ML20246N260
| ML20246N260 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/12/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8907190330 | |
| Download: ML20246N260 (2) | |
See also: IR 05000285/1988201
Text
~ ~
~
% ' ,' ,
7 ]
n c
.
. .
i
'
b
Q" ,
,
p
,
. .. ,
_ yt
In Reply' Refer To: .
e
.
d lI R
l Docket: ~50-285/88-201
,. = Omaha' Public Power District -
ATTN: - Mr. Kenneth J. Morris, Division Manager
ri c _. Nuclear Operations
444 South 16th Street Hall.
Omaha, Nebraska- 68102-2247
Gentlemen:
Thank you for your letters of April 30 and June 15, 1989, in
response to our letters and Notice of V.iolation dated February 9 and March 17,
1989. We have reviewed your reply and find it responsive to the' concerns
' raised in our Notice of V1olation. We will review the implementation of your
corrective actions during a future inspection to determine that full. compliance .
.has been achieved and will be maintained.
Sincerely,
Original Signed By-
T f. C w ynvt
James. ' L. Milhoan, Director
Division of-Reactor Projects
cc:
G. R. Peterson, Manager
Fort Calhoun Station-
P.O. Box 399-.
Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae '
1333 New Hampshire Avenue, NW
Washington, DC 20036 l
Nebraska' Radiation Control Program Director
bectoDMB(IE01)'
, RIV: SRI
'hh DRP g DRP/B ..
17
D/DRP
- / ' PHHarrell/nc RPMullikin . TFWesterman MJLMilhoan
$/89 q/g/89 q/gd89 g 7 //t/89
f 07/)tv
e90 m oaao e m ,,
6 GoI
,
'
gDR ADocx osoooaas 1\l
PNU
_ _ - _ _ _ _ _ _ _ _
_ _ - . - _ _ _ _ _ _ _ - _ .
_
t;, -
.
.
<
' .;
Nk I
'. f:;' _ , , '
"
}f
-
0maha Public. Power District - - 2-
b'cc /*strib. by RIV:
R.-D. Martin,.RA ~ . . MIS System
-.Section Chief (DRP/B). DRP.
-
-RIV File ^ Project Engineer (DRP/B)
RSTS10perator A. Bournia, NRR Project Manager (MS 13-D-14)-
Lisa.Shea,RM/ALF RRI
, , DRS' RPB-DRSS.
'
.
t
}'
+
t
- _ , ~ , . _ . .
.-.-._d..,___,_ _ _ - - - ___ _ . . . . _ _ -__ -____m- - ' ___.__.._.i_ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ -
.,. ___-__-_----.-,
@ 'd SPsGl' 68/01/LO SdN NnOHlOD.1 mod:WOMd-
\ 'q L
\
'
L. E. k N'Mf
__ ._
Omaha Public Power District
f 623 Hamey Omana. Nebraska 68102 2247
402/536 4000
l
April 30, 1989
LIC-89-349
I
U. S. Nuclear. Regulatory Commission i
Attn: Document Control Desk '
Mail Station PI-137 .
Washington, DC 20555 l'
.
References: 1. Docket No. 50-285
2.
March 17,-1989 Letter from NRC (L. J. Callan) to OPPD (K. J. M
3.
February 9, 1989 Letter from NRC (G. M. Holahan) to OPPD (K
4.
April 5, 1989 (LIC-89-335) Letter from OPPD (K. J. M
Gentlemen:
.
.
SUBJECT: \
Operational Safety Team Inspection (OSTI) Respo
Omaha
1989 which was Public
included Power District
in Reference 2 (OPPD) received cthe Not
derivedinfrom
received the 3.
Reference Operational Safety Team Inspection (OSTI) Report,
Mr. J. J. Fisicaro (OPPD) an extension to AprilPer conversations between
30, 1989 was granted for(NRC) and
submittal of this response. the
As described
Enhancement Program in(SEP).
Reference 4, OPPD has integrated the OSTI aeyresults
response, as applicable. The SEP Reference Numbers have been include
OPPD's response to the violations. Pursuant to the provisions of 10 CFR ,
The additional information which was
specifically requested for the unretolved items can be found in Attachment 2
Information on the remaining four open items can be found in Attachment 3 .
.
,
The format of Attachment 1 is such that immediately following the progr
responses
specific to Violations
example. B, C, 0 and F, information is provided to address each
i
1
45Sua
tmoiowmeng opponung
W
, .- . .~
n.
'
-W ; -
U.LS. Nuclear Regulatory commission
" [1 '
-
'
-
LIC-89-349:
Page 2
i
k If you have any questions.concerning this matter, please do not hesitate to
l' contact us.
Sincerely, ,
'
I
. . orris
.D vision Manager
Nuclear Operations.
KJM/jak
Attachment 1: Response to Notice of Violation
Attachment 2: OSTI Unresolved Item Information
Attachment 3: OSTI Open Item Information
c: LeBoeuf, Lamb, Leiby & MacRae
T, E. Nurley, NRC Director, Nuclear Reactor Regulation
R. D. Martin, NRC Regional Administrator-
P. D. Milano, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
U
.
8
U
_
,
-
_
_. _ . _ _ __. _ _ _ _ _
'
' .,
- 9- j
- -_y.. Attachment'1
'
RESPONSE TO NOTfcE OF VIOLATION .
'
,
During an NRC inspection conducted from October 31 through November 10, 1989,
violations of NRC requirements were identified. The. violations involved
' procedural control of shift turnover logs, failure to follow procedures,
inadequate control of temporary procedure changes, inadequate instructions for
the performance of safety-related activities, failure to comply with ASME Code
requirements, and inadequate corrective action program. In accordance with the :3
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR
Part 2, Appendix C (1988), the violations are listed below.
1
)
U l
l
Page 1
.
tj
w _ -__---__.--- ---- - - - - - - - - - - - - - - - - -
^s l
p.*
A. No Procedural Control for Shift Turnover Loos
'
Technical Specification 5.8.1 states, in part, that written procedures
shall be established that meet or exceed the minimum requirements of
Appendix A of Regulatory Guide 1.33.
Paragraph 1 of Appendix A to Regulatory Guide 1.33 requires that
administrative procedures shall be established for shift and relief
turnover,
i ;
,
Contrary to the above, the licensee failed to establish an adequate
procedure for shift turnover in that Standing Order 0-29 did not specify
that Forms FC-95 and FC-95A, used by operations personnel to record plant
status, had to be completed for shift turnover. (285/88201-01)
This is a Severity Level IV violation. (Supplement I)
OpPD Resoonse
1. Admission or Denial of the Alleaed Violation
'0 PPD admits the violation as stated.
2. The Reasons for the Violation. if Admitted
Standing Order 0-29, " Conduct of Operations," Revision 7, did not uniquely
specify check list cotnpletion as part of the shift turnover process.
3 However, operation personnel routinely completed the shift turnover forms
based on non-proceduralized guidance and the general instructions for shift
turnover listed in' Standing Order 0-29. >
3. The Corrective Steos That Have Been Taken and the Results Achieved
Standing Order 0-29, " Conduct of Operation," Revision 10 was issued April
14, 1989. This revision provides specific guidance in regard to the shift
turnover process including specific instructions for completion of shift
turnover check lists, Forms FC-95 and FC-95A. Operations personnel are
currently completing these forms per the instructions of Standing Order
0-29.
4. Corrective Steos Which Will Be Taken to Avoid Further Violation
No other corrective steps are necessary.
5. Date When Full Como11ance'Will Be Achieved
GPPD is currently in full compliance.
Page 2
V
-
_-
6 *d 2G:81 68/01/LO SdN Nn0H10D 180d WO8d
%
\
8. Failure to Follow Procedures
Criterion V of Appendix B to 10 CFR Part 50 and the licensee's NRC-approved
quality assurance program states, in part, that activities affecting
quality shall be prescribed by documented procedures, of a type appropriate ;
to the circumstances, and shall be accomplished in accordance with these '
procedures.
Contrary to the above, six (6) examples were cited.
This is a Severity Level IV violation. (Supplement I)
OPPD Resoonsc
1. Admission or denial of the alleoed violation
OPPD' admits the violation.
2. The reasons for the violation if admitted
The six examples cited were incidents in which personnel failed to follow
procedures. As discussed in the response to the specific examples B.3,
8.4, B.5 and B.6, a contributing factor was that the procedures involved
provided inadequate guidance.
