IR 05000285/1988022
| ML20207L826 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/12/1988 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20207L829 | List: |
| References | |
| EA-88-201, NUDOCS 8810170483 | |
| Download: ML20207L826 (3) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION 3/
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REGION IV
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ARLINGTON, TEXAS 70011 f
$11 RYAN PLAZA DRIVE, SUITE 1000
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Docket No.
50-285 License No. DRP-40 EA 88-201 Omaha Public Power District ATTN:
K. J. Morris, Division Manager Nuclear Operations 1623 Harney Street Omaha, Nebraska 68102
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Gentlemen:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 5085/88-22)
This refers to the inspection conducted June 29 through July 18, 1988, at the
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Fort Calhoun Station, Fort Calhoun, Nebrasks, and to the violations of NRC requirements discussed with you and other OPPD personnel at an August 11
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enforcement conference in NRC Region IV's offices in Arlington, Texas. The results of the inspection were provided to you in a report dated July 29, 1988.
The violations in the enclosed Notice of Violation (Notice) are both related to OPPD's discovery on June 28 that an error had been made in calculating the
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setpoint for'the Thermal Margin / Low Pressure reactor trip function of the Reactor Protection System. According to your initial calculations, this error resulted in a trip setpoint approximately 79 pounds per square inch atmospheric (psia) lower than it should have been during Fort Calhoun Cycle 11 operations which began June 7, 1987 Violation A in the Notice involves your failure to implement design control measures adequate to prevent this potentially significant error from being made. Violation B involves one example of your having provided NRC inaccurate information in a July 1, 1988, letter in which you described your actions in response to the discovery of this calculational error.
Although four channels of the Reactor Protection System's Thermal Margin / Low Pressure (TM/LP) trip function were rendered inoperable, the actual safety significance is low in that the error was not large and that ample safety margins were present in the other factors included in the calculation to more than compensate for any reduction in safety margins caused by the error. We CERTIFIED Mall RETURN RECEIPT REQUESTED 8810170403 esto12 7 -==y
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Omaha Public Power District-2-
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commend you for both your immediate actions to address the potential safety problem and for the corrective actions you described at the enforcement conference, which involvea improving training in *.he computerizdd calculational methods and e1suring that the individuals performing the calculations are experienced.
Nonetheless, NRC is concerned about the breakdown in your design control process that led to this error.
In particular, we are concerned about OPPD having used an inexperienced individual without adquate training to perfom a
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safety-related activity as important as the calculation of the TM/LP reactor
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trip setpoint, which is designed to prevent reactor operation when the Departure from Nucleate Boiling Ratio (DNLR) is less than 1.18. Moreover, the
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person performing the oversight review was equally inexperienced. We would have expected that OPPD would have taken the necessary steps to ensure proper application of the newly acquired computer program such as using the vendor to provide an oversight review function for the computar program's first application.
OPPD should ensure that its long-term corrective actions are effective in addressing the root causes of this violution, which NRC views as an indication of a significant weakness in your management control process.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), Violation A described in the enclosed Notice has been classified at a Severity Level 111. Normally, a civil pen 61ty is proposed for a Severity Level III violation. However, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, I have decided that a civil penalty will not be proposed in this case because OPPD identified this problem and reported it promptly to NRC, took immediate action to address the safety implications' and developed long-term actions to minimize the possibility of such a calculational error t'eing made in the future. Violation B in the Notice has been classified at a Severity Level IV. As discussed at the enforcement conference, NRC places a great deal of importance on the accuracy of information provided by licensees.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
in your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory require %ents.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Pa-t 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
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ObahaPublicPowerDistrict-3-
The responses directed by this letter and the.2nclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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Robert D.(Martin
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Regional Administrator Enclosure:
Nebraska Radiation Control Program Director
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