ML20147F498

Ack Receipt of 870924,1104 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/87-05.Acceptance of Responses Depends Upon Listed Conditions Resulting from Procedures in Effect at Facility

ML20147F498
Person / Time
Site:	Fort Calhoun
Issue date:	03/02/1988
From:	Callan L Office of Nuclear Reactor Regulation
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20147F482	List: ML20147F478 ML20147F498
References
EA-87-072, EA-87-72, NUDOCS 8803070364
Download: ML20147F498 (2)

See also: IR 05000285/1987005

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In Reply Refer To:

Docket: 50-285/87-05

-EA No. 87-72 ,

Omaha Public Power District

ATTN: R. L. Andrews, Division Manager-

Nuclear Production

1623 Harney Street

Omaha, Nebraska 68102

Gentlemen:

Thank you for your letters, dated September 24.'1987,-November 4, 1987, and

January 27, 1988, in response to our letters, dated May 8,1987, and

August 24, 1987. We have no further questions at this time and will review

your corrective action during a future inspection.

Our acceptance of your responses is predicated upon our understanding 'of the

following conditions res'ilting from procedures in effect at Fort Calhoun

' Station:

Meggering of safety-related installations will be continued using

procedures which specify the proper voltages.

• Procedures will be issued to assure the control of the torque on

safety-related bolted joints. The torque valves in the procedures will

'be specified to assure that allowable dynamic (including seismic loads)

design stresses will not be exceeded. The procedures shall also assure

that the minimum allowed torque valves will not be less than that which

will assure adequate joint integrity.

If.the above understanding is incorrect, please notify me of the conditions

which are applicable within 30 days of the date of this letter.

Sincerely.

L. J. Callan, Director

Division of Reactor Projects

cc:

Fort Calhoun Station

ATTH: W. G. Gates, Manager

P.O. Box 399 ,

Fort Calhoun, Nebraska 68023

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j LIC 87 248

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U. S. Nuclear Regulatory Commission

-Attn: Document Control Desk

Washington, DC 20555

References: 1. Docket No. 50 285

2. Letter from NRC (J. E. Gagliardo) to OPPD (R, L, Andrews)

dated May 8, 1987

3. Letter from NRC (R. E. Hall) to OPPD (R.'t. Andrews) dated

August 24, 1987

Gentlemen:

SUBJECT: Response'to Notice of Violation (NRC Inspection Report

50-285/87-05)

Omaha Public Power District (OPPD) recently received the Reference 3 Notice of

Violation, issued as a result of the subject inspection report. This report

identified three violations, containing several examples. The violations

include failure to provide for independent design verification; follow-

maintenance order torque requirements; specify torque acceptance criteria in a

maintenance procedure; conduct a proper review of the deletion of'a design

requirement; establish procedures for ensuring the appropriateness of the

accuracy of calibration instrumentation; specify equipment, criteria, or

procedure for meggering; and follow appropriate maintenance procedure for the

testing of AC tie breakers.

These violations were previously presented in Reference 2 and were discussed in

an enforcement conference held in the Region IV office on May 14, 1987.

Pursuant to the provisions of 10 CFR Part 2.201. please find attached OPPD's

response to the violations, if you have any questions concerning this matter,

please do not hesitate to contact us.

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R. L. Andrews

Division Manager ~97cm300244 tT70W4 ,$ 7r----

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cc: LeBoeuf. Lamb. Leiby & MacRae

R. D. Martin. NRC Regional Administrator

A. Bournia. NRC Project Manager

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P. H. Ilarrell. NRC Senior Resident inspector

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Response to notice of Violation

During an NRC inspection conducted on April 6 10, 1987, violations of NRC

requirements were identified, in accordance with the "General Statement of

Policy and Procedure for NRC Enforcement Actions. * 10 CFR Part 2, Appendix C

(1937), the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion III, requires, in part, that measures

be established to assure that appilcable regulatory requirements and design

bases for those structures, systems, and components to which this appendix

applies, are correctly translated into specifications, drawings,

procedures, and instructions. These measures must include provisions to

assure that appropriate cuality standards are specified and included in

design docusents and that deviations from such standards are contro11c.d.

The design control measures must provide for verifying or checking the

adequacy of design, such as by the performance of design reviews, by the

use of alternate or simplified calculational methods, or by the performance

of a suitable testing program. In addition, des'gn changes, including

fleid changes, must be subject to design control measures commensurate with

those applied to the original design.

Section A.4, "Design Control," of the OPPD Quality Assurance Plan commits

to Regulatory Guide 1.64 and ANSI N45.2.ll-1974. Section 6.0, "Design

Verification," of ANSI N45.2.ll 1974 specifies that design verification is

to be performed by individuals or groups other than those who performed the

original design and that design activities.are to be controlled.

Contrary to the above, in March 1983, the licensee performed Maintenance

Order (MO) 16275, which covered the reinstallation of main steam safety

relief valves (MS SRV) 275, 276, 277, 278, 280, 281, 282, 291, and 292,

1. The M0 contained instructions to torque the subject valves' in-line

flange bolts to 750 foot-pounds; however, there was no documentation

that an independent design verification had been performed in

determining the specified torque value.

2. During MS $RV installation, the bolts were not stressed to the

specified 750 foot pounds but rather were stressed to unknown values

in an uncontrolled manner (the use of a slugging wrench).

This is a Severity Level IV violation (Supplement !!). (285/8705 01)

OPPD's Response

Reason for the Violation. if Admitted

During March 1983, the main steam safety valves (MSSV's) were installed as a '

result of Maintenance Order (MO) 16725. This M0 contained information con-

ccrning torque values for the MSSV inlet flange studs. This information was

! deleted, without Plant Review Committee review, by the craft supervisor. The

i torque vilue of 750 foot pounds was deleted because the craftsman could not

4 physically fit the torque wrench onto the stud due to the limited space

j adjacent to the MSSV's. The use of a slugging wrench was then employed to

tighten the bolted joint.

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OPP 0's Response (Continued) f

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Reason for the Violation. if Admitted (Continued) (

The deletion of the torque value from the maintenance order instructions was  !

not a violation of plant standing orders as a PRC approved procedure was not

'

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P required in order to perform the work. However, this represents improper,

2- management attention to safety related bolted pressure boundary connections. l

This method of bolt-up was utilized untti May 1987, when this violation.was. -l

,- identifled.  ;

The Corrective Stens Which Have Been Taken and'the Results Achieved

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OPPD has developed and issued interim torquing guidelines.- These guidelines  !