3.
Corrective steos that have been taken and the results achieved
The Procedural Compliance effort (SEP Ref. No. 44) which is part of the
Safety Enhancement Program has been used to ensure the proper use of, and
compliance with procedures.
Plant personnel have been informed by memos and in meetings that the proper
use of, and compliance with, procedures is required. In addition,
procedural compliance is included as an evaluation criterion on performance
appraisal s. Incident Reports are being written to document and track
procedural violations. To ensure proper compliance with procedures,
supervisory review and one-on-one meetings have been conducted with most of
the operators which emphasize personal accountability. In addition,
supervisors are now spending more time in the plant providing personal
guidance and direction.
Standing Order 0-29, " Conduct of Operations," has been modified by Revision
10, issued April 14, 1989 to provide station personnel with additional
administrative guidance on procedure use. It defines when station
personnel are required to have a procedure in hand and provides guidance
regarding the review of the procedures prior to use.
4. Corrective steDs which will be taken to avoid further violations
!
The Procedural Compliance effort (SEP Ref. No. 44) will continue to place
emphasis on the proper use of, and compliance with, procedures.
The Procedures Upgrade Project (SEP Ref. No. 48) will be used to improve <
the accuracy and completeness of appropriate precedures. Also, since human
factors are considered during this upgrade effort, it will be easier for {I
personnel to follow the procedures.
Page 3
,
_ _ _ _ _ _ - - _ _
. .- _ _ _ - - - ~ . - - _ - -
l: -('
h s ,
i: \ 5. Date When Full Comoliance Will Be Achieved
'
OPPD is currently in full compliance based on the corrective actions as
J
. described in the responses to the six examples.in regard to failure to
' follow procedures.> The additional corrective actions involving procedure
improvements, for example B.5 and B.6, will be completed by June 30, 1989.
O
Page 4
V
_
!!'d CSISI 69/01/LO SdN Nn0H103 1803 WOW 3
'\
B.1 Paragraph 3.1.4.6 of Standing Order 0-24, " Log Entries" states, in
part, that log entries should be made when documenting compliance with J
the requirements of a Technical Specification limiting condition for
operation.
Contrary to the above, the licensee did not provide the appropriate
log entries in that compliance with the limiting condition for
operation for Technical Specification 2.19(4) for the motor-driven
fire pump was not met and the appropriate log entry was not made.
(285/88201-02)
QPPD Resopnse to 8.1
The missed log entry for the inoperable motor-driven fire pump was due to
personnel error resulting from inattention to detail.
Operations personnel were reminded of the importance of detailed logging of
activities related to inoperable equipment as required in Standing Order
0-24, " Log Entries". In addition, the Control Room Turnover Sheets were
reviewed to determine if inoperable equipment logging could be improved.
Form FC-95 was expanded to include a detailed section for Limiting
Condition for Operation (LCO) entries. Standing Order 0-29, " Conduct d
Operations," Revision 10, now includes specific instructions regarding Jorm
In addition, Technical Specification LCO's are tracked and updated daily by
the shift technical advisors on the newly developed " Plan of the Day".
This enables station management, engineering, and maintenance personnel to
be knowledgeable of all out-of-service technical specification related
equipment.
Page 5
V
_ . -
-_ _ _ _ - - -
- - - - - - _ - - - -
'
- 21'd 05 G1 68/01/LO SdN Nn0HlOD~1803 WOdd
.
,
j .s .
L 8.2 Paragraph 2.3 of Standing Order 0-13 " Operations Memorandums "
I states,.in part, that as soon as practical following the issuance of
L
'
an operations memorandum, a review shall be conducted to ensure that
all information is installed into all applicable operating procedures
or instructions.
Contrary to the above, operations memoranda were issued and the d
information not included into all applicable operating procedures or
instructions in that operations memoranda affecting procedures had
been issued for up to 10 years and the applicable procedure had not
been changed. (285/88201-03)
OPPD Retoonse to B.2
As indicated in your letter, NRC (L. J. Callan) to OPPD (K. J. Morris)
dated March 17,.1989, no response to Violation B.2 is required since the
acceptable corrective action has been completed and is documented in NRC
Inspection Report 50-285/89-03.
The one remaining Operations Memorandum, OPS Memo 88-06, " Inoperable Raw
Water Pump," will be cancelled when Technical Specification Amendment 120,
becomes effective on May 14, 1989.
U
Page 6
V
_ _ _ _ _ _ _ _ _ _ - _ - - - - - . - - -
_ - ____ _ __-____----_ .-
- CI'd PS:St 68/01/L0 SdN NnOH W3 180d WOdd. .
-
, i
L fg' ,
'
. B.3. Paragraph 7.2.2 of Standing Order 0-25, " Temporary Modifications,"
states, in part, that the plant review committee must review and
approve the temporary modification within 14 days after the date of
- its installation.
]
Contrary to the above, the plant review committee did not review I
temporary modifications within 14 days after installation in that {
Temporary Modifications 88-E-46, 88-E-49. - and 88-E-47 had been '
installed greater than 14 days without being reviewsd by the plant
review committee. (285/88201-05)
OPPD Resoonse to B.3
At the time of the violation Standing Order 0-25, " Temporary Modification
.
Control," Revision 25, allowed temporary modifications to be first
installed and then reviewed by the Plant Review Committee (PRC) within 14
days of installation.
This created the situation in which temporary
modifications 88-E-46,.88-E-47, and 88-E-49 were installed, but, due to the
large volume of PRC review items, the temporary modification control
process failed to provide the appropriate follow-up tracking which resulted
in the PRC review and approval not seing performed within the 14 day time ~ '
limit.
Standing Order 0-25. " Temporary Modification Control," Revision 28 was ,
issued February 21, 1989. This revision of 0-25 requires that temporary
'
modifications be reviewed by PRC prior to installation. The only
exceptions allowed to this prior review requirement.is in the case of an
emergency modification as determined by the Shift Supervisor. In this
situation PRC review will.be obtained within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the emergency
. . . . ,
-
modification. To date there have been no emergency modifications.
Since Standing Order 0-25 Revision 28, has been issued, 13 temporary
modification packages have been reviewed by the PRC prior to installation.
OPPD realized that temporary modification control at Fort Calhoun Station
needed additional review and improvement, therefore SEP Ref. No. 71,
" Temporary Modification Control Improvements," was added to the Safety
Enhancement Program,
i
Page 7
U
- -
-. ;
,
e t * d-
^ SS8S! 6s/01/40 ' SdN NnOH~l6D ' 1hlod Wohld
,
'
,t.
' F.
,; = ! '
- ^ ;B.4
.
.
.
Paragraph 1;2 of Standing Order 0-17 states, in part, that the ,.
.
L:
approved operating instructions will be used 'to start-up, operate, and
shutdown all plant systems"and equipment.
Contrary to the above, licensee personnel failed toiuse procedures for.
. operation of, plant systcas in that the component! cooling water and;
resin transfer systems were operated without the use of procedures.
(285/88201-09)
OPpD ResDonse to B.4
The component cooling water system was operated correctly in th'at the-
procedure steps of Operating Instruction 01-CC-4, "Lmponent Coolin
Systems 0utage for Maintenance," Revision 8 were followed, however,gthe
operator did rot have specific guidance that he should have the procedure
"in hand."
The incident involving the failure to follow procedures during spent resin
transfer'resulted from an. inadequate procedure-in that certain steps were
provided in the prerequisite section rather than as clearly defined steps
in the procedure. The problem was compounded when the individual involved
continued on his own rather.than stopping work and obtaining.an approved On
the Spot Change (OTSC) before proceeding.
Standing Order 0-29, ." Conduct of Operations,". has been modified by Revision- "
10, issued-April 14, 1989 to provide station personnel with additional
administrative guidance'on procedure use. It defines when station
personnel are required to have a procedure in hand and provides guidance -
regarding the review of the procedures prior to use. It also allows a
- shift supervisor to take action.outside the scope of a procedure when
required to protect plant personnel and equipment or to meet Technical
Specification requirements. Specific instructions are provided which
define the subsequent actions.and documentation requirements.
Operating Instruction 01-CH-6, "CVCS Resin Transfer," has been revised to
correct identified procedural deficiencies. Revision 12 was issued on
April 27, 1989.
