ML20149L827

Discusses Insp Rept 50-285/87-27 on 870923,1002 & 1102-06 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty

ML20149L827
Person / Time
Site:	Fort Calhoun
Issue date:	02/22/1988
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20149L829	List: ML20149L827 ML20149L835
References
EA-87-210, NUDOCS 8802250063
Download: ML20149L827 (2)

See also: IR 05000285/1987027

Text

. ,

g#% UNITED STATES

y" ', NUCLEAR REGULATORY COMMISSION

$ "

REGION IV

k, 811 RYAN PLAZA DRIVE, SUITE 1000

ARUNGTON, TEXAS 79011

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FE8 2 2 288

Docket No. 50-285

License No. DPR-40

EA 87-210

Omaha Public Power District

ATTN: R. L. Andrews, Division Manager-

Nuclear Production

1623 Harney Street

Omaha, Nebraska 68102

'

Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

(NRC INSPECTION REPORT 50-285/87-27)

This refers to inspections conducted during the periods of September 23 through

October 2, 1987, and November 2-6, 1987, of activities authorized by NRC

Operating License DRP-40 for the Fort Calhoun Station, by personnel of the NRC

Region IV office. The inspections included reviews of the events that

resulted in the inoperability of Emergency Diesel Generator (EDG) 2 due

to the introduction of water into the Instrument Air System on July 6 and a

sepacate occurrence on August 25, 1987. As a result of these inspections, it

was found that certain of your activities were in violation of NRC requirements.

Accordingly, an enforcement conference was held in the Region IV office on

October 29, 1987, to didoss the issues related to these events. On October

23, 1987, NRC Inspectics ' sport 50-285/87-27 was issued to provide details of

the initial inspection performed September 23 through October 2, 1987, and NRC

Inspection Report 50-285/87-30 was issued on December 10, 1987, to provide

details of the followup inspection performed November 2-6, 1987, by a special

review team from the NRC's Region IV office.

Inadequate evaluation and testing of a plant modification as well as inadequate

procedures led to a situation where an emergency diesel generator was rendered ;

inoperable because of the intrusion of water into the instrument air system.

Additionally, once the water intrusion was discovered it was not adequately

corrected, properly classified as a Notice of Unusual Event (NOVE) or properly

reported to the NRC. Collectively, the sequence of events outlined above

indicate a significant failure of your management control system to ensure

t activities that affect quality were properly conducted at the Fort Calhoun

Station. This fsilure resulted in the plant being operated in an unanalyzed

condition where a potential common mode failure condition existed.

To emphasize the need to improve your management control program, I have been

authorized, after consultation with the Director, Office of Enforcement, and

the Deputy Executive Director for Regional Operations, to issue the enclosed

Notice of Violation and Proposed Imposition of Civil Penalty in the amount of

One Hundred Seventy-Five Thousand Dollars ($175,000) for the violations described

in the enclosed Notice. In accordance with the "General Statement of Policy

andProcedureforNRCEnforcementActions,"10CFRPart2,AppendixC(1987)

!. (Enforcement Policy), the two violations and the one problem described in the

l enclosed Notice have each been categorized at Severity Level III. The base

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value of a civil penalty for a Severity Level III violation is $50,000. The

escalation and mitigation factors in the Enforcement Policy were considered.

The base civil penalty amount for Violation A has been increased by 50% because

of poor enforcement history in the area of concern.

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

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

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

actions you plan to prevent recurrence. In formalizing your corrective actions,

you should be aware that the three Severity Level III problems arising out of

the inspections are a clear indication of a need to take strong and effective

corrective actions in the area of your management controls. After reviewing

your response to this Notice, including your proposed corrective actions and

the results of future inspections, the NRC will determine whether more stringent

enforcement action is necessary to ensure lasting corrective action in this

area.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, t

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC Public Document Room. The responses directed by i

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  !

of 1980, Pub. L. No.96-511. '

Sincerely,

f

[

Robert D. Martin  :

Regional Administrator l

Enclosure: I

Appendix - Notice of Violation and Proposed

Imposition of Civil Penalty

l

ec w/ enclosure-

W. G. Gates, Manager

Fort Calhoun Station

P. O. Box 399

Fort Calhoun, Nebraska 68023 d

Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, NW

Washinfon,DC 20036

Kansas Radiation Control Program Director

Nebraska Radiation Control Program Director

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