ML20197A705

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/97-18
ML20197A705
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 12/18/1997
From: Johnson W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Gambhir S
OMAHA PUBLIC POWER DISTRICT
References
50-285-97-18, NUDOCS 9712230145
Download: ML20197A705 (4)


See also: IR 05000285/1997018

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S. K. Gambhir, Division Manager

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Fort Calheun Station FC-2-4 Adm.

P.O. Box 399

Hwy. 75 -~ North of Fort Calhoun

Fort Calhoun, Nebraska 68023-0399

SUBJECT:

NRC INSPECTION REPORT 50-285/97-18

Dear Mr. Gambhir:

Thank you for your letter of December 9,1997,in response to our letter and Notice

of Violation dated ..ovember 10,1997. .Wo have reviewed your reply and find it

tresponsive to the concerns raised in our Not.ce of Violation. We will review the

implementation of your corrective actions during a future inspection to determine that full

= compliance has been achieved and will be maintained.

Sincerely,

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W. D'. Johnson, Chief

Project Branch B

Division of Reactor Projects

Docket No.: 50-285

License No.: DPR-40

cc:

James W. Tills, Manager

Nuclear Licensing

Omaha Public Power District

' Fort Calhoun Station FC-2-4 Adm.

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Fort Calhoun, Nebraska 68023-0399

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ames W. Chase, Manager

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Winston & Strawn

1400 L. Street, N.W.

Washington, D.C. 20005-3502

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Cheryl Ro0ers, LLRW Program Manager-

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Lincoln, Nebraska: 6J509-5007

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December 9,1997

LIC-97-0190

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Mail Station PI 137

Washington, DC 20555

References:

1.

Docket No. 50-285

2.

Letter from NRC (W. J. -Johnson) to OPPD (S. K. Gambhir) dated

November 10,1997

SUBJECT:

NRC Inspection Report No. 50-285/97-18, Reply to a Notice of Violation

The subject report transmitted a Notice of Violation (NOV) resulting from an NRC inspection

conducted September 14, through October 25,1997 at the Fort Calhoun Station (FCS). Attached

is the Omaha Public Power District (OPPD) response to .his NOV.

If you should have any questions, please contact me.

Sincerely,

.

S, K. Gamt,hir

Division Manager

Engineering and Operations Support

SKG/ddd

Attachment

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Winston and Strawn

E. W. Merschoff, NRC Regional Administrator, Region IV

L. R. Wharton, NRC Project Manager

W. C. Walker, NRC Senior Resident Inspector

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Attachment

LIC 97 0190~

Page 1

REPLY TO A NOTICE OF VIOLATION

Omaha Public Power District

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50-285

Fort Calhoun Station

License:

IFR-80

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During an NRC inspection conducted on September 14, through October 25,1997, a violation

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of NRC requirements was identified. In accordance with the " General Statement of Policy

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and Procedure for NP.C Enforcement Actions" NUREG 1600, the violation is listed below:

Appendix B of 10 CFR Part 50, Criterion V, states, in part, that activities affecting

quality shall be prescribed by documented instructions, procedures, or drawings, of

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a type appropriate to the circumstance and shall be accomplished in accordance with

these instructions, procedures, or drawings.

Standing Order SO-M 2, " Preventative Maintenance Program," Revision 24, Step

10.1, states, in part, those preventive maintenance work plans not completed by their

duc date sh-ll have Form FC-1066 initiated to obtain approval for deferral.

Preventive Maintenance Order 9603504, which involved cleaning and eddy current

testing of a-spent fuel pool heat exchanger, was scheduled to be completed on

November 2,1996.

Contrary to the above, Preventive Maintenance Order 9603504 was not completed by

the due date, and the licensee did not initiate the required documention to authorize

deferral of th., preventive maintenance.

This is a Severity Level IV Violation (Supplement I) (285/97018-02)

1.

The Reason for the Violation

A Preventive Maintenance Order was tasked to perform an eddy current test on the Spent

Fuel Pool Heat Exchanger during the 1996 Refueling Outage. This task was removed from

the outage scope using the Outage Scope Change / Addition Request process in accordance

with the requirements of Standing Order M-104. However, no Preven;ive Maintenance

Program Task Deferral / Administrative Closcout form was completed.

The cause of this event was failure to follow the appropriate procedural process for deferral

of preventive maintenance tasks in that the required deferral form, FC-1066, was not

completed in accordance with the requirements of Standing Order M-2.. A contributing

cause was that the Outage Scope Change / Addition Request (OSCAR) process in Standing

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LIC 97-0190

Page 2

Order M 104, Outage Planning and Execution, did not contain a procedural reference to

Standing Order M 2, Preventive Maintenance Program, for completion of the Preventive

Maintenanec Order (PMO) Deferral form, FC-1066.

2.

Corrective Steps Which Have Been Taken and the Results Achieved

A Preventive Maintenance Program Task Deferral / Administrative Closeout form has been

completed and approved for PMO 9603504'.

A review of outage PMOs was r:rformed to determine if other taska were removed from the

outage scope without thC pmper deferral. This review revealed an additional 45 PMOs that

required attention.

3.

Corrective Steps Which Will Be Taken to Avoid Further Violmm

The 45 outage PMOs will be evaluated and deferred in accordance with the requirements

of Standing Order 50-M-2. This action will be completed by December 31,1997.

Standing Order SO-M-2 and Standing Order M-104 will be revised to clarify the interface

between Outage Scope Change / Addition Request fonn and the requirements for PMO

deferral. These revisions will be completed by January 31,1998.

4.

Date When Full Compliance Will Be Achieved

OPPD is currently in full compliance for PMO 9603504 and will be in full compliance for

the other 45 outage PMOs by December 31,1997.

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