ML20246F385
| ML20246F385 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/24/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-796, NUDOCS 8908300311 | |
| Download: ML20246F385 (5) | |
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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 i
August 24, 1989 LIC-89-796
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U. S. Nuclear Regulatory Commission Attn: Document Control Desk
- Mail Station PI-137
. Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (J. L. Milhoan) to OPPD (K. J. Morris) dated July 24, 1989 Gentlemen:
SUBJECT:
Response to Notice of Violation / Deviation - Inspection Report 50-285/89-26 Omaha Public Power District (OPPD) received the subject inspection report. The report identified one violation and one 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 or require additicnal information, please contact me or members of my staff.
Sincerely, K-orris D vision Manager Nuclear Operations l
KJM/pje Attachment c: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator A. Bournia,-NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector 8908300311 090B24 PDR ADOCK 05000285
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ATTACHMENT Response to Notice of Violation During an NRC inspection conducted June 1-30, 1989, a violation of NRC requirements was identified. The violation involved the failure to report a deficient condition.
In accordance with the " General Statement of Policy and 1
Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:
Failure to ReDort A Deficiency Criterion XVI of Appendix B to 10 CFR Part 50 and ANSI 18.7-1976, Section 5.2.11 state, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, r'Munctions, deficiencies, deviations, defective material and egopment, and nonconformances are promptly identified and corrected.
The Fort Calhoun Station Quality Assurance Plan, Section 10.4, implements this requirement and states, in part, that deficiencies shall be documented and brought to the attention of the responsible manager and the Manager, Quality As:;urance and Quality Control.
Contrary to the above, on June 26, 1989, instrumentation and control technicians were observed to have encountered plugged instrumentation lines affecting a safety-related pressure transmitter, a deficiency, during the performance of Procedure ST-ISI-RW-3, " Raw Water Inservice Pamp Test." The technicians were observed to have disass*b4d, flushed, and reinstalled the tubing without documenting or report ng.he deficiency.
This is a Severity Level IV violation.
Dupplement I)(285/6926-02)
OPPD Response 1.
Reason for the Violation. if Admitted OPPD admits the violation occurred as stated. The former work practice of clearing plugged instrumentation lines without documenting this deficiency can be attributed to a lack of guidance on the requirements of Standing Order M-101, " Maintenance Work Control," as pertained to this particular task. Standing Order M-101 requires timely identification and proper documentation of any deficient condition observed.
2.
Corrective Steos That Have Been Taken and the R9sults Achieved The Instrumentation & Control (I&C) Supervisor has discussed proper work control practices with the I&C staff.
This discussion included verbatim compliance with maintenance work activities as required by Standing Order M-101, " Maintenance Work Control", and proper documentation requirements for skill-of-the-craft activities associated with plant maintenance.
In addition, Surveillance Test ST-ISI-RW-3, was revised to include instructions for technicians to ensure instrument tubing used for the test is frea from blockage. This procedure revision also includes
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l requirements t' hat abnormal conditions be documented in the " remarks" l
L section of the procedure. This corrective action will' ensure that this
- subject' activity will now be documented within the surveillance test procedure.- It should be noted.that' surveillance tests are reviewed by various plant' disciplines according to the nature of the surveillance test. These groups review the surveillance test for compliance with procedural _ instructions and verify the test acceptance criteria.is met.
This review would also-identify any potential deficiency by the use of a station incident report, which must be reviewed by the Plant Review
' Committee of which the Manager, -Quality Assurance and Quality Control is a member.
In addition, the Training Department has issued a hotline, dated July 10, 1989, which reemphasized the need to document' skill-of-the-craft activities in the comments section of a procedure. This hotline also noted that if the activity involved is a maintenance item, personnel are to write a maintenance work request in accordance with Standing Order M-101 and document this work in the comments section of the test procedure. This hotline was sent to maintenance crafts, operations,. chemistry, and radiation protection personnel, as well as training instructors for these groups. This corrective action will help to prevent a similar situation from. recurring in that personnel involved with maintenance work activities have been informed on the requirement for documenting skill-of-the-craft activities.
3.
.CorrectiveActions That Will Be Taken to Avoid Further Violations OPPD believes the actions taken above are effective in addressing.the root cause of this violation and will help to prevent further violations of this-kind.
Plant management will continue to monitor maintenance personnel and activities to ensure compliance with Standing Order M-101.