The Procedure tipgrade Project (SEP Ref. No. 48) will be used to improve the-
accuracy and completeness of revised Operating Instructions.
Page 8
- ___- __ _- _
l ,
a *d 90:91 88/01/40 SdN Nn0H' LOD 180d WOBd
,
o,
\ ,
'
B.5 Paragraph 5.9.9 of Standing Order G-17, " Maintenance Order," state.s, '
in part, that the craftsman is responsible for recording the purchasc
order number for parts and materials used that are CQE
(safety-related), limited CQE, fire protection, or radioactive waste
packaging materials.
Contrary to the above, the craftsman failed to provide the appropriate
data on the maintenance order in that the purchase order number was
not recorded on Maintenance Order 884163 for parts used to repair the
breaker for Charging Pump CH-10. (285/88201-10)
OPPD Resoonse to B._5
The part which was used (the breaker racking position indicator) was not a
CQE part. Standing Order G 17, " Maintenance Orders," Revision SS, and the
associated Maintenance Order (MO) Form FC-63 were unclear as to what
information wLs to be included on the M0 for non-CQE subcomponents which
are acceptable for use in CQE components. Standing Order G-17 provided no
guidance for the documentation on M0 Form FC-63 of the use of non-CQE
subcomponents in CQE components. Therefore, the individual completing the-
MO section regarding the Purchase Order No. did not have adequate guidance.
MO 884163 was reviewed by the System Engineer and it was confirmed that the
non CQE part could be acceptably used in the repair of the breaker for
Charging Pump CH-IC without degrading its safety related function.
A revision to the Station Standing Orders will be issued by. June 30, 1989,
which will provide clearly defined instructions regarding docun,entation of
non-CQE parts used in CQE components.
U
Page 9
--
,
!
_-__-.___m __ ._
_______ ___ _ __-. _ - _
,
'
..rh 1, Lcc*d )50;91.68dO1W.0~ SelN E Nn0H lO - 1M04 kl0M d
w ;
.
pg' , *
"
'
'
'
-j
B.6 ProcedutJ ST-ISI-RW-3, " Raw Water Pump Inservice Inspection," states, {
y
-
~
't '
in-part, that the craftsman shall measure and record.the pumpe j"
i
'
peak-to-peak = vibration amplitudes on the stuffing box just:below the
'
bearing packing nut, perpendicular to the pump shaft.t The exact
, ,- location should be marked by a yellowL"X*. If no markits present,
check vibration amplitude completely around the circumference'and use
the maximum amplitude found. Mark the location-for the. greatest
amplitude for future reference.- 'l
,
,
Contrary to.the above,, licensee personnel failed to follow procedure
in that no mark was present on the stuffing box and the craftsman
J
' failed to check the vibration amplitude completely around the~
circumference of the stuffing. box.- (285/88201-22)
OPPD Resnonse to B.6
The individual performing. the vibration test knew the location regarding
the placement of the probe based on prior experience. Because the
procedure was with the operator in the control' room who was directing the
test, the technician performing the vibration monitoring did not'have the-
a procedure "in' hand" and could-not follow the procedure exactly as written-
regarding the' requirement to take multiple readings if the " yellow X" was
not visible.
Subsequent review of Surveillance Test ST-ISI-RW-3, " Raw. Water Pump
Inservice.' Inspection, " Revision 17, revealed that it.was improperly
written in regard to performing the vibration test if the " yellow X" was
missing or obscured.
. Three additional readings were taken on the stuffing box immediately
following the observed incident, however, in some areas readings could not
be obtained due to space limitations in setting up the probe. The " yellow
X's" used to identify the proper locations for the vibration test-probe '
'
placement were remarked and are now clearly visible .
Surveillance Test ST-ISI-RW-3 has been performed successfully 5 times since-
the violation occurred and no problems regarding the proper placement of
, the test probe have been experienced.
Standing Order 0 29, " Conduct of Operations," has been modified by Revision
10 issued April 14, 1989 to provide station personnel with additional
administrative guidance on procedure use. It defines when station
personnel are required to have a procedure in hand and provides guidance
regarding the review of the procedures prior to use.-
ST-ISI-RW-3 was reviewed to establish the basis for the requirement to take
multiple readings around the circumference of the stuffing box if the-
single " yellow X" was not visible. It was determined that taking readings
vibrationtrend}hta.at the same sing e point was the preferred method to obtain reliable pu
The multiple reading requirement appeared to be a
carry over from the initial pump vibration test which was used to determine
which single point provided the highest vibration reading.
Page 10
V
.
_ __,_,_______m ------.----A--- - - - - ~ ^ ^ ^ = - - " ' - ^ - - - - - - ~
_-
,
-.
.
P'*d 90t91 ~ 69/01/40 SdN Nn0H103 1803 WOMd.
.o,'- , .
Surveillance Test ST-ISI-RW-3 " Raw Water Pump Inservice Inspection," is
being revised to. include specific instructions to place the probe in the
single correct location that will provide reliable vibration trending
data. These instructions will provide for the correct placement of the -
. probe without reliance on a mark which could be obscured between ter,ts.
This revision is expected to be issued by June 30, 1989.
The Procedures Upgrade Project (SEP Ref. No. 48) will be used to_ improve
the accuracy and completeness of revised Surveillance Tests. The
Surve111ance' Test Performance Improvement effort (SEP Ref. No. 72) is also -
,
applicable.
O
Page 11
U
_
b g- d' 40:9I 68/01/LO sdN Nn0HlO 1803 WOdd
"
...
'
'
,.
, e ,
"
-C. Inadeounte' Control of Temocrary Procedure Chances
' Technical Specification 5.8 states, in part, that temporary changas to l
procedures may be made pro';ided that the. intent of the original procedure i
is not altered and the change is documented, reviewed by the plant review I
,
couraittee and approved by the Manager, Fort Calhoun Station within 14 days
!~
of implementation. _
3
'
Contrary to the above, two examples were cited.
This is a Severity Level IV violation. (Supplement I)
OPPD Response
1. Admission or Denial of the A11eaed Violation
OPPD admits the violation for example C.1 in that it was a case of failure
to follow procedures combined with an inadequate instructions problem
rather than inadequate control of temporary procedure changes. Refer to
the response' to C.2 for the justification that the temporary procedure
change control process was appropriate and adequate in regard to example
C.2.
2. The Reasons for the Violation. if Admitted
As discussed in the response to example C.1, there were inadequate
instructions regarding the use of "not applicable" for acceptance criteria
sections of the Surveillance Test ST-DC-1, " Station Batteries."
3. The Corrective Steos That Have Been Taken and the Results Achieved
The actions re arding compliance with procedures have been addressed in the
response to Vi lation B. " Failure to Follow Procedures." The actions
regarding inadequate instruction has been addressed in the response to
example C.I.
4. Corrective Steos Which Will Be Taken to Avoid Further Violation
Guidance regarding the acceptable methods to document results while
performing a Surveillance Test is being addressed in the Surveillance Test
Performance Improvement effort (SEP Ref. No. 72). Surveillance Test
procedures will be reviewed for accuracy and completeness as part of the
Procedures Upgrade Project (SEP Ref. No. 48). The compliance with
procedures will continue to be stressed as part of the Procedural
Compliance effort (SEP Ref. No. 44).
S. Date When Full Comoliance Will Be Achieved
OPPD is currently.in full compliance based on the corrective actions in
regard to failure to follow procedures. Surveillance Test ST-DC-1,
" Station Batteries," Revision 38, corrected the inadequate instruction
problem of example C.I.
Page 12
l
V
- . _ -_
._ _ - _ -. - __ . _ - - - - - - - -
'
7 , , 9 'd- 40:91 68/01/LOf SelN.NOOHlO 180d'WOMd
y
o
7
.. . ,.
,
-
- q
W Ci Contrary to:the above, the intent of'a procedure was changed'without. '
o
L prior approval of the plant review committee in that ~ the acceptance
L
'
criteria provided in Surveillance Test ST-DC-1, " Station Batteries,"
P was deleted during performance of the surveillance test. '
~.
