ML20034C962
| ML20034C962 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/29/1990 |
| From: | Gates W OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9006040189 | |
| Download: ML20034C962 (4) | |
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j Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 May 29, 1990 LIC-90 0409 U. S. Nuclear Regulatory Commission j
Attn: Document Control Desk Mail Station PI-137 Washington, DC 20555 l
REFERENCES:
1.
Docket No. 50 285 l
2.
Letter from NRC (S. J. Collins) to OPPD (W. G. Gates) dated l
April 27, 1990 Centlemen:
SUBJECT:
Response to Notice of Violation - Inspection Report 50 285/90-14
(
Omaha Public Power District (OPPD) received the subject inspection re) ort which l
identified one violation.
The violation involved the failure to esta)1ish i
adequate abnormal operating procedures (A0Ps).
Please find attached OPPD's i
response to the Notice of Violation in accordance with 10 CFR Part 2.201.
If you should have any questions, please contact me.
Sincerely, 4Y.N. h W. G. Gates Division Manager l
Nuclear Operations WGG/si-1 Attachment c:
LeBoeuf, Lamb, Leiby & MacRae A. Bournia, NRC Project Manager R. D. Martin, NRC Regional Administrator, Region IV i
l P. H. Harrell, NRC Senior Resident Inspector
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ATTACHMENT RESPONSE TO A NOTICE Of VIOLATION i
During an NRC inspection conducted on March 12 16, 1990, a violation of NRC requirements was identified.
The violation involved the failure to establish adequate abnormal operating procedures.
In accordance with the
- General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989) (Enforcement Policy), the violation is listed below:
Inadeounte Abnormal Operatina Procedures Technical Specification 5.8.1 requires that, ' Written procedures... shall be established, implemented,... that meet or exceed tie minimum t
requirements of sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33...."
Regulatory Guide 1.33, Appendix A, Section 6, requires procedures for l
combating emergencies and other significant events. This includes the following:
Expected transients Loss of electrical power (and/or degraded power sources) fort Calhoun Station Updated Safety Analysis Report, Section 12.3.2, states, " Plant operation during abnonnal conditions are conducted in accordance with written... procedures. These emergency procedures have been written such that the operator can readily perform the immediate action necessary based on a given set of conditions..."
Contrary to the above, the following are examples of procedures that were not adequately established.
1.
Abnormal Operating Procedure AOP-16 " Loss of Instrument Bus Power,"
Revisten 0 (January 4,1990), did not address the loss of vital equipment powered from the four 120V AC inverter buses, such as radiation monitoring panels and steam generating level controls.
The procedure did not provide guidance for operations during the potential off-normal conditions associated with the loss, or degradation of a 120V AC inverter bus.
2.
Written procedures had not been established addressing the loss or degradation of the following vital electrical power sources:
4160V AC Vital bus IA3 or IA4 l
480V AC Vital Buses IB3A,1838,183C, IB4A,1848,1840, 3A-4A, 38-48, 3C-4C 125V DC Vital Bus DC-1 (EE-8F), Al-41A; or DC-2 (EE-8G), AI-41B This is a Severity Level IV Violation. (Supplement I)
.Page 2 OPPD Response:
1.
The Reason For The Violation. If Admitted OPPD admits to the violation as stated.
Prior to Inspection 90 14, it was OPPD's opinion that the existing combination of E0Ps, A0Ps and Alarm Response Procedure (OP-10) were adequate to respond to a loss of an individual electrical bus.
OPPD had initiated action to respond to Inspection follow up Item (285/8936 03) concentrating on upgrading Alarm Response Procedures (ARPs) to enhance OPPD's ability to respond to loss of electrical buses. However, no upgrade work associated with a loss of an electrical bus had been undertaken at the time of Inspection 90-14 on the ARPs. The A0Ps were being upgraded as part of SEP-49, but the A0P upgrade was limited to reformatting and assuring technical accuracy of the existing AOPs. This upgrade did not ex)and the scope of the A0Ps which would have i
been necessary to respond to t11s concern.
2.
The Corrective Steps Which Have Been laken And The Results Achieved OPPD has initiated an upgrade to AOP-16 " Loss of Instrument Bus Power" to address the concerns identified in Inspector Follow-up Item (285/8936 03) to provide guidance on operator res)onse to loss of vital equipment or other equipment which would cause tie plant to undergo a significtnt transient.
3.
Corrective Actions That Will Be Taken To Avoid Further Violations To avoid further violations involving the availability of written procedures for combatting emergencies and other significant events OPPD is taking the following actions:
a.
As discussed in item 2, OPPD is currently in the process of upgrading AOP-16, " Loss of Instrument Bus Power".
This upgrade will encompass losses of any of the following instrument buses:
1)
The four vital 120V AC instrument buses (instrument buses A, B, C, and D) 2)
The two non vital 120V AC instrument buses (instrument buses 1 and 2) 3)
The two vital 125V DC instrument buses (DC buses DC 1 and DC 2)
OPPD expects the upgrade of A0P-16 to be completed by October 1, 1990.
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b.
OPPD plans to develop a new Abnormal Operating Procedure to direct j
operator actions under the following circumstances:
1)
A Loss of Offsite Power or Station Blackout while the unit is shut down.
2)
Loss of any single vital 4160V AC power bus, vital 480V AC power bus, or vital 480V AC Motor Control Center.
OPPD expects the development of this new procedure to be completed by March 1, 1991.
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$Page 3 l
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Date When Full Comoliance Will Be Achieved.
i With the implementation of the changes to AOP 16, and with'the development i
of the new AOP.cn loss of AC power buses, OPPD expects to h in full
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compliance with the requirements of Technical Specification 5.8.1 as they relate to abnormal operating procedures, by March 1, 1991.
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