[. provided torque values for the following: CQE and fire protection pressure .

boundary bolted connections; seismic mounting or supports of mechanical and  !

electrical equipment; EEQ equipment where required to maintain qualifications.

, and NSSS threaded connections unless safety wired or lock-nutted. These l

4 -

guidelines were implemented in May 1987. i

'

Upon issuance of these guidelines, specific attention was given to those l

' maintenance orders which encompassed the above noted items to ensure the (

4

requirements of the guidelines were being fulfilled. ' Additionally, a review  !

was conducted of 1987 outage completed M0's and any "in progress" M0's which  !

needed to adhere to the requirements of the guidelines.. Corrective action was t

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taken as necessary to ensure compliance.

j The MSSV reinstallation during the 1987 refueling outage' occurred in early June

>

1987. OPPD, in an effort to ensure that'the reinstallation of the MSSVs did

l not involve the use of a possibly over-stressed stud due to previous slugging

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operations, chose to purchase new studs for the MSSV inlet flanges. A raw

procedure was developed and received PRC. approval for the reinstallation. This

procedure, MP MS 4, provided a calculational method to ensure that the pre-load

stress of the studs on the inlet flange to the MS$Vs was at a valuL of less

than 50 percent of the yield strength of the particular stud material. :This

was vertfled by measuring actual stud elongation using vernier calipers.

Slugging of MSSVs as in the past at Fort Calhoun Station, has proven to be a'

reliable leak free method of bolting up the inlet flanges of the MSSVs.- On

July 2, 1986, when the Fort Calhoun Station tripped from full power operation,.

the MSSVs operated as designed to prevent overpressurization-of the Main. Steam

piping. - The inlet flange, after experiencing a higher than normal' pressure .

during the transient, remained leak free throughout the remainder of the

operating cycle.

OPPD reviewed the method for performing the slugging. Based on the access in

the area, the longest wrench that could have been used was a one foot wrench.

If a craftsman were to use a one foot long slugging wrench in order to "slug-

up" the MSSV studs, he would have to exhibit a force of 2085 foot-pounds at the

very end of the slugging wrench. This would require a large swing of the

sledge hammer and subsequently, a lot of room to swing it in. Very little rote

exists to perform this operation. OPPO therefore believes that previous slug-

ging operation, even though uncontrolled, did not cause the stud m4terial to be

overstressed.

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The Corrective Steos Which Will be Taken to Avoid Further Violations

OPPD has expanded upon the interim torquing guidelines program and has

developed a new procedure concerning bolting. This procedure requires either

vendor supplied torque values or torque values that have been independently

verified. This procedure is currently under review and awaiting PRC  :'

concurrence. This procedure will provide written instruction for selecting

torque values for any bolted joint and will be used when updating or issuing

procedures which require torquing.

The Date When Full Como11ance Will be Achieved

OPPD is presently in full compliance.

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B. 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities

that affect quality shall be prescribed by documented instructions, pro-

cedures, or drawings of a type appropriate to the circumstances and shall

be accomplished in accordance with these instructions, procedures, and

drawings. Instructions, procedures, or drawings shall include appropriate

quantitative or qualitative acceptance criteria.

Section A.6, "Instruction, Procedures, and Drawings," of the OPPD Quality

Assurance Plan implements this requirement, and specifies, in part, that

quality related activities for plant operations, fabrication, processing,

assembly, inspection, and test be accomplished in accordance with the

instructions, procedures, or drawings, and that such documentation ade-

quately reflects all applicable quality requirements and contain the

appropriate quantitative acceptance criteria (such as dimensions, toler-

ances, and sac;ples) for determining that important activities have been

satisfactorily accortplished.

Contrary to the above:

1. The Itcensee's procedure HP MS 1, Revision 13, ' Main Steas Safety

Valve Inspection and Repair," dated March 19, 1987, which was used to

reinstall MS SRV 275, 276, 277, 278, 280, 281, 282, 291, and 292 did

not specify torque values to assure that design bolt stress was

achieved.

2. The initial MO 16275 ssecified a bolt torque value; however, the

parameter was marked tirough with the consent "cannot be torqued."

Later MOs did not specify torque values. Therefore, a design require.

ment was deleted without a proper review and acceptance of the revised

work instruction.

3. The licensee failed to establish procedures for assuring that the

acetracy of instruments used to calibrate (a) the wide range level

indicators for steam generators A and B, and (b) the temperature

detectors for reactor coolant hot and cold legs were within the

accuracy constraints required by the design bases.

4. The licensee failed to specify equipment, acceptance criteria, or

procedure for meggering. Examples of such failures include the

following:

a. Procedures PM EE-VA 3/7, Revision 0, and PM MOV-1, Revision 3,

indicated that meggering was to be accomplished, however, neither

the instrument nor the voltage of the instrument was provided.

b. Procedures PM EE VA 3/7, Revision 0; PM EE-1-13. Revision 5; and

PM EE-3.0, Revision 0, do not specify meggering acceptance

criteria.

c. No procedure specified meggering controls to be applied to

containment ventilation and cooling fan motors.

This is a Severity Level IV violation (Supplement !!). (285/870502)

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Violation 8 (Continued)  !

OPPD's Response

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Reason for the Violation. if Admitted ,

l 1. MP MS-1, Revision 13, ' Main Steam Safety Valve Inspection and Repair," '

dated March 19, 1987, did not specify torque values for reinstallation of

I the Main Steam Safety Valves (MSSVs). Past practice for installation of I

i the MSSVs has utilized the practice of "slugging." This was due to the

j fact that it was, and still is, impossible to physically fit to the torque

! wrench cnto the flange stud nuts due to the limited space adjacent to the ,

t MSSVs. This method of bolt up was discontinued in May 1987 when this

violation was identified.

'

2. M0 16275 was issued to reinstall the main steam safety valves. The work

was completed in March 1983. The M0 contained instructions to torque the -

MSSVs to 750 foot pounds. These instructions were marked through with a

comment "cannot be torqued." Because a PRC approved procedure was not f

required, the fact that utilizing a torque wrench was not possible was not

noted by the group which supplied the values. This failure to feed back

information resulted in the violation.

.

'

3. In the area of instrument accuracy, OPP 0 was found to be deficient of

procedures for assuring the accuracy of instruments used to calibrate (a) {

the  !

the wide range

temperature level indicators

detectors for reactorfar steamhet

coolant generators A and

and cold legs B, and

were with (b)in the j

accuracy constraints required by the design bases. OPPD did not have a

specific procedure assuring instrument accuracies during calibration of the i

specified instrumentation. However, an investigation into this accuracy l

question has demonstrated that OPP 0 currently meets appropriate acceptance

criteria for accuracies between test and measuring equipment and process  !

equipment.

