ML20199H824

Notice of Violation from Insp on 971207-980117.Violations Noted:Changes to Operating Procedures Affecting Nuclear Safety Were in Effect,Implemented,Via Five Different Operations Memos W/O Performed Requirements of TS

ML20199H824
Person / Time
Site:	Fort Calhoun
Issue date:	01/28/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199H799	List: ML20199H794 ML20199H824 ML20199H861
References
50-285-97-20, NUDOCS 9802050130
Download: ML20199H824 (2)

Text

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l ENCLOSURE 1 NOTICE OF VIOL.ATION Omaha Public Powar District Docket No.: 50-285  :

9 Fort Calhoun Station License No.: DPR 40-During an' NRC inspection conducted on December 7,_1997, through January 17,1998, one violation of NRC requirements was identified. In accordance with the " General Statement of -

. Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below: s

[ Technical Specification 5.8.1 requires lin part, that written procedures and administrative policies  :

shall be established, implemented, and maintained that meet or exceed the minimum '

requirements of Appendix A of NRC Regulatory Guide 1,33.-

1 Technical Specification 5.8.7 aquires that changes to procedures of Technical' L Specification 5.8.1 determined to affect nuclear safety shall be reviewed and approved as

! described in this section.

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Technical Specification 5.8.2,1 requires, in part, that each procedure, or change thereto, shall be -

reviewed by a Qualified Reviewer who is knowledgeable in the functional area but is not the p

Individual preparer, and the reviewer shall render a determination, in writing, of whether cross-

disciplinary review of the change is necessary. 1

_ Technical Specification 5,8.2.2 requires,- in part, that the Department Head shall review each procedure, or change thereto, and the review shall include a determination of whether or not a -

10 CFR 50.59 safety evaluation is required.

Standing Order SO-G-30, ? Procedure Change and Generation," Revision 74, provided the -

. required procedure to implement Technical Specification 5.8.2.

f L Contrary to the sbove, between' October 16 and December 12,1997, changes to operating

procedures affecti.ng nuclear safety were, in effect, implemented, via five different operations memorandums, without having performed the requirements of Standing Order SO-G-30l The

' practice of using operations memorandums to direct operator actions in emergency operating F procedures, abnormal operating procedures, and emergency plan procedures, without actually

- revising the procedurtis, introduced the vulnerability that required steps or actions may not get t performed during penods of high stress such as those that may be present when those

procedures are being ,'nplemented.

~ This'is'a Severity Level IV violation (Supplement 1) (50-285/9720-01).

Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District is hereby required to

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submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, l Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of i

9802050130 980128 PDR

, ADOCK 05000285 0 0 PDR 3

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the lotter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation: (1) thr, ,eason for the vio!alion, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the resulte achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed co,Tespondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the tJme specified in this Notice, an order or a Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be pisced in the PDR and provide the legal basis to support your request for withholding the information from the public.

Dated at Arlington, Texas this 28th day of January 1998