ML20210R731
| ML20210R731 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/11/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8702170485 | |
| Download: ML20210R731 (2) | |
See also: IR 05000285/1986003
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FEB 111987.
In Reply Refer To:
Docket: 50-285/86-03
Omaha Public Power District
- ATTN:
R. L. Andrews, Division Manager-
Nuclear Production
1623 Harney Street
Onaha, Nebraska 68102
Gentlemen:
Thank you for your letters of May 18, 1986, and January 16, 1987, in
response to our letters dated April 18, 1986, and December 19, 1986. We~have
reviewed your supplemental reply and find it responsive to the concerns raised
in our Notice of Violation, but we continue to believe that Violation A in our
April 18, 1986, letter to you is a violation as cited. We will review the
s
implementation of your corrective actions during a future inspection to
detennine that full compliance has been achieved and will be reaintained.
Sincerely,
or!dmt st;m~t ny
J. E. Gag!brda
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
W. G. Gates, Manager
Fort Calhoun Station
P. O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NW
Washington, DC 20036
Kensas Radiation Control Program Director
Nebraska Radiation Control Program Director
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(see next page)
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Omaha Public Power District
1623 Harney Omaha. Nebraska 68102-2247
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January 16, 1987
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TS-FC-87-22
LIC-87-024
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Document Control Desk
U.S. iiuclear Regulatory Coumisslun
Washington, D.C.
20555
SUBJECT:
Inspection Report 86-03 - Notice of Violation
Reference:
Docket No. 50-285
Gentlemen:
Omaha Public Power District (0 PPD) recently received your letter requesting
additional information addressing the portion of Violation 285/8603-01 con-
cerning valves F0-116, F0-117. F0-Il8 and FO-119. OPPD's response is
attached.
If OPPD can be of further assistance, please do not hesitate to
contact us.
Sinc el
R. L. Andrews
Division Manager
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Nuclear Production
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Attachment
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{U'.S.' Nuclear Regulatory Commission
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Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas
76011
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036
Mr. P. H. Harrell, NRC Senior Resident Inspector
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Attachment to Docket: 50-285/86-03
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OPPD's response to the NRC's requests for additional information regarding
Inspection Report 50-285/86-03, dated December 19, 1986, are as follows:
a.
NRC Request
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Do records exist that indicate F0-118 was pro-
vided as a Stockham valve by the diesel genera-
tor supplier?
OPPD Response
No.
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b.
NRC Request
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Do records exist that indicate F0-116, F0-117
and F0-119 were provided as Crane valves by the
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diesel generator supplier?
OPPD Response
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No.
c.
NRC Request
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If the answer to a. and/or b. above is No, do
you have records to show that the valves were
properly receipt inspected and installed in
accordance with approved design changes?
OPPD Response
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No.
d.
NRC Request
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If the answer to c. above is No, have you per-
formed an engineering evaluation to verify that
the valves installed in this safety-related sys-
tem can perform their intended safety function?
OPPD Response
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Yes; OPPD has performed an engineering evalua-
tion which concludes that valves F0-116, F0-117,
F0-118 and F0-119 will perform their intended
safety function.
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Omaha Public Power District
1623 Harney Omaha. Nebraska 68102 2247
402 536 4000
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May 18, 1986
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LIC-86-236
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Mr. J. E. Gagliardo, Chief
Reactor Projects Branch
U. S. Nuclear Regulatory Commission
RWion IV
6119yan Plaza Drive, Suite 1000
h W;fon, Texas 76011
Refe w m :
1.
Docket No. 50-285
2.
Inspection Report 50-285/86-03 dated April 18, 1986.
Dear Mr. Gac<iardo:
Inspection Report 86-03
Omaha Public Power District (OPPD) recently received Reference 2 containing a
notice of violation for the failure to check nonfunctional fire barriers hourly
and for the modification of systems without use of an approved procedure.
OPPD's responses to these violations are attached to this letter.
If you have
any questions concerning any of these responses, please do not hesitate to
contact us.
Sincerely
N
R. L. Andrews
Division Manager
,
Nuclear Production
RLA/me
Attachment
cc: LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Ave., N.W.
Washington, DC 20036
Mr. D. E. Sells, NRC Project Manager
Mr. P. H. Harrell, NRC Senior Resident Inspector
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ATTACHMENT
"During an NRC inspection conducted during the period February 1-28, 1986,
violations of the NRC requirements were identified. The violations involved
the failure to check nonfunctional fire barriers hourly and the modification of
systems without use of an approved procedure.
