ML20147F498
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: |
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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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.
-
Sincerely,
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R. L. Andrews
Division Manager ~97cm300244 tT70W4 ,$ 7r----
Nuclear Production f ^*3CH'#UTbl
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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-
! 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
-
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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- Attn: Cact: ant Control Dask
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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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R. L. Andrews
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.
..
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' . .
,
.. ., ,
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.
-
._
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,
' " *
- 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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