!

4. We do not believe this to be a violation of Criterion V of Appendix 8.te 10 t

CFR Part 50. OPPD has long used meggering as a gross indication of cable .

and/or equipment integrity. The measurements taken have been used as a  !

qualitative measurement, not quantitative. Additionally, OPPO believes ,

that meggering is in excess of the requirements as it relates,to vendor I

manual requirements. Also, surveillance testing (refueling Survelliance  :

Tests and Operational Surveillance Tests) ensure proper operability of  :

equipment.

l

The Corrective Steos Which Have Been Taken and the Results Achieved.

1. OPPD has developed and issued interim torquing guidelines. With these  !

! guidelines in place, a new procedure was written and issued covering the l

! reinstallation of the MS$ys, including necessary quantitative acceptance r

criteria.

l 2. Increased attention has been given to maintenance of safety related' systems

< and detailed attention has been given to the areas of procedures and

! torquing requirements. In this new environment, the reinstallation of the  ;

, MSSVs requires the use of a PRC approved procedure (MP MS 4). As noted in  !

l

Violation A. 1987 refueling outage maintenance orders were also reviewed

for torquing considerations. [

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Violation 8 (Continued)

'Jhe Corrective Steos Which Have Been Taken and the Results Achieved,

(Continued)

3. Safety related calibration procedures performed during the 1987 refueling

outage were evaluated for compliance with calibration accuracy requirements

stated in Standing Order M 28, "Calibration of Test Equipment and Plant

Process Equipment used to Support the 'In service inspection of Nuclear

Plant Components' Progras." Those procedures examined complied with the

requirements of Standing Order M 28. In the interia pericd, prior to

safety related calibration procedure upgrading, a policy has been laple-

mented requiring engineering to identify safety related accuracles prior to

performance of any safety related calibration procedure.

4. OPID believes that this ites is not a violation of Criterion V of 10 CfA

50, Appendix 8. OPPD has reviewed these areas of concern and will invest-

igate the applicability of quantitative rather than qualitative acceptance

criteria for incorporation into applicable procedures,

The Corrective Steos Which Will be Taken to Avoid further Violatlans

1. OPPD ha' xpanded upon the interin torquing guidelines and is currently

awaitiny rRC approval of the new procedure concerning bolting. This pro-

cedure wl" irovide written instructions for selecting torque values for

any bolteu Joint and will be used when updating or issuing precedures thich

require torquing.

2. Heightened management attention to the use of PRC approved procedures for

maintenance on safety related equipment has resulted in the development of

a new bolting procedure. As with itee 1, this procedure will provide the

necessary written guidance to ensure bolted joints are formed to the proper

written acceptance criteria.

3. OPPD uses generic test instruments rather than job specific test instru.

ments to perform calibrations on process equipment. In order to ensure

that appropriate quantitative acceptance criteria exists between process

equipment and its test equipment, OPPD will review and update safety re-

lated calibration procedures following an evaluation of all safety related

process equipment versus appropriate test equipment accuracies.

4. Heightened management attention to this matter is being given and will

result in the development of a generic procedure to identify proper meg-

gering techniques. This procedure will identify applicable acceptance

criteria (either qualitative or quantitative) to be used during the

meggering process and will be used when updating or issuing procedures

which require meggering.

'

Also, OPPD is currently developing a procedure writer's guide which will be

l used as guidance to prepare and update specific procedures. Requirements

l for such items as torquing, test equipment accuracy. and meggering will be

addressed and reviewed for inclusion into the appropriate procedures.

,

Ibt M c when full Come11ance will be Achieved

! OPPD is currently in full compliance relative to the appItcable interim

l.

policies and programs.

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C. Technical Specification 5.8.1 requires that written procedures and

administrative policies shall be established, implemented and maintained

that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of

ANSI N18.7-1972 ano Appendix A of USNRC Regulatory Guide 1.33.

Tie Breaker Calibration Procedure, Revision 3, satisfies the above

requirements for AC circuit breaker testing.

Contrary to the above, the licensee failed to implement the appropriate

procedure and instead an incorrect procedure for CP main breakers was used

for testing the.CP tie breakers.

This is a Severity. Level IV. violation (Supplement 1)

OPPD's Resognig

The Reason for the Violation. if Adnitted

l

OPPD admits the violation occurred. Investigation into the reason for the use

L of the incorrect calibration procedure revealed that the preventive maintenance

(PH) sheet for the tie breaker did not specify which calibration procedure to

,

use. As a result, the foreman in charge of the task obtained what he felt was

j the correct procedure and assigned the task to an electrician. The

electrician, assuming he had the correct procedure, commenced performance of

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the procedure untti trouble occurred during ewercurrent testing. At that time

the electrician determined that the incorrect procedure was be'ng used.

! The Corrective Steen That Have Been Taken and the Results Achieved

The correct calibration procedure was obtained and performed satisfactorily on

the tie breaker. Additionally, main and tie breakers previously calibrated ~

,

during the 1987 refueling outage were verified to be calibrated using the

i

correct procedures.

Ihg, Corrective Stees Which Have been Taken to Avoid Further Violatlann

. The PM sheets associated with the main breakers and tie breakers were revised

l on Aprl1 21. 1987 to list the specific calibration procedures to be used.

!

The Date k' hen Full Come11ance wlli be Achieved

OPPD is now in full compilance.

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Roforencos:- 1. Dockot No. 50 205

2. Letter ' rom liRC (J. E. Gagliardo) to UPPO (R. L. Andrews) .

dated hay 0, 1987

LetterfroaNRC(R;E. Hall)toOPPD(R.L.Andrews) dated

'

3.

August 24, 1937.

4. .

Lottor OPPD (R. L. Andrews) to NRC (Document Control Desk)

dated September 24, 1987 (LIC 87-248)

Gentlemen:

SU3 JECT: Rovitnd Response - Notice of Violation (NRC Inspection Report

50 205/07 05)

Dasha Public Power District's-(OPPD) responso to the Notice of Violation as

contained in Roforcnco 4 has been revised. Tho revision portains to the

responso to Violation 0(4) and is denoted by a vertical line in the right

margin. If you have any questions concerning this slatter, please contact us.

Sincoroly,

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Division Hanager.