-(285/88201-15)
OPPD'Resoonse'to C.1
When Surveillance-Test-ST-DC-1 " Station Batteries," Revision 33, was
performed on= February 2,-1988.there was inadequate guidance concerning-the
use 'of "not applicable" statements in the completion of the procedure. The
-individual performing the Surveillance Test did not have proper guidance,-
therefore he assumed he was not altering the procedure when he indicated :
"NA", " test values not available." Therefore, he did not. initiate a
procedure change.
The Surveillance Test ST-DC-1 was subsequently reviewed and revised with
the appropriate PRC approval. The revision re-worded the initial
'
conditions and procedural steps so that clearly defined responses are.now-
required. ' Surveillance Test ST-DC-1, " Station Batteries," Revision 38,-
which revised theLinappropriate steps, was issued on September 2, 1988..
Guidance regarding the acceptable methods to document results while
performing a Surveillance Test is being addressed in the Surveillance Test
.
p Performance Improvement effort (SEP Ref. No. 72 Revisions to
Surveillance Tests will be reviewed for ac:uracy).
'
and completeness as part
of the Procedures Upgrade Project (SEP Ref. No. 48). Compliance with
procedures will continue to be stressed.as part of the Procedural
Compliance effort (SEP Ref. No. 44).
.Inaddition,OSTIRe$ortUnresolvedItem.(285/88201-15) contained anoder
exanle'related to t e improper use of an On The Spot _ Change (OTSC) for
conducting Surveillance Test ST-FIL-2, " Charcoal /HEPA Filter Bank In-Place
~
Testing." The technician performed the test on October 20, 1988 using a
procedere marked " DRAFT 10-10-88" with.a copy of Procedure Change No. 25450
attacheo which indicated it was an OTSC initiated on October 18, 1988.
Upon investigation of this incident it was discovered that the original
Procedure Change No. 25450 had undergone PRC review on October 19, 1988 and
was approved by the Plant Manager on October 20, 1988. Surveillance Test
ST-FIL-2, Revision 16 was issued for use on October 20, 1988. . The
. technician used the-draft version of Revision 16 rather than the properly
reviewed, approved and issued Revision 16. The requirement to use the
latest approved procedure is included in the Procedural Compliance effort
(SEP Ref. No, 44) which will continue to emphasize the proper use of,'and
compliance with, procedures. The difference between the draft and issued
versions was in the prerequisite section. Revision 16 draft stated
" Personnel qualification and calibration records are available for QA
review" whereas the issued version stated " Personnel qualification and
calibration records have been reviewed and accepted for use by QA." The
intent of the procedure was not significantly changed between the draft
version which was used and the formally issued version.
This was an incident where the individual failed to obtain the latest
approved procedure prior to performing the test. The requirement to use
,-
'
the latest approved procedure is included in the Procedural Compliance
effort (SEP Ref. No. 44) which will continue to emphasize the proper use
of, and compliance with, procedures.
Page 13
- l_- _ ___
_ _ _ _ - _ - - . _. -- ---.
{' .
,
-
t ..
i
b. C.2 Contrary to the above, the plant review connittee did not review and ?
l
'
the Manager, Fort Calhoun Station, did not approve temporary procedure
changes within 14 days in that temporary changes were made to Surveil-
Li j lance Test ST-CONT-2, " Local Leak Rate Testing-Type B," and the tempor-
'
W 'ary changes were not approved within the 14-day time limit.
(285/88201-19)
OPPD Resnonse to C.2
As described in the following response to the specifics of the OSTI Report 3
Unresolved Item 285/88201-19 the temporary procedure change control process
was appropriate and adequate.
Because Surveillance Test ST-CONT-2, " Local Leak Rate Testing - Type 8,
was conducted over several weeks, the test activities involved the use of
procedure Revision 26 in effect at the start of the test. Revision 26 had
been subsequently updated with On The Spot Changes (OTSC's). The
technician had followed the authorized practice of continuing to use
Revision 26 and attaching the approved OSTC's to his work package during
the on going testing.
As indicated in the OSTI report, the NRC inspec+or, during the review of
this activity, was using Revision 29. The techn.':ian was using Revision 26
in conjunction with three approved OTSC's which provided the equivalent of
Revision 29. The three OTSC's No. 24726, No. 24764, and No. 25069; were
implemented on 9-28-88, 9-29-88, and 10-11-88; and were reviewed by PRC-
and approved by the Plant Manager on 10-1-88, 10-7-88 and 10-25-88,
respectively. The OTSC's therefore had proper PRC review and Plant Manager
approval within the 14 day time limit.
The issue raised in the Unresolved Item 285/88201-19 was what happens if
the'PRC disagrees or has concerns about an OTSC that has alre:4y been
implemented in the plant. If the PRC has a concern regarding an OTSC an
Incident Report (IR) is issued to track, evaluate the effect on plant
safety and document the resolution of the concern. Since January 1, 1989,
388 OTSC's have been initiated. Two Incident Reports have been initiated
to address PRC concerns regarding three of these OTSC's. IR-89-0009 were
issued on OTSC 27362 and IR-89-0400 were issued on OTSC's 27858 and 27860.
!
Page 14
_
_ - - . _ _ _ _ , _ _
,
ed 60:91'68/01/40 SdN NnOH1C 180,3 WOdd. i
1
- -
.
'
i
4
- '
'
D. Inadeaunte Instructions for Performance of Safety-Related Activities.
Criterion V of Appendix B to 10 CFR Part 50 and the licensee's NRC-approved
quality assurance program states, in part, that activities affecting
quality shall be prescribed by documented instructions of a type. I
appropriate to the circumstances.
l
Contrary to the above, two examples were cited.
This is a Severity Level IV violation. (Supplement 1)
3
OPPD Resoonse
1
1. Admin': ion or Denini nf the A11 coed Violation l
OPPD admits the violation as stated.
2. The Reasons for the Violation. if Admitted
The specific reasons for the two examples are c scussed in the response to
D.1 and D.2. The generic problem with inadequate procedures has been
acknowledged and is being addressed in the Safety Enhancemen+, Program as
part of the Procedures Upgrade project (SEP Ref. No. 46; and other
procedures upgrade efforts in progress.
3. The Corrective Steos That Have Been Taken and the Results' Achieved
Safety related procedures are currently being reviewed'and revised per the
Procedures Upgrade Project (SEP Ref. No. 48). The specific corrective
action taken for the cited examples can be found in the response to D.1 and
U:., g,g,
4. Corrective Steos Which Will Be Taken to Avoid Further Violation
The Safety Enhancement Program will continue to be applicable to the cited
examples as well as other safety related procedures.
5. Date When Full Comoliance Will Be Achieved
OPPD will be in full compliance at the completion of the safety related
portion of the Procedures Upgrade Project (MP Ref. No. 48) in conjunction
with the Preventative Maintenance Program which is currently scheduled for
completion by December 31, 1989. )
{
Page 15
U l
i
i
_ _ _ _ _ _ - _ - -
- . e, *d 60
- 91 68/01/LO. SdN Nn0H103 1803 WOdd
..
D.1 Contrary to the above, Procedure PM-EE-4.0, "7700 Line Motor Control
1
. Centers," that provided instructions for post-maintenance testing of
480-volt breakers did not provide instructions for post-maintenance
-
testing of all 480-volt breakers. For example, no instructions were
1
. included in the procedure for post-maintenance testing'of the breaker-
for the pressurizer relief isolation valve (HCV-150). (285/88201-13)
OPPD Resoonse to 0.1
Procedure PM-EE-4.0, "7700 Line Motor Control Centers," due to an oversight
in the preparation of the procedure, did not list the breaker for the
pressurizer relief isolation valve (HCV-150).
The breaker for HCV-150 was cycled as part of the plant start-up from the
1988 outage which confirmed its post maintenance operability. It was
determined that corrections to procedure PM-EE-4.0 and the review and
revision of other maintenance procedures to correct deficiencies regarding
post maintenance testing would be included as part of the Procedures
Upgrade and Preventative Maintenance Projects.
Post-maintenance testing of safety related equipment in 480 volt Motor
Control Centers, is being addressed in the Safety Enhancement Program,
Post-maintenance Tes.ing Requirements Criteria effort (SEP Ref. No. 35).
The review and revision to the procedures using the post-maintenance
testing requirements criteria developed from SEP Ref. No. 35 will be
performed as part of the Procedures Upgrade Project (SEP Ref. No. 48) and
the Preventative Maintenance Project (SEP Ref. No. 41).
