ML20128P615

Forwards Insp Rept 50-285/90-20 on 900820-31 & Nov. Violation Involved Failure to Establish & Maintain Appropriate Emergency Operating Procedures

ML20128P615
Person / Time
Site:	Fort Calhoun
Issue date:	10/31/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gates W OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20128P618	List: IR 05000285/1990020 ML20128P615 ML20128P632
References
NUDOCS 9610180027
Download: ML20128P615 (3)

See also: IR 05000285/1990020

Text

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UNITED STATES ,

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.< q NUCLEAR REGULATORY COMMISSION

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611 RYAN PLAZA DRIVE. SulTE 1000

%> , ,] , / ARUNGTON. TEX AS 76011

OCT 31 1990

Docket No. 50-285/90-20

License No. DPR-40

Omaha Public Power District

ATTN: W. G. Gates, Division Manager

Nuclear Operations

444 South 16th Street Mall

Omaha, Nebraska 68102-2247

Gentlemen:

SUCJECT: NOTICE OF VIOLATION

(NRC INSPECTION REPCRT NO. 50-285/90-20)

This refers to the Nuclear Regulatory Commission (NRC) special team inspection

conducted from Au 20-31. 1990, of activities authorized for the Fort

CalhounStation(gustFCS). At the conclusion of the inspection, the finding

discussed with you and other members of your staff.

This inspection was performed to ascertain if your emergency operating

procedures (E0Ps) were technically accurate; if their specified actions could

be meaningfully accomplished using existing equipment, controls, and

instruments; and if the available procedures had the usability necessary to

provide the operators with an effective operating tool. The areas examined

during the inspection are identified in the enclosed report. Within these

areas, the inspection team examined selective procedures and representative

records, conducted plant walkdowns, interviewed personnel, and observed the use

of E0Ps on the FCS plant-specific simulator.

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The team det, ermined that the E0Ps, when used by the standard complement of 4

trained operat6rs, could preclude serious damage to plant systems, mitigate

accident events, and place the plant in a safe shutdown condition. However,

the team qu.estioned

effectively the ability

under the minimal of the requirements

staffing operating crew ofto

the perform E0P actions }

Technical

Specifications. In addition, the team concluded that the licensee's 4

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verification and validation efforts for the current E0Ps were inadequate. l

There were several inconsistencies in the procedures, omission of important:

operator-action instructions, and errors between procedure action steps and

in-plant component designations. Other weaknesses in the E0P program are

$c: discussed in the report.

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oo Based on the results of this inspection, certain of your activities appeared to

5@ be in violation of NRC recuirements, as specified in the enclosed Notice of

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' Violation. We are concerned about the violation because it involved the

Ne failure to establish and maintain appropriate emergency operating procedures. ,

@a You are required to respond to this letter and should follow the instructions

@C specified in the enclosed Notice when preparing your response. In your

g response, you should document the specific actions taken and any additional

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maha Public Power District -2-

actions you plan to prevent recurrence. Af ter 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.

During the course of the inspection, you and other members of your staff made

consnitments regarding immediate and long-term actions you would implement to

resolve some of the concerns identified by the inspection team. These commit-

ments were discussed with you during the exit interview and during subsequent

telephone conversations and are sumarized in paragraphs 2.4 and 2.5 of the

enclosed report. In your letter of October 1,1990, you delineated your

imediate conunitments to address our concerns. If our characterization of your

commitments is correct, no additional statement of these commitments, on your

part, is required. If, hcwever, we have failed to correctly articulate your

commitments, please provide clarification of your commitments as part of your

response to the Notice of Violation.

We are concerned that you and your staff had received ample notice of the

types of concerns identified by inspections at other facilities, the NRC

inspection team identified a significant number of weaknesses that could have

been avoided had the available, lessons-learned been applied.

The response directed by this letter and the accompanying Notice is not subject

to the clearance procedures of the Office of lianagement and Budget as required

by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concernir.g this letter, please contact us.

Sincerely,

'?-f

Samuel J. Collins, Director

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Division of Reactor Projects

Enclosures:

1. Appendix A - Notice of Violation

E. Appe'ndif B - NRC Inspection Report *

50-285/90-20 w/ attachments

cc w/ enclosures:

leBoeuf, Lamb, Leiby & MacRae

ATTN: Harry H. Voigt, Esq.

1333 New Hampshire Avenue, NW

Washington, D.C. 20036

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Omaha Public Power District -3-

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Washington County Board

of Supervisors

ATTN: Jack Jensen, Chairman

Blair, Nebraska 68008

Combustion Engineering, Inc.

ATTH: 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

2

301 Centennial Mall, South

P.O. Box 95007

Lincoln, Nebraska 68509

Fort Calhoun Station

ATTN: T. L. Patterson, Manager-

P.O. Box 399

Fort Calhoun, Nebraska 68023

U.S. Nuclear Regulatory Commission

ATTH: Resident Inspector

>

P.O. Box 309

,

Fort Calhoun, Nebraska 68023

U.S. Nuclear Regulatory Commission

ATTN: Regional Administrator, Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, Texas 76011

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