy Hall
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237K829 List:
References
50-285-87-05, 50-285-87-5, NUDOCS 8708270318
Download: ML20237K845 (3)


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NOTICE OF VIOLATION Omaha Public Power District Docket No. 50-285 1623 Harney Street License No. DPR-40 Omaha, Nebraska 68102 EA No. 87-72 During an NRC inspection conducted on April 6-10, 1987, violations of NRC l

requirements were identified.

In accordance with the " General Statement of j

Policy and Procedure

'.,r NRC Enforcement Actions," 10 CFR Part 2, Appendix C i

(1987), the violations are listed below:

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A.

10 CFR Part 50, Appendix B, Criterion III, requires, in part, that measures be established to assure that applicable regulatory requirements and design bases for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions. These measures must include j

provisions to assure that appropriate quality standards are specified and j

included in design documents and that deviations from such standards are i

controlled. The design control measures must provide for verifying or checking the adequacy of design, such as by the performance of design l

reviews, by the use of alternate or simplified calculational methods, or j

by the performance of a suitable testing program.

In addition, design j

l changes, including field changes, must be subject to design control i

measures commensurate with those applied to the original design.

Section A.4, " Design Control," of the OPPD Quality Assurance Plan commits to Regulatory Guide 1.64 and ANSI N45.2.11-1974 Section 6.0, " Design Verification," of ANSI N45.2.11-1974 specifies that design verification is to be performed by individuals or groups other than those who performed the original design and that design activities are to be controlled.

j Order (y to the above, in March 1983, the licensee performed Maintenance Contrar M0) 16275, which covered the reinstallation of main steam safety reliefvalves(MSSRV) 275, 276, 277, 278, 280, 281, 282, 291, and 292.

1.

The M0 contained instructions to torque the subject valves in-line flange bolts to 750 foot-pounds; however, there was no documentation that an independent design verification had been performed in determining the specified torque value.

2.

During MS SRV installation, the bolts were not stressed to the i

specified 750 foot-pounds but rather were stressed to unknown values l

1 in an uncontrolled manner (the use of a slugging wrench).

This is a Severity Level IV violation (Supplement II).

l 8708270318 870824 PDR ADOCK 05000205 G

PDR

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Omaha Public Power District i B,

10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities that affect quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these a

instructions, procedures, and drawings.

Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance l

criteria.

l Section A.6, " Instructions, Procedures, and Drawings," of the OPPD Quality l

Assurance Plan implements this requirement, and specifies, in part, that quality-related at.tivities for plant operations, fabrication, processing, assembly, inspection, and test be accomplished in accordance with the instructions, procedures, or drawings and that such documentation adequately reflects all applicable quality req (uirements and contain the appropriate quantitative acceptance criteria such as dimensions, tolerances, and samples) for determining that important activities have been satisfactorily accomplished.

Contrary to the above:

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 282, did l

not specify torque valves to assure that design bolt stress was

achieved, i

2.

The initial MO 16275 specified a bolt torque valve; however, the i

parameter was marked through with the comment "cannot be torqued."

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Later M0s did not specify torque valves. Therefore, a design requirement was deleted without a proper review and acceptance of the revised work instruction, j

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 the instrument nor the voltage of th; instrument was provided.

b.

Procedures PM-EE-VA-3/7, Revision 0; PM-EE-1-13, Revision 5; and PM-f.E-3.0; Revision 0, do not specify meggering acceptance criteria.

Omaha Public Power District !

c.

No procedure specified meggering controls to be applied to l

containment ventilation and cooling fan motors.

l This is a Severity Level IV violation (Supplement II).

C.

Technical Specification 5.8.1 requires that written procedures and j

administrative policies shall be established, implemented and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33.

l Tie Breaker Calibration Procedure, Revision 3, satisfies the above f

l requirements for AC circuit breaker testing.

Contrary to the above, the licensee failed to implement the appropriate procedure and instead, an incorrect procedure for CP-main breakers was used for testing the CP-tie breakers.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation:

(1) the reason for the violations if admitted,

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(2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Under the authority of j

Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation, Where good cause is shown,

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consideration will be given to extending the response time.

1 FOR THE NUCLEAR REGULATORY COMMISSION

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h R. E. Hall i

I Acting Director, Reactor Safety and Projects Division i

Dated /t Arlington, Texas, this21 day of August 1987 i

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