IR 05000285/1996017

Discusses Insp Rept 50-285/96-17 on 970129 & Forwards Notice of Violation

ML20135B377
Person / Time
Site:	Fort Calhoun
Issue date:	02/26/1997
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20135B380	List: IR 05000285/1996017 ML20135B391
References
EA-96-489, NUDOCS 9703030027
Download: ML20135B377 (4)

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\ NUCLEAR REGULATORY COMMISSION

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9*** [8 611 RYAN PLAZA DRIVE. sulTE 400 AR LINGToN, TE XAS 76011 8064 February 26, 1997 l

EA 96-489 I l

S. K. Gambhir, Division Manager  !

Production Engineering Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 399 Hwy. 75 - North of Fort Calhoun I Fort Calhoun, Nebraska 68023-0399  !

SUBJECT: NOTICE OF VIOLATION (NRC SPECIAL INSPECTION REPORT 50-285/96-17)

Dear Mr. Gambhir:

This refers to the predecisional enforcement conference conducted in the Region IV office on January 29,1997. The conf arence was conducted to review the circumstances surrounding apparent violations described in the subject report, which was issued on December 29,1996. The inspection reviewed the apparent inoperability of the Post-Accident Sampling System (PASS) from February 1996 to July 1996. The results of that inspection were discussed with you and your staff on December 20,1996.

Based on the information developed during the inspection and the information that you provided during the conference, the NRC has determined that two violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. Both violations relate to the containment atmospheric portion of the PASS. The first violation involves a failure to follow procedures in two examples: (1) af ter the in-line isotopic analyzer had been disabled in August 1995, plant oersonnel failed to revise or cancel a preventive maintenance order which required drawing a containment atmospheric sample utilizing the analyzer; and (2) a preventive maintenance order (to perform containment atmosphere sampling) was administratively closed without the plant manager's approval. The second violation involves a f ailure to follow procedures when configuration changes to the PASS were made prior to completion and issuance of an Engineering Change Notice. This violation is of concern because an Engineering Department manager gave verbal authorization to remove the in-line isotopic analyzer prior to completion of the Engineering Change Notice, in violation of configuration control procedures.

Your cause determination indicated that the violations resulted from inappropriate responses to material deficiencies on the PASS (inappropriate use of Chemistry Reject Tag, lack of timely leak evaluation, lack of timely maintenance, . . .), problems with the /

configuration control process (lack of depth in evaluation and review by engineering, and [

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less than timely completion of the Engineering Change Notice), and inconsistencies in the j

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administrative requirements for closecut of preventive maintenance.

At the time of the inspectior,, we were concerned that the violations caused the containment atmospheric portion of the PASS to be inoperable for 4 months. However, after the inspection, your staft conducted extensive analyses and determined that the system had been operable. Given tiieir safety significance, the violations have been classified at Severity Level IV.

Nevertheless, these violations raise concerns about the implementation of the Fort Calhoun l Station (FCS) configuration control program and about the proper adherence of FCS personnel to administrative procedures. Proper implementation of the configuration centrol j l program is essential to ensure that plant physical and functional characteristics are i consistent with and are being maintained in accordance with their licensing and design j bases. The instances cited and other instances discussed as contributing causes during '

the predecisional enforcement conference indicate weakness in implementing administrative procedures. If left uncorrected, this type of weakness can lead to a degradation in the overall performance at FCS. In addition, there are indications of a lack of thoroughness in operability evaluations regarding the PASS from January 1996 through system restoration in July 1996. Proper evaluation of degraded conditions identified in '

important systems, even though they do not have Technical Specification limiting conditions for operation, is important to ensure that the systems can function in accordance with their licensing and design bases.

You are required to respond to this letter and should follow the instructions specified in the I enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with '

regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.

Sincerely

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W J. E. yer Acting Regional Administrator Docket No. 50-285 License No. DPR-40 Enclosure: Notice of Violation cc w/ enclosure: (see next page)

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cc w/ enclosure:

James W. Tills, Manager i Nuclear Licensing

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Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 James W. Chase, Manager Fort Calhoun Station P.O. Box 399 Fort Calhoun, Nebraska 68023 Perry D. Robinson, Esq.

Winston & Strawn 1400 L. Street, N.W.

Washington, D.C. 20005-3502 Chairman

. Washington County Board of Supervisors Blair, Nebraska 68008 Cheryl Rogers, LLRW Program Manager Environmental Protection Section -

Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 J

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