The Post-maintenance Testing Requirements Criteria effort (SEP Ref. No. 35)
is scheduled for completion June 1,1989. The safety related portion of
'
the Procedures Upgrade Project (SEP Ref. No. 48) is currently scheduled for
completion September 30, 1989. The revised Preventative &intenance
Program is currently scheduled for implementation by December 31, 1989,
i
)
I
l
Page 16
_ _ _ _ _ _ _ - _ _ - _ - - -
.,
- '
,
'
O l '.* ci E01:91'68/01/40. SdN: Nn0H'It:0 J.80d WOddL
, J. -
.. <>:
'"# . ., '
10.2 Contrary to the above, Procedure ST-ISI-RW-1,i" Raw Water Valves-
Inservice Testing," did:nor provide; instructions foritesting'of Bettis
' ' - valve operators;. however,- the procedure was : issued for. testing the, .
-
- valve stroke time for a valve with'a Bettis operator. (285/88201-21)
- ,0 PPD Resoonse to 0.2
Prior to the'1988 Refueling Outage, OPPD initiated a program to provide an. ,
interim upgrade of outage-related procedures since the Procedures Upgrade. "
Project was just beginning.- Surveillance' Test ST ISI-RW-1, " Raw Water:
,
Valves . Inservice Testing," was upgraded as a part of this -interim program.
The' purpose ~of the interim program was to provide an.immediate improvement
in procedures to facilitate procedural compliance during the-outage. This'
upgrade included: format changes and, to some extent. procedure content
upgrades.- The review process lacked sufficient detail- to. verify. correct
instructions for-testing of the Raw Water pump discharge valve Bettis.
o perators.
ST-ISI-RW-1,.Rev.111, provided only.a general' statement to open the valve
and did not specifically include the method to accomplish this activny.
The' procedure as changed in, Revision 12 as part of the. interim'upgralef
attempted to provide more specific steps,. however, the. instructions uere
incomplete. The upgraded procedure'in Revision 12 should have incluoM all
stops necessary to complete the test, however, due to an inadequate review
7 of this procedure this objective was not' met. As a result, steps
previously performed in Revision 11 by technician knowledge oft starting.the;
associated pumps to open the valves were not included in the procedure.
The limited review process. of'the interim procedures upgrade program
o focused on differences between Revision 11 and the upgraded Revision 12 and
.did not detect the inaccurate step-included in Revision 12.
Revision 13 to ST-ISI-RW-1 was issued and approved by the PRC on November
8, 1988. This revision contained the correct steps to perform the test.-
-.
This and other procedures changed during the' interim procedure upgrade
effort are currently undergoing reviews for accuracy and enmpleteness and
are subject to the verification and validation effort of the Procedures.
Upgrade Project (SEP Ref. No. 48). The Surveillance Test Performance
Improvement effort (SEP Ref. No. 72) is also applicable.
l
Page 17
- ._. _ _ _ _ _ _ _ _ _ _ _ _ _ _
i!*d i129I 68/01/LO SdN Nn0H103 1803 WOMd
E. Failure to Comely With ASME Code Reouire;;ents
Section 50.55a(g)(4) of 10 CFR Part 50 requires that the appropriate
l
'
provisions of Section XI of. the ASME Code be applied during conduct of
inservice tests of the operability of pumps and valves. Article IWV-3413
of Section XI statas that full-stroke time is that time interval from
initiation of the actuating signal to the end of the actuating cycle.
i Contrary to the above, the licensee performed inadequate inservice testing
of Valve HCV-1749 in that the full-stroke time was detennined from the time
of actuation of the local solenoid until the end of the actuating cycle in
lieu of the determination of the full-stroke time from initiation of the
actuati% signal (i.e., when the control switch for the valve is operated).
(285/88201-16)
This is a Severity 1.evel IV violation. (Supplement I)
OPPD Resoons_e
1. Admission or Denial of the Alleoed Violation
OPPD admits the violation as stated.
2. The Reasons for the Violation. if Admitted
At the time of the violation the FCS Inservice Inspection program used the
locally measured stroke time from beginning to end of valve stroke motion,
because it was assumed that the time from actuating s 7al to the start of
valve motion was negligible. The initial test valuer .are measured locally
so the subsequent trending values were also measured locally and intended
to indicate degrading valve conditions.
3.
Ihe Corrective Steos That Have Been Taken and the Results Achieved
The ISI Program is currently developing acceptance criteria for valve
stroke times based on the initiation of the actuating signal to the end of
the actuating cycle.
4.
Corrective Steos Which Will Be Taken to Avoid Further Violation
after the limiting values are determined and the required ISI program
changes are approved, the ISI Surveillance Tests will be upgraded as part
of the Procedures Upgrade Project (SEP Ref. No. 48) to include timing the
valves from the remote station to include full stroke time from initiation
of the actuating signal (i.e., when the control switch for the valve is
operated). Additionally, remote position indication will be periodically
verified such that the two year ASME code requirement will be met. The
Surveillance Test Performance Improvement effort (SEP Ref. No. 72) will
also be applicable.
5. Date When Full Comoliance Will Be Achieved
These actions are scheduled to be completed by November 15, 1989.
Page 18
- _ _ _ _ _ _
c.
p 31*d 11191,68/01/LO SdM Hn0H"lOQ 1803.WO8d:
.
-
- .
et' ' '. *
F. I_nadeauate Corrective Action Procram
'
'
' Criterion XVI of Appendix B to 10 CFR Part 50 and the ifcensee's
,
NRC-approved quality assurance program states, in part, that measures shall
be established to assure that conditions adverse to quality are promptly
'_
~ identified and corrected. In the case of significant conditions adverse to.
quality, the measures shall assure that the cause of the condition is
determined and corrective action taken to preclude repetition.
Contrary to the above, two examples were cited.
This is a Severity Level IV violation. (Supplement I)
OPPO Resoonte
1. Admission or Denial of the Alleoed V*;1ation
.
OPPD admits the violation as stated.
2. The Reasons for the Violation. if Admitted
The corrective action program in the Fort Calhoun Station Quality Assurance.
Plan lacks specific guidance in regard to reviews concerning operational
safety. considerations and the associated identification and follow-up
requirements.
3.
The Corrective Steos That Have Been Taken and the Results Achieved
U The definition for significant deficiencies has been revised to lower the
threshold for reporting of conditions adverse to quality in this
classification. The definition now includes elements which include
operational safety considerations. More deficiencies are now being
reported as significant.
4.
Corrective steos Which Will Be Taken to Avoid Further Violation
The Quality Assurance Plan section on corrective action will be revised to
require an operational safety assessment of identified conditions adverse
to quality that could potentially have operational safety significance.
The implementing procedures for the corrective action program will be
revised accordingly.
In addition, the overall Safety Enhancement program will effectively
address and correct the deficiencies that were discussed in the OSTI Report
for Unrosolved Item 285/88201-24.
5. Date When Full Como11ance Will Be Achieved
The Quality
January 1990.Assurance Plan and implementing procedures will be revised by
Page 19
V '
p
e
- ~
g;.d 21:91 68/01/2.0 SdN Nn0H100 180d WO83
. _ -
p :
g,z .
-
't
,
F.1 Contrary to the above, a condition potentially adverse to quality was
not resolved in that the stroke time for Valve HCV-1749 varied:from
3.8. seconds for the remote indication to 12.2 seconds for the local
-
,
indication and the discrepancy was not identified to the appropriate
licensee personnol, As a result, no corret. Live was initiated to
promptly resolve the identified discrepancy. (285/88201-17)
OPPD Resoonse to F.1
The HCV-1749 remotely measured- stroke time of 3.8 seconds was less than the
locally measures stroke time of 12.2 seconds because the remote indicator
was not properly adjusted.
The difference in the two recorded times was
not identified as a problem since both times are recorded simultaneously at
different stations and the only acceptance criterion is less than 30
seconds.
Both times were less than 30' seconds and therefore were both
determined as acceptable. Since only local valve timing was trended, the
discrepancy for the remote station time was not identified.
'
Standing Order G-23, " Surveillance Test Program," has been revised and
approved by the PRC. The change includes a checklist for items to be
considered when reviewing completed Surveillance Tests. Included in the
checklist is a review of test results by the responsible supervisor to
insure that the System Engineer is promptly notified of any marginal or
unacceptable results so that corrective action can be taken. If
unacceptable acceptance criteria is identified the Shift Supervisor will be
'promptly notified. Standing Order G-23, " Surveillance Test Program,"
.ision 29 will be issued during the first week of May, 1989 when the " Hot
ine" training has been completed.
