IR 05000285/1997020
| ML20216B692 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/10/1998 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gambhir S OMAHA PUBLIC POWER DISTRICT |
| References | |
| 50-285-97-20, NUDOCS 9803130154 | |
| Download: ML20216B692 (4) | |
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UNITED STATES I
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REGION IV
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SUBJECT:
NRC INSPECTION REPORT 50-285/97-20
Dear Mr. Gambhir:
Thank you for your letter of February 27,1998, in response to our letter and Notice of Violation dated January 28,1998. 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, e
W. D. ohnson, Chief Project Branch B Division of Reactor Projects Docket No.:
50-285 License No.: DPR-40 cc:
l James W. Tills, Manager l
Nuclear Licensing I
Omaha Public Power District I
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399 Hwy. 75 - North of Fort Calhoun llllllllllllllfllll]llfllfllll Fort Calhoun, Nebraska 68023-0399 9803130154 980310 ' gDR ADOCK 05000285 PDR L
. . ! I , Omaha Public Power District-2-James W. Chase, Manager l Fort Calhoun Station l: P.O. Box 399 'i q Fort Calhoun, Nebraska 68023
J Perry D. Robinson, Esq.
Winston & Strawn - 1400 L. Street, N.W.
l 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 l - P.O. Box 95007 l Lincoln, Nebraska 68509-5007' l ' ! .. l l l i
. . ... ' Omaha Public Power District-3-MAR I O 1998 ' bec to DCD (IE01) bec distrib. by RIV: Regional Administrator DRS-PSB DRP Director-MIS System Branch Chief (DRP/B) RIV File - Project Engineer (DRP/B) Branch Chief (DRP/TSS) Resident inspector ' l , l , i
l DOCUMENT NAME: R:\\_FCS\\FC720AK.WCW To receive copy of document, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy lRIV:SPE:DRP/B C:DRP/B () lDNGraves;df k, WDJohny)fi l3/ o /98 I 3/10/98 f OFFICIAL RECORD COPY
... -, i Omaha Public Power District-3-MAR I O 1998 g M9 bec distrib. by RIV: Regional Administrator _ DRS-PSB DRP Director MIS System Branch Chief (DRP/B) RIV File Project Engineer (DRP/B) Branch Chief (DRP/TSS) Resident inspector l ! l l , l l DOCUMENT NAME: R:\\_FCS\\FC720AK.WCW To receive copy of document,ind6cate in box:"_C" = Copy without enclosures "E" = Copy wnh enclosures "N" = No copy RIV:SPE:DRP/B C:DRP/B () DNGraves;df b WDJohn%6 3/,o /98 I 3/10 98 / OFFICIAL RECORD COPY j
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. . , 0_.9_98_ ' _ 444 Soue fde Stost Add M-3 Omaha, Nebrada 68fME47 J . ' February 27,1998 - LIC-98-0030 U.S. Nuclear Regulatory Commission ATTN: Docum:nt Control Desk MailStation Pl-137 Washington,DC 20555 e References: 1.
Docket No. 50-285 2.
Letter from NRC (W. D. Johnson) to OPPD (S. K. Gambhir) dated January,28,1998 SUBJECT: NRC Inspection Report No. 50-285/97-20, Reply to a Notice of Violation The subject report transmitted a Notice of Violation (NOV) resulting from a NRC inspection conducted December 7,1997 through January 17,1998 at the Fort 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,
f) / S. Division Manager Engineering and Operations Support SKG/ddd ' Attachment ! c: E. W. Merschoff, NRC Regional Administrator, Region IV l L. R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector Winston and Strawm 9 S- 09 I5 ) '55 Employment with Equalopportunity < p ;,( 3rp.
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Attachment l l LIC-98-0030 l Page1 REPLY TO A NOTICE OF VIOLATION l l Omaha Public Power District Docket No.: 50-285 L Fort Calhoun Station License No.: DPR-40 i During an NRC inspection conducted on December 7,1997, through January 17,1998, one i violation of NRC requirements was identified. In accordance with the " General Statement i of Policy and Procedure for NRC Enforcement Actions," NUREG-1,600, the violation is listed below: i Technical Specification 5.8.1 requires,in part, that written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the minimum rei uirements of Appendix A of NRC Regulatory Guide 1.33.
l Technical Specification 5.8.2 requires that changes to procedures of Technical Specification 5.8.1 determined to affect nuclear safety shall be reviewed and approved as described in ! this section.
Technical Specification 5.8.2.1 requires, in part, that each procedure, or change thereto, shall be reviewed by a Qualified Reviewer who is knowledgeable in the functional area but is not the individual preparer, and the reviewer shall render a determination,in writing, of whether cross-disciplinary review of the change is necessary.
Technical Specification 5.8.2.2 requires,in part, that the Department Head shall review each procedure, or change thereto, and the review shall include a determination of whether or not a 10 CFR 50.59 safety evaluation is required.
Standing Order SO-G-30," Procedure Change and Generation," Revision 74, provided the required procedure to implement Technical Specification 5.8.2.
Contrary to the above, between October 16 and December 12,1997, changes to operating procedures affecting nuclear safety were,in effect, implemented, via five different operations memorandums, without having performed the requirements of Standing Order SO-G-30. The practice of using operations memorandums to direct operator actions in emergency operating procedures, abnormal operating procedures, and emergency plan procedures, without actually revising the procedures, introduced the vulnerability that required steps or actions may not get performed during periods of high stress such as those that may be present when those procedures are being implemented.
This is a Severity Level IV violation (Supplement 1)(50-285/9720-01).
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Attachment LIC-98-0030 ) Page 2 OPPD Response 1.
Reason for the Violation
The reason for this violation was management's belief that Operations Memorandums offered l clarification of existing procedures, provided more conservative direction, and were bounded by the 10CFR50.59 Safety Evaluations for the respective procedures. Management also believed , that by following the approved process for implementing Operations Memorandums, per Standing Order SO-O-13, " Operations Memorandums," the intent of;the Technical
Specifications 5.8.1 and 5.8.2 was being met.
2.
Corrective Steps Taken and Results Achieved ' The appropriate Department Head directed that all active Operations Memorandums be a.
- evaluated using the 10CFR50.59 Safety Evaluation process for Unreviewed Safety Questions (USQ's). This action is complete and based upon this evaluation, no USQ's were found, b.
A Qualified Reviewer evaluated the active Operations Memorandums to determine if cross-disciplinary reviews of the memorandums were necessary. As a result of this evahration, it was determined that no additional cross-disciplinary reviews were required.
c.
Standing Order O-13, " Operations Memorandums," has been revised to require that Operations Memorandums have a 10CFR50.59 Evaluation perforTned prior to issuance.
3.
Corrective Steps That Will Be Taken To Avoid Further Violations
a.
Standing Order 0-13, " Operations Memorandums," will be revised to require all fbture Operations Memorandums to be reviewed and approved to the same requirements as procedure changes governed by Standing Order G-30," Procedure Changes." This action will be completed by April 1,1998. In addition, Operations Memorandums will no longer be used to make changes to Abnormal Operating Procedures, Emergency Operating Procedures, or Emergency Plan Implementing Procedures.
b.
Currently, Standing Order O-13, " Operations Memorandums," requires a 10CFR50.59 applicability screening to be performed on Operations Memorandums. Ifit becomes necessary to issue an Operations Memorandum before the revision to Standing Order G-30 is implemented, the requirements of Technical Specificaitons sections 5.8.2 will be followed.
4.
The date when full compliance will be achieved Fort Calhoun Station is currently in full compliance.
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