In accordance with the ' General
Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CFR Part 2,
Appendix C (1985), the violations are listed below:
A.
Criterion V of Appendix B to 10 CFR Part 50 requires that activities affect-
ing quality shall be prescribed by documented instructions, procedures, or
drawings, of a type appropriate to the circumstances and shall be accom-
plished in accordance with these instructions, procedures or drawings.
Section 5.1, ' Control of Plant Design and Modifications,' of the OPPD Qual-
ity Assurance (QA) Manual and Standing Order G-21, ' Station Modification
Control,' have been established to implement requirements of Appendix B and
require that modification of equipment be performed in accordance with
written procedures.
Contrary to the above, the licensee performed a modification to the fuel
oil system for the emergency diesel generator without the use of a written
and approved procedure.
This is a Severity Level IV violation (Supplement I.0) (285/8603-01)
B.
Technical Specification 2.19(7) states, in part, ' All penetration fire bar-
riers protecting safety-related areas shall be functional (intact). With a
penetration fire barrier nonfunctional, within one hour . . . establish an
hourly fire watch patrol.'
Contrary to the above, the hourly fire watch patrol had net been properly
established in that on February 11, 1986, the security gur i tour (hourly
fire watch patrol) had not accomplished and documented t:m hourly tours
of certain portions of the auxiliary building to check two nonfunctional
fire barriers, a fire door and a ventilation port.
This is a Severity Level IV violation (Supplement I.E) (285/8603-02).
Pursuant to the provisions of 10 CFR Part 2.201, Omaha Public Power District is
hereby required to submit to this Office within 30 days of the date of the
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letter transmitting this Notice, a written statement or explanation in reply,
including for each violation:
(1) the reason for the violation if admitted,
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(2) the corrective steps which have been taken and the results achieved, (3)
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the corrective steps which will be taken to avoid further violations, and (4)
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the date when full compliance will be achieved. Where good cause is shown,
consideration will be given to extending the response time."
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OPPG RESPONSE TO A.
(1) Reason for the Violation If Admitted
The alleged violation involved valve F0-118 which is located on the fuel
oil system of emergency diesel generator #2. The discussion of the viola-
tion in Appendix A, page 4, of the NRC inspection report letter indicates
that, "During a walkdown performed in December 1985, the NRC inspector no-
ted that a valve had been added to the fuel oil system for the emergency
diesel generator." When the NRC inspector discussed this with the Plant
Engineer, he (the inspector) noted that a " shiny" valve was installed at
FO-ll8 but the other 1/4" valves on the system (sampling, instrument
isolation, etc.,) were not as shiny. The shiny valve is a Stockham valve;
the others are Crane valves.
The plant personnel who have been interviewed recall that the fuel oil
system was supplied with a valve in this location, and a valve had always
F en there. No evidence was obtained supporting changet.ut of this valve.
Bt<ed on this information, OPPD takes exception to the wording, ". . . a
valve had been added . . . " because it is inaccurate.
Inspection of
drawing revisions to the system flow diagram show that the drawing was
incorrectly changed for a period of time to indicate that the valve was
not installed.
With reference to the NRC inspector's concern that the valve was a differ-
ent make, a documentation search was performed but no records were found
which provided an approved procedure for installation of the Stockham
valve. However, the original documents provided by the emergency diesel
generator supplier which have been reviewed do not prove that the Stockham
valve was not an original installation.
OPPD does not believe that a violation has occurred based on the above
information.
(2) Corrective Steps Taken and Results Achieved
OPPD does not believe a violation occurred.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
OPPD does not believe a violation occurred.
(4) Date When Full Compliance Will Be Achieved
OPPD is presently in full compliance.
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RESPONSE TO B.
(1) Reason for the Violation If Admitted
The violation occurred because of personnel error on the part of members
of the Security Force.
Several of the guards did not understand the im-
portance of checking all fire barriers on the hourly fire watch patrol
list. These guards' fire watch patrol had been interrupted by security
alarms, and they had not resumed the patrol after responding to the se-
curity alarms.
(2) Corrective Steps Taken and Results Achieved
All members of the Security Force have been instructed on the necessity
for checking all fire barriers on the hourly fire watch patrol list. The
Officer-In-Charge of each security shift has been made responsible for
verifying that each barrier has been checked and that guards have properly
logged in on the appropriate Radiation Work Permit when checking fire
barriers in the radiation controlled portion of the auxiliary building.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
The steps described in (2) above are believed to be adequate to prevent
further violations.
(4) Date When Full Compliance Will Be Achieved
OPPD is presently in full compliance.
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