ML16343A287

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Forwards Insp Rept 50-285/94-24 on 941114-1227 & Notice of Violation.Violations Involve Failure to Implement Established Procedures for Documentation & Evaluation of Design Deficiency
ML16343A287
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 02/15/1995
From: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Tira Patterson
OMAHA PUBLIC POWER DISTRICT
Shared Package
ML16343A288 List:
References
EA-94-267, NUDOCS 9502220280
Download: ML16343A287 (8)


See also: IR 05000285/1994024

Text

UNITE D STATES

LEAR REGULATORY COMMlSSlO

REGION IV

611 RYAN PLAZA DRIVE, SUITE 400

ARLINGTON,TEXAS 76011 6064

ENCLOSURE

2

EA 94-267

February

15, -1995

Omaha Public Power District

ATTN:

T. L. Patterson,

Division Hanager

Nuclear Operations

Fort Calhoun Station

FC-2-4

Adm.

P.O.

Box 399,

Hwy.

75 - North of Fort Calhoun

Fort Calhoun,

Nebraska

68023-0399

SUBJECT:

NOTICE OF VIOLATION AND ENFORCEHENT DISCRETION

(NRC Inspection

Report 50-285/94-24)

This refers to the special

inspection

conducted

by Hr.

R. Hullikin and the

inspectors

identified in the enclosed

report, of this office, on November

14.

through

December

27,

1994.

The inspection

included

a review of activities

authorized for your Fort Calhoun Station facility.

At the conclusion of the

inspection,

the findings were discussed

with you and those

members of your

staff identified in the enclosed

report.

This special

inspection

was conducted

to review the immediate safety concerns

and corrective actions

associated

with your staff's identification of a

significant design deficiency with the control

room air conditioning units.

On November

14,

1994,

Omaha Public Power District determined that both control

room air conditioning units would have

been rendered

inoperable during certain

design

basis

accident conditions.

Specifically,

increases

in component

cooling water

(CCW) temperature

following a main steam line break in the

containment building or

a large break loss of coolant accident

would result in

the control

room air conditioning units'ompressors

shutting

down

and the

possible

release

of the Freon to the control

room.

With the loss of control

room air conditioning, certain engineered

safeguards

features

(ESF) equipment

may have

been

rendered

inoperable,

as described

in the report.

This was

identified by your staff and documented

in

a letter dated

November

29 to the

Region

IV Regional Administrator and in Licensee

Event Report 94-10,

"Potential Acci'dent Scenario

Involving a Loss of Control, Room Air

Conditioners."

The special

inspection consisted

of selective

examinations of

procedures

and representative

records,

interviews with personnel,

and

observation of activities in progress

and provided

a determination

whether

activities authorized

by the license

were conducted

safely

and in accordance

with NRC requirements.

Based

on the results of this inspection,

certain licensed activities appeared

to be in violation of NRC requirements

as described

in the enclosed

Notice of

Violation (Notice)

and details to this report.

The first violation involved

a

failure to assure

that the control

room air conditioning unit design

modification correctly translated

the design basis specifications for assuring

syste01 operability during certain design

basis

accidents.

As

a result,

the

control

room air conditioning units that were purchased

and installed in 1988

Omaha Public Power District

were not capable of operating within the component cooling water maximum

temperatures

following a postulated

main steam line break inside the

containment or

a large break'loss

of coolant accident.

The second violation

involved

a failure to implement the established

procedures

for the

documentation

and evaluation of the design deficiency.

These violations are being cited in the aggregate

as

a Severity Level III

problem because

of the high potential for rendering the control

room air

conditioning units inoperable during certain design basis

accidents

and the

probability that this in turn would have rendered certain

ESF equipment

inoperable.

The subsequent

failure of plant personnel

to appropriately

document

and evaluate this design deficiency resulted

in the plant operating

at

100 percent

power for an additional

month outside its design basis.

Normally,

a civil penalty is considered

for

a Severity Level III problem.

However,

I have

been authorized after consultation with the Director, Office

of Enforcement,

not to propose

a civil penalty for this problem.

