LIC-04-0070, Reply to Notice of Violation to Inspection Report 050000285/2004002

Reply to Notice of Violation to Inspection Report 050000285/2004002

ML041670405
Person / Time
Site:	Fort Calhoun
Issue date:	06/11/2004
From:	Phelps R Omaha Public Power District
To:	Document Control Desk, NRC Region 4
References
EA-04-078, IR-04-002, LIC-04-0070, NRC-03-0199, NRC-04-0063
Download: ML041670405 (4)

Text

• EWEN

,MW am Omaha Public Power District 444 South 16th Street Afall Omaha NE 68102-2247 June 11, 2004 LIC-04-0070 U. S. Nuclear Regulatory Commission ATITN: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285

2.

Letter from NRC (K. M. Kennedy) to OPPD (R. T. Ridenoure) dated October 17, 2003 (NRC-03-0199)

3. Letter from NRC (K. M. Kennedy) to OPPD (R. T. Ridenoure) dated May 14, 2004 (NRC-04-0063)

SUBJECT:

NRC Inspection Report 050000285/2004002, Reply to a Notice of Violation Reference 3 transmitted a Notice of Violation (NOV) to the Omaha Public Power District (OPPD). The NOV resulted from failure to restore compliance within a reasonable time after a noncited violation was identified in Reference 2. Attached is the OPPD response to this NOV.

OPPD agrees that corrective actions to the Reference 2 noncited violation were not addressed in a timely manner. FCS management intends to share this incident with employees as "lessons-learned." This will foster the understanding of the importance of properly categorizing the safety significance of issues to complete corrective actions in a timely manner.

Substantive surveillance test changes have been implemented in response to this violation. Additional changes are under consideration to further enhance the Emergency Diesel Generator (EDG) surveillance testing program.

This letter does not contain any regulatory commitments. If you should have any questions, please contact me.

Sincerely, R. L. Phelps Division Manager Nuclear Engineering RLP/GRC/grc Attachment c:

B. S. Mallett, NRC Regional Administrator, Region IV Alan Wang, NRC Project Manager J. G. Kramer, NRC Senior Resident Inspector

'- C-- (D J,

I?

Employmnent with Equal Opportunity

Attachment LIC-04-0070 Page 1 REPLY TO A NOTICE OF VIOLATION Omaha Public Power District Docket No. 50-285 Fort Calhoun Station License No. DPR-40 EA-04-078 During an NRC inspection conducted on January 1 through March 31, 2004, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and procedure for NRC Enforcement Actions," NUREG-1 600, the violation is listed below.

10 CFR Part 50, Appendix B, Criterion V, states, in part, that procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, on January 21, 2004, the licensee failed to assure that procedures included appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Specifically, the licensee failed to assure that Procedure OP-ST-DG-0001, "Diesel Generator I Check," Revision 39, contained appropriate acceptance criteria for frequency when performing a fast start of the diesel generator. The acceptance criteria did not account for a 2 hertz speed droop of the fully loaded diesel generator when selecting the minimum acceptable frequency. The licensee had previously received a noncited violation (NCV 05000285/2003005-02) as a result of a similar condition.

This is a violation of very low safety significance (Green).

OPPD Response

1.

Reason for the Violation This violation was a result of Fort Calhoun Station (FCS) Engineering focus being solely on the testing requirements of the FCS Technical Specifications (TS) when this item was initially reviewed in July 2003. The FCS TS does not require testing the unloaded steady state speed of the Emergency Diesel Generators (EDG) to specific speed criteria. Since FCS TS does not require such a test, FCS Engineering did not prioritize the work to add this testing requirement to the existing full speed test in a timely manner.

Some corrective actions were implemented. Additional corrective actions were either planned or under consideration, but were not scheduled to be completed commensurate with the importance of the issue.

Although FCS TS do not specifically require a verification of unloaded steady state speed, OPPD has concluded that unloaded steady state speed should be tested to a specified criterion to be in full compliance with 10CFR Part 50, Appendix B, Criterion V.

Attachment LIC-04-0070 Page 2

2.

Corrective Steps Taken and Results Achieved

a.

FCS personnel worked with the EDG technical representative, and performed additional bench testing to gain a more thorough understanding of the mode of operation of the EDG governors. This has instilled a higher level of confidence in the ability of the governors to achieve consistent performance.

This was completed on May 26, 2004.

b.

FCS personnel completed an apparent cause analysis. Based on this analysis, FCS personnel have taken steps to ensure that the design basis of the speed performance criteria for the EDGs is fully understood. This was completed on June 2, 2004.

c.

The six month full speed start test procedures have been revised to include a requirement to check the unloaded steady state speed of the EDGs at the point which the governor is controlling EDG speed. This was completed on June 11, 2004.

3.

Corrective Steps That Will Be Taken To Avoid Further Violations

a.

When any violation of 10CFR has occurred, it is incumbent upon the responding organization to complete corrective actions in a timely manner. FCS management will take this incident to the employees and share it as a "lessons-learned." This will be completed under the FCS condition reporting system.

b.

In 2003, the Institute of Nuclear Power Operations issued a Significant Operating Experience Report (SOER) 2003-01, Emergency Power Reliability. The SOER was based upon World Association of Nuclear Operators (WANO) SOER (2002-2). One of the items requiring review as part of the SOER was:

Review testing practices for emergency power systems to verify that the practices are representative of actual demand conditions and appropriately exercise equipment that is expected to respond in an actual demand condition. Staff performing this review should identify and use applicable industry best practices for comparison to current testing practices at their NPP [nuclear power plant]. Implement appropriate changes to system testing practices as found necessary by this review.

As part of the FCS response to this SOER, FCS will ensure that current testing practices of the EDGs are representative of actual demand conditions and appropriately exercise equipment that is expected to respond in an actual demand condition. This will be completed under the FCS condition reporting system.

Attachment LIC-04-0070 Page 3

c.

The procedure controlling the condition reporting system has been reviewed for potential process enhancements. As a minimum, FCS will establish an interim check to verify timeliness of planned corrective actions in response to 10 CFR violations. This will be completed under the FCS condition reporting system.

4.

The Date When Full Compliance WVill Be Achieved Fort Calhoun Station is currently in full compliance.