IR 05000285/1997011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/97-11. Corrective Actions Will Be Reviewed During Future Insp

ML20149G320
Person / Time
Site:	Fort Calhoun
Issue date:	07/21/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
References
50-285-97-11, NUDOCS 9707230140
Download: ML20149G320 (4)

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p t >"A MGuy UNITED STATES

g 'g NUCLEAR REGULATORY COMMISSION L $ REGloN Iv

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JUL 21 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 50-285/97-11

Dear Mr. Gambhir:

Thank you for your letter of July 3,1997, in response to our letter and Notice of Violation dated June 4,1997. We hc.c reviewed your reply and find it responsive to ti,e 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.

Sincere ,

T omas P. Gwynn Dir to l Division of React P ject Docket No.: 50-285 License No.: DPR-40 ,

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James W. Tills, Manager l Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

l P.O. Box 399 Hwy. 75 - North of Fort Calhoun j Fort Calhoun, Nebraska 68023-0399 EMll 9707230140 970721 il.EEE. l.E.E 1 L * -

PDR ADOCK 05000295 G PDR l

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Omaha Public Power District -2-

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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 r

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444 South 16th StreetMall i i NL ' 8 k Omaha NE68102-2247  % y July 3. 1997 - d7-4 LIC-97-0103 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, DC 20555 References: 1. Docket No. 50-285 2. Letter from NRC (T. P. Gwynn) to OPPD (S. K. Gambhir) dated June 4, 1997 SUBJECT: NRC Inspection Report No. 50-285/97-11. Reply to a Notice of Violation l

The subject report transmitted a Notice of Violation (NOV) resulting from an i NRC special insnection conducted May 19 through May 23. 1997 at the Fort

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Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD)

response to this NOV.

If you should have any questions, please contact me.

Sincerely, py S. Division Manager Engineering and Operations Support l SKG/ddd Attachment c: Winston and Strawn E. W. Merschoff. NRC Regional Administrator Region IV L. R. Wharton, NRC Project Manager W. C. Walker. NRC Senior Resident Inspector

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a Attachment LIC 97-0103 Page 1 REPLY TO A NOTICE OF VIOLATION l

l Omaha Public Power District- Docket: 50 285 Fort Calhoun Station License: DPR 40

During an NRC inspection conducted on May 19 23, 1997, one violation of NRC l requirements was identified. In accordance with the " General Statement of l . Policy and Procedure for NRC Enforcement Actions" NUREG 1600, the violation is

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A. Technical Specification 5.8.1 requires, in part, that written procedures I be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of- Regulatory Guide 1.33, Revision

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2, February 1978. Regulatory Guide 1.33, Appendix A recommends, in part, that procedures should be written covering administrative procedures for safe operation.

1. Standing Order 50 0-1, Revision 31, " Conduct of Operations,"

l requires in step 12.1.28 that if while performing a procedure it is discovered that the anticipated response was not received.

l initiate a temporary or permanent change in accordance with Standing Order G 30, " Procedure Change and Generation."

2. Contrary to the above, the licensee did not properly implement the administrative procedure applicable to the activity in that on May 12, 1997, the licensee did not initiate a procedure change as required when the governing Procedure OP-2A, " Plant Startup," did

, not specify actions to be taken if all Group 4 control rods were withdrawn without reaching criticality.

This is a Severity Level IV Violation (285/97011-01) (Supplement I)

OPPD Response

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- The above NOV (failure to change an inadequate procedure) was a violation of S0-0-1, but did'not impact nuclear safety.

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! 1. The Reason for the Violation l

l Withdrawal to criticality is controlled under operations procedure OP-2A, " Plant Startup." This procedure did not address the potential

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condition of not achieving criticality by all rods out (ARO).

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Attachment i LIC 97-0103 l Page 2 j i

Additionally, this condition, subcritical with Group 4 rods at ARO, is )

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' believed not to have occurred previously at Fort Calhoun Station. When '

this condition arose on May.12, 1997, discussions of possible actions _to i l take and the consequences;of those actions were held in the Control Room l-between the Reactor Engineer, the Shift Supervisor, the Licensed Senior

, Operator, and the Assistant Plant Manager before proceeding. This discussion maintained a high emphasis on reactivity management issues and conservative decision making.. Prior to proceeding, the Shift Supervisor received Manager - Operations concurrence via telephone. J

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The licensed members of this operating crew had recently received I training on reactivity management (04/21/97) and the Reactor Engineer was also present at that training session as a Subject Matter Expert.