Nuclear Production

RLA/me

ccr LoBoeuf. Lamb, Lotby & MacRae

R. O. Hartin, NRC Regional Administrator

A. Bournia, NRC Project Manager

.P. H. Harro11, NRC Sanior Resident inspector

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Responie to Notice of Violation

'During an NRC. inspection conducted on. April 6 10, 1987, violations of HRC

requirements' wore identified. In accordance with the "General Statecent of-

Policy and Procedure for NRC Enforcement Actions,~" 10 CFR ' art 2, Appendix C-

,1 (1937), the violations are listed below:

'A. 10 CFR Part'.50, Appendix B, Critorion-!!!, require',, in part.:that reasures

-

be established to assure that applicable regulatory requirements and design

bases. fur those structures, systems, and componentt.to which this appendix

applies, are correctly translated into specifications', drawings,

procedures, and instractions. These measures must include provisions to

assure that appropriate quality standards are sp?cified and_ included-in

design documents and that deviations from such standards.are conts011ed,

The design contr measures must provide for. verifying or checking .the-

adequacy of design,-such as by the performance of design reviews, by the

use of alternate or simplified calculational methods, or-by the perforsaance

of a suitable testing. program, in addition, design changes, including-

fleid changes, must be subject to design control' measures commensurate with

those applied to the. original design.:

Section A.4, ."Design' Control'," of the OPPD Quality Assurance Plan commits.

' to. Regulatory Guide 1.64 and ANSI ~N45.2.ll 1974. -Section 6.0, "Design

Verification," of ANSI N4'i.2.ll-1974 specifies that design verification is,

to be. performed by individuals or groups.other than those who performet the

original' design and that design activities ars'to-be controlled.

Contrary to the above, in March 1983,.the~1icensee performed Maintenance- '

Order (HO)'16275, which covered the reinstallation of mala steam safety

relief valv2s (MS SRV) 275, 276, 277, 278, 280,-281, 282..-291, and 292.'

.

!. .The H0 contained instructions to torque'the subject valves'.in-line

flar.ge bolts to 750 foot-poJnds; however, there was no docueentation

that an independent design verification had been performed in

determining the specified torque value.

2. During MS SRV installation,Lthe bolts'were not' stressed lto the

specified 750 foot pounds but rather were stressed:to uni.nown values

in an uncontrolled manner (the use of a' slugging wrench).

This is a Severity Level IV violation (Supplement !!). (285/8705 01)

OPPD's Response

<

Treason for the Violation. If Admitted ,

During Harch 1983, the main steam safety valves (MSSV's) were installed as a

~

result of Haintenance Order (HO) 16725. This M0 contained information con-

corning torque values for the HSSV inlet flange studs. This information was

deleted, without Plant Review Committee review, by the craft supervisor. The

torque value of 750 foot pounds was deleteo because the craftsman could not

physically fit the torque wrench onto the stud due to the limited space

adjacent to the HSSV's. The use of a slugging wrench was then employed to

tighten the boited joint.

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ViolationAi(Continued)L

0 PPD's Resom ig (Continued).

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, Reason for the Violation. if Admitted (Continued)

.

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The. deletion of the torque value from the maintenance order instructions was

not a violation of plant standing orders as a PRC: approved procedure was not-

required in order to perform the work. However, this represents leproper'

management attention to safety related bolted pressure boundary cor.wctions.

This method of bolt up was utilized until May 1987, when this violation was:

Identified.

The Corrective Steos Which Have Been Taken and the Results Achieved

OPPD has developed and issued interim torquing guidelines. These guidelines

provided torque values for the following: CQE and fire protection pressure-

boundary bolted connections; seismic mounting or supports of mechanical:and

electrical equipment; EEQ equipment where required to maintain qualification;

and NSSS threaded connections unless safety wired or lock nutted. These:

guidelines-were implemented in-May 1987.

^

Upon issuance of these guidelines, specific attention was gl'ven to those'~

maintenance orders which encompassed the above noted items-to ensure the'

requirements of the guidelines were being fulfilled.~ Additionally,'a review-

was conducted of 1987 outage completed M0's and any "in progress" M0's which

needed to adhere to the requirements of the guidelines, Corrective action'was

taken as necessary to ensure compliance.

The HSSV reinstallation during the 1987 refueling outage occurred in early June

1987. OPPD, in an effort,to ensure that the reinstallation of'the.MSSVs'did

not involve the use of a possibly over stressed stud due to previous slugging- ,

' operations, chose to' purchase new studs for the' MSSV inlet flanges. A new.

procedure was developed and received PRC approval for the reinstallation. . This ,

procedure, MP-MS-4, provided a calculational method to ensure that 'the-pre load. -

stress of the studs on the inlet flange to the MSSVs was at-a1value:of less

than 50 percent of the yield strength of the particular-stud material. This - '

was verified by measuring actual stud elongation using vernier calipers..

. Slugging of MSSVs, as in the past at' Fort Calhoun' Station, has proven to be 'a >

'

.. reliable leak-free method of bolting up the inlet flangas of the MSSVs. On ,

July 2, 1986, when the Fort Calhoun Station tripped from full power, operation,

the MSSVs operated as designed to prevent overpressurization of the Main Steam

piping. The inlet flange, after experiencing a higher than-normal pressure-

during the transient, remained leak free throughout the. remainder-'of the.

operating cycle.

'

-OPPD reviewed the method for performing the slugging.- Based on the access in

the area, the longest wrench that could have been used was a one foot wrench.

,

if a craftsman were to use a one-foot long slugging wrench in order to "slug.

'

up" the MSSV studs, he would have to exhibit-a force of 2085 foot pounds at the

very end of the slugging wrench. This wuld require a large swing of the

sledge hammer and subsequently, a lot of room to swing it in. Very little room

exists to perform this operation. OPPD therefore believes that previous slug.

ging operation, even though unc utrolled, did not cause the stud material to be i

L overstressed.

- _. __ ._ __ _ _ ___,.._ _ ._ _ _ _.__._ _ _._ . _ . _ _ , _ _ . , _

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.

Violation A (Continued) [

The Corrective Steps Which W111~be Taken to Avoid Further Violationi

OPPL has expanded upon the interim torquing guidelines program and has

developed a new procedure concerning bolting, This procedure requires either

vendor supplied torque values or torque values that have been independently .l

verified. This procedure is currently under review and awaitina PRC -

concurrence. This procedure will provide written instruction for selecting l

torque values for any bolted joint and will be used when updating or issuing

procedures which require torquing.

The Dato When Full Comoliance Will be Achieved

OPPD is presently in full compliance.

