ML20207L905

Discusses Insp on 880406-0513 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty.Violation a Involves Potential for Common Mode Failure of air-operated Safety Injection & Refueling Water Tank Level Switches

ML20207L905
Person / Time
Site:	Fort Calhoun
Issue date:	10/12/1988
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20207L909	List: ML20207L905 ML20207L917
References
EA-88-145, NUDOCS 8810180020
Download: ML20207L905 (5)

Text

_ - _ _ _ _ _ . _ __.

. O' %4 UNITED ST ATES NUCLEAR REGULATORY COMMISS13N f{,,,ij 5?

l REoloN tv Gli RY AN PLAZA oRIVE, SUITE 1000

\ ,,,,, ARLINoTON. TEX AS 70011 I  !

t OCT I 2 19P3 Docket No. 50-285 ,

License No. DPR-40 EA 88-145 Omaha Public Power District ATTN: R. L. Andrews, Division Manager.

Nuclear Production 1623 Harney Street Omaha, Nebraska 68102 i Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY (NRC INSPECT!0N REPORT 50-285/68-15)

This refers to the inspection conducted during the period April 6 through May 13, 1988 at the Fort Calhoun Station by personnel of the NRC Regien IV office. As a result of this inspection, two violations of NRC requireraents ,

were identified and reported to theinvolving NRC: p(roblems that had been discovered by the licensee 1) th -

Safety injection and Refueling Water Tank (SIRWT) level controllers resulting  :

in a possible loss of safety in  !

Loss of Coolant Accident (LOCA)jection

and (2) a loss and containment of containment spray fle.1 during a integrity beceuse of a failure to reinstall a test cap on a pressure sensing line after

completion o'f a leak rate test. The details of these violations were described in an NRC . inspection report sent to ycu on June 1, 1988. An enforcement ,

conference was held in the Region IV office on June 8, 1988, to discuss these violations.

Violation A in the enclosed Notice of Violation and Proposed imposition of Civil Penalty (Notice) involves the potential for a comon mode failure of the air-operated SIRWT low level switches and is considered by the NRC staff i to be a significant violation of NRC requirements. Because of leakage past the accumulator check valves, which separate the non-safety-related and the safety- ,

related air supply to the SIRWT low level switches, a problem identified during  !

testing in April 1988, a loss of the normal air supply to these level controllers  ;

coincident with a LOCA could have resulted in the premature actuation of the i

I CERTIFIED MAIL RETURN RECEIPT REQUESTED

'[N 8810100020 881012 I

(

PDR ADOCK 05000293 Q FDC

>  ?

nCT I2 m Omaha Public Power District- .

1 recirculation actuation signal, which, if the containment sump were dry, could have resulted in the failure of the high head safety injection and containment spray pumps. Although this problem was identified in April 1988, it could have been identified earlier had you responded more aggressively to the results of 3 an NRC inspection in late 1985, in which a failure to test instrument air accumulator check valves was identified. The NRC staff considers the original installation of check valves designed for steam and water in the instrument 1 air system at the Fort Calhoun Station and the failure of your programs to 1 identify the SIRWT instrument air accumulator check valves as safety-related and to conduct appropriate tests to assure the performance of their safety function as major contributors to this violation.

l Violation B in the enclosed Notice involves a loss of containment integrity because of the failure to reinstall a test cap on a containment instrument l pressure sensing line (3/8-inch) after completion of a local leak rate test.

The cap was discovered missing during an audit that was in response to a previous violation issued in May 1987. Apparently, it had been missing for over a year. The NRC staff considers this violation significant because the missing cap could have resulted in a significant increase in radiation exposure to the public and plant personnel in the event of a design basis accident.

Technical Specification limits for leakage (local type B and C) were exceeded

by a factor of almost seven. In addition, the missing cap was not brought to the attention of the proper level of management which caused the Engineered

Safety Features instrumentation, which was affected, not to be placed in a tripped or bypassed condition. Further, it was not until the next day that i the cap was replaced.

L j

Violations A and B are similar in that an extended period of time elapsed before these potential safety significant problems were identified and j corrected although NRC inspections had indicated deficiencies in these areas.

For each case, a more aggressive response to correcting the previous deficiencies may have led to an earlier discovery of these problems and would l

have minimized the duration of the degraded plant conditions. To emphasize the j importance of promptly correcting deficiencies that have been brought to yv

' attention, I have been authorized, after consultation with the Director, Ofitee of Enforcement, and Deputy Executive Director for Regional Operations, to issue l the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in l the amount of Fifty Thousand Dollars ($50,000) for the violations described in j

the enclosed Notice, in accordance with the "General Statement of Polic Procedure for NRC Enforcement Actions " 10 CFR Part 2, Appendix C

! (Enforcement Policy), Violations A and B described in the enclosed Notice have i been categorized as a Severity Level !!! problem. The base value The of a civil l

penalty for a Severity Level 111 problem or violation is $50,000.

escalation and mitigation factors in the Enforcement Policy were considered, j

The NRC recognizes that: you identified these violations; once the violations were identified, the corrective actions taken were broad and considered the implications of the violations; and your past performance The NRC viewsinthe theimplementation area of maintenance and surveillance has been good.

l of the Design Bases Reconstitution Program as a very positive action and i

h

CCT I 2 [goa Omaha Public Power District .

encourages your efforts in this program to continue. The NRC also notes that:

these violations should have been discovered earlier had more aggressive action been taken; immediate corrective actions to replace the missing test cap were not taken; and there was an extended duration for which the violations existed.

Therefore, on balance, neither mitigation nor escalation of the base civil penalty was considered appropriate.

The NRC staff also identified, as a result of this inspection, a concern with regard to the the SIRWT outlet Valves !.CV-383-1 and LCV-383-2, which provide parallel suction to the safety injection and containment spray pumps and isolate the SIRWT in the recirculation mode, and which are supplied by a single air accumulator assembly. While the single air accumulator was a part of the original licensing basis, the NRC staff understands that you plan to add an additional accumulator in the near future. This matter is presently under ,

review by the Office of Nuclear Reactor Regulation.

You are required to respond to this letter end should follow the instructions specified in the enciosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the Nht will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, 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 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 Act of 1980, PL 96-511.

Sincerel ,

e b{ f/(

Robert D. Martin Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty CC:

See attached i

OCT I 21983

- Omaha Public Power District cc w/ enclosure:

W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 '

Fort Calhoun,liebraska 68023 Harry H. Voigt, Esq.

LeBoeuf, Lanb Leiby & MecRae 1333 New Hampshire Avenue, NW Washington, DC 20036 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director

Onaha Public Power District 3 DISTRIBUTION:

bec w/ enc 1:

PDR SECY CA JMTaylor, DEDRO TMurley, NRR JLieberman, OE HWong, OE LChandler, OGC  !

Enforcement Officers R1, Ril, RIII, RV H0enton, OGPA EJordan, ACOD SConnelly, OIA OE:ES File

. _m BSumers, OE (1tr hd)

- oCS RIV Distribution:

RMartin JMontgomery JCallan BBeach TWesterman JGilliland (1tr hd)

GSanborn EO Files RIV Files '

HIS Coordinator CHackney PHarrell i

1 i

^%

(df i 5).46 l OE RIWk OGC D:0E DEDR0 HWong kORDMartin l M Chandler JLieberman JTaylor l 10/ 5 /88 \ 10/5 /88 10/ 5 /88 10/5/88 10/r/88 i H E 24mewwiw-1 wwf md<< h3 CM l