ML20247G184
| ML20247G184 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/31/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-326, NUDOCS 8904040152 | |
| Download: ML20247G184 (3) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000 March 31, 1989 LIC-89-326 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callar.) to OPPD (K. J. Morris) dated March 1, 1989 Gentlemen:
SUBJECT:
Response to Notice of Violation NRC Inspection Report 50-285/89-03 Omaha Public Power District (OPPD) received the Notice of Violation dated March 1, 1989. The violation involved the lack of drawing control for temporary modifications.
Pursuant to the provisions of 10 CFR Part 2.201, please find attached, OPPD's response to the violation.
If you have any questions concerning this matter, please do not hesitate to contact us.
Sincerely, W
5%
K. J. Morri Division Manager Nuclear Operations KJM/jak Attachment c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector 40l 8904040152 890931
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PDR ADOCK 05000285 O
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Attachment RESPONSE TO NOTICE OF VIOLATION During an NRC inspection conducted on January 1-31, 1989, a violation of NRC requirements was identified. The violation involved the failure to provide appropriate drawing control for temporary modifications.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below.
Lack of Drawina Control for Temporary Modifications 10 CFR 50, Appendix B, Criterion III, requires that measures be established for the control of design changes, including field changes. Appendix A of the Fort Calhoun Station Updated Safety Analysis Report, Attachment 1, paragraph L states, in part, that the licensee's Quality Assurance (QA)
Program and QA Plan comply with the requirements of ANSI N45.2.11-1974,
" Quality Assurance Requirements for the Design of Nuclear Power Plant."
ANSI N45.2.11-1974 states, in part, that documented procedures shall be provided for design changes, including field changes, which assure that information concerning the change is transmitted to all affected persons and organizations.
a.
Contrary to the above, Procedure S0-0-25, " Temporary Modification Control," Revision 26 does not assure transmittal of design changes to the control room drawings utilized by the plant operations staff during the interim time from submittal of the drawing revision request to the actual issuance of a drawing revision incorporating the design change.
I b.
Contrary to the above, temporary modifications 8E-M-011, which added a nitrogen bottle supply to supplement the instrument air accumulators associated with Safety Injection Water Refueling Tank Outlet Valves LCV-383-1 and LCV-383-2 in April 1988, had not been incorporated into the control room drawings when reviewed by the NRC inspector on January 15, 1989.
This is a Severity Level IV violation.
(Supplement I) (285/8903-01)
OPPD RESPONSE 1.
Admissi.on or Denial of the Alleaed Violation OPPC admits the violation occurred 6.
stated.
2.
The Reasons For the Violation, If Admitted The reason for the violation can be attributed to the inadequacy of the procedure for tempecary modifications.
The Standing Order 50-0-25 Rev. 26, which was in effect at the time of the violation, did not specify actions yequired to update the control room drawings when installing a temporary modification.
The Temporary Modification Control Form associated with temporary modifications were added to the Shift Supervisors " Temporary Mod Log" in descriptive tarms but not always with a drawing backup.
I
3.
.The Corrective Steos That Have Been Taken and The Results Achieved Tne immediate corrective action taken was the temporary modifications that were in effect at the time of the inspection were reviewed and the control room drawings were updated (red lined) to show temporary modifications. A revision change request to the Procedure S0-0-25, " Temporary Modification Control" was also initiated at that time.
4.
Corrective Steos Which Will Be Taken To Avoid Further Violations In order to prevent the violation from occurring in the future, Procedure S0-0-25 " Temporary Modification Control" Revision 28 was issued on February 21, 1989.
Section 7.2 (8); (9); and (10) of the procedure specifically addresses actions to be taken during the evaluation and verification processing of the Temporary Modification Control Form (FC-66A) to provide modification on the control room drawings when a temporary raodification is to be installed in the field.
5.
Date When Full Compliance Will Be Achieved OPPD is currently in full compliance with the corrective actions described above.
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