ML20245D254
| ML20245D254 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/19/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-608, NUDOCS 8906270030 | |
| Download: ML20245D254 (6) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/536 4000 l
June 19, 1989 LIC-89-608 l
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U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
References:
1.
Docket No. 50-235 2.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated May 19, 1989 Gentlemen:
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SUBJECT:
Response to Notice of Violation - Inspection Report 50-285/89-13 Omaha Public Power District (0 PPD) received the inspection report noted in Reference 2.
The report identified two violations. Attached please find OPPD's response to these items in accordance with 10 CFR Part 2.201.
If you have further questions on this matter or require additional information, please contact me or members of my staff.
Sincerely, dwu~
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. J.
orris fDivisionManager Nuclear Operations KJM/jak c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector 0906270030OhhBS PDR ADOCK O PNV
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4551/4 E mployment with Equal Opportunny Male f emale
Attachment l
Besponse to Notice of Violation 1
During an NRC inspection conducted on March 1-31,.1989, violations of NRC requirements were identified. The violations involved the failure to follow the procedures for equipment tag-out and installation of cable tray covers, and
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an inadequate procedure to address the loss of component cooling water.
In accordance with the " General Statement of Policy and Procedure for NRC.
i Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below-1 l
A.
Failure to Follow Procedures j
The following are two examples of the licensee's failure' to follow approved.
procedures:
i 1.
Technical Specification 5.8.1 states, in part, that written procedures shall be implemented that meet the minimum requirements of Appendix A i
Paragraph 1.c of Appendix A to Regulatory Guide 1.33 requires that l
l equipment control (e.g., tagging and locking) be addressed. by written procedures.
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Paragraph 4.1.6 of Procedure 50-0-20, " Equipment Tagging Procedure,"
states, in part, that [ danger] tags shall be hung in accordance with
'j the tag-out sheet and the components shall be in their required position.
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Contrary to the above, the-licensee failed to properly implement i
Procedure S0-0-20 in that a danger tag was installed on Valve MS-100 and the Valve was not.in the required position. The danger tag stated i
the valve position was shut; however, the valve was found to be open..
l This is a Severity Level IV Violation (Supplement I) (285/8913-01)
OPPD Response l
l 1.
Reason for the Violation if Admitted OPPD admits the violation occurred as stated.
l The reason for this violation has been determined to be operator error.
Valve MS-100 is an isolation valve to both a pressure test line on the RC-2B steam header and the Post Accident Steam Header Radiation Monitor, RM-064. Maintenance of RM-064 required that a danger tag be placed (March '
21, 1989) on MS-100 directing that this valve be closed. A temporary clearance tag was subsequently placed on the valve March 23, 1989 in order that the valve could be opened to allow testing of RM-064.
The temporary clearance tag is'a method used for temporarily changing the position of valves and components without removing-the danger tag. When the temporary l
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clearance tag is removed, the component is to be returned to the position-specified on the danger tag. However, when the temporary clearance tag was removed from MS-100 on March 24, 1989, the operator failed to return the valve to the closed position specified by the danger tag.
It should be noted that the RM-064 line is also equipped with another normally closed isolation valve, HCV-922. This valve was also danger tagged closed for maintenance.
Since HCV-922 was closed and tagged closed, the monitor was sufficiently isolated for work to take place. MS-100 is a normally open valve and thus would not adversely affect operation of the plant.
In addition, no work was performed on RM-064 from March 24, 1989 until the valve was found by the NRC inspector on March 27, 1989, therefore, no personnel safety hazard existed.
2.
The Corrective Stoos That Have Been Taken and the Results Achieved Upon identification.of the open~ valve by the NRC inspector, an OPPD shift supervisor immediately shut the valve. A discussion was held with the operator involved in this incident on the requirements of S0-0-20..The operator stated he was aware of the procedural requirements and admitted the error.
This event resulted in an Incident Report (890403) issued March 28, 1989 to review the root cause and develop corrective ' actions. This report initiated a corrective action to issue a training hotline to all l' censed and non-licensed operators, shift technical advisors, and operations training instructors. This hotline, issued March 29,'1989, provided information on this event occurrence and emphasized the importance of.
ensuring valve positions are consistent with the directions on danger tags. As a result, those personnel responsible for hanging danger tags or manipulating valves were informed of this event and it was re-emphasized that the proper positioning of valves consistent with tag instructions must be ensured. This hotline required a review by all addressees. acknowledged by signature. All addressees had acknowledged this hotline by May 22, 1989.
In addition, OPPD has performed a review of all danger and caution-tags installed in the plant to verify that all currently tagged components were in the position specified on the tag. This review was concluded by March 28, 1989 and found that all currently tagged components were in the proper position.
No additional problems were identified during this review.
3.
Corrective Steos That Will be Taken to Avoid Further Violations OPPD believes that the actions taken above will minimize.the potential for further violations in this area.
In addition, new operations personnel are given instruction on the importance of equipment tagcing through the
" Auxiliary Operator Nuclear Training" class.
q 4.
Date When Full Comoliance Will be Achieved OPPD is currently in full compliance with S0-0-20 as it pertains to this violation.
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4 2.
Criterion V of. Appendix 8 to.10 CFR 50 and the. licensee's NRC-approved-
. _ quality assurance program state,- in part,' that activities affecting:
quality shall be prescribed by documented -instructions of a type; appropriate to the circumstances and shall' be accomplished in I
accordance with'these instructions.