This

determination

was

based

on our finding that this problem

and your actions

in

addressing it satisfied

the provisions of 10 CFR Part 2, Appendix C, section

VII.B(4) for old design

issues.

Specifically,

(1) the basic violation existed

since

the air conditioning units were purchased

in 1988

and is appropriately

characterized

as

an old design

issue;

(2) the problem was discovered

by the

licensee

during

a voluntary,

formal review and

was promptly reported

once the

ramifications of the problem were recognized;

(3) the problem was not likely

to be identified through routine inspection,

surveillance,

or gA activities,

and

(4) once the problem was recognized,

the licensee

developed

appropriate

short-term compensatory

measures

and comprehensive

long-term corrective

action.

Although section VII.B(4) also provides that the

NRC may refrain from

issuing

a Notice of Violation for old design

issues

under certain

circumstances,

we are issuing

a Notice of Violation in this case

because

as

indicated in the

NOV, your staff did not respond appropriately to indications

of this problem in October

1994 that should

have resulted

in a prompt

operability determination

and would have lead to earlier identification and

correction.

A management

meeting

has

been

scheduled

for March 2,

1995,

in the Region

IV

Public Heeting

Room at

1 p.m.

The purpose of this meeting is to discuss

your

staff's actions to improve the corrective action process

and the concerns

identified in its implementation following the identification of the control

room air conditioning design deficiency in October

1994.

This meeting is open

to public observation.

You are required to respond

to this letter

and should follow the instructions

specified in the enclosed

Notice of Violation (Notice)

when preparing your

response.

In your response,

you should

document

the specific actions

taken

and

any additional

actions

you plan to prevent recurrence.

After reviewing

your response

to this Notice, including your proposed

corrective actions

and

the results of future inspections,

the

NRC will determine

whether further

NRC

enforcement

action is necessary

to ensure

compliance with NRC regulatory

requirements.

Omaha Public Power District

In accordance

with 10 CFR 2.790 of the NRC's "Rules of Practice,"

a copy of

this letter, its enclosures,

and your response will be placed in the

NRC

Public Document

Room (PDR).

To the extent possible,

your response

should not

include any personal

privacy, proprietary, or safeguards

information so that

it can

be placed in the

PDR without redaction.

However, if you find it

necessary

to include

such information, you should clearly indicate the

specific information that you desire

not to be placed

in the

PDR,

and provide

the legal basis to support your request for withholding the inFormation from

the public.

The responses

directed

by this letter and the enclosed

Notice are not subject

to the clearance

procedures

of the Office of Management

and Budget

as required

by the Paperwork

Reduction Act of 1980,

Pub.

L. No. 96.511.

Sincerely,

Docket:

50-285

License:

DPR-40

org signed

by

L. J. Callan

Regional Administrator

Enclosures:

1.

Notice of Violation

2.

NRC Inspection

Report

50-285/94-24

cc w/enclosures:

LeBoeuF,

Lamb,

Greene

& HacRae

ATTN:

Mr. Michael

F. HcBride

1875 Connecticut

Avenue,

N.W.

Suite

1200

Washington,

D.C.

20009-5728

Washington

County Board

of Supervisors

ATTN:

Jack Jensen,

Chairman

Blair, Nebraska

68008

Combustion Engineering,

Inc.

ATTN:

Charles

B. Brinkman,

Manager

Washington Nuclear Operations

12300 Twinbrook Parkway,

Suite

330

Rockville, Maryland

20852

Omaha Public Power District

Nebraska

Department of Health

ATTN:

Harold Borchert, Director

Division of Radiological

Health

301 Centennial

Mall, South

P.O.

Box 95007

Lincoln, Nebraska

68509-5007

Nebraska

Department of Health

ATTN:

Dr. Nark B. Horton, M,S.P.H.

Director

P.O.

Box 950070

Lincoln, Nebraska

68509-5007

Fort Calhoun Station

ATTN:

James

M. Chase,

Manager

P.O.

Box 399

Fort Calhoun,

Nebraska

68023