U
-
The surveillance tests for ISI valve stroke times will be reviewed and
upgraded, as applicable, as part of the Procedures Upgrade Project (SEP
Ref. No. 48) to include timing the valves from the remote station. After
remate
lo9ger position indication has been initially verified local timing will no
ae used for trending. A significant change in the valve stroke time
caused by malfunctioning position indicators will show up as a definite
abnormal trend and will be picked up in the trend review. Remote position
indication will be periodically verified based on the two year ASME code
requirement. The Surveillance Test Performance Improvement effort (SEP
Ref. No. 72) is also applicable.
These actions are scheduled to be completed by November 15, 1989.
Page 20
[a
~~
l
r r 1. # 'ct:st se/0t/40 SciN Nn0H"It:0 1W03 MONd
\c , y,.
...
7". "
F.2' Contrary to the above, the licensee has not. established adequate
messures to assure conditions adverse to quality are promptly
identified in that the corrective action program does not contain all
-
the elements necessary to address operational safety as listed below.
,
Corrective actions -specified in response to audit findings.
Corrective action responses to material deficient conditions.
Licensee review of NRC Information Notices does not consider the
. generic aspects of potential problems identified in' the notices.
.
. Corrective action to be taken in response to preventive
maintenance specified by the equipment vendor.
The corrective action to be taken when post-maintenance testing
had not been performed on safety-related equipment.
' Corrective action operability.
affect equipment.
to ensure installed deficiencies would not
- '
The licensee's
s ignificant threshold for
is inadequately identification of deficiencies as
defined.
The examples listed above identify areas wh6 7 operational safety is not
considered in the corrective action program. (285/88201-24)
- OPPD Resoonse to F.24
M The' corrective action program specified in the Quality Assurance Plan for
Fort Calhoun Station does not require an operational safety assessment'of
conditions adverse to quality.
The definition for significant deficiencies has been revised to lower the
threshold for-reporting of conditions adverse to quality in this
classification. The definition now includes elements which include
operational safety considerations. More deficiencies are now being
reported as significant.
The Quality Assurance Plan section on corrective action will be revised to
require an operational safety assessment of identified conditions adverse
to quality that could potentially have operational safety significance.
The;1 implementing procedures for the corrective action program will be ,
revised accordingly. 1
Additionally, the accomplishment of the Safety Enhancement Program will'
effectively address and correct the deficiencies that were discussed in the
OSTI Report for Unresolved Item 285/88201-24. '
The Quality
January 1990.Assurance Plan and implementing procedures will be revised by l
Page 21
- - - _ _ - _ _ - - - _ - - 1
_ _ _ - , - _ - -
"
' glad et:91'68/01/40' . SdN Nn0H 10-) .L803 WOMd
.
s ,
y. ,
- ,
Attachment 2
Response to OSTI Onresolved Items
UNRESOLVED ITEM 285/88201-04
Inaccurate entry of information into the temporary modification log.
OPPD RESPONSE
The inaccurate entry into the temporary modification -log occurred due to
personnel error resulting from weakness of the Temporary Modification
Control process in effect at the time of the OSTI review.
Standing Order 0-25 has undergone extensive review and upgrading to improve-
the overall Temporary Modification' Control process. Standing Order 0 25,
Revision 28 issued February 21, 1989 improves the temporary modification
process by having the cognizant System Engineer being accountable for the
necessary process steps.
The Procedural Compliance effort (SEP Ref. No. 44) will be used to ensure
the proper use of, and compliance with, procedures. In addition, the
Temporary Modification Control Improvements effort (SEP Ref. No. 71) will
also be applicable.
,
Page 1
- _ - _ _ _ _
91'd rt:st 68/01/40 SdN NnOH163 180d WOdd
..,
..
, , .
,
,
- o
N
PNAESOLVED ITEM 285/88201 06
Operability requirement of the steam generator blowdown radiation monitors
affected by temporary modifications. l
OPPD RESPONSE
i
Standing Order 0-25, " Temporary Modification Control," in effect at the
i
time of this incident was inadequate in that the proper review of temporary
modifications prior to their installation was not required to be performed. i
j
i
Standing Order 0-25 has undergone extensive review and upgrading to improve
the overall Temporary Modification Control process. Standing Order 0-25, {
Revision 28 issued February 21, 1989 now requires that the Plant Review (
1
Committee (PRC) review and approve temporary modifications prior to their
installation. Operability requirements for redundant systems and
components is a factor which is now considered before a temporary
modification is approved for implementation. Also the cognizant System
Engineer's comprehensive review of the Temporary Modification will address
operability requirements for redundant components. j
The Temporary Modification Control Improvements effort (SEP Ref. No. 71)
will be applicable for any other enhancements that may be made to the
Temporary Modification Control process.
i
,
"i
!
Page 2
i
o -
- _ _ _ - _ _ _ _
,
..
4.!*d, 5189l' 68/01/40.- EdN NnOH"103 1803 WO8d
.. % ' '
UNRESOLVED ITEM 285/88201-07
Temporary Modification drawing control.
'
OPPD RESPONSE
A: stated in 'your letter, NRC (L. J. Callan) to OPPD (K. J. Morris) dated
March 17, 1989, a response to this unresolved item was not required since
our response to the violation issued'in NRC Inspection Report 50-285/89-03-
will addressed this issue. The response was forwarded in our letter, OPPD
.(K. J. Morris) to NRC dated March 31,1989(LIC-89-326).
_
l
l
Page 3
L
__ _ _ _ _ - - - - _ - _ - - - - _ - - _ _ - _ _ _ _ _ _ - _ - _ _ _ ~
-_-_-. . _ - - .
t
81*d' S I : 91: 68/01/40 SdN Nn0H103 1803 WOdd
.
.
( ,' 6-
.tf.
UNRESOLVED ITEM 285/88201 08
.,
Plant Review Committee review of temporary modifications within 14 days.
OPPD RESPONSE
Standing Order 0-25, " Temporary Modification Control," in effect at the
time of this incident was weak in regard to the necessary steps required to
assure proper and timely review of temporary modifications.
Standing Ordor 0-25 has undergone extensive review and upgrading to improve
the overall Temporary Modification Control process. ' Standing Order 0-25,
Revision 28 issued February 21, 1989 now requires that the Plant Review
Committee (PRC) review and approve temporary modifications prior to their
installation.
The Temporary Modification Control Improvements effort (SEP Ref. No. 71)
will be applicable for any other enhancements that may be made to the
Temporary Modification Control process.
O
l
.
i
k
]
l
page 4
l
_ - _ _ _ _ _ _ - _ - _ __
..e _ _ _
_ _ . _
__. _
- ~- - w yv-
q
. @S '.' 'I y
- g'; I? N ,
.
f . UNRESOLVED 1 TEM 285/88201-18. .)
=!
The control room indication.for valves HCV-11078 and HCV-11088 was not
tested, i
i DPPD RisP0NSE
.!
4
This unresolved item is addressed in the response to Violation E,
{
I
O
l
l'
)
Page 5
l;
l
[
L_u_ _- =---__ - - . - a
___ . .
-
,
02*d 9li91 68/0t/40 SdN Nn0HlO3 1803 WOdd
.'
+ e.
.,.,...,
UNRESOLVED ITEM 285/88201-23
"- Quality Assurance reviewed Surveillance Test ST-DC-1 which had the
acceptance criteria' deleted and the quality assurance auditor did not
identify the discrepancy.
OPPD RESPONSE
The Quality Assurance Surveillance Program, in effect at the time of the
activity referenced
guidance in this unresolved item, did not provide appropriate
to the auditor. Audit Report 2-88-1 indicated that no deviations
or deficiencies were identified for Surveillance Test ST-DC-1, Revision 33,
performed on February 2, 1988 because the procedural steps appeared to be
adequate based on the limited guidance available to.the auditor at that
time.
The surveillance plans have been revised to provide more guidance to the
auditors for observing activities.
The auditors have been instructed to be
more specific in the reporting of activities they observe. The.
surveillance plan for surveillance test observation now includes a specific
item to observe the progress of the test and to assure that the procedural
steps are followed.
