ML20246H857
| ML20246H857 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/28/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-763, NUDOCS 8909010390 | |
| Download: ML20246H857 (5) | |
Text
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Omaha Public Power District
{
1623 Harney Omaha. Nebraska 68102-2247 j
402/536-4000 August 28, 1989 LIC-89-763 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 14, 1989 Gentlemen:
SUBJECT:
Response to Notice of Violation - Inspection Report 50-285/89-01 Omaha Public Power District (OPPD) received Reference 2 which identified two violations. A two week extension was granted by the NRC in order for OPPD to obtain further information on the subject violations. 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 additional information, please contact me or members of my staff.
Sincerely, K.b. Morris Division Manager Nuclear Operations s
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 1
89o9010390 89082G
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1 I mployment with Equal OPD0flunstu Mdle F emale
ATTACHMENT Response to Notice of Violation During an NRC inspection conducted June 1-30, 1989, a violation cf NRC requirements was identified. The violation involved the failure to report a deficient condition.
In accordance with failure to take prompt corrective action of conditions adverse to. quality.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:
A.
Violations Involvina Chanaes in the Facility 10 CFR Part 50.59, requires that the licensee shall maintain records of changes in the facility. These records must include a written safety evaluation, which provides the bases for the determination that the change does not constitute an unreviewed safety question.
Contrary to the above, Omaha Public Power District failed to have a safety evaluation for each of the modifications listed below:
1.
A spray shield was installed in the switchgear room over load Center 184B. The spray shield was attached to a safety-related cable tray on one end with the other end being supported by a conduit from the load center.
2.
The diesel generator exciter brush housing inspection covers had been replaced with plexiglass covers.
3.
Installations of a temperature inversion switch in Radiation Monitoring Panel AI-338.
4.
Unsupported wiring with no redundant channel separation in the RCS hot leg and cold leg temperature and steam generator pressure control room instruments.
This is a Severity Level IV violation.
(Supplement I) (285/8901/05)
OPPD Response 1 -.
Reason for the Violation. if Admitted l
OPPD admits the violation for failing to provide a written safety evaluation for the modifications listed in items one (1) and two (2) above.
Subsequent to this inspection, OPPD located documented safety evaluations for modifications listed in items three (3) and four (4) above. With respect to the modification listed in item three (3) above, Engineering Evaluation and Assistance Request (EEAR) No. 80-68, completed July 3, 1980, documents, with a written safety evaluation, the installation of the temperature inversion switch in radiation monitoring panel Al-338.
With respect to the modification listed in item four (4) above, modification request MR-FC-85-132, completed January 13, 1989, documents, with a written safety evaluation, the instrument installation activities for control room panel CB-4.
Both safety evaluations noted above are available for NRC review.
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h-The spray shield modification (Item 1 above) was installed due to a water leak (since repaired) in the compartment above the switchgear room. A search of historical maintenance records and verbal discussions with cognizant personnel failed to identify the required source documentation.
It was determir.ed that the installation of this shield occurred between 1977 and 1079. The reason for the absence of required documentation cannot be determined.
The plexiglass cover modification (No. 2 above) was installed under maintenance order M0 2734, dated October 23, 1973. This maintenance order was reviewed and approved by the Plant Review Committee (PRC). At this time, there was no formal documentation for the evaluation of an unreviewed safety question. This practice'was changed in 1976 with the introduction of Form FC-154 which required the evaluation of an unreviewed safety question to be formally documented. This requirement for written documentation is currently in place at Fort Calhoun.
i 2.
Corrective Steos That Have Been Taken and the Results Achieved The' spray shield modification was removed under Maintenance Or(.ar 892046, dated March 30, 1989, therefore this plant condition no longer exists.
The plexiglass cover modification has been reanalyzed as two temporary modifications (there are two diesels with the plexiglass covers), under temporary modification requests TM-89-M-021 and TM-89-M-022,' including documented safety evaluations. Therefore, these installations are now documented as temporary modifications which include safety evaluations. A long term resolution has been approved to include these temporary modifications into the scope of a permanent modification, FCS-MR-FC-83-133, to be completed during the 1990 refueling outage.
3.
Corrective Steps That Will be Taken to Avoid Further Violations l
OPPD believes that procedure N00-QP-3 "10 CFR 50.59 Safety Evaluations",
provides strong guidance' for personnel on the requirements of 10 CFR 50.59. This procedure requires documentation be provided prior to the approval of any known temporary or permanent modification to Fort Calhoun Station.
Personnel who perform safety evaluations at Fort Calhoun receive training on N0D-QP-3. OPPD believes the present procedures and training constitute a strong 50.59 program that will minimize the potential for further violations in this area.
OPPD is currently evaluating the impact of this violation on events that
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occurred early in the operating history of Fort Calhoun Station. The
'j results of this evaluation and a subsequent plan of action will be complete by December 1, 1989.
i 4.