Although OP-2A did not contain specific steps to perform the subsequent actions it was believed that existing procedural guidance provided adequate direction and control of the continuing evolution to critical.

Procedure OP-2A. " Plant Startup'" contains a note which allows additional hold points for 1/M plotting at the discretion of the Reactor i Engineer. Procedure 01-RR-1, " Reactor Regulating System Normal Operation." was used to manipulate the control rods. Procedure OI-CH-4.

" Chemical and Volume Control System Makeup Operation.~ provided guidance to' perform the required dilution of the RCS. Additionally, since it was agreed to continue with the withdrawal to criticality, OP-2A Attachment l 2, "CEA Withdrawal to Criticality Mode 2" was the appropriate procedure to follow.

o Upon his arrival, later that morning, the Manager - Operations reviewed the actions taken with the Assistant Plant Manager and the Reactor Engineer and they determined that a procedure change was warranted and requested that a Condition Report be generated to document his concern.

Since procedure OP-2A was not revised prior to continuing with the approach to criticality, the violation of S0-0-1 occurred.

OPPD has the following comment on the NRC observation (01.1.2b) that

"the failure to immediately place the reactor in a safe, stable condition and then to initiate a procedure change prior to continuing..

was a violation..." Standing Order S0-0-1, " Conduct of Operations."

Step 121.2B states, in part. -that if while performing a procedure it is

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discovered that the anticipated response was not received... the following actions shculd be carried out:

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(1) Place the system / component in a safe condition.

o (2) Contact the Shift Supervisor and inform him of the situation l

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l Attachment LIC 97-0103  ;

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i and the status-of the component / system.

(3) Evaluate the situation to determine the cause of the t-

. unexpected response. ,

(4)! Initiate a temporary or permanent procedure change in  !

accordance with G-30 to allow usage of

the procedure for the-current situation.

The reactor was in a safe condition as it was subcritical with adequate ['

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shutdown margin. Therefore, immediate operator action was not required.

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The Shift. Supervisor was being consulted to inform him of the situation and to determine the cause of the situation. This situation was not  ;

necessarily unexpected as the Reactor Engineer was aware that the worth ,

of Group 4 from the predicted critical condition was less than the-administrative limit'between measured and predicted critical conditions j (1 0.5% delta rho). Additionally, a dedicated operator was assigned to

take the reactor critical. A portion of the eighteen minutes noted l before inserting the rods was spent allowing the reactor to stabilize i while it was being monitored for indications of criticality. The remainder was spent evaluating the current situation and determining the i next course of action. Therefore, with the exception of Step. ,

12.1.2.B(4), all actions taken by 0 PPD personnel were correct and

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prudent.

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-2. Corrective Steps Which Have Been-Taken and the Results Achieved i

< a) OPPD has revised procedure OP-2A to address the. procedural l deficiency. The procedure was issued:on May 28, 1997.

i b)- Plant personnel were informed of this event during Human  !

Performance Day, which was held on June 11, 1997. This training ;

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reinforced the need for verbatim procedural compliance and the-need to correct procedural deficiencies as they occur.

I c)- The S0-G-92. " Conduct of Infrequently Performed Procedures," 1

' criticality briefing has been revised to address the observed

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l weakness that the criticality briefing did not address the o possibility of not going critical within the worth of Group 4 from l 85 inches to AR0.

3. Corrective Steps Which Will Be Taken to Avoid Further Violations I Operations personnel will be trained on this event and the revised

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Attachment LIC 97-0103 Page 4-procedure OP-2A, during the next regularly scheduled training (Rotation 97-05). This training will be completed on September 19. 1997. In the event the reactor must be shut down and then started up prior to September 19, 1997, this training will be provided to the crew that will take the reactor critical.

4. Date When Full Compliance Will Be Achieved l OPPD is currently in full compliance. l

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