IR 05000285/1997009

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/97-09

ML20211B617
Person / Time
Site:	Fort Calhoun
Issue date:	09/23/1997
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
References
50-285-97-09, 50-285-97-9, NUDOCS 9709250288
Download: ML20211B617 (4)

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$'5?*kO ~"# AR LINoToN, TEXAS 760118064 9.....8 September 23, 1997 S. K. Gambhir, Division Manager Engineering & Operations Support Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 SUBJECT: NRC INSPECTION REPORT 50 285/97-09, REPLY TO A NOTICE OF VIOLATION

Dear Mr. Gambhir:

Thank you for your letter of September 10,1997, in response to our letter and Notice of Violation dated August 11,1997, resulting from an NRC inspection conducted April 23 through June 10,1997. We havo reviewed your reply and find it responsive to the technical 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.

We note, however, in your response that, though you do not wish to contest the the violation and that you have taken actions to correct the root cause of the violation, you believe your f acility was in full compliance with the requirements of 10 CFR 50.65. It remains the NRC's position that a violation did in fact exist at your facility as described in the Notice of Violation, which was transmitted on August 11,1997. Further, you should be aware that future occurrences of a similar nature as described in the Notice of Violation will result in additional enforcement actioris.

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September 10,1997 LIC-97-0145

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hiall Station PI-137 Washington, D.C. 20555 References: 1. Docket No. 50-285 2. Letter from NRC (E. W. hierschoff) to OPPD (S. K. Gambhir) dated August 11,1997 3. Letter from NRC (A. T. Ilowell) to OPPD (S. K. Gambhir) dated June 17, 1997 4. Letter from OPPD (S. K. Gambhir) to NRC (Document Control Desk),

dated June 4,1997 (LIC-97-0087)

5. Letter from OPPD (S. K. Gambhir) to NRC (Document Control Desk),

dated August 12,1997 (LIC-97-0116)

6. Letter from OPPD (S. K. Gambhir) to NRC (Document Control Desk),

dated May 21,1997 (LIC-97-0079)

SUBJECT: Reply to a Notice of Violation, NRC Inspection Report No. 50-285/97-09 Your letter of August 11,1997, (Reference 2) transmitted a Notice of Violation (NOV) resulting from an NRC inspection conducted April 23,1997, through June 10,1997, at the Fort Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD) response to this NOV.

If you should have any questions, please contact me.

Sincerely, S. Division hianager Engineering & Operations Support EPhi/ cpm Attachment c: Winston and Strawn E. W. hierschoff, NRC Regional Administrator, Region IV L. R. Wharton, NRC Project h!anager W. C. Walker, NRC Senior Resident Inspector 97- nz c 4s.su4 MN vCJ/5 CO T ' yment with Equal opportunity

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. U.S. Nuclear Regulatory Commission LIC-97-0145, Attachment

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Page 2 OPPD Response A. Reason for_the31olation The reason the violation occurred was that the methods used to monitor wall thickness of extraction steam piping as part of the Erosion / Corrosion (EC) program were inadequate. The root cause of this inadequacy was an incomplete utilization of plant history data as detailed in Reference 5. Contributing causes were discussed in References 4 and 5 and in:luded:

• over reliance on one factor,1.c., that typical wear rates for large radius sweeps in extraction steam piping are low, with the result that OPPD omitted the failed site from previous inspections, e a lack of detailed, proceduralized methodology for selecting inspection sites.

OPPD recognizes the inadequacies of the EC program and while we are not contesting the violation, it is our position that our compliance with the maintenance rule,10 CFR 50.65, was adequate. The nonsafety related extraction steam piping was included within the scope of the maintenance rule program per 10 CFR 50.65(b)(2)(ill) since failure of the SSCs could cause a reactor scram. The extraction steam piping was classified as non risk significant and plant level performance criteria were established in accordance with NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Plants," Rev. 2, i 9.3.2.

As part of the initial implementation of the maintenance rule, extraction steam SSCs were evaluated against the plant-level performance criteria using historical data. Per NUMARC 93-01, i 9.3.3, a review of SSC failures and maintenance history was performed from July 1,1992, through June 30,1995, using NPRDS and other plant data. The FCS Maintenance Rule Program adopted NPRDS failure monitoring for all SSCs within the scope of the rule. SSCs have been monitored for failure (e.g., thru wall leakage) by the NPRDS since 1991. During the period covered by the historical review, no prior failures of extraction steam piping were identified that would have caused the established performance criteria to be exceeded. Accordingly, consistent with 10 CFR 50.65 and NUM ARC 93-01, the extraction steam SSCs were placed in Paragraph (a)(2) of the rule and addtessed as part of the preventive maintenance program.