As part of the Safety Enhancenient Program, Ref. No. 20 " Evaluate, improve
depth and strengthen quality audit and surveillance program," OPPD's
Quality Assurance. Surveillance Program has undergone extensive improvement
including additional guidance to the auditor. SEP Ref. No. 20 was
completed on March 31, 1989.
O
Page 6
,
- - - _______-_ _ _ _ _ . _ _ - _ _ - _ ._
.j
- _.
..
.,
12*d LI:91 88/01/L0 . SdH N00H 100 '1803 WOBd
{o=-
LY ' Attachment 3
i
QPEN ITEM 285/88201-11
Electrical safety and electrical safety training concern,
QPPD Action
The Training Department is reviewing and upgrading, as necessary, of the
Electrical Safety Training program to address the concerns of this Open
Item. The need to be aware of electrical safety requirements has been
1 discussed-during Maintenance Department meetings and with the craft ' foreman
and supervisor.
OPEN ITEM 285/88201-12
Clearance Procedure regarding use of Danger Tags.
OPPD Action
' The Operations Department is reviewing and revising, as necessary Standing
Order 0-20, " Equipment Tagging Procedure," to address the concerns of this
Open Item. Standing Order 0-20 will be upgraded and training conducted
prior to implementation.
OPEN ITEM ~285/88201-14
Improve QC inspection guidance for CQE component repair and modifications.
OPPD Action
The Quality Assurance and Quality Control Department is reviewing and
upgrading, as necessary, the QC inspection guidance to address the concerns
of this Open Item.
OPEN ITEM 285/88201-20
Concerns related to the adequacy of the penetration test rig.
OPPD Actions
Station Engineering and Maintenance will evaluate the penetration test rig
and respond to the specific concerns identified in this Open Item.
_ 4
-
.
_ - - - - - - - -
- - - . - - - - - - - - - - - - - - - - - - - - - . - - - - - - - - - - - - - - - - - - -
r ,
.
.
)
.. . .
=== - = - - -
__. ___- .- .
. _ - -
-
- - -
- - . .
. .
-
Omaha Public Power District
l
l June 15, 1989 1623 Harneu Omana. Nebraska 68102 2247
402/536 4000
LIC-89-562
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
February 9, NRC
1989 (G. M. Holahan) to OPPD (K. J. Morris) dated
3.
Letter 17,
March from
1989 NRC (L. J. Callan) to OPPD (K. J. Morris) dated
4.
Letter from OPPD (K. J. Morris) to NRC (R. D. Martin) dated
April 5, 1989 (LIC-89-335)
5. Letter from OPPD (K. J. Morris) to NRC (Document Control
Desk) dated April 30, 1989 (LIC-89-349)
Gentlemen:
SUBJECT: Response to NRC Questions Resulting from Operational Safety Team
Inspection (OSTI)
Omaha Public Power District (OPPD) submitted Reference 5 in response to the
Notice of Violation included in Reference 3. The violations and unresolved
items were derived from the Operational Safety Team Inspection (OSTI) Report,
which was received in Reference 2. Upon NRC reviewing OPPD's response included
in Reference 5, a telephone conversation was conducted between members of OPPD
and NRC Region IV staff on May 10, 1989. This conversation resulted in several
questions being presented by NRC staff to OPPD. An Attachment includes the
questions presented and answers submitted in support of Reference 5.
If you should have any questions, please do not hesitate to contact us.
Sincerely.
. . Morris
Division Manager
Nuclear Optrations
KJM/jak
Attachment
c: LeBoeuf Lamb, Leiby & MacRae
T. E. Murley, NRC Director, Nuclear Reactor Regulation
R. D. Martin, NRC Regional Administrator
A. Bournia, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
- . m , m o nnu
onnummq r ;
___ -_
~%MhM -- -
.
_ _ _
- _ . - _ _ .-
-
Attachment.
o _
' ' *
4 NRC QUESTIONS ON OPP 0's.
s
OSTI VIOLATION RESPONSE
B.4 Does Standing Order 0-29 Revision 10 address guidance on when and how to
.
initiate an on The Spot Change (OTSC)?
Response:
No, Standing
to process Order G-30 "Setpoint/ Procedure Changes".provides the guida
an OTSC.
Standing Order 0-29 addresses the requirement for
verbatim compliance with procedures and provides the guidelines for
' procedure deviation during emergency and abnormal conditions.
the normal course of performing a procedure, an individual encounters aIf, during
the specific guidance for processing a temporary OTSC
procedure changes.
-
A briefing was conducted by the Plant Manager to
numerous Shift Supervisors and other operations personnel on the overall
importance of procedural compliance as it pertains to operations. Minutes
of this session will be distributed to the non-attending operators.
B.5 Quality Does the System Engineer approve the use of non-CQE parts in Certified
Equipment
Maintenance Order M0)7CQE) components prior to the implementation of the
Response:
No,
M0. the System Engineer performs an independent technical review of the
specify the acceptability of non-CQE part usage in a CQE
Is this a wide spread problem?
order number information is left blank on CQE MOs.7Are there other cases wher
Response:
No, indications reveal that this is not a _ widespread problem. QA
reviews each CQE H0's for completeness as part of the post work r/QC
process. eview
listed for non-CQE parts.There have been some other cases where P.O. number
However, this was considered acceptable because
non-CQE parts generally do not tave P.O. numbers and the current revision
of G-17 "parts.
non-CQE Maintenance Orders" doe.; not require P.O. numbers to be listed for
[ " Work Control" and Procedure G-17It should be noted that at present, Standing O
" Maintenance Order" are both in effect.
Do individuals know-they have to enter the Purchase Order (P.O.) number for
all
for parts use in used
a CQEincomponent)?
a CQE component (i.e. even for non-CQE parts acceptable
,
y Response:
Yes, individuals know they must enter the P.O. number for CQE parts,
however,
non-CQE parts. OPPD does not required documentation regarding P.O. numbers for ,
!
This is The
in accordance with the current revision of G-17
'
" Maintenance Orders". non-CQE part used for M.0. 884163 l
!
from another breaker and therefore had no P.O. documentation.was Additional borrowe
Page 1
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ - - - --- -- a
__
- - - - - - - _ - - _ _ ,
- - - - - - - - - -
- '
, guidance was issued to the craftsran concerning what documentation is
required when an approved non-CQE part is used in a CQE component. This
guidance was issued in a memo on May 17, 1989, and will remain in effect
-
until procedure G-17 " Maintenance Orders" is replaced with the new
procedure M-101 " Work Control". At present, both Standing Order M-101
" Work Control" and Procedure G-17 " Maintenance Orders" are both in effect.
Why is there a delay to revise the Standing Order until June 30, 1989 and
what is being done in the interim?
Response:
Standing Order M-101 " Work Control" which replaces G-17 was implemented on
5/23/89. At present, both Standing Order M-101 " Work Control" and
Procedure G-17 " Maintenance Orders" are both in effect. A memo was issued
on May 17, 1989 to the craftsmen which provided interim guidance as to
proper documentation requirements.
B.6 Is properly locating the vibration test probe a problem on other pumps?
Was this also a problem in Inspection Report 88-267
Response:
The problem is unique to the Raw Water pumps because the design is such
that the stuffing box corrodes due to controlled packing leakoff, which
tends to leach / remove the markings. This does not occur with other IST
pumps. The technicians performing the vibration tests are very familiar
with where to place the probes; however, because of the procedure
compliance effort, the need for identification of probe placement if
markings are not visible has been established. A change to procedure
- ST-ISI-RW-3 to clarify position of probe was submitted on 5/23/89 to
)rovide clarification to the mechanic and will be approved for use on or
Jefore 6/30/89.
.
Enhancements (e.g., drawing, procedures guidance, etc) in this area are
being imptomer.ted to provide for monitoring point reidentification.
How is the permanent fix to be implemented?
Response:
Procedure changes are being accomplished to provide guidance which will
identify the monitoring point if the marking is not visible. In the
interim, a memorandum was issued to give specific guidance to craftsmen
until procedure changes had taken place.
There is action underway to permanently mark safety-related pumps required
to be vibration tested. This activity will be completed on or before the
1990 refueling outage.
Page 2
i
l
.
Y
. _ _ - _ - -
'*
' '
' D.1 Why doesn't OPPD c*rrect the known defect la the procedure now rather thaa
.
