IR 05000285/1985022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-285/85-22 & 50-285/85-29.Responses to Violations Under Review

ML20215B662
Person / Time
Site:	Fort Calhoun
Issue date:	06/11/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
References
EA-86-176, NUDOCS 8706170398
Download: ML20215B662 (2)

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f l-In Reply Refer To:

-Docket: 50-285/85-22

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.50-285/85-29 EA.86-176 Omaha Public Power District R. L. Andrews~, Division Manager-

' ATTN:. . Nuclear Production-1623 Harney Street Omaha, Nebraska 68102 Gentlemen:

Thank you for your letter of April 10,-1987, in response to our Notice of -

Violation and Proposed Civil Penalty date'd January 26,.1987. The responses.to the violations are presently under review. We will respond to the' adequacy of-your responses in the near future.

Sincerely

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Or6nd ryned By J. E. Gachda J. E. Gagliardo, Chief Reactor Projects Branch cc:

.W. G. Gates, Manager i Fort Calhoun Station i P. 0. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, D. C. 20036 _

Kansas Radiation Control Program Director Nebraska Radiation Control Program Director i i

bec: (see next page).

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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000 April 10, 1987 -

LIC-87-086 Docket No. 50-285 93 kk_Mp j

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i Mr. James M. Taylor, Director Office of Inspection and Enforcement s -

V. S. Nuclear Regulatory Commission Washington, DC 20555 References: Reference Index Provided on Page 4 of This Cover Letter

Dear Mr. Taylor:

The Omaha Public Power District (OPPD) received the Notice of Violation and .

Proposed Civil Penalty, Reference 6, dated January 26, 1987. The Notice of Violation involved one level III, eight Level IV, and two Level V violations resulting from the findings of the Safety Systems Outage Modifications.

Inspections (SSOMI), References 2 and 3.

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OPPD provided responses to the SSOMI findings by References-4 and 5. An En-forcement Conference was conducted i'n NRC Region IV offices on July 10, 1986; a working meeting was held on August 7, 1986 to discuss the details of the inspection findings and OPPD's responses (Reference 7). These discussions! ' '3 proved to be extremely beneficial and provided a better understanding of the areas of concern identified by the inspection. -

Reference 6 requested that a response be provided'within'30 days. By Reference 8, OPPD requested that an extension of time, until April:10, 1987 be granted for the preparation of responses to the subject enforcement action. The addi-tional time was requested because the subject enforcement action required  !

careful review and analysis of the corrective action program. which had already._..- y been initiated at OPPD. The time was necessary to assure thattroot'caQtEE have ' ..

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been clearly identified and that our corrective actions correlated uith'.thoW causes. By Reference 9, the request for time extension for"cause wa s granted by the NRC.

Pursuant to 10 CFR s2.205, OPPD has elected to answer the Notice ofbioIat' ion in lieu of paying the Civil Penalty. Our response in accordance' with 10 CFR'

@ 2.205 is separately set forth as Attachment No. 6 to this ' letter. Sased on J. - ;

OPPD's appraisal of the conclusions previously made that an unreviewed safety' '

question as determined f rom the performance of 10 CFR 50.59 evaluations',. the results of recent analyses, and an additional safety evaluation that support i these conclusions, OPPD respectfully requests reevaluation of the Severity l Level of the Violation and remission of the Civil Penalty. '

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LIC-87-086 Page 2 i

Pursuant to 10 CFR s2.201, the following information is respectfully submitted i to respond to the Notice of Violation:

Attachment No. 1 Response to Level III Violation l Attachment No. 2 10 CFR s2.201 Responses to Severity Level IV and V j Violations Not Assessed A Civil Penalty Attachment No. 3 Comments / Status of Specific Items Cited by NRC as Examples of the Violations Discussed in Attachment No. 2.

Attachment No. 4 Corrective Action Implementation Plan i Attachment No. 5 Clarifications / Corrections to Information Previously )

Provided by References 4 and 5.

Although OPPD has requested a review of the Severity Level of the Violation now cited as a Level III and remission of the Civil Penalty, OPPD shares the con-cerns of the NRC with regard to the programmatic aspects of the violations that I were documented as a result of the inspections. Although the inspection did not indicate findings of a significant safety concern, these concerns have made i OPPD aware of the need for enhancements in our programs. Following the SS0MI, l OPPD formed a Design Change and Modification Review Committee to review and j evaluate the design change process in use at OPPD. Evaluations were directed -

at improving effectiveness and, where necessary, corrective actions have been taken and/or are planned. q j

Attachment No. 4 contains the Corrective Action Implementation Plan that' has ;

resulted from recommendations contained in the Design Change and Modification i Program Review Committee Report. These action items were previously discussed '

with NRC Region IV at the July 10, 1986 enforcement conference. . Several corrective actions have been implemented and have resulted in' noticeable im-provements. Other corrective actions will require time to fully implement.

These actions have been incorporated into the Corrective Action Implementation

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Pl an . I As a result of your initial findings and the results identified by our Review Committee, OPPD assessed our capabilities to continue to perform modifications at the Fort Calhoun Station. It was determined that the modification process could be continued based on the interim programs that have been established by.

the Design Change and Modification Review Committee. OPPD recognizes that personnel workloads would be impacted by additional requirements that have l resulted from the corrective actions to resolve programmatic concerns. Man-power requirements for groups responsible for design, construction, and testing activities relating to modifications will be reviewed to ensure that adequate engineering support is available to ensure proper quality and timeliness of modification packages. If deemed necessary, additional manpower will be dedi-cated to engineering activities to help ensure adequate support of OPPD's modification program. The level of modification activity will continue to be reviewed until corrective actions which have been identified have been com-

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J pleted. At that time, OPPD vill reassess our capabilities and adjust the design change activity accordingly.

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James M. Taylor- t

.LIC-87-086-Page 3

'0 PPD's Quality Assurance Department was tasked with' conducting a spa: 'al independent review of CQE modifications planned for;our 1987 refueling- outage. ,

.The review was to provide additional assurance that modifications involving !

' safety systems addressed requirements imposed by our corrective actions,. !

adequately addressed the original SS0MI findings, and.did not introduce new (

areas of concern into our modification program. The QA review of the-design j phase of 1987 outage modifications involving CQE equipment has.been completed. l The Quality Assurance Department review will be_ continued through.the-instal-lation and testing phases of-CQE modifications planned for the 1987 refueling.

outage.

Attachment No. 5 provides clarification of information provided _in References 4 and 5. The information contained in the attachments to this letter. supersedes and/or' updates the information provided in References 4 and 5.

Should you have any questions concerning this letter or the attachments thereto, we wi_ll be glad to discuss them with you.

Sincerely R. L. Andrews Division Manager Nuclear Production RLA/me I

J c: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.

Washington, DC 20036 R. D. Martin, NRC Regional Administrator J. E. Gagliardo, Chief, Reactor Projects Branch 5 I

A, C. Thadani, NRC Project Director W. A. Paulson, NRC Project Manager i

P. H. Harrell, NRC Senior Resident Inspector  ;