ML20029E006
| ML20029E006 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/10/1994 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Tira Patterson OMAHA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20029E007 | List: |
| References | |
| EA-94-026, EA-94-26, NUDOCS 9405160040 | |
| Download: ML20029E006 (5) | |
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ARLINGTON, T E XAS 76011 8064 MAY l 01994 Docket:
50-285 License:
DPR-40 EA 94-026 Omaha Public Power District ATIN:
- 1. L. Patterson, Divisiori Manager Nuclear Operations Fort Calhoun Station fC-2-4 Adm.
Post Office Box 399, Hwy. 75 - North of Fort Calhoun fort Calhoun, Nebraska 68023-0399
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
525,000 (NRC INSPECTION REPORT NO. 50-285/94-06)
This is in reference to the inspection conducted January 24-28, 1994, at the fort Calhoun Stat. ion (FCS) nuclear power plant.
This special inspection was conducted to review the circumstances surrounding four events occurring at FCS between November 13, 1993 and January 18, 1994.
A report documenting the results of the inspection was issued on February 22, 1994. On March 11, 1994, OPPD representatives attended an enforcement conference in the NRC's Arlington, Texas office to discuss the apparent violations, OPPD's corrective actions, and other issues relevant to NRC's enforcement decision.
As described in the inspection report in more detail, the events that prompted this' inspection include:
- 1) an uncontrolled withdrawal of a Control Element Assembly (CEA) with the plant in Mode 5 (refueling); 2) both trains of the auxiliary feedwater system (AFW) being made inoperable (unable to respond to an automatic initiation signal) simultaneously with the plant at power; 3) a failure to place both trains of the control room ventilation system in the recirculation mode with both toxic gas monitors inoperable; and 4) an unplanned dilution of the reactor coolant system (RCS) boron concentration that caused reactor power to exceed 100 percent of full power for 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
Based on the NRC's review of information developed during the inspection and the information exchanged during the enforcement conference, the NRC has determined that violations of requirements occurred relative to three of the four events.
The violations, which are described in more detail in the enclosure, involve multiple failures to follow procedural requirements, a failure to have an adequate procedure in place in one instance, and a failure to meet plant Technical Specification requirements in one instance.
With regard to the control room ventilation system event, operators failed to follow procedures by not placing the control room ventilation system in the recirculation made when both toxic gas monitors became inoperable.
This omission, which was caused in part by a lack of understanding of the system, resulted in a violation of the Technical Specifications for assuring the safety of the control room in the event of a toxic gas or chemical event.
With regard to the unplanned dilution event, operators performing this activity failed to have in their possession the procedures for restoring an N85 PDR g
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- ion exchanger to service and did not carry out this activity in accordance with such procedures.
With regard to the AFW event, a faulty surveillance 4
procedure resulted in operators making both trains of the AFW system inoperable with the plant at power.
In this event, operators recognized the procedural inadequacy and took some steps to assure that the AFW system could be activated.
The NRC is concerned however that the operators proceeded nonetheless to render both trains incapable of responding to an automatic initiation signal.
In the event involving the uncontrolled CEA movement, in which the operators failed to verify the position of all CEAs, no violations are being cited.
This is primarily because equipment failure and some lack of specificity in the annunciator response procedure resulted in this event.
Nevertheless, the NRC believes that operators with appropriate training and regard for attention to detail should have checked all CEA position indications to determine the cause of the rod motion alarm.
The violations in the enclosure were caused by-inattention to detail, a lack of command and control of licensed activities, and other performance-related weaknesses on the part of licensed operating personnel.
Although none of these events posed a significant threat to the safety of the facility, our review of each of these events found that licensed operating personnel did not perform up to NRC expectations.
The circumstances surrounding the unplanned dilution of the RCS are particularly disturbing in-that operations personnel failed to make use of the necessary procedurcs and violated key procedural requirements designed to prevent an unplanned power excursion.
In addition, despite the fact that one of the violations involved a procedure that was flawed, the NRC believes that these events could have been prevented by more positive control of licensed activities, closer attention to detail, or a more questioning attitude on the part of licensed personnel.
Collectively, the events and associated violations reflect negative trends in control of licensed activities and performance of licensed operating personnel and are indicative of a potentiaHy significant lack of attention or carelessness toward licensed responsibilities.
t from the NRC's perspective, and for the reasons discussed above, the events and associated violations occurring within approximately a two-month period represent a significant regulatory concern.
Thus, the NRC has classified the violations described above and in the enclosure as a Severity Level III problem in the aggregate, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy).
OPPD appears to have taken or initiated action to address the factors that played a significant ro',e in or contributed to the occurrence of these events and violations of requirements.
These actions, which were described in detail during the enforcement conference, include prompt action to correct the procedural deficiency and plant hardware problems and a comprehensive effort to address underlying concerns about a negative performance trend on the part i
of operating and support personnel, including the development of an Operations Performance Enhancement Program.
I
b To emphasize the importance of effective and lasting action to reverse negative trends in the control of licensed activities and the performance of licensed operating personnel, I have been authorized after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $25,000 for the Severity Level 111 problem described above.
The base value of a civil penalty for a Severity Level III problem is $50,000.
The civil penalty adjustment factors in the Enforcement Policy were considered and resulted in a reduction of $25,000 (50 percent of the base value) based on the corrective actions that you have taken or have planned. Although you described many of these issues as self-identified during your enforcement conference presentation, the NRC did not mitigate the penalty under the
" Identification" factor because we view the majority of these violations and performance problems as having been revealed by plant events.
The remaining adjustment factors were considered but no further adjustments to the base penalty were considered appropriate.
OPPD is required to respond to this letter snd should follow the instructions specified in the enclosed Notice when preparing its response.
In its response, OPPD should document the specific actions taken and any additional actions it plans to prevent recurrence. After reviewing OPPD's response to
.this Notice, including its 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.
Please note that not all of the apparent violations discussed in the inspection report are cited in the Notice.
As discussed above,.no violations are being cited regarding the movement of a CEA because equipment failure was the primary cause of that event.
In addition, the apparent violation of Technical Specification 2.5, which requires that both AFW punips be operable during power operations, is not being separately cited in this instance because the underlying procedure violation is being cited.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
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.
S:ncerely, L.
. Callan Rec onal Administrator
Enclosure:
Notice of Violation-and Proposed imposition of Civil Penalty cc w/
Enclosure:
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Enclosure:
LeBoeuf, Lamb, Leiby & MacRae
- ATTN: -Mr. Michael F. McBride IS75. Connecticut Avenue, NW 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 Nebraska Department of Health ATTN: Harold Borchert, Director Division of Radiological Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Fort Calhoun Station ATTN:
James W. Chase, Manager P.O. Box 399 fort Calhoun, Nebraska 68023 1
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