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Drawing 11405-E-60, " Reactor Auxiliary Building Tray C5nduit Layout Plan," requires.in Note 17 that' solid covers be installed on cable; trays.
Contrary to the above, cable tray installations have not been
'l maintained in accordance with design documents in that cable _ tray covers were not properly reinstalled on trays =in Room 19,.the upper-level electrical penetration room, and in the east and west switchgear rooms.
q This.is a Severity Level IV Violation. ;(Suppl _ement I)'(285/8913-01) i 1.
Enson for the Violation. if Admitted j
OPPD admits the violation occurred as stated.
It has been determined that.
I the reason:for this violation was lack.of adequate standards concerning modification installations.. Specifically, procedure S0-M-100, " Conduct'of-Maintenance," governs the work standards for all. craftsmen at Fort Calhoun (both modification and maintenance). The procedure did_not include specific directions for obtaining;the required documentation for removal of cable tray covers.
2.
Corrective Steos That Have Been Taken and the Results Achieved U)on identification of this problem by the NRC inspector, OPPD reinstalled t1e tray covers.
In addition, OPPD performed an undocumented walkdown of the cable trays in Room 19, the upper-level electrical penetration room, and in the east and west switchgear rooms to verify installation of all other cable tray covers. No other instances; of improper installation of cable tray covers were identified.
1 A hotline was_ issued on June 19, 1989 to all Fort Calhoun Station electrical craftsmen. This hotline emphasized the need to keep cable trays intact and not to modify any part of a cable tray unless the work package specifically provides for this.
This hotline requires a review by all addressees acknowledged by signature. As a result, those personnel who work with cable trays were informed of this event and it was re-emphasized that cable tray covers cannot be removed without approved work -
documentation.
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3.
Corrective Steos That Will be Taken ~to Avoid Further Violations A sample plant area will be walkeddown in order to. ensure no similar cable tray problems exist. This action will be completed by September 30, 1989.
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As a result of this violation, OPPD plans to revise its " Conduct of Mai.ntenance" Standing Order, M-100, to include specific direction
- prohibiting removing or modifying cable tray covers without maintenance orders or an approved modification package. Also, modification installation procedures will be reviewed to ensure they include or reference the standards contained in M-100.
In addition, a corporate review of this procedure will be conducted to identify and correct any further inadequate areas.
TF revision will be completed by September 30, 1989. All appropriate field supervisors will receive training on this new procedure.
The information contained in the hotline noted above shall be included into a training course currently under development titled "An Introduction to Work at Fort Calhoun Station". This course is to be completed before the 1990 refueling outage and will be given to both contractor and OPPD maintenance personnel before every refueling outage.
4.
Date When Full Compliance Will be Achieved OPPD is currently in full compliance with S0-M-100 as it pertains to this violation. However, the actions noted above will' result in a higher standard for the conduct of maintenance.
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e Inadequate Procedure to Address the Loss of Component Coolina' Water B
Technical Specification 5.8.1 states, in part, that written procedures.
. shall be established that meet or exceed the minimum requirements of -
Appendix A to Regulatory Guide 1.33.
Section 6.y of Appendix A to Regulatory Guide l'.33 stat'es.that procedures shall be written to address the abnormal: releases of radioactivity during emergencies or other significant events.
Contrary to the above, Procedure' A0P-ll,. " Loss of Component Cooling Water,"
. did not address the potential for abnormal releases of radioactivity during emergencies or other significant events when raw water is being' supplied as the backup cooling water source to the component cooling water system..
Specifically, Procedure AOP-ll did not address the operability of Radiation.-
Monitors RM-056A and RM-056B, or provide for alternate grab samples in the event the radiation monitors became: inoperable when raw water is being supplied as the backup cooling water source.
This is a Severity Level IV Violation.. (Supplement I)'(285/8913-05)
OPPD Response 1.
The Reason for the Violation. if Admitted OPPD admits the violation occurred as stated.
Abnormal Operating Procedure, A0P-11, Revision 2, issued February 29,'1988, did not specifically direct operators to ensure that RM-056A and B are operable when the Raw Water System (RW) is used as a backup upon failure of the Component Cooling Water System (CCW).
In addition, there was no provision in this procedure for alternate sampling in'the event that the radiation monitors become inoperable when RW is being utilized as the backup cooling water source.. Therefore, the reason for this violation was lack of specific instructions with respect.to radiation monitor operability and alternate sampling.
2.
The Corrective Steos That Have Been Taken and the Results Achieved As a result of this inadequacy, A0P-11 has been revised. A0P-11, Revision.
2, issued April 11, 1989, now includes a step to ensure both RM-056A and B are operable whenever the RW System is being used as a backup cooling source for the CCW system. This revision also includes a provision for grab samples to be taken by the plant chemist if either of these monitors are inoperable.
3.
The Corrective Steos That Will be Taken to Avoid Further Violations OPPD has determined that'the actions taken above have corrected the root cause of this violation, therefore, no further corrective. steps are needed.
4.
Date When Full Compliance Will be Achieved OPPD is currently in full compliance with Technical Specification 5.8.1 and section 6.y of Appendix A to Regulatory Guide 1.33 as it applies to this violation.