IR 05000285/1997006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/97-06 on 970414-28 & 0502

ML20198F384
Person / Time
Site:	Fort Calhoun
Issue date:	08/08/1997
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
References
50-285-97-06, 50-285-97-6, NUDOCS 9708130027
Download: ML20198F384 (4)

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.....c' AR LINGT oN. T E X AS 76011-8064 August 8, 1997 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 Fort Calhoun, Nebraska 68023-0399 SUBJECT: NRC INSPECTION REPORT 50 285/97-06

Dear Mr. Gambhir:

Thank you for your letter of July 28,1997, in response to our letter and Notice of -

Violation dated June 27,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

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qb Arthur T. Howell til, Director Division of Reactor Safety /

Docket No.: 50-285

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License No.: DPR-40

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James W. Tills, Manager Nuclear, Licensing -

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

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l Fort Calhoun Station l~ 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---

_ 1 Lincoln, Nebraska 68509 5007

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O Omaha Public Power District -3 E Mail report to T. Boyce (THB)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

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Regional Administrator DRS-PSB DRP Director MIS System Branch Chief (DRP/B) RIV File Project Engineer (DRP/B) Branch Chief (DRP/TSS)

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DOCUMENT NAME: R:\_FCS\FC706RP,TFS To receive copy of document, indicate in box: "C" = Copy without glosures "E" = Copy wdh enclosures "N" = No copy RIV:SRl:EB l p, C:EB lg D:DRP( ) D:DRSfg 9 TFStetkallmbgf( '

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bec distrib. by RIV:

Regional Administrator DRS-PSB DRP Director MIS System Branch Chief (DRP/B) RI V File Project Engineer (DRP/B) Branch Chief (DRP/TSS)

Resident inspector DRS Al 97-G-0075 DOCUMENT NAME: R:\_FCS\FC706RP.TFS To receive copy of document, indicate in box: "C" = Copy weout ysures "E" = Copy with enclosures "N" a No copy RIV: SRI:EB p, C:EB lg D:DRP( j D:DRSA p

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NNEE Omaha Public Power Distnct 444 South 16th Street Mall

a *OA-Omaha NE 68102-2247 July 28, 1997 LIC-97-0121 N79@ -

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U.S. Nuclear Regulatory Commission

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ATTN: Document Control Desk Mail Station P1-137 Washington, D.C. 20555 4~

d References: 1. Docket No. 50-285 2. Letter from NRC (A. T. Howell) to OPPD (S. K. Gambhir) dated June 27. 1997 SUBJECT: NRC Inspection Report No. 50-285/97-06. Reply to a Notice of Violation The subject report transmitted a Notice of Violation (NOV) resulting from an NRC inspection conducted April 14-18 and April 28 - May 2. 1997. at the Fort Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD) response to this NOV.

It was also requested that OPPD confirm its commitment to perform a safety system functional inspection (SSFI) of the fire protection system. OPPD has completed an integrated Appendix R and Fire Protection Self Assessment with OPPD personnel and the consulting firm. Engineering Planning and Management Incorporated. OPPD will perform a Fire Protection Functional Inspection (FPFI) on the fire protection system for areas not addressed by this Self Assessment by October 31, 1997. The draft NRC FPFI procedure will be followed for this inspection.

If you should have any questions, please contact me.

Sincerely

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6w J. W. Chase Manager - Fort Calhoun Station BRH/brh Attachment c: Winston ar.d Strawn i E. W. Me: Ahoff. NRC Regional Administrator. Region IV L. R. Wiarton, NRC Project Manager W. C. W:ilker. NRC Senior Resident Inspector 4s.s u4 4 7 g yny y empioym ni itn gqu.iopponuntry

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L' U.S. Nuclear Regulatory Commission Attachment. LIC-97-0121 Page 1 l

NOTICE OF VIOLATION I

0maha Public Power District Docket: 50 285 Fort Calhoun Station License:-DPR 40 During an NRC inspection conducted on April 14 18 and April 28 through May 2, 1997, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion III, requires that measures shall be astablished to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. The design control measures shall also provide for verifying or checking the adequacy of design, such as, by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Design control measures shall be applied to items, such as, accident and hydraulic analyses.

Contrary to the above, the measures established by the licensee were not adequate, as evidenced by the following examples:

1. From initial licensing through May 1, 1997, the design basis requirements were not correctly incorporated into surveillance test procedure acceptance criteria for the motor-driven auxiliary feedwater pump, the high pressure safety injection pumps, the containment spray pumps, the low pressure safety injection pumps, and the raw water pumps.

Specifically, the acceptance criteria that provided the minimum flow for these pumps was slightly less than would have been required to mitigate their design basis accidents.

2. On April 5,1997, design control measures were not adequately applied to the hydraulic analysis calculation for the component cooling water surge tank to assure that following a temperature transient there would be sufficient net positive suction head for the component cooling water pumps.

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U S. Nuclear Regulatory Commission

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Attachment. LIC-97-0121 Page 2 3. - From initial licensing through May 1, 1997, a design basis requirement was not correctly incorporated into the technical specifications in that a technical specification limiting condition for operation did not assure that the minimum water level in the emergency feedwater storage tank was sufficient to mitigate accident scenarios. Specifically, Technical Specification 2.5(2) requ; red 55,000 gallons of water to be available in the tank: however, calculations indicatd that 55,969 gallons were required to mitigate design basis accidents.

This is a Severity Level IV violation (Supplement I)(50 285/9706 01)

B. 10 CFR 50.71e, requires that the Updated Safety Analysis Report be updated periodically to assure that the information included in this report contains the latest material develep'd.