In addition, the Plant Syrtem Engineering group has under development an Engineering Assistance Request (EAR 89-019, initiated on August 17,1989) for the purpose of evaluating the plugged instrumentation line problem for the raw water system. Additional preventive maintenance activities or system modifications may be initiated as a result of this evaluation to mitigate this problem. This evaluation is currently scheduled for completion by November 30, 1989.
4.
Date When Full Comoliance Will Be Achieved OPPD is currently in full compliance with Standing Order N-101 and the Fort Calhoun Station Quality Assurance Plan, Secticn 10.4, as it pertains to this violation.
.s Response to Ngtice of Deviation Based on the results of an NRC inspection conducted during the period of June 1-30, 1989, a deviation of OPPD commitments made to the NRC was identified.
The deviation consisted of failure to properly support steamlines.
In accordance with the " General $tatement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the deviation is listed below:
l Steam Lines not Properly SuDDorted The Fort Calhoun Station Updated Safety Analysis Report, Appendix A, states, in part, that Class II equipment and components are required to conform to applicable industry design codes and standards. The applicable industry code for the Fort Calhoun Station is USAS B31.1-1967, " Power Piping." This codes states, in part, that in the absence of an alternate I
documented design calculation, the maximum unsupported span for 1-inch steam piping shall be 9 feet.
In deviation from the above, 1-inch steam service piping was discovered by the inspector supported at spans of 12 feet which exhibited excessive vibration and which had no retrievable design analysis proving its j
acceptability.
OPPD Res90nse 1.
Reason for the Deviation. if Admi.ited.
OPPD denies the deviation.
Support spacings provided by USAS B31.1-1967 are recommendations only. Section 121.1.4 of USAS B31.1-1967, Hanger Spacing, states "(w)here calculations are not made, suggested maximum spacing of supports for standard and heavier pipe are given in Table 121.1.4."
Tcble 121.1.4 states for a nominal pipe size of one (1) inch, the suggested maximum span is 9 feet. The intent of the suggested spans is to limit sag to 0.1 inches for operational considerations.
Footnote 3 to Table 121.1.4 in B31.1-1967 states that these spans result in a maximum combined bending and shear stress of 1500 psi. Section 102.3.2(d) of B31.1-1967 provides that the maximum longitudinal stresses for pressure, weight, and other sustained loads shall not exceed the allowable stress.
l For this material (A-106, Grade B), the allowable stress equals 15,000 psi at design temperature. As such, considerable latitude is acceptable when locating pipe supports on Class II (non-CQE) piping.
Further confirmation of the conservatism contained in the recommended support spans is demonstrated in a calculation, Calculation number FC05191, approved on August 10, 1989, prepared by 0 PPD.
In this analysis, OPPD calculated the maximum pemissible span for 1-inch, schedule 80, insulated piping. The calculation used simple beam theory, stress intensification factors taken from B31.1-1967, and included longitudinal membrane stress frodi design pressures. Span lengths derived in this calculation exceed 18 feet thus proving adequacy of the observed 12 foot span.
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The observed excessive ~ movement, estimated to be 1/2 inch peak to peak, of the service piping which was due to a worn lateral support reduced the vibration in the. service line. An evaluation of the estimated 1/2 inch peak to peak displacement resulted in stresses within allowable levels.
e OPPD also prepared an additional. analysis to address the NRC inspectors question regarding vibration observed in these lines. The analysis performed, Calculation number FC05192, approved on August 10,1989, is based on ASME/ ANSI OM3-1987, ~" Requirements for Preoperational and Initial Start-up Vibration Testing of Nuclear Power Plant Piping System". The.
calculation explores the effects of low amplitude, high frequency vibrations and prospective fatigue failures at critical locations. The results of this analysis show that the measured displacements after the repair, tinich range from 1/64 inches to 7/64 inches, peak to peak, will not result in fatigue failure.
It should be noted that within the general piping contract at the time of the steam piping installation (pre 1970) there was the following requirement for piping 2 inches or smaller: "(t)he Contractor shall develop the detailed dimensions for installation." Although these documents, due to the type and age, cannot be located, the above calculations. confirm that the origina1' installation conformed to USAS B31.1-1967.
2.
The Corrective Steos Which Have Been Taken and the Results Achieved.
No. corrective steps-have been taken.
3.
The Corrective Steos Which will be Taken to Avoid Further Deviations.
No corrective steps are planned.
4.
Date When Full Comoliance Will be Achieved.
With respect to the deviation, OPPD is in full compliance with USAR Appendix A, and USAS B31.1-1967 as it pertains to this deviation.
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