ML20210D629
| ML20210D629 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/26/1987 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20210D635 | List: |
| References | |
| EA-86-176, NUDOCS 8702100130 | |
| Download: ML20210D629 (4) | |
See also: IR 05000285/1985022
Text
a
-
'
'l
-.
,
,
,
D
c,4
UNITED STATE 3
,
-*
y
NUCLEAR REGULATORY COMMISSION
'
,
-h-
.
REGION IV
S
sf
$11 RYAN PLAZA DRIVE. SUITE 1000
\\
8
ARUNGTON, TEXAS 79011
JM 2 6 SBT
> Docket No. 50-285
l
'
License No. DRP-40
EA 86-176
!
i
Omaha Public Power District
L
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 REPORTS NO. 50-285/85-22 AND NO. 50-285/85-29)
r
This refers to the Safety Systems Outage Modifications Inspections (SSOMI)
i
conducted of activities authorized by NRC License No. DPR-40 during the
1985(50-285/85-22),and
periods September 16-20, 30, and October 1-8,(50-285/85-29)at the Fort
November 6-8, 18-22, and December 9-17, 1985
Calhoun Station. The special inspections identified violations of NRC
!
' requirements in the design, installation, and testing of certain modifications
at the Fort Calhoun Station. Accordingly, an enforcement conference was
conducted in the Region IV office on July 10, 1986 to discuss the apparent
violations and other concerns identified during the SS0MI.
l
Violation I of the enclosed Notice of Violation and Proposed Civil Penalty
I
(
(Notice)involvesasignificantviolationassociatedwiththemodificationof
!
the steam admit valve to the turbine-driven auxiliary feedwater pump steam
supply system without conducting and documenting a review in accordance with
!
10 C.F.R. I 50.59. The proposed modification consisted of a change to the
consion steam admit valve (YCV-1045) from the " fail close" to the " fail open"
design mode with the addition of safety-related air accumulator systems for
the two individual " fail open" steam supply valves (YCV-1045 A and B). Air
accumulators were to provide the capability for remote manual operation of
the steam supply valves upon loss of non-safety-related instrument air. Plant
personnel, however, only partially completed the modification in March 1980
by changing the steam admit valve to the " fail open" design mode without adding
the air accumulators to the steam supply valves. This partially completed
modification introduced an unreviewed safety question in that during a steam
generator tube rupture incident with concurrent loss of non-safety-related
instrument air, the inability to close the steam supply valves would result
in an additional fission product release path not previously analyzed in the
Updated Safety Analysis Report (USAR). The facility was operated in this
unanalyzed condition from March 1980 until the two individual steam supply
valves were equipped with safety-related air accumulator operating systems
dt. ring the 1985 refueling outage.
It is significant that during the period between 1980 and 1985, several organi-
zationswithinOmahaPublicPowerDistrict(OPPD)wereapparentlyawareof
the partial modification. Further, when a safety evaluation was performed
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
8702100130 870126
~
$DR
ADOCK 05000285
p%
l
L-
- -
- - -
-
.
'
.
.
.
.
Omaha Public Power District
-2-
on January 15, 1985, it was inappropriately concluded that an unreviewed
safety question did not exist when, in fact, one did exist. This violation
reveals weaknesses in your program for the review of plant changes and in
the administrative controls established to assure that design reviews are
properly performed, including safety evaluations performed in accordance with
the requirements of 10 C.F.R. 5 50.59.
To emphasize the need for improved management attention in the area of
10 C.F.R. I 50.59 reviews, I have been authorized, after consultation with the
Director, Office of Inspection and Enforcement, to issue the enclosed Notice
of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty
ThousandDollars($50,000)forViolationIdescribedintheenclosedNotice.
In accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions," 10'C.F.R. Part 2, Appendix C (1986) (Enforcement Po?. icy),
Violation I in the enclosed Notice has been categorized as a Severity Level III
violation. The base civil penalty for a Severity Level III violation is
$50,000, and although the escalation and mitigation factors in the Enforcement
Policy were considered, no adjustment was deemed appropriate in this case.
Violations in Section II of the enclosed Notice involve additional deficiencies
identified in the areas of design control, equipment testing, maintenance pro-
l
cedure adequacy and accuracy, control of special processes, control of material
!
storage, corrective action, and document control. Although these deficiencies
were considered as less serious than those described in Violation I and have
been categorized as Severity Level IV violations, the numerous deficiencies
in the areas of design control and procedural adequacy and adherence demon-
strate the need for increased management attention in these areas.
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
I
actions you plan to prevent recurrence. You may reference previous correspon-
dence or discussions which described your actions taken to correct the violations.
After reviewing your response to this Notice, including your proposed corrective
actions, the NRC 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,
l
.
'
.
..
.
c'52' 2E TUJ
Omaha Public Power District
-3-
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, Pub. L. No.96-511.
Sincerely,
/
A
>
h
Y ll-
V
obert D. Martin
Regional Administrator
Enclosure:
Proposed Imposition of
Civil Penalty
cc w/ encl:
W. G. Gates, Manager
Fort Calhoun Station
P. O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NW
20036
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
,
!
l
l
l
l
-_
_ . - _ _
- -
- .
-
. . - . _ . - .
.
--_ _ _ - _ - . , _ _ . . _ . - - - - - - . . - . -
.
.
~
1
.. _ __
.
-
-
.
.
.
Omaha Public Fower District
d4N 2 6 IS87
DISTRIBUTION:
SECY
CA
JMTaylor, IE
RStarostecki, IE
BBeach, IE
EYachimiak, IE
BGrimes, IE
JKonklin, IE
RArchitzel, IE
JLieberman, OGC
Enforcement Officers
RI, RII, RIII, RIV, RV
FIngram, PA
HDenton, NRR
BHayes, 01
SConnelly, OIA
4
JCrooks, AEOD
ES File
EA Eile - ~-
EMENb i
RIV Distribution:
Regional Administrator
DRSP Division Director
f'
RPB Branch Chief
. ', p'
PS-B Section Chief
pr
Inspector (2 copies)
A
'/
W
PA0 (1tr hd)
,)
[V
k {p F) 7
RIV Files
MIS Coordinator
i
_.
RIV:PS
C/P
C/RPB
/
D/DRSS
E0
MEMurph
c
ter
JEGagl[
do
EHJohnson
DAPowers
10/gi86
10/4486
10/7,1 [8
10/p/86
14/ 3 /86
g
~
~ ~~~~
-
__
I, k g?
d
%%
fe'sk* *
uff.em
E
gy
~/e A a t*!
gg ,
IE:ES
E
IE:DD
HWona
RMartin
JLieberman
BBeach
RS<:prostocki
J
r
1//87
1/6/87
1/ M 87
1 g; /87
1/f/87
1//J /87
/
/
. - .
--
..
.
._.
_.
._