, wait far the Procedure Upgrade Project?
Response:
Since the.next time the breakers will be PM'd is the 1990 refueling outage,
the Project 1991 upgrade would, by its schedule, upgrade the procedure
before it would be needed. If needed prior to this time, the procedure
will be upgraded prior to use.
Is this an isolated case or are there other breakers which were not tested?
Response:
It is not known at this time if this was an isolated case. However, the
verification and validation effort performed as part of the Procedures
Upgrade Project will provide the necessary level of review to ensure that
the breakers are properly included in the PM procedure. Maintenance will
review this condition to ensure that every safety-related breaker has been
properly tested. This activity will be completed on or before the 1990
refueling outage.
D.2 Are the other Bettis Operators tested properly?
Response:
Yes. Other Bettis operators, as well as other types of air operators, are
tested properly in that the air is actually failed to the operator per the
requirements of ASME Section XI Subsection IWV 3415. This is usually
accomplished by use of the control switch which allows a solenoid valve to
vent.the air from either the top or bottom of the operator. The vent path
will depend on whether the valve falls open or closed. The difference was
based on design in that this velve operates when the pump starts. In the
example given in the OSTI report, the procedure was rushed through, did not
)
'
have an adequate technical review and was not walked down. The fix was to
delete this procedure and resurrect the old one. Formal control on
ensuring adequate reviews, walkdowns, etc. are in place to prevent a
situation like this from occuring again.
E. What is OPPD doing in the interim to verify Tech Spec valve time limits?
!
Response:
The valve stroke time limits as presently stated in the ISI Pump and Valve
Surveillance Tests are within the Tech Spec limits as previously determined
by Engineering and vendor evaluation. A review is presently being
performed by Design Engineering to accomplish the following:
l
a. Establish and document a design basis for valve stroke times.
b. Establish and document a practical stroke time based on Safety
Analysis, Engineering evaluations, and the actual stroke time,
c. Verify that the current maximum stroke time for the Surveillance
Tests have a basis in the Safety Analysis and that there is an
adequate safety margin.
Page 3
l
l
l
u _ _ __ _ ___ ____________. -- ;
-_
'
.
,', In the interim, OPPD will perform the test in accordance with specific
q precedures, in general by an operator initiating the valve function from
the switch and another operator remotely timing the valve stroke. We
reccgnize a deficient condition in our program in that it fails to
consistently document the operability of the position indicating lights.
However, from existing procedures and training, we are assured that the
lights work by observation of operator initiating the switch and the valve
strokes in the prescribed time is measured locally from solenoid pickup (or
moter start) to end of stroke. Further evaluation is being performed in
this area to ensure compliance with the ASME Code until issuance of the
revised procedure scheduled for November IS,1989.
F.1 After November 15, 1989, When only remote indication is used for stroke
timing, will ASME requirements be met?
Response:
Yes. The stroke timing will be accomplished by timing the valve from
initiation of the actuating signal (moving the control switch) to the end
of the actuating cycle (as indicMed by remote lights) per the requirements
of ASME Section XI, Subarticle IW-3413(a). The remote indicating lights
will be ts:ted and verified to be operating properly per the requirements
of ASHE Section XI, Subarticle IWV-3300.
F.2 What procedure was changed which lowered the threshold definition of
significant deficiencies?
Response:
Quality Assurance & Quality Control Department Procedure, QDP-17, Rev. 8
" Control of Deficiencies and Corrective Action", was revised to lower the
threshold of significant deficiencies and more clearly define the necessary
compenents of a significant deficiency.
What are the spectisc S4fety Enhancement Program Reference Numbers that
address the identified concerns on the corrective action plan?
Response:
OPPD has determined that the overall improvements brought about by the
Safety Enhancement Program will address the conce ns that were noted in the
OSTI Report Section 2.5. As discussed in the response, a revision to
QDP-17 " Control of Deficiencies and Corrective Action" has been approved
which will address the specific concerns regarding Operational Safety
Assessment incorporation into the corrective action program.
The following specific SEP References are examples of how the overall
enhancements in plant operation and safety related procedures will result
in a more effective and improved corrective action program:
l SEP Ref. No. 44 Procedural Compliance effort
l SEP Ref. No. 48 Procedures Upgrade Project
l SEP Ref. No. 60 Surveillance Test Program controls improvement
! SEP Ref. No. 20 QA Audit and Surveillance Program enhancements
SEP Ref. No. 41 Implement a Preventive Maintenance Program
Page 4
_ _ _
,
p- ,
' '
',..' SEP Ref. No. 35 Establish post-maintenance testing requirement
criteria-
SEP Ref. No. 21 Develop a Safety System Functional Inspection Program
SEP Ref. No. 10 Implementatica of Trending and Root Cause' Analysis
Program
i
'
SEP,Ref. No. 22 Increased Field Supervisory activity
SEP Ref. No. 62 Establish interim System Engineers
SEP Ref. No. 63 Vendor Manual Upgrade Project
Prior to the revision of implementing procedures in January 1990, what
interim action does OPPD plan regarding Operational Safety assessment?'
Response:
A change to QDP 17 has been initiated requiring addressees of deficiencies
to provide an operational safety assessment when responding to deficien-
cies. In addition to this change, the operational safety assessment
requirement will be noted in an attachm,nt which is included on newly
issued deficiency reports. These two interim actions will ensure that
operational safety assessments are conducted prior to the revision of the
Quality Assurance Plan section per,ining to corrective action.
Page 5
!
-__ __ _
_ __ . - - -
_ ,
Response:-
e The w;akness in Standing Ord::r 0-25 " Temporary Modification Control "
Le which was in effcct at the time of this incident was that different
individuals would have varying degrees of responsibility for initiation,
, review and preparation, logging and preliminary approval, implementation,
post-implementation review and approval and restoration. The old
procedure had the potential for poor communication and misunderstanding !
between the different individuals involved. It was this inherent l
'
weakness that'resulted in the inaccurate log entries due to personal
error. The current Revision 28 of_ S.0. 0-25 has improved this process by
using the System Engineer as the responsible individual with clearly
defined personal accountability to ensure proper temporary modification
processing. 3
1
'
UNR 88201-06
Was OPPD outside a Tech Spec LCO for the inoperable Steam Generator
Blowdown Radiation Monitors? 1
Response:
Tech Spec 2.9.le is governing. It states, in part, that if both
radiation monitors are inoperable, steam generator liquid release may
continue provided appropriate grab samples are analyzed for the principal
gamma emitters'at a sensitivity of 5.0E-07 micro curies por ml and
recorded at least daily when the specific activity of the sample is less
than or equal to 0.01 micro curies per gram dose equivalent 1-131.
During the time from September 29 through October 2, 1988, when both
temporary modifications were in effect, the Technical Specification was
complied with. On October 2, the ralant entered mode 4. At that time the
,
monitors were jumpered per 01-FW-6 " Draining of the Steam Generators.""
UNR 88201-18
Was the control room indication for valves HCV-1107B and HCV-11088
specifically tested?
Response:
Valves HCV-11078 and HCV-11088 were tested in January and April, 1989 per
ST-ISI-FW-1 "Feedwater Valves In-Service Testing." Even though
ST-ISI-FW-1 does not have a specific checkoff for control room indicating
lights, operators through training would recognize an abnormal
condition. If, after actuating the control switch, the operator does not
observe the close/open indicator lights change, then an investigation
will be made to determine the cause of the problem (i.e., burned out
bulb, failed position indicator switch, etc).
Page 6
I
o
a
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - -
-
.- .
- _ - - - .
. .,
Isl currently scheduled for completion by 12/31/85.
l
j- 01_88201-12 Clearance procedure.regarding use of Mr.ger Tags.
'
' Response:' D. R.-Trausch
_
'I
- ,
Is-currently scheduled for completion by 9/30/89.
01 88201-14 Improve QC inspections guidance for CQE component. repair and
- ,
modification.
a
<
Response: W. W. Orr .]
Is currently scheduled for completion by 11/15/89 j
a
O! 88201-20 Concerns related to the adequacy of the penetration test rig.
Response: K, A. Miller.
Is currently scheduled for completion by 7/31/89
- , /
4
e
Page 7
.
%w
a
0
k .-- ---_.-_-_a___ _ _ _ . _ . _ _