I

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B. 10_ CFR Part 50, Appendix.B. Criterion.V recuires, 'in part, that activities

that affect quality shall be prescribed by cocumented instructions, pro-

cedures, or drawings of a type appropriate to the circumstances and shall

be accomplished in accordance with these instructions, procedures, and-

drawings. ' Instructions, procedures, or drawings shall include appropriate

quantitative or qualitative acceptance. criteria. ,

9

Section A.6. "Instruction, Procedures, and Drawings," of the OPPD Quality i

Assurance Plan implements this requiremont, and specifies, in part, that l

quality related activities for plant operations, fabrication, processing,  !

assu oly, inspection, and test be accomplished in accordance with the

instructions, procedures, or drawings, and that such docur.entation ads,

quately reflects all applicable quality requirements and contain the

appropriate quantitative acceptance criteria (such as dimensions, toler-

ances, and samples) for determining that important activities have been

satisfactorily accomplished.

Contrary to the above:

1. The licensee's procedura MP-MS-1, Revision 13, "Main Steam Safety

Valve Inspection and Repair," dated March 19, 1987, which was used to

reinstall MS SRV 275, 276, 277, 278, 280, 281, 292, 291 and 292 did

not specify torque values to assure that design bolt stress was

achieved.

2. The initial H0 16275 specified a bolt torque value; however, the

parameter was marked through with the comment "ctnnot be torquad,"

Later H0s did not specify turque values. Therefore, a design require-

ment was deleted without a proper review and acceptance of the revised

work instruction.

3. The licensee failed to establish procedures for assuring that the - ,

"

accuracy of instruments used to calibrate (a) the wide range-level

indicators for steam generators A and B, and (b) the temperature

detectors for reactor coolant hot and cold legs were within the

accuracy constraints required by the design bases.

4. The licensee failed to specify equipment, acceptance criteria, or,

procedure for meggering. Examples of such failures include the

following:

a. Procedures PM EE VA-3/7, Revision 0, and PM MOV 1, Revision 3,-

indicated that meggering was to be accomplished, however, neither

the instrument nor the voltage of the instrument was provided,

b. Procedures PM EE VA 3/7, Revision 0; PM EE-1 13, Revision 5 and

PM EE 3.0, Revision 0, do not specify meggering' acceptance

criteria,

c. No procedure specified meggering centrols to be applied to-

containment ventilation and cooling fan motors.

This is a M erity Level IV violation (Supplement !!). (285/970502)

_ _ _ -

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Violation 8 (Continued)

OPPO's Response -

!

Reisen for the Violation. if Admitted  !

\

1. HP flS-1, Revision 13. "Main Steam Safety Valve Inspection and Repair," j

dated Harch 19, 1987, did not specify torque values for reinstallation of r

the Main Steam Safety Valves (HSSVs). Past practice for installation of i

the MSSVs has utilized the practice of "slugging." This was due to the }

fact that it was, and still is, impossible to physically fit to the torque

wrench onto the flange stud nuts due tre the limited space adjacent to the

HSSVs. This method of bolt up was discontinued-in May 1987 when this  ;

violation was identified.

2. H0 16275 was issued to reinstall the main steam safety valves.. The work-

was completed in March 1983. The M0 contained instructions to torque the

MSSVs to 750 foot pounds. These instructions +ere marked through with_a

coceent "cannot be torqued." Because a PRC approved procedure was not-

required, the fact that utilizing a torque wrench wer not possible was not

noted by the group which supplied the values. This failure to feed back

information resulted in the violation.

3. In the area of instrument accuracy, OPPD was found to'be deficient of

procedures for assuring the accuracy of instruments used to calibrate (a) .

the wide range level indicators _for. steam generators A and B. and (b) the

temperature detectors for reactor coolant hot;and cold legs were within the

accuracy constraints required by the design bases. OPPD did not have 4-

specific procedure assuring instrument accuracies during calibration'of the

specified instrumentation. However,_an investigation into this accuracy

question has demonstrated that OPPD currently meets appropriate acceptance.

criteria for accuracies between test and measuring equipment.-and process

equipment.

4. OPPD uses meggering as a gross indication of cable and/or equipment inte-

grity. The measurements taken have been used as a. qualitative measurement,

not quantitative. Surveillance testing also ensures proper operability of.-

equipment.

The Corrective Steos Which Have Been Taken and the Results Achieved.

'

1. OPPD has developed and issued interim torquing guidelines. With these

guidelines in place, a new procedure was written and issued covering the

reinstallation of the MSSVs, including necessary. quantitative acceptance

, criteria.

. 2. - Increased attention has been given to maintenance of safety related systems

and detailed attention has been given to the areas of procedures and

torquing requirements, in this new environment, the reinstallation of the

HSSVs requires the use of a PRC approved procedure (HP MS 4)~. As noted in

Violation A, 1987 refueling outage maintenance orders were also reviewed

for torquing considerations.

,

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Violation B (Continued)

.

The Corrective Stoos Which Have Been Taken and the Results Achieved.

(Continued)

3. Safety related calibration procedures performed during the 1987 refueling

outage were evaluated for compliance with calibration accuracy requirce.ents

stated in Standing Order M 28 "Calibration of Test Equipment and Plant

Process Equipment used to Support the 'In Service Inspection of nuclear

Plant Corponents' Program." Those procedures ext:nined coglied with the

requirements of Standing Order H-28. In the interim period, prior to . l

safety related calibration procedure upgrading, a policy has been leple-  !

conted requiring engineering to identify safety related accuracles prior te

performance of any safety related calibration procedure.

-4. OPPD has reviewed these areas of concern and will investigate.the

applicability of quantitative rather than qualitative acceptance criteria

for incorporation into applicable procedures.

The Corrective Steos Which Will be Taken to' Avoid Further Violations

1. OPPD has expanded upon the interim torquing guidelines and is currently

awaiting PRC approval of the new procedure concerning bolting. This. pro-

cedure will provide written instructions for selecting torque values for

any bolted joint and will be used when updating or issuing pror.edures which

require torquing.

2. Heightened mantgeant attention to the use of PRC approved procedures for

maintenance on safety-related equipment has resulted in the developsent of

a new bolting procedure. As with item 1, this procedure wlII provide the

necessary written guidance to ensure bolted joints are formed to.the proper

written acceptance criteria.

~

3. OPPD uses generic test instruments rather than job specific test 1nstru-

ments to perform calibrations on process equipment. In order to ensure

that appropriate quantitative acceptance critoria exists t,etween process

equipment and its test equipment, QPPD will reviw and~ update safety re-

. ,

lated calibration procedures following an evaluation of all safety related

process equipment versus appropriate test equipment accuracies. .

