ML20006C240
| ML20006C240 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/30/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20006C238 | List: |
| References | |
| 50-285-89-40, NUDOCS 9002070169 | |
| Download: ML20006C240 (2) | |
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APPENDIX A 4
NOTICE OF-VIOLATION Omaha Public Power District Docket: '50-285 Fort Calhoun Station
, Operating License: DPR-40 t
1 ' During:an NRC inspection conducted fron October 23 through November 9,1989, a_
violation of NRC requirements was identified. The violation. involved inadequate emergencyandabnormaloperatingprocedures(EOPs/A0Ps).
In'accordance with the'" General Statement of Policy and Procedure for NRC Enforcement Actions,"
Tit 1s10oftheCodeofFederalRegulations(10CFR)Part2,AppendixC(1989),
the violation is state,d below:
2
-Technical, Specification (TS) 5.8.1 states, in part, that written procedures 4
~shall.:be established, impicmented, and maintained that meet or exceed the minimum requiremen.ts of Appendix A to Regulatory Guide (RG) 1.33.
Section 6 of Appendix A to RG 1.33 requires procedures for combating emergencies and other significant events. The licensee has issued-Procedures:AOP-17 " Loss of Instrument Air"; E0P-02, " Loss of Offsite
< Power. and Loss of Forced Circulation"; E0P-06 " Loss of All Auxiliary
' Feedwater";. and E0P-20, " Functional Recovery Procedure," to meet the requirements stated in TS 5.8.1.
Contrary to the above,<the licensee failed to maintain these emergency and 3
abnormal' operating procedures adequately as evidenced by the specifics D
listed.below:
1.
Procedure AOP-17:
a.
The procedure instructs operators to control feedwater flow, using the feedwater regulating bypass valves through the alternate auxiliary'feedwater injection path. However, the auxiliary feedwater injection valves (normal flow path) fail 3
open on loss of instrument air, which would mean that while the operator is establishing flow control with the main feedwater regulating bypass valves, the steam-generators would be filled through the~ normal flow path. This procedural inadequacy represents a potential for initiation of an overcooling event.
b.
Upon loss of instrument air pressure to containment, the pressurizer spray valves fail closed. The procedure notss that reactor coolant system pressure control may be difficult; however, the procedure does not provide the alternate method available for pressurizer spray. The availability of this alternate pressurizer spray method to operations personnel could prevent a potential overpressurization event and unnecessary challenges to the primary coolant system relief and safety valves.
9002070169 900130 FDR ADOCK 03000283 g
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' Procedures E0PiO2,dO6, and -20:
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Ja. q Step 1316.d of E0P-02 does not address the need to augment the-cooling water for the air compressors if turbine plant coolingL water is not available. The failure-to provide adequate? cooling.
water flow could result'.in' overheating'and subsequent loss.of,
C, the: air 7 compressors.
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- b.
Steps 13.8 and:3.9 of E0P-02 do not. provide instructions for the y
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control room operator to ensure that the radiator exhaust.
y dampers open for emergency diesel generators 1 and:2. The-
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failure of the dampers to open would result in overheating and
' subsequent 11oss of the the. diesel generator; VJ
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Step 3.11 of E0P-06 states, in'part, that the control room..
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operator'should immediately initiate once-through. cooling (0TC) i C;,
if both-steam generators are less than 20 percent water level F
- and rsactor coolant system (RCS) temperature'is-increasing.
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'v However, the control room operator may never get to Step-3.11 if these conditions exist and the safety-function status check
-success criteria are not met because the control room operator
.is directed by the procedure to enter E0P-20. The immediate initiation of OTC is necessary to preclude core damage.
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- d.
Resource Tree E of E0P-20 indicates that OTC will be> successful ifithere is-one' operating high-pressure ~ safety injection (HPSI) y
' pump and:RCS pressure is less than 1350 psig. Step 6.8 of-the-J safety function status check-does_not designate 1the-number of
~HPSI. pumps required.. The~ procedure fails to provide adequate 1 success criteria to assure that'the proper number of HPSI pumps 1
are,available to support OTC.
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This.is a Severity Level IV violatione,(Supplement I)(285/8940-01)
Pursuant.to the provisions of 10"CFR 2.201, Omaha Public Pow'er District is
'hereby required to submit to this' office, within:30 days of the'date of:the
".j Ilettertransmittingthis. notice,awrittenstatementinreply,(2) thel including for j
R each ' violation (1) the. reason for the violation, if admitted; i
corrective steps' that have been taken and the:results achieved; (3) the correctivestepsthatwillbetakentoavoidfurtherviolations;and(4).the date'when full compliance;will be achieved. Where good cause is shown, consideration will-be given to extending the response time.
Dated at Arlington, Te as,
- this f o W day of 1990 j
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