ML20212C287
| ML20212C287 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/18/1986 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20212C269 | List: |
| References | |
| LIC-86-236, NUDOCS 8612290440 | |
| Download: ML20212C287 (4) | |
Text
l 6-Omaha Public Power District 1623 Harney Omaha, Nebraska 68102-2247 402:536 4000 gg May 18, 1986 LIC-86-236 O27E
.L_
1 Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. fluclear Regulatory Commission Rcgion IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
References:
1.
Docket flo. 50-285 2.
Inspection Report 50-285/86-03 dated April 18, 1986.
Dear Mr. Gagliardo:
Inspection Report 86-03 flotice of Violation Omaha Public Power District (0 PPD) 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 WW R. L. Andrews Division Manager Nuclear Production RLA/me Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 flew Hampshire Ave., fl.W.
Washington, DC 20036 Mr. D. E. Sells, flRC Project Manager Mr. P. H. Harrell, NRC Senior Resident Inspector 8612290440 861219 PDR ADOCK 05000285 O
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iM 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.D) (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 not been properly established in that on February 11, 1986, the security guard tour (hourly fire watch patrol) had not accomplished and documented three 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 letter transmitting this Notice, a written statement or explanation in reply, including for each violation.
(1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, 1
consideration will be given to extending the response time."
1
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~ OPPD PESPONSE 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 F0-118 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 been there. No evidence was obtained supporting changeout of this valve.
Based 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 responsibin 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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