4. Heightened management attention to this matter la being given and will

result in the development of a generic procedure to. identify proper meg.

gering techniques. This procedure will identify appilcable acceptance

criteria (either qualitative or quantitative) to be used during the

meggering process and will be used when updating or issuing procedures

which require meggering.

.

Also, OPPD is currently developing a procedure writer's guide which will be

used as guidance to prepare and update specific procedures. Requirements

e for such items as torquing, test equipment accuracy. and meggering will be

addressed and reviewed for inclusion into the appropriate procedures.

The Date When Full Como11ance will be Achieved

OPPD is currently in full compliance relative to the applicable interim

policies and programs.

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C.1 Technical Specification 5.8.1-rcquires that written proceduras and

administrative policios shall be established, implecented and maintained

that ceot or exceed ,the minicum requirccants of Sections 5.1 and.5,3 of

-ANSI N18.7 1972 and Appendix A of USNRC Regulatory Guide 1,33,

Tie-Breaker Calibration-Proceduro, Revision 3, satisfiss the above

requirecents for AC circuit breaker testing.

leplement the appropriate

Contrary

proceduretoand

theinstead,

above,an

theincorrect

licenscoprocedure

failed to. for CP main breakers was used

for testing the CP tie breakers.

This is a Severity Level IV violation (Supplement 1)

OPPD's Resoonse

The Reason for the Violation if Admitted

OPPD admits the violation occurred. Investigation into the reason for the use

of the incorrect calibration procedure revealed that the preventive maintenance

(PH) sheet for the tie breaker did not specify which calibration procedure to

use. As a result, the foreman in charge of the. task obtained what ' '-1t was

the correct procedure and assigned the task to an electricisn, '

electrician, assuming he had the correct procedure, comenced pas o' . cs

the procedure until trouble occurred during overcurrent testing, AL that t

the electrician determined that the incorrect procedure was being used.

The Corrective Steos Tnat Have Been Taken and_the Results Achieved-

The correct calibration procedure was obtained and performed satisfacto .m

the tie breaker. Additionally, main :nd tie breakers previously calibratu

~

, during the 1987 refueling outage were verified to be calibrated using the

i

correct procedures.-

The Corrective Stoos Which Have Been Taken to Avoid Further Violations

The PM sheets associatsd with the main breakers and tie breakers were revised -

on April 21, 1987, to list the specific calibration procedures to be used .

The Date When Full Comoliance will be Achieved

OPPD is now in full compilance.

• .

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Omaha Public Power District --

1623 Harney Omaha. Nebraska 68102

402/536 4000 F g<

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January 27, 1988 s', i FEB - l M

!

LIC-88-024 t s

._-

V. S. Nuclear Regulatory Commission

Attn: Document Control Desk

Washington, DC 20555

References: 1. Docket No. 50-285

2. Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews)

dated May 8, 1987

3. Letter from NRC (R. E. Hall) to OPPD (R. L. Andrews) dated

August 24, 1987

4. Letter from 0 PPD (R. L. Andrews) to NRC (Documcat Control

Desk) dated September 24, 1987 (LIC-87-248)

5. Letter from 0 PPD (R. L. Andrews) to NRC (Document Control

Desk) dated November 4, 1987 (LIC-87-680)

Gentlemen:

SUBJECT: Update to Response - Notice of Violation (NRC Inspection Report

50-285/87-05)

l Omaha Public Power District's (OPPD) response to the Notice of Violation as

l contained in Reference 5 has been updated. Changes have been made in the

"Corrective Steps" of Violation A, the "Reason" portion in Violation B.4, and

the "Corrective Steps" of Violation B. The revised portions are denoted by a

i vertical line in the right margin. If you have any questions concerning this

I matter, please contact us.

Sincerely,

/$

R. L. Andrews

l Division Manager

Nuclear Production _p4g 7 g p

l -

l

RLA/me

l cc: LeBoeuf, Lamb, Leiby & MacRae

'

CR.;Di; Martin, NRC Regional Administrator

A. Bournia,'NRC Project Manager

4'2 ,/ P. H. Harrell, NRC Senior Resident Inspector

\9

I

45 $'24 Employment with (Qual Opportunity

Male Female

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Response to Notice of Violation ,

-During an NRC inspection conducted on April 6-10, 1987, violations of NRC

requirements were identified. _In accordance with the "General Statement of'

Policy and Procedure for NRC Enforcement Actions, " 10 CFR Part 2, Appendix C

(1987), the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion III, requ res, in part, that measures

be established to assure that applicable regulatory requirements and design

bases fo'r those structures, systems, and components to which this appendix

applies, are correctly translated into specifications, drawings, proce-

dures, and instructions. These measures must include provisions to. assure

that appropriate quality standards are specified and included in design

documents and that deviations from such standards are controlled. The

design control measures must provide for verifying or checking the adequacy

of design, such as by the performance of design reviews, by the use of

alternate or simplified calculational methods, or by the performance of a

suitable testing program. In addition, design changes, including field

changes, must be subject to design control measures commensurate with those

applied to the original design. *

Section A.4, "Design Control," of the OPPD Quality Assurance Plan commits

to Regulatory Guide 1.64 and ANSI N45.2.ll-1974. Section 6.0, "Design

Verification," of ANSI N45.2.11-1974 specifies that design verification is

to be performed by individuals or groups other than those who performed the

original design and that design activities are to be controlled.

Contrary to the above, in Harn v the licensee performed Maintenance

Order (H0) 16275, which cove- *

,m einstallation of main steam safety

relief valves (MS SRV) 275, W ,, w ,'278, 280, 281, 282, 291, and 292.

1. The M0 contained instructions to torque the subject valves' in line

flange bolts to 750 foot-pounds; however, there was no documentation

that an independent design verification had been performed in deter-

mining the specified torque value.

2. During MS SRV installation, the bolts were not stressed to the speci-

fled 750 foot-pounds but rather were stressed to unknown values in an

uncontrolled manner (the use of a slugging wrench).

This is a Severity Level IV violation (Supplement II). (285/8705-01)

OPPD's Resoonse

Reason for the Violation, if Admitted

During March 1983, the main steam safety valves (MSSV's) were installed as a

result of Maintenance Order (MO) 16725. This MO contained information con-

cerning torque values for the MSSV inlet flange studs. This information was

deleted, without Plant Review Committee review, by the craft supervisor. The

torque value of 750 foot-pounds was deleted because the craftsman could not

physically fit the torque wrench onto the stud due to the limited space

adjacent to the MSSV's. The use of a slugging wrench was then employed to

tighten the bolted joint.

