ML20112J479

Responds to NRC Re Violations Noted in Insp Rept 50-285/84-29.Corrective Actions:Responses to 20 Overdue Deficiency/Quality Repts Submitted to QA Dept & Containment Spray to Safety Injection Valve Padlocked Closed

ML20112J479
Person / Time
Site:	Fort Calhoun
Issue date:	02/27/1985
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20112J478	List: ML20112J479
References
LIC-85-076, LIC-85-76, NUDOCS 8504050158
Download: ML20112J479 (5)

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',.g-l Omaha Pubilc Power District 1623 Harney Omaha. Nebraska 68102 402/536 4000 February 27, 1985 LIC-85-076 Mr. Robert D. Martin i 3@M 0VM %  !

Regional Administrator ,7 U. S. Nuclear Regulatory Commission Region IV i N~lE 611 Ryan Plaza Drive, Suite 1000 -

I Arlington, TX 76011

Reference:

Docket No. 50-285

Dear Mr. Martin:

IE Inspection Report 84-29 Notice of Violation The Omaha Public Power District received IE Inspection Report 84-29 dated January 28, 1985. This report identified two (2) violations, 285/8429-01,

" Failure to Take Prompt Corrective Action," and 285/8429-02, " Failure to l Follow Procedures." Pursuant to 10 CFR 2.201, please find attached the l District's response to these violations. '

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Sincepelf, b ld Y R. L. Andrews Division Manager Nuclear Production RLA/DJM/dao l Attachment 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 i

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4s wa Employmen h ual opportunity

ATTACHMENT Based on the results of an NRC inspection conducted during the period of December 1-31, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2. Appendix C), 49 FR 8583, dated March 8,1984, the follow-ing violations were identified:

1. Failure to Take' Prompt Corrective Action 10 CFR 50, Appendix B, Criteria XVI, " Corrective Action," requires that,

" measures ... be established to assure that conditlons adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified-and corrected."

Quality Assurance Procedure (QAP) No. 17, " Audit Planning, Performance, ,

and Reporting," (effective in April 1981) and Quality Assurance Department Procedure (QADP) No. 17, " Control of Deficiencies and Corrective Action,"

Section 3.2.4, required that the addressee's response to Quality Reports and Deficiency Reports "be completed and forwarded to the originator within 30. days of report issuance."

NRC Inspection Report 50-285/81-07 cited the licensee for-failure to pro-vide a response to Deficiency Report FCI-80-A-0044 within the required 30, days. In response to this violation, the licensee committed to " develop-ing a procedure to provide for consolidating the listing and for tracking

... the status of major . outstanding items," and to include QA Deficiency Reports "as a tracked item." 0 PPD stated that the District would be "in full compliance by August 1, 1981."

NRC Inspection Report 285/83-08 issued a deviation for " failure of the ,

licensee to meet the August 1981, commitment to correct the late report-ing problem."- In their response of June 3,1983, the licensee indicated that the Deficiency / Quality Report Status Report was " inadequate for track- "

ing 'the initial 30-day response," and stated that "each division involved in +he report process has established an _ internal short term tickle system." 0 PPD stated that the District would "be in full compliance with _

the 30-day initial response requirements for deficiency and quality reports by July'1, 1983."

Contrary to the above, on December 18, 1984', the NRC' inspector determined that 20 out of 44 active deficiency / quality. reports exceeded the 30-day _

response requirement and were classified as overdue by the licensee's' tracking system. 1 This is a Severity Level IV Violation. -(SupplementI.D.3)-(285/8429-01) 9

DISTRICT'S RESPONSE (1) The corrective steps which have been taken and the results achieved.

Responses to the 20 overdue deficiency / quality reports have been sub-mitted to the Quality Assurance Department. The QA Department has accepted the initial response and planned actions for the 20 overdue deficiency / quality reports.

The District has reviewed the process and procedures utilized in an attempt to streamline the process. This review resulted in changes detailed below.

