ML20246N614
| ML20246N614 | |
| 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 8907200003 | |
| Download: ML20246N614 (1) | |
See also: IR 05000285/1989013
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In Reply Refer To:
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Docket:: c50-285/89-13
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Omaha Public0 Power District
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' ATTN: Mr. Kenneth J.' Morris,, Division Manager-
Nuclear Operations
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444 South 16th Street Mall
Omaha, Nebraska '68102-2247-
Gentlemen:
Thank y6u Ior your, letter of June ~ 19,1989, in response to our letter and
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Notice of Violation dated May'19 A 989. . e have reviewed your reply and find
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1_t responsive to the concerns raised in our Notice of Violation.. 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,
9907200003 890722 5'
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ADOCK 05000205
James L. Milhoan,- Director
PNU,
Division of Reactor Projects
cc:
G. R. Peterson, Manager
' Fort Calhoun Station
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P.O. Box 399
Fort Calhoun, Nebraska 68023'
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Harry H. Voigt, Esq.
LeBoeuf, Lamb Leiby & MacRae
~1333 New Hampshire Avenue, NW
Washington, DC 20036
Nebraska Radiation Control-Program Director
-bec to DMB (IE01) w/ copy of licensee 1tr.
, bec distrib. by RIV w/ copy of licensee ltr.:
R. D. Martin, RA
MIS System
SectionChief(DRP/B)
RIV File
Project Engineer (DRP/B)
RSTS Operator
A. Bournia, NRR Project Manager (MS 13-D-14)
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Omaha Public Power District
1623 Harney Omana. NeDraska 68102 2247.
402/536 4000
June 19, 1989
LIC-89-608
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Station P1-137
Washington. DC 20555
References:
1.
Docket No. 50 285
2.
Letter from 1 RC (L. J. Callan) to OPPD (K. J. Morris) dated
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May 19, 1989
Gentlemen:
SUBJECT:
Response to Notice of Violation - Inspection R
285/89 13
Omaha Public Power District (OPPD) received the inspection report noted in
Reference 2.
The resort identified two violations. Attached please find
OPPD's response to t.1ese items in accordance with 10 CFR Part 2.201.
If you have further questions on this matter or require additional information.
please contact me or members of my staff.
Sincerely,
,j,' dw~
. J. Morris
Division Manager
, Nuclear Operations
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LeBoeuf, Lamb, Leiby & MacRae
R. D. Martin, NRC Regional Administrator
A. Bournia, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspect 5r
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- Attachment
Resoonse to Notice of Vio, h
Ouring an NRC-inspection conducted on March 1-31, 1989, violations of-NRC'
. requirements were identified.
The violatio.ns; involved the failure to follow
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the procedures for equipment tag out and installation of cable tray covers, and
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an inadequate procedure to address the loss of component cooling water.
In
accordance with the " General Statement of Policy and Procedure for NRC
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Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are
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. listed below:
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..A.
Failure'to Follow Procedures
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- The following are two' examples of the licensee's failure to follow approved
procedures:
1.
Technical Specification 5.8.I' states, in part, that written procedures
shall be implemented that meet the minimum requirements of Appendix A
Paragraph I.c of Appendix 'A to Regulatory Guide 1.33 requires that
equipment control- (e.g., tagging and locking) be addressed by written
procedures..
Paragraph 4.1.6'of Procedure S0-0-20, " Equipment Tagging Procedure,"
states, sin part, that-[ danger
the tag-out sheet and the comp]onents shall be in their requiredtag
position.
Contrary to the above, the' licensee failed to pro erly. implement
Procedure 50-0-20 in that a danger tag was instal ed on valve Ms-100
and the Valve was not in the required position.
The danger tag stated
the valve position was shut; however, the valve was found to be open.
This is a Severity Level IV Violation (Supplement. I) (285/8913-01)
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OPPD Resoonse
1.
Reason for the Violation if Admitted
OPPO admits the violation occurred as stated.
The reason for this violation has been determined to be operator error.
Valve MS-100 is an isolation valve to both a pressure test line on the
RC-2B steam header and the Post Accident Steam Header Radiation Monitor,
RM 064.