.

,

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Violation A (Continued) }

OPPO's Response (Continued)

Reason for the Violation, if Admitted (Continued)

The deletion of the torque value from the maintenance order instructions was

not a violation of plant standing orders as a PRC approved procedure was not

required in order to perform the work. However, this represents improper

management attention to safety related bolted pressure boundary connections.

This method of bolt-up was utilized until May 1987, when this violation was

-identified.

The Corrective Steos Which Have Been Taken and the Results Achieved

OPPD has developed and issued interim torquing guidelines. These guidelines

provided torque values for the following: CQE and fire protection pressure

boundary bolted connections; seismic mounting or supports of mechanical and

electrical equipment; EEQ equipment where required to maintain qualification;

and NSSS threaded connections unless safety-wired or lock-nutted. These

guidelines were implemented in May 1987.

Upon issuance of these guidelines, specific attention was given to those

maintenance orders which encompassed the above noted items to ensure the

requirements of the guidelines were being fulfilled. Additionally, a review

was conducted of 1987 outage completed M0's and any "in-progress" M0's which  !

needed to adhere to the requirements of the guidelines. Corrective action was

taken as necessary to ensure compliance.

The MSSV reinstallation during the 1987 refueling outage occurred in early June

1987. OPPD, in an effort to ensure that the reinstallation of the MSSVs did

not involve the use of a possibly over-stressed stud due to previous slugging

operations, chose to purchase new studs for the MSSV inlet flanges. A new

procedure was developed and received PRC approval for the reinstallation. This

procedure, MP-MS-4, provided a calculational method to ensure that the pre-load

stress of the studs on the inlet flange to the MSSVs was at a value of less

than 50 percent of the yield strength of the particular stud material. This

was verified by measuring actual stud elongation using vernier calipers.

Slugging of MSSVs, as in the past at Fort Calhoun Station, has proven to be a

reliable leak-free method of bolting up the inlet flanges of the MSSVs. On

July 2,1986, when the Fort Calhoun Station tripped from full power operation,

the MSSVs operated as designed to prevent overpressurization of the Main Steam

piping. The inlet flange, after experiencing a higher than normal pressure

during the transient, remained leak-free throughout the remainder of the

operating cycle.

OPPD reviewed the method for performing the slugging. Based on the access in

the area, the longest wrench that could have been used was a one-foot wrench.

If a craftsman were to use a one-foot long slugging wrench in order to "slug-

up" the MSSV studs, he would have to exhibit a force of 2085 foot-pounds at the

very end of the slugging wrench. This would require a large swing of the

sledge hammer and subsequently, a lot of room to swing it in. Very little room

exists to perform this operation. OPPD therefore believes that previous slug-

ging operation, even though uncontrolled, did not cause the stud material to be

overstressed.

_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _

.- .-

* *.. .

~

-.

Violation A (Continued) .'

_,

The Corrective Steos Which Will be Taken to Avoid Further Violations

~

OPPD has expanded upon the interim torquing guidelines program and has de-

veloped a new procedure concerning bolting. This procedure requires either

vendor supplied torque values cn* torque values that have been independently

reviewed. This procedure provides written instruction for selecting torque

fvalues for any safety related bolted joint and will be used when updating or

issuing procedures which require torquing. This procedure is currently

awaiting approval.

The Date When Full Comoliance Will be Achieved

OPPD is presently in full compliance.

..

r

' . .

,

.. ., ,

m B. 10 CFR Part 50, Appendix B, Crite' r ion V, requires, in part, that activities 's

that affect quality shall be prescribed by documented instructions, pro-

cedures, or drawings of a type appropriate to the circumstances and shall

be acccmplished in accordance with these instructions, procedures, and

drawings. Instructions, procedures, or drawings shall include appropriate

quantitative or qualitative acceptance criteria.

Section A.6, "Instruction, Procedures, and Drawings," of the OPPD Quality

Assurance Plan implements this requirement, and specifies, in part, that

quality-related activities for plant operations, fabrication, processing,

assembly, inspection, and test be accomplished in accordance with the

instructions, procedures, or drawings, and that such documentation ade-

quately reflects all applicable quality requirements and contain the

appropriate quantitative acceptance criteria (such as dimensions, toler-

ances, and samples) for determining that important activities have been

satisfactorily accomplished.

Contrary to the above:

1. The licen'see's procedure MP-MS-1, Revision 13, "Main Steam Safety

Valve Inspection and Repair," dated March 19, 1987, which was used to

reinstall MS SRV 275, 276, 277, 278, 280, 281, 282, 291, and 292 did

not specify torque values to assure that design bolt stress was

achieved.

,

2. The initial M0 16275 specified a bolt torque value; however, the

parameter was marked through with the comment "cannot be torqued."

Later M0s did not specify torque values. Therefore, a design require-

ment was deleted without a proper review and acceptance of the revised

work instru:: tion.

3. The licensee failed to establish procedures for assuring that the

accuracy of instruments used to calibrate (a) the wide range level

indicators for steam generators A and B, and (b) the temperature

detectors for reactor coolant hot and cold legs were within the

accuracy constraints required by the design bases.

4. The licensee failed to specify equipment, acceptance criteria, or

procedure for meggering. Examples of such failures include the

following:

a. Procedures PM-EE-VA-3/7, Revision 0, and PM-H0V-1, Revision 3,

indicated that meggering was to be accomplished, however, neither

the instrument nor the voltage of the instrument was provided.

b. Procedures PM-EE-VA-3/7, Revision 0; PM-EE-1-13, Revision 5; and

PM-EE-3.0, Revision 0, do not specify meggering acceptance

criteria.

c. No procedure specified meggering controls to be applied to

containment ventilation and cooling fan motors.

This is a Severity Level IV violation (Supplement II). (285/8705-02)

• e O

. . . . . ~

V'iolation B (Continued)

"

m OPPD's Response

Reason for the Violation, if Admitted

1. MP-MS-1, Revision 13, "Main Steam Safety Valve Inspection and Repair,"

dated March 19, 1987, did not specify torque values for reinstallation of

the Main Steam Safety Valves (MSSVs). Past practice for installation of

the MSSVs has utilized the practice of "slugging." This was due to the

fact that it was, and still is, impossible to physically fit to the torque

wrench onto the flange stud nuts due to the limited space adjacent to the

MSSVs. This method of bolt-up was discontinued in May 1987 when this

violation was identified.