Date When Full Compliance Will be Achieved OPPD is currently in full compliance with the requirements of 10 CFR 50.59
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as it pertains to this violation. OPPD will inform the NRC of the results i
of the evaluation of past practices by December 15, 1989.
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I B.
Failure to Take Prompt Corrective Action Criterion XVI of Appendix B to 10 CFR 50 requires that, " Measures shall be established to assure that conditions adverse to quality, such as failures, l
malfunctions, deficiencies, deviations, defective material and equipment, and nonconfomances are promptly identified and corrected."
j This requirement is implemented by Section 10.4 of the licensee's quality assurance plan, which states in Section 4;1.1 that, " Conditions adverse to l
quality, such as failures, malfunctions, deficiencies, deviations, defective l
material and equipment, and nonconformances, shall be promptly identified and corrected as soon as practicable."
Contrary to the above, the NRC inspectors found on April 19, 1989, an energized lighting circuit in the No. I diesel generator room which was routed outside of conduit with the energized wiring hanging on the valves on the air start receivers.. This problem had Seen identified by the licensee in 1987 and Maintenance Order 874799 w
- 1ssued on October 14, 1987, to correct the problem. The MO was subsequently lost or misplaced. The condition was again addressed in January 1989. Maintenance Order 890297 was issued on January 10, 1989, to repair the wiring, but the problem had not been corrected at the time l
of this inspection.
This is a Severity Level IV violation.
(Supplement I)(285/8901-06) 1 OPPD Response 1.
Reason for the Violation. if Admitted l
OPPD admits the violation occurred as stated.
The untimeliness of completion of this task can be attributed to assignment of a low priority for this task.
The wiring temporarily routed outside of conduit can be attributed to a diesel generator turbocharger modification performed during the 1987 refueling outage. The modification required removal of a light fixture and two sections of conduit to accommodate installation of temporary lifting eyes to remove and install turbocharger.
It has been determined the conduit work should have been included in the scope of the turbocharger modification.
Because of late preparation of modification work packages, pre-modification work and subsequent post modification work was accomplished with the use of maintenance orders. Maintenance Order 874799 was written to reinstall the light fixture and conduit as a post-modification work item. This practice l
was allowed at the time (late 1986), but is no longer allowed at Fort Calhoun Station.
Standing Order M-101, " Maintenance Work Control",
approved May 23, 1989, now requires the system engineer to review
. maintenance work orders to ensure the maintenance work order does not fall within the scope of the modification program.
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2.
Corrective Steos That Have Been Taken and the Results Achieved To address and correct the identified condition, the wiring was placed back in conduit on May 4, 1989 under maintenance work order 890297. Subsequent
-investigations indicate that an unauthorized modification was performed in that~ the light fixture was not reinstalled, and the conduit was not placed along its original route. No modification package was prepared for this.
work and the use of a maintenance order to perform the work was inappropriate. A Quality Assurance Deficiency Report, FCl-89-252, was issued on this unauthorized modification on August 9,1989 which requires this work to be documented as a modification or the installation returned to its original configuration. The NRC will be appraised of the outcome of the investigation of this separate issue by September 30, 1989.
l The problem of inadequate control over modification related work has been addressed by a revision to Standing Order G-21, " Station Modification l
Control". This revision, dated December 14, 1988, requires a field 1
walkdown (after work completion) to verify conformance with the design package and identify any other discrepancies discovered (e.g. wiring outside of conduit).
j To address the timeliness of maintenance activities, the Safety Enhancement l
Program (SEP) goal of reducing the corrective, nonoutage maintenance order I
backlog to less than 600 items was achieved by the end of April,1989.
This has resulted in more manageable control over work.
j 3.
Corrective Steos That Will Be Taken to Avoid Further Violations OPPD believes the steps taken above are effective for ensuring prompt corrective actions. The recommendation from Quality Assurance Deficiency j
Report FCl-89-252 will be reviewed and corrective actions taken based on l
that review.
It should also be noted that a significant enhancement to the Fort Calhoun maintenance program is planned which includes a program reorganization and personnel additions to both planning and scheduling i
groups to ensure proper task prioritization and timely execution of
,i maintenance activities. The implementation of this program enhancement is expected by September 30, 1989.
Engineering procedures will be reviewed and revised as necessary to ensure that the removal and reinstallation of interfering plant equipment or other activities that could alter the i
configuration of FCS are controlled by the modification package only and j
without the utilization of maintenance orders. This task will be completed j
by December 1, 1989. OPPD intends to continue monitoring the above program j
enhancements and take corrective actions, as necessary, to ensure effective l
and timely maintenance actions remain in place at Fort Calhoun Station.
4.
Date When Full Compliance Will Be Achieved OPPD is currently in full compliance with Criterion XVI of Appendix B to 10 CFR 50 and Section 10.4 of OPPDs Quality Assurance Plan as it pertains to this violation. The NRC will be appraised when full compliance will be achieved with respect to the OPPD identified deficiency by September 30, 1989.
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