LIC-12-0041, NRC Inspection Report 05000285/2011006, Reply to a Notice of Violation; EA-12-035 (Revision 0)

NRC Inspection Report 05000285/2011006, Reply to a Notice of Violation; EA-12-035 (Revision 0)

ML12107A036
Person / Time
Site:	Fort Calhoun
Issue date:	04/13/2012
From:	Bannister D Omaha Public Power District
To:	Document Control Desk, NRC Region 4
References
EA-12-035, IR-11-006, LIC-12-0041
Download: ML12107A036 (7)

Text

Omaha Public Power ~istrict 444 South 16'11 Street Mall Omalw, NE 68102- 2247 L1C-12-0041 April 13, 2012 u.s. Nuclear Regulatory Commission Attn : Document Control Desk Washington, DC 20555-0001

References:

1. Docket Number 50-285

2. Letter from NRC (R. D. Alexander) to OPPD (D. J. Bannister) dated March 16,2012 (NRC-12-0027)

SUBJECT:

NRC Inspection Report 05000285/2011006, Reply to a Notice of Violation (NOV); EA-12-035 (Revision 0)

In Reference 2, the Nuclear Regulatory Commission (NRC) transmitted a Notice of Violation (NOV) to the Omaha Public Power District (OPPD) that contained a Cited Green Violation.

This letter contains regulatory commitments that are summarized on the last page of the Enclosure. If you should have any questions, please contact me.

Sincerely,

>>~

D. J. Bannister Vice President and Chief Nuclear Officer Fort Calhoun Station DJB/epm Enclosure c: E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector

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LlC-12-0041 Enclosure Page 1 REPLY TO A NOTICE OF VIOLATION Omaha Public Power District Docket No. 50-285 Fort Calhoun Station License No. DPR 40 EA- 12-035 During an NRC inspection conducted on November 14, 2011, through February 2, 2012, one violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

a. Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non conformances are promptly identified and corrected.

Contrary to the above, from 1998 to October 28, 2011, the licensee failed to establish measures to assure that conditions adverse to quality were promptly identified and corrected. Specifically, following the discovery of water intrusion in manholes MH-5, and MH-31, in 1998, 2005, and 2009, the licensee failed to establish an appropriate monitoring frequency to identify when the condition was occurring in order to mitigate potential common mode failure of safety-related raw water 4160 V motor cables in underground ducts and manholes.

This viotation is associated with a (Green) SOP finding.

OPPD Response

1. Reason for the Violation Timeline of Events:

7/7/2005 Engineering Change (EC) 36835 (Manhole MH-5 Sump Pump) initiated.

10/15/2007 Plant Health Issue (PHI) 42873 (Submergence of medium voltage cables routed through manholes MH-5 and MH-31) generated and tied to the completion of EC 36835.

9/11/2009 Condition Report (CR) 2009-4216 (level "C") generated documenting past CRs indicating water leakage into manholes.

10/2009 Preventative Maintenance (PM) task was generated to inspect MH-5 and MH-31 on a quarterly basis.

LlC-12-0041 Enclosure Page 2 10/12/2009 PHI 42873 (EC 36835) was closed with no plan to install EC and to manage the issue by PM tasks.

1/15/2010 Licensing generated CR 2010-0222 for CDBI Green Non-cited violation for fai.lure to take adequate corrective action fonowing the discovery of water intrusion in manholes MH-5 and MH-31.

1/21/2010 CR 2009-4216 upgraded to LevellB" CR by Condition Review Group (CRG) which requires an Apparent Cause Analysis (ACA).

2/3/2010 Business Unit Review Committee (BURC) statuses EC 36835 as "on hold" until 12/31/11. Engineering OM did not approve the installation estimates; thus the issue was addressed by establishing a preventive maintenance task. (Note: This update was provided at a BURC meeting but was not found in the meeting minutes. This date and statement is found in the BURC section of PHI FC-10 0100 in Long-Term Asset Manager (LTAM)).

2/11/2010 ACA for CR 2009-4216 completed by the analyst .

2/19/2010 ACA for CR 2009-4216 approved by Station CARB.

5/13/2010 CR 2009-4216 Action Item (AI) 9, Implement benchmarking results from utility response to GL 2007-01, "Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients," is closed.

5/19/2010 CR 2009-4216 AI 10, Develop PM task for periodic inspection of switch yard manholes and ducts with Maintenance Rule medium voltage cables, is closed .

6/30/2010 CR 2010-3258 generated to document 25 inches of water found in MH-5.

7/9/2010 CR 2010-3429 generated to document 5 feet 5 inches of water found in MH-4 and cables were submerged. MH-4 was pumped down. MH-3 was inspected and found to have 5 feet of water.

MH-3 was not pumped out due to testing needed to be performed by Chemistry prior to pumping.

8/3/2010 CR 2010-3776 generated as roll up CR to document 3 instances of water found in manholes and that an improved method of testing and dewatering manholes is needed.

8/2010 Temporary modification 50029 put in place. This temporary modification placed wooden covers over the manholes for dai'ly access along with sump pumps with float switches for MH-1 through MH-4 and surface pumps for MH-5 and MH-31.

11/30/2010 Temporary modification 50029 was removed.

2/1/2011 CR 2011-0696 was generated by QA documenting that CR 2009 4216 effectiveness review had failed.

2/22/2011 BURC approved additional scoping dollars to resolve costs associated with installation of EC 36835.

3/29/2011 CR 2009-4216 AI 11 (Effectiveness review) closed due to failure (original date was 9/2011 which is an 18 month time frame).

