ML20112H424

Responds to NRC 841109 & 850215 Ltrs Re Violations Noted in Insp Rept 50-285/84-21.Corrective Actions:Qa Plan,Section 6.3,will Be Revised to Reflect Recommendations of ANSI 45.2.1 Re Cleaning of Fluid Sys by 850630

ML20112H424
Person / Time
Site:	Fort Calhoun
Issue date:	03/15/1985
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20112H408	List: ML20112H424
References
LIC-85-106, NUDOCS 8504020252
Download: ML20112H424 (2)

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Omaha Public Power District I 1623 Harney Omaha. Nebraska 68102 402/536-4000 flarch 15, 1985 LIC-85-106 g g g g },

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MAR 2 01985 4

L q Mr. Richard P. Denise, Director g b

Division of Resident, Reactor Project and Engineering Programs --

U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Reference:

(1) Docket No. 50-285 (2) IE Inspection Report 285/8421 Item Olb (3) Letter OPPD (R. L. Andrews) to NRC (R. P. Denise) dated December 10, 1984 (LIC-84-419)

(4) Letter NRC (D. R. Hunter) to OPPD (R. L. Andrews) dated February 15, 1985

Dear Mr. Denise:

IE Inspection Report 84-21 Item Olb Reference 4 requested addi tional information regarding the District's plans to implement the requirements of ANSI N45.2.1-1973. This letter serves as the response to that request.

Regulatory Guide 1.37, dated March 16, 1973, (Quality Assurance Requirements for Cleaning of Fluid Systems & Associated Components of Paragraph 2 I Water-Cooled Huclear Power Plants) endorses ANSI 45.2.1-1973.

of Regulatory Guide 1.37 states that

...many of the requirements and l n recommendations contained in the standards are also appropriate to mm cleaning of fluid systems and associated components during the operations l S$$ phase of a nuclear power plant, and they should be used when applicable."

@@ It is the District's intention to develop more specific guidelines on regarding what " requirements and recommendations contained in the standard

• guidelines will be re flected in the are al so approp ri a te . . . " The M District's Quali ty Assurance Plan and are intended to eliminate gg uncertainty regarding compliance with ANSI 45.2.1-1973.

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@ Accordingly, the District olans to revise Quality Assurance Plan (QAP) gg Section 6.3 to more specifically identify the requirements and mae recommendations of ANSI 45.2.1-1973 which we believe are applicable to the operation of the Fort Calhoun Station. Following revision to QAP 6.3, the Fort Calhoun Station Standing Orders and/or procedures will be revised or developed as required to more formally implement the requirements and recommendations of ANSI 45.2.1-1973.

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l LIC-85-106 Page Two The District currently plans on completing the above activities by June 30, 1985.

Sincerely, R. L. Andrews Division Manayr Nuclear Production RLA/KJM:jbk cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, DC 20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Inspector

l Omaha Public Power District l 1623 Harney Omaha. Nebraska 68102 402/536-4000 December 10, 1984 LIC-84-419 ,

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Mr. Richard P. Denise, Director IN @ (~25-' [P 'I Pf/

' "F l Division of Resident, beactor Project and Engineering Programs U. S. Nuclear Regulatory Commission DEC I 4124

Region IV t 611 Ryan Plaza Drive, Suite 1000  ! -- -

I l Arlington, Texas 76011 l

Reference:

Docket No. 50-285

Dear Mr. Denise:

Notice of Violation j Inspection Report 84-21 The Omaha Public Power District received the Commission's letter dated October 25, 1984 which forwarded two Notices of Violation: Item 285/8421-01,

" Failure to Follow Procedures," and Item 285/8421-02, " Lack of Adequate Pro-cedures." Pursuant to 10 CFR 2.201, please find attached the District's l

i response to these Notices of Violation.

I Sincerely,

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491 R . Andrews 3

Division Manager Nuclear Production RLA/JJF/dao Attachment F

cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, DC 20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, Senior Resident Inspector 45 5124 Employment with Ecuat Opportunity

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Attachment Based on the results of an NRC inspection conducted during the period of August 28-31, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following violations were identified:

1. Failure to Follow Procedures Criterion V of Appendix B to 10 CFR Part 50 requires, in part,

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. . ."

a. The OPPD Quality Assurance Program Manual, paragraph A.13 states, in part, ". . . When inspection and testing equip-ment is found to be out of calibration due to use or damage, or when out of limits at recalibration, all items inspected, tested or measured with that equipment since the latest valid calibration shall be considered as being potentially unacceptable. Resolution of those cases shall be determined on a case by case basis treating them as a nonconformance."

FCS Standing Order No. M-28, paragraph 6.8, states, in part, "Any instruments found to be out-of-calibration, or that ,

require repair, shall have a ' Defective /Rejective Test Equipment Analysis Sheet' completed upon recalibration. . ."

