ML20246A858
| ML20246A858 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/30/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8907070112 | |
| Download: ML20246A858 (2) | |
See also: IR 05000285/1989009
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JUN' 3 0 1989,
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.In' Reply lReferTo:
. : Docket: '50-285/89-09
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. 0maha: Public. Power District
_ATTH:' Kenneth J.. Morris, Division Manager
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, Nuclear Operations.
444rSouth'16th Street Hell-
Omaha , . Nebraska 68102-2247
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- : Gentlemen:
Thank you for:your letter of June 1,1989, in response to our letter,
~ Notice of Violation, and Notice of Deviation dated March '31,1989. We have
reviewed your reply and.f'ind it responsive to the concerns raised in our. Notice .
of Violation'and Notice of Deviation.
Your exception to Item 1 of. the deviation
wasi noted and we. agree.- We will review the implementation of-your corrective
actions >during-a future inspection to determine that- full compliance has been
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achieved and will be maintained.
Sincerely.
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Original Signed By:
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James L Milboan
James L. Milhoan, Director
Division of Reactor Projects
cc:
Fort Calhoun Station
ATTN:
G. R. Peterson, Manager
P.O. Box 399
Fort Calhoun, Nebraska ~68023.
Harry H. Voigt, .Esq.
LeBoeuf, Lamb, Leiby & MacRae
- 1333 New Hampshire Avenue, NW
fWashington,.DC 20036:
Nebraska Radiation Control Program Director
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Omaha Public Power District
1623 Harney Omaha Nebraska 68102 2247
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402/536-4000
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June 1, 1989
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LIC-89-408
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0. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Station P1-137
Washington, DC 20555
References:
1.
Docket No. 50-285
2.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated
March 31, 1989
Gentlemen:
SUBJECT:
Response to. Notice of Violation / Deviation - Inspection Report
50-285/89-09
Omaha Public Power District (OPPD) received the subject inspection report.
The
report identified one violation and one deviation. A one month extension was
granted in order to obtain more information on the subject violation and
deviation. Attached please find OPPD's response to these items in accordance
with 10 CFR Part 2.201.
If you have any questions concerning this matter, please contact us.
Sincerely,
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J. Morris
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Division Manager
Nuclear Operations
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Attachment
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LeBoeuf, Lamb, Leiby & MacRae
R. D. Martin, NRC Regional Administrator
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,A. Bournia, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
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Attachment 1
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RESPONSE TO NOTICE OF VIOLATION
During an NRC inspection conducted on February 1-28, 1989, a violation of NRC
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requirements was identified.
The violation involved modification of a plant
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system without the use of approved instructions.
In accordance with the
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" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below.
Modification of a Plant _ System Without the Use of Acoroved Instructions
Criterion V of Appendix B to 10 CFR Part 50 and the licensee's NRC-approved
quality assurance program state, in part, that activities affecting quality
shall be prescribed by documented instructions and shall be accomplished in
accordance with these instructions.
Procedure 50-G-21, " Station Modification Control," states, in part, that
modification of equipment shall be performed in accordance with written
procedures.
Contrary to the above, the licensee modified equipment without written
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instructions in that two hangers on the fire water system were removed without
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written procedures and removal of the supports potentially affected the
operability of Emergency Diesel Generator No.1.
This is a Severity Level IV violation.
(Supplement I) (285/8909-05)
OPPD RESPONSE
1.
Reason for the Violation. if Admitted
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0 PPD admits the violation occurred as stated.
Starting in August, 1988, scaffolding was being erected in room 63, housing
diesel generator (DG) 1, for work on Modification FC-88-60, DG 1/2, Exhaust
Pipe Seismic Supports. The scaffolding was erected around and above a two
inch fire water system pipe.
The scaffolding was erected and removed under
separate Maintenance Orders with no instructions in the Maintenance Orders
to remove or replace the fire water piping hangers.
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Sometime between scaffolding erection (August, 1988) and disassembly
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(December, 1988) two fire water hangers were removed.
Routine inspections
of the area by a shift supervisor in late December 1988, discovered the
hangers to be removed.
It is not known who removed these hangers and no
documentation could be found to indicate why these hangers were removed.
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The reason for this violation, therefore, was personnel failure to adhere
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to the procedural requirement for identifying and reporting tasks which are
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beyond the scope of a maintenance order.
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'2.* Corrective Steos That Have Been Taken and the Results Achieved
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A deficiency tag'(no. 881487) and a maintenance' order (no. 890025) were
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written on January 1,1989 to identify and correct the problem.
Outstanding maintenance orders were jointly reviewed for safety concerns
before startup by outage and maintenance management personnel. However,
maintenance order 890025 was determined not to affect operability,
therefore, was not scheduled for completion before startup. This error is
considered an isolated instance since all other maintenance orders were
assessed for safety concerns and acted on promptly.
Subsequent to startup
on January 31, 1989, the NRC senior resident inspector noticed these
hangers missing on a plant tour February 13, 1989 and communicated this to
OPPD. These hangers were reinstalled on February 15, 1989.
An investigation was conducted via discussions with the Supervisor of
Maintenance, and with those personnel who had worked in the area (general
maintenance, insulators, steamfitters, and ironworkers) to determine the
reason for the hanger removal.
However, no person claimed responsibility
for the hanger removal or knowledge of why they were removed.
The Training Department has issued a " hotline" on the removal of pipe
hangers, seismic supports, and snubbers to all maintenance craftsmen and
planners, modification planners, and system engineers. This hotline
emphasized awareness to operability concerns and strict procedural
adherence for obtaining authorization to remove a seismic support, snubber,
or hanger. This authorization and review must be obtained before work
starts. This hotline requires a review by all the addressees and
acknowledgment by signature. New maintenance personnel are taught strict
procedural compliance requirements both in the General Employee Training
(GET) course and the " Conduct of Maintenance" course.
