ML20079M239
| ML20079M239 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/04/1991 |
| From: | Gates W OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-91-272R, NUDOCS 9111080103 | |
| Download: ML20079M239 (3) | |
Text
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c, Omaha Public Power District 444 South 16th Street Mall November 4, 1991 Omaha. Nebraska 68102-2247 LIC-91-272R 402/636 2000 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, DC 20555
References:
1.
Docket No. 50 285 2.
Letter from NRC (A. B. Beach) to OPPD (W. G. Gates) dated October 3, 1991 Gentlemen:
SUBJECT:
NRC Inspection Report No. 50-285/91-21 Reply to a Notice of Violation The subject report transmitted a Notice of Violation resulting from an NRC inspection conducted August 14 through September 24, 1991 at fort Calhoun Station. Attached is the Omaha Public Power District response to this violation. Mr. A. B. Beach of Region IV agreed on November 1,1991 to a delay in submitting this response due to inclement weather conditions.
If you should have any questions, please contact me.
Sincerely,
- s. D. k W. G. Gates Division Manager Nuclear Operations WGG/sel c:
LeBoeuf, Lar.b, Leiby & MacRae R. D. Martin, NRC Regional Administrator, Region IV W. C. Walker, NRC Project Manager R. P. Hullikin, NRC Senior Resident inspector g\\
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e U. S. Nuclear Regulatory Commission LIC-91-272R ATTACHMENT REPLY TO A N0ilCE OF VIOLATION VIOLATIQH During an NRC inspection conducted on August 14 through September 24, 1991, a violation of NRC requirements was identified. The violation involved the failure to take prompt corrective action after a battery 1ar crack indicated the potential for a common-mode failure.
Inaccordancewlththe' General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1991), the viohtion is listed below:
Criterion XVI of A7pendix B of 10 CFR Part 50 and the licensee's approved Cuality Assurance Erogram require that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, the licensee failed to promptly correct an identified condition adverse to quality in that a station battery jar was discovered to be cracked on July 1,1991, but no corrective action was taken until a similar event occurred on September 11.
This is a Severity Level IV Violation.
OPPD Resoonse A.
Reason for the violation This violation resulted from inadequate a nlication of programs and procedures Omaha Public Power District (0))D)dverse to quality.
has established for identification and correction of conditions a These programs and procedures provide for use of case-specific evaluatien and engineering judgement based on available information and experience.
l l
Although several evaluations and corrective actions were initiated when the crack was discovered on July 1,d by past experience, gnificance and I
1991, the level of si the actions assigned were influence vendor guidance, and engineering judgement available at the time for previous similar cracking.
For example, a detailed, documented operability determination for the station batteries was not promptly initiated or performed after the crack was discovered in July; however, king in an engineering evaluation had been performed for similar crac another battery cell in res)onse to NRC questions in March, 1991.
This evaluation concluded that tiere was no operability concern and influenced the decision in July that the batteries were still operable.
l OPPD acknowledges that several opportunities for validatinknappropriate the I
operability status of the batteries were misse1 due to an signific.ance level being assigned to the issue as noted above.
More detailed guidance in equipment condition evaluation and action tracking programs could have improved response to this event.
U. S. Nuclear Regulatory Commission LIC-91-272R The less than optimal 0 PPD response to this event is not indicative of overall performance in identification and correction of conditions adverse to quality.
Programs, procedures, and implementation are audited by independent groups, such as the OPPD Quality Assurance organization.
These reviews have confirmed the overall effectiveness of the OPPD self-assessment and quality verification programs.
B.
Corrective steos taken and the results achievid The station batteries were declared inoperable and subsequently replaced during the resultant plant outage.
Licensee Event Report 91-18, submitted on October 15, 1991, details the history of battery cell cracking.
Based on an independent investigation completed October 8, 1991 by the plantNuclearSafetyReviewGroupluderecurrenceofthisviolation.OPPD has developed an actio noted in Section C below, to prec C.
Corrective steos that will be taken to avoid further violattgni Existing implementation and assessment programs for identification, tracking, and resolution of conditions adverse to quality have been evaluated, and enhancements necessary as a result of this violation will be implemented throuah an action plan.
S]ecific programs included in the action plan are Root Cause Analysis, Operability Evaluation, Nonconformance Reports, Incident Resorts, Plant Review Committee Action Tracking, and Trending / Performance Monitoring.
The enhancements will include more stringent documentation and review requirements for vendor information, increased assessment of generic implications and safety significance, and more stringeht analysis and review for operability evaluations.
The performance deficiencies which resulted in this violation will be reviewed by appropriate personnel in a " lessons learned" training package.
D.
Date when full compliance _will be achievsd The corrective steps noted above will be completed by January 31, 1992.
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