Contrary to the above, two secondary standards (I&C#1 and I&C#28) were found to be out of tolerance at calibration and were not identified on a " Defective / Rejected Test Equipment Analysis Sheet" as required and no investigation made to determine the effect of the out of tolerance condition (285/8421-02a).

b. The OPPD Quality Assurance Program Manual, paragraph A.13 states, in part, " Calibration activities being performed by OPPD personnel are in accordance with Standing Orders."

FCS Standing Order No, M-28, paragraph 5.2, states, in part,

" Minimum schedules for performing calibration and certifica-tion are established in Appendix A. . ."

Contrary to the above, minimum calibration schedules had not been established in Schedule A for oscilloscopes and electri-cal current measuring standards as required (285/8421-02b).

This is a Severity Level IV Violation. (Supplement I)

. Response (1), The corrective steps which have been taken and the results achieved.

a. The disposition of the two secondary standards is as follows: A " Defective / Rejected Test Equipment Analysis Sheet" was properly filled out for I&C#1 and I&C#28.

The appropriate analyses were performed on the equipment that was calibrated using I&C#1 and I&C#28 to determine the effect of the out.of tolerance condition. :The results of these an. lyses indicates that the equipment calibrated with I&C#1 end I&C#28 were within acceptable tolerance, consequently no additional action was taken. By completing the above mentioned forms and performing the necessary analyses it has been verified that the out of tolerance condition is not of safety significance.

b. It has been District policy not to use oscilloscopes for calibrating Station instrument loops.

In the past, they have been used for troubleshooting only and not to make quantitative measurements. However, the District has, in the recent past, developed calibration procedures 4

for oscilloscopes and has decided to include them in l Appendix A. Electrical current measuring standards are

j. included in Appendix A by virture of the fact that cur-rent measuring standards are the same piece of equipment i as voltage measuring standards. Appendix A has been

, changed to clarify the category of test equipment to l read " voltage / current measuring equipment". By making the above mentioned changes or clarification to Appendix A has assured that schedules are established for the calibration of oscilloscopes and electrical current measuring standards.

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(2) Corrective steps which will be taken to avoid further violations.

i a. Tne procedure governing the disposition and resolution of problems in the measuring and test equipment will be re-written to include comprehensive procedures to be followed-when a piece of measuring and test equipment is found to be out of calibration.

b. No further action is required.

(3) The date when full compliance will be achieved.

a. The District will be in full compliance by January 31, 1985.

b. The District is presently in full compliance.

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2. Lack of Adequate Procedures Criterion V of Appendix B to 10 CFR Part 50 requires, in part,

" Activities affecting quality shall be prescribed by documented

' instructions, procedures, or drawings of a type appropriate to the circumstances. . ."

a. The OPPD Quality Assurance Program Manual, paragraph A.13 states, in part, ". . . When inspection and testing equip- '

2 ment is.found to be out of calibration due to use or damage, or when out of limits at recalibration, all items inspected, tested, or measured with that equipment.since the latest valid calibration shall be considered as being potentially

-unacceptable. Resolution of those cases shall be determined on a case by case basis treating them as a nonconformance."

Contrary to the above, FCS procedures did not provide for the identification of equipment and subsequent resolution of possible nonconformances associated with plant process instru-mentation, surveillance test instrumentation,,and pressure gauges when found to be out of tolerance at calibration (285/8421-01a).

b. The OPPD Quality Assurance Program Manual, paragraph A.1 states, in part, "The program is based on . . . the guidance provided in American National Standard, ANSI 45.2 . . . and its' associated daughter standards. . ." i ANSI N45.2.1-1973, paragraph 2.2 states, in part, " Cleaning procedures as well as procedures or work instructions for cleanliness control practices and inspections, examinations or test to verify cleanliness of items shall be prepared. . ."

Contrary to the above, procedures had not been prepared to implement the cleaning requirements for fluid systems and associated components (285/8421-Olb).

This is a Severity Level V Violation. (Supp1 ment I)

Response

(1) The corrective steps which have been taken and the results achieved.

a. The, instrument and control group has implemented a test equipment checkout log that provides for track-ing of test equipment. The addition of~the above mentioned log has provided a mechnanism to ensure that when test equipment is found in an out of tolerance condition the necessary review can be done in a timely manner.

! b. At present, cleanliness of safety related systems is ensured by having Quality Control inspectors perform close-out inspection of systems where practical. The close-out inspection requirement is included either on the maintenance order or in the procedure which governs the maintenance or modification activity.

(2) Corrective steps which will be taken to avoid further violations.

a. The District intends to rewrite the procedure governing the disposition of a piece of test equipment found to be out of calibration. Included in the procedure will be timely noti-fication of appropriate management personnel of a deficiency to ensure prompt corrective action is taken,

b. The standing orders which govern the maintenance or modifi-cation of plant systems will be reviewed and revised as appropriate to formally address the requirements of Quality Assurance Manual Plan 6.3 on Cleanliness Controls.

(3) The date when full compliance will be achieved.

a. The District will be in full compliance by January 31, 1985.

b. The review and revision of standing orders will be completed

by June 30, 1985.

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