Maintenance of RM 064 required that a danger tag be placed (March
21, 1989) on MS-100 directing that this valve be closed. A temporary
clearance tag was subsequently placed on the valve March 23, 1989 in order
that the valve could be opened to allow testing of RM 064.
The temporary
clearance tag is a method used for temporarily changing the position of
valves and components without removing the danger tag.
When the temporary
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clearance tag is' removed, the component is to be returned to the position.
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specified on the danger tag. . However, when the temporary clearance tag was
removed from MS-100 on. March 24, 1989,:the operator failed to return the
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valve to the closed position specified by the danger tag. 'It should be
nohd that the RM-064 line is also equipped with another normally closed
isolation valve,.HCV-922.
This valve was also danger tagged closed for-
maintenance.
Since HCV-922 was closed and ta
.sufficiently isolated for work to take place.gged closed, the monitor was
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MS-100 is a normally open-
valve and thus would not adversely affect operation of the plant.
In
addition, no work was performed on RM-064 from March 24, 1989 until the
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valve was found by.the NRC inspector on March 27, 1989, therefore,' ' no
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personnel safety hazard existed.
2.
The correctivejteos That Have Been Taken and the Results Achieved
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Upon identification of the open valve by the NRC inspector, an OPPD shift
supervisor immediately shut the valve.
A discussion was held with the
operator involved in this incident on the requirements of S0-0 20.
The
operator stated he was aware cf the procedural requirements and admitted
the' error.
This event resulted in an Incident Report (890403) issued March 28, 1989'to
review the root cause and develop corrective actions.
This report
initiated a corrective action to issue a training hotline to all licensed
and non-licensed operators, shift technical advisors, and operations
training instructors. This hotline, issued March 29, 1989, provided
information.on this event occurrence and emphasized the importance of
ensuring _ valve posittas are consistent with the directions on danger
tags. As a result, those personnel responsible for hanging danger tags 'or
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manipulating valves were informed of this event and it was re-emphasized
that the proper positioning of valves consistent with tag instructions must
be ensured.
This hotline required a review by all addressees acknowledged
by signature.
All addressees had acknowledged this hotline by May 22,
1989.. In addition, OPPD has performed a review of all danger and caution
tags installed in the plant to verify that all currently tagged components
were in the position specified on the tag.
This review was concluded by
March 28, 1989 and found that all currently tagged components were in the
proper position. No additional problems were identified during this
review.
3.
Corrective Steos That Will be Taken to Avoid Further Violations
OPPD believes that the actions taken above will minimize the potential for
further violations in this area.
In addition, new operations personnel are
g' Auxiliary Operator Nuclear Training" class.iven instruction on the impor
4.
Date When Full ComDliance Will be Achieved
OPPD is currently in full compliance with S0-0-20 as it pertains to this
violation.
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2.
Crite?fon V of Appendix 8 to 10 CFR 50-and the licensee's NRC-approved
quality assurance program state,-in part,'that activities affecting
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quality shall be prescribed by documented instructions of a type.
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appropriate to the circumstances and shall be accomplished in
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sccordance with these instructions.
Drawing 11405-E-60, " Reactor Auxiliary Building Tray Conduit layout
Plan," requires in Note 17 that solid covers be installed on cable.
trays.
Contrary to the above, cable tray installations have not been-
maintained in accordance with design documents in that cable tray
covers were not properly reinstalled on trays in Room 19, the
upper-level electrical penetration room, and in the east and west
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switchgear rooms.
This is a Severity Level IV Violation.
(Supplement I) (285/8913-01)
1.
Reason for the Violation. if Admitted
OPPD admits the violation occurred as stated.
It has been determined that
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the reason for this violation was lack of adequate standards concerning
modification installations.
Specifically, procedure 50 N-100, " Conduct of
Maintenance," governs the work standards _ for all craftsmen at Fort Calhoun
(both modification and maintenance).
The procedure'did not include
-specific directions for obtaining the required documentation for removal of'
cable tray covers.
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21 Corrective Stoos That Have 'Been Taken and the' Results Ar:tieved
Upon identification'of this problem by the NRC-inspector, OPPD reinstalled
the tray covers.