2. M0 16275 was issued to reinstall the main steam safety valves. The work

was completed in March 1983. The M0 contained instructions to torque the

MSSVs to 750 foot-pounds. These instructions were marked through with a

comment "cannot be torqued." Because a PRC approved procedure was not

required, the fact that utilizing a torque wrench was not possible was not

noted by the group which supplied the values. This failure to feed back

information resulted in the violation.

3. In the area of instrument accuracy, OPPD was found to be deficient of

procedures for assuring the accuracy of instruments used to calibrate (a)

the wide range level indicators for steam generators A and B, and (b) the

temperature detectors for reactor coolant hot and cold legs were within the

accuracy constraints required by the design bases. OPPO did not have a

specific procedure assuring instrument accuracies during calibration of the

specified instrumentation. However, an investigation into this accuracy

question has demonstrated that OPPD currently meets appropriate acceptance

criteria for accuracies between test and measuring equipment and process

equipment.

4. In the past, OPPD dsed meggering as a gross indication of cable and/or

equipment integrity and considered meggering to be a craft skill that did

not require procedural control,

a. OPPD agrees that procedures PM-EE-VA-3/7 and PM-MOV-1 did not specify

the instrument to be used for meggering and the test voltage to be

applied.

b. OPPD agrees that procedures PM-EE-VA-3/7, PM-EE-1 and PM-EE-3.0 did

not specify meggering acceptance criteria.

c. OPPD agrees that no procedure specified meggering controls to be

applied to containment ventilation and cooling fan motors.

The Corrective Steos Which Have Been Taken and the Results Achieved.

1. OPPD has developed and issued interim torquing guidelines. With these

guidelines in place, a new procedure was written and issued covering the

reinstallation of the MSSVs, including necessary quantitative acceptance

criteria. A new procedure (HP-BOLT-1) has been written and is awaiting

approval for selecting torque values for any safety related bolted joint

and will be used when updating or issuing procedures which require bolting.

Torque values for bolting will be as specified by the vendor or as

determined by MP-BOLT-1.

-

._

.

,

' " *

Violation B (Continued)

m The Corrective Steos Which Have Been Taken and the Results Achieved.

(Continued).

2. Increased attention has been given to maintenance of safety-related systems

and detailed attentien has been given to the areas of procedures and torqu-

ing requirements. In this new environment, the reinstallation of the MSSVs

requires the use of a PRC approved procedure (MP-MS-4). As noted in Viola-

tion A,1987 refueling outage maintenance orders were also reviewed for

torquing considerations.

3. Safety related calibration procedures that were evaluated complied with

calibration accuracy requirements stated in Standing Order M-28, "Cali-

bration of Test Equipment and Plant Process Equipment used to Support the

'In-Service Inspection of Nuclear Plant Components' Program." 0 PPD has

reviewed and updated Standing Order M-26 "Calibration Procedures" to in-

clude steps to ensure test and measurement equipment inaccuracies are

evaluated to ensure process instrumentation can be properly calibrated. A

list of affected instrument loops has been included in the Standing Order

and another review of the list for completeness is being performed. A new

form FC-1102 "Calibration Accuracy Verification" has also been issued to

verify Tecuracy.

4. A generic procedure to ider.tify proper meggering techniques (HP-EE-MEGGER)

has been approved. This procedure identifies applicable accegtance cri-

teria to be used during the meggering process and will be used when

updating or issuing procedures which require meggering. Form FC-45 "Insula-

tion Resistance - Dielectric Absorption Test Sheet" has been revised to add

temperature corrected megger values to the data sheet, to reformat the data

sheet for clarity, and to add information not listed on the previous data

sheet revision.

Procedures PM-EE-VA-3/7, PM-MOV-1, PM-EE-1, and PM-EE-3.0 have all been

revised to list the megger test voltage to be applied and to megger in

accordance with MP-EE-MEGGER.

Procedure MP-EE-12 has been revised to have the containment ventilation and

cooling fan motors meggered in accordance with MP-EE-MEGGER. Other proce-

dures that have been revised to megger in accordance with MP-EE-MEGGER are

HP-EE-8, HP-RC-10-3, PM-EE-2, - 3.2, 4.0, 21, PM-ST-2, and ST-ESF-6.

The Corrective Steos Which Will be Taken to Avoid Further Violations

OPPD is :urrently developing a procedure writer's guide which will be used as l

guidance to prepare and update specific procedures. Requirements for such

items as torquing, test equipment accuracy, and meggering will be addressed and

reviewed for inclusion into the appropriate procedures. The procedure address-

ing torquing values has been written and is currently being reviewed by the

Plant Review Committee (PRC) and will be issued upon approval.

The Date When Full Comoliance will be Achieved

OPPD is currently in full compliance.

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m C. Technical Specification 5.8.1 requires that written procedures and -

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administrative-policies shall u. established,, implemented and maintained

that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of

ANSI N18.7-1972 and Appendix. A of USNRC Regulatory Guide 1.33.

Tie Breaker Calibration Procedure, Revision 3, satisfies the above

requirements for AC circuit breaker testing.

Contrary ~to the above, the licensee failed to implement the appropriate-pro-

cedure and instead, an incorrect procedure for CP-main breakers was used

for testing the CP-tie breakers.

This is a Severity Level IV violation (Supplement I)

OPP 0's Response

The Reason for the Violation, if- Admitted

OPPD admits the violation occurred. Investigation into the reason for the use

of the incorrect calibration procedure revealed that the preventive maintenance

(PM) sheet for the tie breaker did not specify which calibration procedure to

use. As a result, the foreman in charge of the task obtained what he felt was

the correct procedure and assigned the task to an electrician. The electric-

ian, assuming he had the correct procedure, commenced performance of the

procedure until trouble occurred during overcurrent testing. At that time the

electrician determined that the incorrect procedure was being used.

.

The Corrective Steos That Have Been Taken and the Results Achieved

The correct calibration procedure was obtained and performed satisfactorily'on

the tie breaker. Additionally, main and tie breakers previously calibrated

during the 1987 refueling outage were verified to be calibrated using the

correct procedures. The PM sheets associated with the main breakers and tie

breakers were revised on April 21, 1987, to list the specific calibration

procedures to be used.

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The Corrective Steos Which Will be Taken to Avoid Further Violations

No further action is required. l

The Date When Full Comoliance will be Achieved

OPPD is now in full compliance.

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