For inhial maintenance rule implementation, extraction steam piping was considered effectively controlled by the EC program so that the Paragraph (a)(2) classification was appropriate. OPPD's review indicated a well developed EC inspection program that was pro-actively replacing EC-susceptible piping prior to reaching minimum wall thickness. From a maintenance rule standpoint, r.a functl'onal failures or MPFFs were identified during the previous two operating cycles that would suggest that preventive maintenance was ineffective.

OPPD continues to believe that the implementation of the maintenance rule was correct. The extraction steam piping, prior to the April 21,1997, event, had met its performance criteria and had not experienced a Maintenance Preventable Functional Failure (MPFF) during the period relevant to the maintenance rule implementation. OPPD therefore determined that the piping was being effectively controlled through preventive maintenance. This view is consistent with NRC guidance. In SECY-97-055, " Maintenance Rule Status, Results, and Lessons i. earned," dated March 4,1997, (page 5) the I

NRC stated its position as follows: "Provided that an SSC meets its performance criteria or does not experience a repetitive maintenance preventable functional failure (MPFF), the preventive maintenance

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. U.S. Nucient Regulatory Commission 1,1C 97 0143, Attachment

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Page 3 for that SSC is considered to be effective, and monitoring can continue under Paragraph (a)(2). When the SSC does not meet a performance criterion or experiences a repetitive hiPFF, the licensee must

<letermine whether the SSC should be monitored under Paragraph (a)(1)." Since the extraction steam piping had inet the performance criteria and had not experienced a h1PFF until the April 21 event.

OPPD mainta ns that monitoring under Paragraph (a)(2) was adequate.

OPPD's relian:e on its existing EC program was also consistent with the regulatory guidance.

Regulatory Guide 1.160, Rev. 2, " hionitoring the Effectiveness of hiaintenance at Nuclear Power Plants,* issued hiarch 1997, encourages the use of existing licensee programs in meeting the maintenance rule. Speclucally, Regulatory Guide 1.160 states (page 3) that the *NRC staff encou, ages licensees to use to the maximum extent practicable, activities currently being conducted, such as technica! specification surveillance testing, to satisfy monitoring requirements." In implementing the maintenance rule, OPPD's review indicated that the EC Program was generally effective and that thettfore it was appropriate to utilize this existing program for monitoring purposes.

OPPD agrees that one purpose of the maintenance rule is to minimize frilures and events caused by the lack of effective maintenance. Nevertheless, the maintenance rule cannot and does not preclude failures from occurring. In fact, the rule and associated guidance contemplate that failures may occur, and specify that when they do, a cause determination must be performed and corrective action taken. As stated in SECY 97 055 (page 9), "From a regulatory standpoint, the occurrence of an h1PFF is not a violation. Rather, an h1PFF indicates a potential problem: what is important is that the licensee take effective corrective actions." In essence, then, the maintenance rule has a built in self improvement s mechanism by which licensee programs are enhanced if a hiPFF or unacceptable performance occurs.

In the case of the April 21 event, this failure was identined as the first h1PFF of the extraction steam piping, and, as cont:mplated by maintenance rule, a cause determination was performed and the appropriate SSCs were dispositioned to Paragraph (a)(1) with monitoring against established goals. In this manner, OPPD complied with 10 CFR 50.65.

11. Corrective StepsWhich llave Ileen Taken and the Results Achieved The corrective actions and results achieved prior to returning Fart Calhoun to power operation are discussed in our previous submittal, Reference 3, documenting the information requested from the public meeting of hiay 5,1997, and in Licensee Event Report 97-003, Reference 6. The status of additional corrective actions were discussed duriag the predecisional enforcement conference on July 21,1997.

Specincally, the CilECWORKS' model has been revised and verined. The results of the updated CllECWORKS* model nre being used as one of the tools to select inspection sites for the 1998 refueling outage.