In addition, OPPD performed an undocumented walkdown of
the cable trays in Room 19, the upper-level electrical penetration room,
and in'the east and west switchgear rooms to verify installation of all
other cable tray covers.
No other instances'of improper installation of
cable tray covers were. identified.
A hotline was issued on June 19, 1989 to all Fort Calhoun Station
electrical craftsmen.
This hotline emphasized the need to keep cable trays
' intact and not to modify any part of a cable tray unless the work package
specifically provides for this.
addressees acknowledged by signature.This hotline requires a review by all-
As a result, those personnel who
work with cable trays were informed of this event and it was re-einphasized
that cable tray covers cannot be removed without approved work
documentation.
3.
Corrective Stoos That Will be Taken to Avoid Further Violations
A sample plant area will be walkeddown in order to ensure no similar cable
tray problems exist.
This action will be completed by September 30, 1989.
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~ As a result of this violation. OPPD plans to revise its " Conduct of
Maintenance" Standing Order, M-100, to include specific direction
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prohibiting removing or modifying cable tray covers without maintenance
orders or an approved modification package. Also, modification
installation procedures will be reviewed to ensure they include or
reference the standards contained in M-1.00.
In addition, a corporate
review of this procedure will be conducted to identify and correct any
further inadequate areas. This revision will be' completed by September 30,
1989. All appropriate field supervisors will receive training on this new
procedure.
The information contained in the hotline noted above shall be included into
a training course currently under development titled "An Introduction to
Work at Fort Calhoun Station". This course is to be completed before the
1990 refueling outage and will be given to both contractor and OPPD
maintenance pcraonnel berus e every I'WruelIng Out194.
4.
Date When Full Comoliance Will be Achieved
OPPD is currently in full compliance with S0-M-100 as it pertains to th'.s
violation.
However, the actions noted above will result in a higher
standard for the conduct of maintenance.
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Technical Specification 5.8.1 states, in part, that written procedures
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shall be established that meet or exceed the minimum requirements of
Appendix A to Regulatory Guide 1.33.
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Section 6.y of Appendix A to Regulatory. Guide 1.33 states that procedures
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shall be written to address the abnormal releases of radioactivity during
emergencies or other significant events.
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Contrary to the above, Procedure AOP-ll, " Loss of Component Cooling Water,"
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did not address the potential for abnormal releases of radioactivity during
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emergencies or other significant events when raw water is being supplied as
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the backup cooling water source to the component cooling water system.
Specifically, Procedure AOP-11 did not address the operability of Radiation
Monitors RM-056A and RM-0568, or provide for alternate grab samples in the
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event the radiation monitors became inoperable when raw water is being
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supplied as the backup cooling water source.
This is a Severity Level IV Violation.
(Supplement 1) (285/8913-05)
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0 PPD Resoonse
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1.
The Reason for the Violation. if Admitted
OPPD admits the violation occurred as stated.
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Abnormal Operating Procedure, AOP-II, Revision 2, issued February 29, 1988,
did not specifically direct operators to ensure that RM-056A and B are
operable when the Raw Water System (RW) is used as a backup upon failure of
the Component Cooling Water System (CCW).
In addition, there was no
provision in this procedure for alternate sampling in the event that the
radiation monitors become ino
backup cooling water source. perable ,vhen RW is being utilized as the
Therefore, the reason for this violation was
lack of specific instructions with respect to radiation monitor operability
and alternate sampling.
2.
The Corrective Steos That Have Been Taken and the Results Achieved
As a result of this inadequacy, AOP-11 has been revised. AOP-11 Revision
2, issued April 11, 1989, now includes a step to ensure both RM-056A and B
are operable whenever the RW System is being used as a backup cooling
source for the CCW system.
This revision also includes a provision for
grab samples to be taken by the plant chemist if either of these monitors
are inoperable.
3.
The Corrective Steos That Will be Taken to Avoid Further Violations
OPPD has determined that the actions taken above have corrected the root
cause of this violation, therefore, no further corrective steps are needed.
4.
Date Whea_E911 Comoliance Will be Achieved
OPPD is currently in full compliance with Technical Specification 5.8.1 and
section 6.y of Appendix A to Re9ulatory Guide 1.33 as it applies to this
iiolation,
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