ML20205G270
| ML20205G270 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/02/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20205G225 | List: |
| References | |
| LIC-87-120, NUDOCS 8703310416 | |
| Download: ML20205G270 (4) | |
Text
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Omaha Public Power District
- T.-: -T 1623 Harney Omaha Nebraska 68102 402/536 4000 March 2, 1987 gI1 LIC-87-120 J. E. Gagliardo Reactor Projects Branch U.S. Nuclear Regulatory Cor,unission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 RE:
- 1) Docket 50-285
- 2) Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated January 29, 1987 Gentlemen:
Subject:
Inspection Report 86-34 The subject inspection report dated January 29, 1987, identified two violations concerning valve alignments of the waste gas sampling system and security doors not being installed in accordance with in-structions.
Please find attached the Omaha Public Power District's reponse to these violations.
Sincerely,
'f b
/Vdens R. L. Andrews Division Manager Nuclear Production RLA/sa Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 Mr. R. D. Martin, Regional Administrator Mr. D. E. Sells, NRC Project Manager Mr. P.11. flarrell, NRC Senior Resident Inspector 1
0703310416 070302 i
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,s Attachment During an NRC inspection conducted December 1-31, 1986, two violations of NRC requirements were identified. One violation involved the incorrect valve line ups of the waste gas sampling system, and the second violation involved fire barrier / security doors not being installed in accordance with documented instructions.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions",10 CFR Part 2, Appendix C (1986), the vi11ations are listed below:
Violation A.
Incorrect Valve Line ups of the waste gas sampling system Technical Specification 5.8.1 requires that procedures, as listed in Appendix A to Regulatory Guide 1.33, be established and implemented.
Section 7.C of Appendix A to Regulatory Guide.1.33 includes procedures related to sampling and monitoring of the gaseous effluent system.
Procedure 01-WDG-3 has been established in accordance with this Technical Specification requirement and requires that the waste gas sampling system will be placed in a standby mode upon completion of sampling.
Contrary to the above, the waste gas sampling system was found, on three occasions on December 4, 29, and 31, 1986, during this inspection period, not to have been placed in the specified standby mode after completion of sampling. This is a Security Level IV violation (Supplement I.D.)
(285/8634-03).
OPPD's Response 1.
Reason for the violation, if admitted The cause of the violation was inadequate procedural guidance. The applicable procedures were confusing and unclear with respect to operator required actions.
2.
Corrective steps which have been taken and the results achi[ved CMP-2.2"WasteGasSamplingbyitem,",and01-WDG-3"WasteGasSampling System (Al-110) Operation" were revised ainuary 7,1987 to correct the problems noted above. Changes incluled the designation of specific valves to be operated and inclusion of all required valve manipulations in the body of the procedures.
The revised procedures have been used successfully for both grab sampling and on-line analysis.
3.
Corrective steps which will be taken to avoid future violations OPPD believes the actions described in #2 above will assure future compliance.
4.
Date when full compliance will be achieved OPPD is currently in compliance.
. ".1 Violation B.
Fire barrier / security doors not installed in accordance with documented instructions Criterion V of Appendix B to 10 CFR Part 50 and Section A.6 of the licensee's quality assurance plan require that activities affecting quality be described in documented instructions, installed in accord-ance with the instructions, and appropriate quantitative acceptance criteria be provided.
Installation package MR-FC-85-38 A/B was established in accordance with the requirements specifying that the installation requirements for the fire barrier / security doors (1025-4, 1011-28, and 1036-2) be installed in accordence with the Underwriter Laboratory (UL) standards.
Contrary to the above, fire barrier / security doors were not installed in accordance with documented instructions and the instructions did not provide appropriate quantitative acceptance criteria as related to the UL standards, in that:
1.
Work proceeded past the specified QC hold points during installation of doors 1036-2 and 1011-28.
2.
The installation packages for doors 1025-4, 1036-2, and 1011-28 were signed off as " work complete," when in fact steps were not complete.
3.
The installation package step for painting door 1025-4 was signed off as " work complete," however, door 1025-4 was not painted.
4.
The gap at the bottom of door 1025-4 was excessive.
5.
Six holes were left unplugged in door 1036-2, which exposed the door core.
This is a Security Level IV violation.
(SupplementI.D.)(285/8634-02)
OPPD's Response Reason for the violation, if admitted This violation occurred because the personnel involved did not adequately verify completion prior to signing the installation steps in question.
Corrective steps which have been taken and the results achieved Two Operations Incidents (01's), identifying administrative deficiencies, were written as a result of this violation. The personnel involved from both Engineering and Central Maintenance have received appropriate re-instruction.
, ".'i,
e Corrective maintenance for the doors identified in the inspection re-port was initiated under M.0. #864475 (door 1025-4) and M.0. #870028 i
(door 1036-2). Corrective maintenance on door 1025-4 has been completed per the criteria provided in MP-Firedoor-1.
Corrective maintenance on door 1036-2 will be completed by April 1, 1987. A continuous fire watch is being maintained by the personnel on duty within the control room complex.
Corrective steps which will be taken to avoid future violations A memo has been issued to Generating Station Engineering personnel and will be emphasized to assure that planners are cognizant of their responsibilities when signing procedural steps in the future.
In addition, Civil Engineering personnel will be instructed in the fire door inspection criteria in MP-Firedoor-1. Central maintenance training in administrative procedures has re-emphasized the requirements for procedural signoff.'
Date when full compliance will be achieved Corrective maintenance will be performed on door 1036-2 by April 1,1987.
Civil Department training will be completed by April 1, 1987, and Central Maintenance training continues to emphasize the requirements for procedural signoff.