LlC-12-0041 Enclosure Page 3 4/24/2011 EC 50456 was completed to replace the manhole lids with new cast lids that have an 11 inch inspection port built in to allow easier and safer access without requiring a crane and confined space entry requirements.

5/512011 Temporary Modification 52677 was issued to again install temporary wooden manhole covers over the manholes to allow for daily monitoring and pumping due to high water levels in the spring of 2011.

5/9/2011 PHI FC-1 0-01 00 (formerly PHI 42873) was re-opened and approved by the Plant Health Committee for an engineering resolution to design and install a means to automatically dewater manholes.

9/15/2011 Installation of EC 50456 was completed after flood waters receded.

10/14/2011 Additional Corrective actions added to CR 2009-4216 .

10/27/2011 Tan delta testing of medium voltage Maintenance Rule cables completed as part of Flood Recovery Plan.

12/1/2011 Licensing generated CR 2011-9788 for repeat violation of untimely corrective actions to protect safety related cables in manholes.

As documented on the timeline, from the February 3, 2010, dated BURC notes in LTAM for PHI FC-1 0-01 00, the Division Manager (OM) of Engineering did not approve the installation costs for EC 36835. The basis for this decision was not only limited to cost but also included implementation issues that would require a plant equipment air outage. The proposal only resolved issues with manhole MH-5 and not the other identified manholes. Information was obtained from an executive industry meeting where feedback was provided that utilities did not need to install elaborate dewatering systems for manholes that contain cables. It was determined that the issue would be addressed by utilizing a quarterly PM task. The OM of Engineering at that time is no longer with OPPD; therefore the information was obtained through staff interviews with others that were knowledgeable about the issue at the time .

Therefore, the Apparent Cause is that the Engineering Division Manager made a business decision to not approve the installation estimates (for EC 36835) and to address the issue by establishing a quarterly preventative maintenance task.

On October 12, 2009, Plant Health Issue (PHI) 42873 was closed with no plan to install EC 36835. The EC was placed in hold status with no plans to implement it.

No additional work was performed to develop a permanent solution for dewatering of manholes that contained Maintenance Rule cables until February 22,2011, when BURC approved funding to perform further scoping for alternate strategies or solutions for EC 36835. PHI 42873 was reopened (as PHI FC-10 0100 due to implementation of the LTAM system) and approved by the Plant Health Committee on 5/9/11.

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L1C-12-0041 Enclosure Page 4 Therefore, the first Contributing Cause is that for approximately 16 months the organization failed to perform any work to develop a permanent solution for dewatering manholes that contained Maintenance Rule cables.

On July 9, 2010, CR 2010-3429 was written to document submerged cables in MH-4. This fai'lure made CR 2009-4216 fail its effectiveness review. On February 1, 2011, QA generated CR 2011-0696 documenting that the effectiveness review had failed. However, the effectiveness review was not dispositioned and closed as failed until March 29, 2011. Furthermore, the additional corrective actions as required by station procedures were not generated until October 14, 2011. Station procedures do not provide timeframe guidance for the required actions if an effectiveness review fails. The eight (8) month timeframe between effectiveness review failure and documentation in the Corrective Action Program (CAP) as well as the seven (7) months taken to enter the required corrective actions in the CAP do not meet station expectations.

The second Contributing Cause is that CR 2009-4216 did not have the failed effectiveness review or additional corrective actions documented in the CAP in a timely manner.

2. Corrective Steps Taken and the Results Achieved Pending a final resolution the station is currently monitoring manholes MH-5 and MH-31 on at least a quarterly basis and whenever river level exceeds 994 feet mean sea level (MSL) with an increasing trend. River level is monitored twice per day by plant operators. If river level is 944 feet msl operations contacts engineering to ensure appropriate action is taken to protect the cables.

The station attempted to perform an evaluation to determine an appropriate inspection frequency to mitigate potential common mode failures of safety-related raw water 4160 V motor cables in underground ducts and manholes (MH-5 and MH-31). However, it was determined the number of variables and the capricious nature of the hydrologic conditions prohibit reliance on a periodic inspection schedule.

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LlC-12-0041 Enclosure Page 5 To verify the conditions of cables in the manholes, testing was completed on the following cables after the flood of 2011:

• CW-1A/8/C - Circulating Water Pumps

• AC-10A/8/C/D - Raw Water Pumps

• 13.8kV cable - from substation to transformer

• FP-1 A - Fire Protection Pump These cables are located in manholes MH-5 and MH-31 and in subsurface conduits. The testing was completed utilizing industry recognized best practices testing methods. The medium voltage cables tested are in good condition , with no indications of any short term or long term degradation due to exposure to submergence. Safety related low voltage cables were also tested and evaluated with the conclusion that no short term degradation or failure of the cables occurred. Submergence of the safety related cables has had no identified impact on the raw water pump cables or the other safety related cables.

3. Corrective Steps That Will be Taken Prior plant startup, as a part of the recovery effort the station will establish appropriate measures to mitigate the potential for common mode failure of the safety re'lated cables in manholes MH-5 and MH-31 .

4. Date When Full Compliance Will be Achieved OPPD will be in full compliance prior to plant startup.

LlC-12-0041 Enclosure Page 6 Regulatory Commitments CR Number Commitment AR Number Prior to plant startup, as a part of the recovery effort, the station will establish appropriate measures to mitigate the potential for common 2012-02096 mode failure of the safety related cables in manholes MH-5 and 52334 MH-31. This is a one-time commitment.