The District's Quality Assurance Plan (QAP), Section 10.4, establishes requirements and controls for the tracking, trending and control of conditions adverse to quality and associated corrective actions. Pro-cedures have been developed to implement the requirements and controls of Section 10.4 of the QAP.

The Quality Assurance Department issues a monthly report providing a status of deficiency and quality reports. These status reports are dis-tributed to.those Managers and Supervisors having primary responsibility 1 for the affected areas. As was identified previausly, this system was not always effective for tracking the initial 30-day response.

To provide additional assurance that timely corrective action is initia-ted, additional direct management involvement is deemed necessary and appropriate. Prior to the issuance of the status report referenced above, the Division Manager-Nuclear Production and Division Manager having pri-mary responsiblity for the affected area is advised of any items which have the potential for exceeding the 30-day response requirement.

Since the implementation of the above-mentioned practice initial responses to deficiency / quality reports have been provided within the required 30-day time frame. It is believed that this increase in management involve-ment will aid in the timely resolution of conditions adverse to quality at the Fort Calhoun Station including providing timely initial responses to Quality Reports and Deficiency Reports.

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

The additional management involvement described in item (1) will be forma-lized by appropriate procedure changes by March 29, 1985.

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

The District is currently in . full compliance.

2. Failure to Follow Procedures Technical Specification 5.8.1 requires that " written procedures ... be established, implemented, and maintained that meet or exceed the mini-mum requirements of Sections 5.1 and 5.3 of ANSI 18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 . .. ."

Standing Order G-7 establishes the Operating Manual and states in Section 1.3 that " adherence to the Operating Manual is mandatory."

Valve Checklist 01-CS-1-CL-A to Operating Instruction AI-CS_1, "Contain-ment Spray-Normal Operation," requires that Valve SI-342 be locked closed during nornal operation.

Contrary to the above, on December 4,1984, the NRC inspector found SI-342 closed, but unlocked.

1 This is a Severity Level IV Violation. (SupplementI.D.3) (285/8429-02)

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

The containment spray to SI Check Valve Leakage Header Valve SI 342 has been chained and padlocked shut to prevent unauthorized operation of the valve.

Although unlocked, the valve was found in the closed position by the NRC inspector. - Had the valve been open or opened during the time it was unlocked, the Operating crew would have been alerted by one of the following conditions.

(a) Abnornal increase in spent regenerant tank level indication which is recorded every two hours.by the Auxiliary Building Operator and also alarmed when the inservice tank reaches the high alarm point.

(b) Reduced Pressure indication on PI-325 (low pressure safety injection header pressure indicator on control panel AI-30A) located in the Control Room.

(c) Abnormal decrease of the safety injection tanks pressure and Llevel indication which is alarmed and monitored by the Control

• Room operators.

(2) The corrective steps which will be taken to avoid further violations. '

The' failure to lock valve SI-342 was basically a procedural deficiency.

The outage that the plant was-recovering from at the time this viola-tion was discovered was a short (2 week) outage to repair pressurizer

. spray valve gaskets. Very little other maintenance took place during

-the outage. As a result, it was felt that abnormal valve lineups would

- be returned to normal by (1) the procedures that initiated the abnormal lineups, and (2) by the equipment tagging (tagout) system. Therefore, the containment spray valve lineup was exempted from being performed because that system is returned to normal by the " Termination of Shut-down Cooling" procedure. Similarly, checklist 0I-RC-28-CL-D, " Reactor

Startup Locked Valves" was deleted from Step IV.B. Note 2 of Operating Instruction 01-RC-28 since any out-of-position locked valves should have been caught within the. body of the procedures. (Note that the pro-cedure change that deleted checklist OI-RC-28-CL-D was a one-time-only change due to the circumstances of the subject outage.) Obviously.-

returning SI-342 to its normally locked closed status following its use per 01-RC-4 was not adequately covered within the appropriate procedures.

In order to ensure that SI-342 is returned to its proper locked closed position following future plant outages, the appropriate procedure (s) will be updated to provide definite direction regarding its operation.

.This procedure update will be completed by March 31, 1985.

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

In as much as valve SI-342 is currently locked closed, the District is currently in full compliance.

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