With respect to the question of diesel generator operability posed by the
hanger removal, Engineering Study 89-10 was initiated on February 15, 1989
to determine the system impact due to removal of the two subject hangers.
The analysis indicated that this pipe would not rupture or fall during a
seismic event with the two subject supports removed. Consequently, there
was no safety concern posed to diesel generator operability.
3.
Corrective Steps Which Will be Taken to Avoid Further Violations
OPPD believes the actions taken above are effective in addressing and
correcting the root cause of this violation.
However, continued emphasis
on this training is planned by a commitment to develop a course for an
introduction to work at the Fort Calhoun Station. This course will contain
information in the hotline noted above. 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 Comoliane ,_ Vill Be Achieved
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OPPD is currently in full compliance both with Criterion V of Appendix B to
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,10'CFR Part 50 and S0-G-21 as it pertains to this violation.
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RESPONSE TO NOTICE OF DEVIATh ,
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Based on the results of an NRC inspection conducted on February 1-28, 1989, a
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deviation of OPPD commitments made to the NRC was identified. The deviation
consisted of the failure to install and test portions of the fire water
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sprinkler system.
In accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the
deviation is listed below.
Failure to Install and Test Portions of the Fire Water Sprinkler System
(1) Section 9.11.3 of the Updated Safety Analysis Report (USAR) states, in
part, that a safe shutdown analysis has been performed on an area-by-area
basis to satisfy the provision of Appendix R to 10 CFR part 50.
Evaluation
of fire protection for safe shutdown is contained in the Safety Evaluation
Report (SER), " Fort Calhoun Power Station Unit 1," dated August 23, 1978.
Section 4.9 of the SER states, in part, that water curtains will be
installed to reinforce protection by 3-hour fire doors at doorway openings
between the turbine and the auxiliary building.
In deviation from the above, the licensee did not install a water curtain
at the doorway opening between the fan room (in the turbine building) and
Room 81 (in the auxiliary building).
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(2) Section 9.11.4 of the USAR states in part that testing is performed and
verified by inspection and audit to demonstrate conformance with subsequent
design and system readiness requirements.
In deviation from the above, the licensee failed to test the eight
fusible-link valves that supply the water curtains.
OPPD RESPONSE
1.
Reason for the Deviation. if Admitted
With respect to No. I above, OPPD respectfully requests the NRC to
reconsider classifying this item as a deviation.
Subsequent to the exit
meeting with the senior resident inspector, more information became
available which was not presented at the exit meeting. Water curtains are
installed at all doorway openings between the turbine building and the
auxiliary building. Water curtains are not required between the fan room
(Room 82) and Room 81 because they are both in the auxiliary building. Due
to the unavailability of information at the exit meeting, an apparent
misunderstanding regarding the location of the fan room (called the turbine
building mechanical equipment room) occurred due to this room being
evaluated in conjunction with the turbine building in the FCS Updated Fire
Hazards Analysis, Rev. 3, dated September 9, 1988, as Fire Zone 46.1.
The
Fire Protection Program Review dated December 31, 1976, upon which the SER
is based, describes the fan room as Fire Area 44 located in the auxiliary
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opening from the fan room into the turbine building.
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With respect to deviation No. 2, OPPD admits the deviation. However, no
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specific surveillance program is required or in place to test the
fusible-link valves.
These valves are considered part of the turbine
building sprinkler system and are visually inspected weekly by Operating
Instruction 01-FP-6 " Fire Protection System Inspection and Test" as part of
the turbine building sprinkler system as described in the USAR. OPPD
classifies the fusible link valves as special hazard wet pipe sprinkler
heads and believes this classification is more in keeping with the intent
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of the NFPA codes and ANI recommendations.
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2.
The Corrective Steos Which Have Been Taken and the Results Achieved,
OPPD requests reconsideration of this deviation (see OPPD response No. 1).
With respect to deviation No. 2, OPPD has reviewed the evaluations of areas
protected by the water curtain installations in the latest revision of the
Fort Calhoun Fire Hazards Analysis (Rev. 3). The water curtain
installations were incorporated into the SER on Technical Specification
Amendment 40 (August 23,1978) to reinforce protection by three hour fire
doors at doorway openings between the turbine building and the auxiliary
building.
It has been determined that the water curtains are not required
to protect safe shutdown components due to the adequacy of installed fire
barriers between the turbine building and auxiliary building openings.
Consequently, OPPD is pursuing an amendment to the Fire Protection SER to
delete the requirement for these water curtains as additional protection
since they are unnecessary to preserve safe shutdown capability in the
event of a turbine building fire.
3.
The Corrective Steos Which Will Be Taken To Avoid Further Deviations.
OPPD requests reconsideration of this deviation (see OPPD response No. 1).
With respect to deviation No. 2, OPPD has implemented a Fire Protection
Design Basis Review Program which has the goal of adopting the standard
license condition for fire protection as described in NRC Generic Letter 86-10. This will incorporate the fire protection program and major
commitments, by reference, into the USAR.
Inherent in this review is a
reassessment of fire protection commitments for clarity and compliance.
This effort should help to avoid future deviations of fire protection
commitments.
For the reasons noted above, no interim compensatory measures
are needed since the safe shutdown function is preserved without the fire
water curtains.
4.
Date When Full Comoliance Will Be Achieved
OPPD requests reconsideration of this deviation (see OPPD response No. 1).
With respect to deviation No. 2, OPPD will be in full compliance upon
approval of the SER amendment noted. Submittal of this amendment is
scheduled by June 30, 1989.
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