Based on the extraction steam line failure, the following actians were taken in accordance wPh 10 CFR 50.65:

• A cause determination was performed based on the Root Cause Analysis and Failure Analysis on the extraction steam pipe.

• The failure was identined as an hiPFF.

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,* U.S. Nuclear Regulatory Commission

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LIC-97-0145, Attachment

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• OPPD determined that all FAC susceptible piping should be placed in Paragraph (a)(1) with monitoring against established goals. This resulted in the extraction stearn piping being dispositioned to Paragraph la)(1),

in addition, comprehensive corrective actions were also taken under the Maintenance Rule to provide assurance that other p! ping was being effectively controlled by adequate preventive maintenance.

Specifically, OPPD conducted a review of piping in ot%r systems to determine whether the piping was being effectively monitored by the EC Program or other preventive maintenance activities. As a result of this review, piping in three additional systems were dispositioned to Paragraph (a)(1) of the maintenance rule.

C. Corrective Steps TVhich3Ylli lic Taken As discussed in Reference 6 the following additional corrective measures will be taken:

1. Revise the Erosion / Corrosion Program Plan, controlling procedures and modules to be consistent with industry standards. This revision will include upgrade of the implementing procedures to be consistent with industry standards (e.g., NSAC 202L, Rev.1), development of susceptibility documentation and requirements for use of current industry experience. This will be completed by the beginning of the 1998 Refueling Outage.

2. Revise and verify that the Fort Calhoun CllECWORKS8 models are consistent with industry standards by December 31,1997.

Included in item 2 is a review of maintenance performed on the CllECWORKS8 modeled systems to identify components replaced during the period 1988 to 1984, when the Fort Calhoun computerized maintenance order system was instituted. A review of the CllECWORKS$ model data shows that components replaced after 1988 we'e incorporated into the model, in addition, OPPD is planmng the following enhancements, 1. The sixth stage extraction steam piping is planned for replacement during the 1998 refueling outage. The other extraction steam piping will be evaluated and replaced as dictated by the improved EC program.

2. A review of maintenance history prior to 1984 will be conducted to include any appropriate failure data into the CllECWORKS8 models.

D. Date3Yhen Full. Compliance 3Yllt lle. Achieved OPPD is currently in full compliance.

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<* U.S. Nuclear Regulatory Commission l 1.lC 97-0145, Attachment

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NOTICE OF VIOLATION Omaha Public Power District Docket No. 50 285 Fort Calhoun Station License No. DPR 40 EA 97 280 During on NRC inspection conducted on April 23 through June 10, 1997, a violation of NRC requirements was identified. In accordance with the * General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

10 CFR 50,65(a)(1) states, in part, that each holder of a license to operate a nuclear plant shall monitor the performance of structures, systems, or components, against licensee established goals, in a manner sufficient to provide reasonable assurance that such structures, systems and components, as defined in paragraph (b), are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety and, where practical, take into account industry wide operating experience, 10 CFR 50.65(b) states, in part, that the scope of the monitoring program specified in paragraph (a)(1) shall include safety related and nonsafety related structures, systems, and components as follows: (2) Nonsafety related structures, systems, or components: (iii) Whose failure could cause a reactor scram or actuation of a safety-related system.

10 CFR 50.65(a)(2) states, in part, that monitoring as specified in paragraph (a)(1)

is not required where it has been demonstrated that the performance or condition of a structure, system or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system or component remains capable of performing its intended fuiction.

Contrary to the above, as of July 10, 1996, the time when the licensee elected to not monitor the perforcance or condition of the turbine extraction steam system against licensee established goals pursuant to the requirements of section (a)(1), the licensee had failed to demonstrate that the condition of this system wn being effectively controlled through the performance of appropriate preventive maintenance, such that the system remained capable of perfctming its intended function.

Specifically, the licensee's method of demonstrating the condition of the system, nonitoring pipe wall thicknesses using a predictive methodology to ensure that minimum wall thicknosses were not exceeded, was inadequate. The method was inadequate because errors and omissions in the licensee's approach created erroneous predictions in wall thicknesses. These erroneous predictions allowed significant degradation to go undetected in certain piping sections within the fourth stage extraction steam system without appropriate maintenance being performed. As a result, a catastrophic fcilure of the second downstream large radius piping sweep in the fourth stage extraction steam system occurred on April 21, 1997, which resulted in a plant transient.

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

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