IR 05000285/1990014
| ML20044A043 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/21/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gates W OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9006270337 | |
| Download: ML20044A043 (2) | |
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i '!! In Reply. Refer To:
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' Docket: 50-285/90-14.
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- 0maha Public Power District-
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ATTN:. W. G. Gates, Division Manager
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Nuclear Operations 444 South 16th Street Mall Mail Stop BE/EF4 Omaha, Nebraska 68102-2247
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Gentlemen:
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Thank you for your letter of May 29, 1990, in response to our letter and
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. Notice of Violation dated April 27, 1990. We have reviewed your reply and find 3-
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it respoM :n to the concerns raised in our Notice of Violation. We will
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review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be mainiained, j;
Sincere.ly,
@inalsynod By:
Samuel J. Couins i
Samuel J. Collins, Director-Division of Reactor Projects
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LeBoeuf, Lamb, Leiby & MacRae
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ATTN: Harry H.: Voigt, Esq.
1333 New Hampshire Avenue, NW Washington, D.C.
-20036
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Washington County Board
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ATTN: LJack Jensen, Chairman Blair, Nebraska 68008
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. Combustion Engineering, Inc.
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- ATTN: Charles.B. Brinkman, Manager
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-ATTH:1. Harold Borchert, Director
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P.O. Box 95007:.
Lincoln, Nebraska 68509 l
Fort Calhoun Statione
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ATTN: 'G. R.LPeterson, Manager
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P.O.' Box 399-
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~ Fort Calhoun, Nebraska = 68023:
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. U.S. Nuclear Regulatory Comission
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' ATTN:
Resident Inspector-
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P.O. Box 309;
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U.S. ' Nuclear Regulatory Comission
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ATTH: Regional Administrator,-Region IV
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May~29, 1990'
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LIC-90-0409
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.U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
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L Mail Station PI-137
Washington, DC 20555 L
L REFERENCES:
1.
Docket No. 50 285 2.
Letter from NRC.(S. J. Collins) to OPPD (W. G Gates) dated April 27, 1990 Gentlemen:
i SUBJECT:
Response to Notice of Violation - Inspection Report 50-285/90-14
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' Omaha Public Power District (OPPD) received the subject inspection -report which'
-identified one violation. The violation involved the failure to establish adequate abnormal operating procedures (A0Ps).
Please find attached OPPD's response to the'Netice of Violation in accordance with 10 CFR Part 2.201.
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If you should1have any questions, please contact me.
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Sincerely,
- W Jf. /M W.
G'. Gates Division Manager Nuclear Operations WGG/sl Attachment c:
LeBoeuf, Lamb. Leiby & MacRae
. A. Bournia,lNRC Project Manager R. D.LMartine NRC Regional Administrator, Region IV-P.'H. Harrell, NRC Senior Resident Inspector tJss / wm i V-G f~
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ATTACHMENT
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p RESPONSE TO A NOTICE OF VIOLATION
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- During an NRC inspection conducted on March 12 16, 1990, a violation of NRC requirements was identified.
The violation involved the failure to establish
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adequate abnormal operating procedures, in accordance with the " General L
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, b
Appendix C-(1989) (Enforcement Policy), the violation is listed below:
Inadeouate Abnormal Ooeratina Procedures
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_ Technical Specification 5.8.1 requires that, " Written procedures... shall
be established, implemented,... that meet or exceed the minimum J.A requirements of sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of f
USNRC Regulatory Guide 1.33...."
Regulatory Guide 1.33, Appendix A, Section 6, requires procedures for combating emergencies and other significant events.
This includes the
following:
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Expected transients
Loss of electrical power (and/or degraded power sources)
Fort Calhoun Station Updated Safety Analysis Report, Section 12.3.2, states, " Plant operation during abnormal conditions are conducted in
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accordance with written... procedures.
These emergency procedures have been written such that the operator can readily perform the immediate action necessary based on a given set of conditions..."
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Contrary to:the above, the following are examples of procedures that were not adequately established, t
1.
Abnomal Operating Procedure A0P-16, " Loss of Instrument Bus Power,"
Revision' 0 (January 4,1990),' did not address the loss 'of_ vital equipment-powered from the four 120V AC inverter buses, such as radiation monitoring panels and_ steam generating level controls. The procedure did not provide guidance for operations during the potential:
'l off-normal conditions associated with the loss, or degradation of a
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120V AC inverter bus.
2.
Written procedures had not been established addressing the loss or degradation of the following vital electrical power sources:
4160V AC Vital bus IA3 or lA4
48G1' AC Vital Buses 183A,1838, IB3C, IB4A,1848,184C, 3A-4A, 38-48,
3C-4C 125V DC Vital Bus DC-1 (EE-8F), AI-41A; or DC-2 (EE-8G), AI-418-
This is a Severity Level IV Violation. (Supplement I)
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OPPD Response:
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The Reason For The Violation. If Admitted
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OPPD admits to the violation as stated.
Prior to Inspection 90 14, it was 0 PPD's opinion that the existing combination of E0Ps. A0Ps and Alarm Response Procedure (0P 10) were adequate to respond to a loss of an individual electrical bus.
OPPD had initiated action to respond to inspection follow-up. Item (285/8936 03) concentrating on upgrading Alarm Response Procedures (ARPs) to enhance OPPD's ability to respond to loss of
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electrical buses.
However, no upgrade work associated with a loss of an
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electrical bus had been ondertaken at the time of Inspection 9014 on the ARPs.
The AOPs were being upgraded as part of SEP-49, but the A0P upgrade was limited to reformatting and assuring technical accuracy of the existing AOPs.
This upgrade did not ex)and the scope of the A0Ps which would have
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been necessary to respond to t11s concern.
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The Corrective Steos Which Have Been Taken And The Results Achieved r
OPPD has: initiated an upgrade to A0P-16 " Loss of Instrument Bus Power" to address the concerns identified in Inspector Follow-up Item (285/8936 03).
t to provide guidance on operator response.to loss of vital equipment or
.i other equipment which would cause the plant to undergo a significant transient..
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Corrective Actions That Will Be Taken To Avoid Further Violations To avoid further violations involving the availability of written procedures for combatting emergencies and other significant events, OPPD is
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taking the following actions:
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a.
As discussed in item 2, OPPD is currently in the process of upgrading I
A0P-16, " Loss of Instrument Bus Power".
This upgrade will encompass losses of any'of the following instrument buses:
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1)
'The four vital 120V AC instrument buses (instrument buses A, B, C, and D)
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The two non-vital 120V AC instrument buses (instrument buses 1
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and 2)
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The two vital 125V DC instrument buses (DC buses DC 1 and DC-2)
OPPD expects the upgrade of A0P-16 to be completed by October 1,1990.
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b.
OPPD plans to develop a new Abnormal Operating Procedure to direct-operator actions under the following circumstances:
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A Loss of Offsite Power or Station Blackout while the unit is-shut down.
2)
Loss of any single vital 4160V AC power bus, vital 480V AC power
bus, or vital 480V AC Motor Control Center.
OPPD expects the development of this new procedure to be completed by March 1, 1991.
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Date When Full Compliance Will Be Achieved
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'With the implement' tion of the changes to A0P 16, and with the development i
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of the new AGP on loss of AC power buses, OPPD expects to.be in. full
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compliance with the requirements of Technical Specification 5.8.1 as they j
relate to abnormal operating procedures, by March 1, 1991.
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