Contrary to the above, the periodic update of the Updated Safety Analysis Report performed on October 12, 1995, did not assure that the report contained the latest material developed, in that it did not provide the correct information regarding the capacity of the diesel driven auxiliary feedwater pump fuel oil day tank. The Updated Safety Analysis Report specified that the fuel oil day tank contained sufficient fuel oil for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of continuous operation. However, the tank was routinely maintained at a less than full-level such that 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of continuous operation would not be obtained form-the-available fuel oil in the tank.

This is a Severity Level IV violation (Supplement I)(50 285/9706 03)

These violations were cited separately as Violation A (9706-01) and Violation B (9706-03). OPPD is providing a separate response to each-violation.

OPED_ Response _toJiolationl A. The_ Reason _for_the_V.iolation The reason for the violation was inadequate procedural guidance for ;

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incorporation of assumptions and results of engineering analyses and calculations into implementing documents.

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'U S. . fluclear Regulatory Commission Attachment. LIC-97-0121 Page 3

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B. Corrective _ Steps That Have_Been_Taken_and_the..Results_ Achieved

.All safety-related pump surveillance tests have been reviewed to ensure the acceptance criteria reflect the pumps' design basis requirements. All applicable surveillance tests have been revised to account for instrument

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error and ensure acceptance criteria exceeds the pumps' design basis minimum performance requirements.

l The hydraulic calculation for the component. cooling water (CCW) surge tank.

L FC06378 was reviewed in light of the issues identified in the report.

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Although the calculation errors noted would have resulted in a different final CCW surge tank pressure._the results and conclusion of the calculation remain unchanged. As stated in the inspection report the CCW pumps would have had sufficient net positive suction head for transient conditions.

A review of Emergency Feedwater Storage Tank (EFWST) level readings recorded in OP-ST-SHIFT-0001 from 6/17/94 to 5/07/97 found that the EFWST has been maintained above the Technical Specification (TS) limit, including instrument uncertainty. The TS limit bounds the Enalytical requirements of 53,824 gallons. A revision to calculation FC06284 was completed; this determined a more realistic instrument error for the EFWST to be 2.83%. OP-ST-SHIFT-0001 has been revised to incorporate a operability limit of 88% to account for the most recent instrument error calculation. Technical Data Book Figure.

" Emergency Feedwater Storage Tank. FW-19. has been revised to include the 88%

operabili_ty limit.

OPPD considers the TS limit adequate without the' inclusion of measurement uncertainties, as the surveillance test incorporates these uncertainties.

This is consistent with other Fort Calhoun TS for tanks and is consistent with certain Standard TS that do not include measurement-uncertainties. As an example, all_ Standard TS contain_a requirement to maintain 23 feet of water above the reactor flange when moving irradiated fuel. The 23 feet is a requirement directly from Regulatory Guide 1.25 with no measurement uncertainties applied. The 1ssue of whether measurement uncertainties must be incorporated into the TS value is being discussed with the Office of Nuclear.

Reactor Regulation.

Generically, steps have been taken to strengthen the incorporation of design basis requirements of structures, systems, and components into specifications.

drawings, procedures, and instructions through an extensive revision of l-M 7

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U.S. Nuclear Regulatory Commission Attachment. LIC 97-0121 Page 4 Quality Procedure PED-OP 5. " Engineering Analysis Preparation. Review and Approval." and Quality Procedure N0D 0P-3. "10 CFR 50.59 Safety Evaluations,*

The provisions of these two procedures and the importance of incorporation of design Dasis requirements into implementing documents has been reinforced through training provided on these documents.

C. Corrective _ Steps _ThaLWilL Be_Taken Safety analysis pump minimum performance requirements will be incorporated into the USAR and the system design basis documents by December 31. 1997.

The hydraulic calculation for the component cooling water surge tank. FC06378, will be revised by November 30. 1997.

The basis for the required inventory of the EFWST will be incorporated into the USAR and the system design basis documents by December 31, 1997.

Quality Procedure PED OP-3. " Calculational Preparation. Review and Approval."

will be revised to strengthen the incorporation of calculation assumptions and results into implementing documents. This revision will be completed by December 31. 1997.

D. Date_WhelL EutLCompli ance_WilLBe_ Achieved OPPD is currently in full compliance.

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U.S. Nuclear Regulatory Commission Attachment. LIC-97-0121 Page 5 OPPD Response toJiolation_B A. The Reason _for_the liolation The diesel-driven auxiliary feedwater pump was installed, and the Updated Safety Analysis Report (USAR) was updated, in 1992. The statement incorporated into the USAR. ~a fuel oil day tank located adjacent to the engine provides fuel storage capacity for eight hours of continuous operation," was developed from the modification. There was no design or licensing basis contained in the modification to maintain 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of fuel in the day tank, as the tank automatically refills from the 18.000 gallon Auxiliary Boiler Fuel Oil Tank when low level is reached. After the original installation, procedures involved with filling the tank were subsequently revised with the statement in the USAR interpreted as reflecting the tank storage capacity and not an operating limitation. Therefore, it was not recognized that a USAR revision was required,

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B. Corrective _ Steps _That_Have_Been Takerland._the_Results_ Achieved A 10 CFR 50,59 safety evaluation and associated USAR revision were approved by the Plant Review Committee on May 2. 1997 that more accurately describe the operation of the tank, This change was included in the OPPD 10 CFR 50.59 report and USAR update transmitted to the NRC on May 23, 1997.

C. Coctective_ Steps _That_WilLBe_Taken OPPD has previously committed to conduct a review of safety related and safety significant systems following the Nuclear Energy Institute (NEI) Guidelines for Assessing Programs for Maintaining the Licensing Basis (NEI-96-05) in response to a request pursuant to 10 CFR 50.54(f). This commitment includes review of applicable sections of the USAR.

D. Date_WhenlulLCompliance_WilLBe_ Achieved OPPD is- currently in full compliance.

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