ML20210D689

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Noted:Change Made to Facility W/O Conducting & Documenting Review to Determine That Change Did Not Involve Unreviewed Safety Question

ML20210D689
Person / Time
Site:	Fort Calhoun
Issue date:	01/26/1987
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210D635	List: ML20210D629 ML20210D689
References
50-285-85-22, 50-285-85-29, EA-86-176, NUDOCS 8702100144
Download: ML20210D689 (13)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Omaha Public Power District Docket No. 50-285 Fort Calhoun Station License No. DPR-40 EA 86-176 During an NRC Safety System Outage Modification Inspection (SSOMI) conducted on i September 16-20, 30, and October 1-8, 1985 (documented in NRC Inspection Report No.50-285/85-22), and on November 6-8, 18-22, and December 9-17, 1985 (documented i- in NRC Inspection Report No. 50-285/85-29), a number of violations of NRC requirements were identified. The violations involved the design change and design change implementation programs related to the 1985 refueling outage. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 C.F.R. Part 2, Appendix C (1986), the Nuclear Regulatory Commission

-proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, (42 U.S.C. I 2282, (ACT)), and 10 C.F.R. I 2.205.

The particular violations and associated civil penalty are set forth below:

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1. Violation Assessed a Civil Penalty l 10C.F.R.I50.59(a)allowstheholderofalicensetomakechangesin the facility as described in the safety analysis report (SAR) without prior Commission approval unless it involves a change in the technical specifi-cations or involves an unreviewed safety question. An unreviewed safety question is created if the probability of occurrence or the consequences

of an accident or malfunction of ecuipment important to safety previously '

evaluated in the SAR may be increased, if a possibility for an accident l

or malfunction of a different type than any evaluated previously in the SAR may be created, or if the margin of safety as defined in the basis for any technical specification is reduced.

10C.F.R.I50.59(b) requires,inpart,thatthelicenseemaintainrecords

of changes in the facility to the extent that such changes constitute l

changes in the facility as described in the SAR. These records shall include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety j

question.

Section14.14oftheFortCalhounUpdatedSafetyAnalysisReport(USAR) states that during a steam generator tube rupture incident, gaseous fission products would be released to atmosphere from the secondary i I system at the condenser vacuum pump discharge. Those fission products not discharged in this way would be retained by the main steam, feedwater j and condensate systems.

Contrary to the above:

1. From March 1980 to January 1985, the licensee failed to meet the requirements of 10 C.F.R. I 50.59 in that a change was made to the facility as described in the USAR without conducting and documenting a review to detemine that the change did not involve an unreviewed j $5$$$h85 PDR

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Notice of Violation safety question. The change to the facility involved the modiff-cation of the auxiliary feedwater pump turbine consion steam admit valve (YCV-1045)fromthe"failclose"tothe"failopen" design mode, completed in March 1980, without the addition of a safety-related air accumulator system for the individual " fail open" steam supply valves (YCV-1045 A and B). The inability to close the " fail open" steam supply valves upon the loss of non-safety-related instru-ment air would result in an additional fission product release path, not analyzed in the USAR, for a steam generator tube rupture incident.

Consequently, the change involved an unreviewed safety question because the consequences of an accident previously evaluated in the USAR may have been increased.

2. On January 15, 1985 the licensee improperly analyzed the change to its facility as described above and concluded that an unreviewed safety question did not exist when, in fact, an unreviewed safety question did exist.

ThisisaSeverityLevelIIIviolation(SupplementI).

Civil Penalty - $50,000.

II; Violations Not Assessed a Civil Penalty A. 10 C.F.R. i 50.59(a)(1) .itates, in part, that the licensee may make changes in the facility as described in the safety analysis report, without prior Commission approval, unless a proposed change involves an unreviewed safety question.

10C.F.R.I50.59(b) requires,inpart,thatrecordsofchangesin the facility shall be maintained and the records shall include written safety evaluations which provide the bases for the determination that the changes do not involve unreviewed safety questions.

Contrary to the above, documented safety evaluations to determine whether changes constituted unreviewed safety questions were not available for:

1. Five(5)modificationstononsafety-relatedsystemsdescribed in the USAR. (InspectionReport(IR) 50-285/85-22 Deficiency (D)6.1-1)

2. The installation of lead shielding which had existed on safety-related piping for at least the past 21 years.

(IR50-285/85-29,D2.2-1)

3. A design change involving a penetration through a fire barrier which had been completed for several years. (IR 50-285/85-29, D2.2-2)

e Notice of Violation 4. Safety-related electrical jumpers which had been installed for as long as 18 months. (IR50-285/85-29,D2.2-3)

5. Three emergency modifications performed in 1983 and 1984 (MR 483-129 and MR 483-152 associated with the emergency diesel generators, and MR 484-84 associated with safety injection valves). (IR 50-285/85-22, UnresolvedItem(U)6.1-2)

ThisisaSeverityLevelIVviolation(SupplementI).

i B. TechnicalSpecification,Section2.19(8), requires,inpart,thata continuous fire watch be posted and backup fire suppression equipment be provided when the Halon fire suppression system is disabled in the switchgear room.

Contrary to the above, no continuous fire watch or backup fire suppression equipment were provided in the switchgear room during December 6-10, 1985, when the Halon fire suppression system was disabled. (IR50-285/85-29,D2.4-2)

This is a Severity Level IV violation (Supplement I).

C. Technical S)ecification 5.8.2 requires that procedures, which meet or exceed tie minimum requirements of Section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33, and changes thereto, shall be reviewed by the Plant Review Committee (PRC) and approved by the Manager, Fort Calhoun Station, prior to implementation.

Contrary to the above, procedure change 13494 to Operating Instruction 01-FW-3 for the steam generator level control was not reviewed by the PRC until November 8,1986, after both the approval of the change by the Plant Manager on November 2, 1984 and implementation of the change on November 1, 1984. (IR50-285/85-29,02.3-3)

ThisisaSeverityLevelIVviolation(SupplementI).

D. 10 C.F.R. Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to control design activities.

The OPPD Quality Assurance Plan (QAP), Section A.4, Design Control, implements this requirement and connits the licensee to the provisions of Regulatory Guide 1.64/ ANSI N45.2.11 - 1974.

ANSI M45.2.11, Section 3.0, " Design Impact Requirements;" Section 4.0,

" Design Process;" Section 5.0, " Interface Control;" Section 6.0,

" Design Verification;" and Section 8.0, " Design Change Control" require, in part, that design activities are to be controlled and planned in a manner that is correct and traceable and design changes are to be subject to design control measures cor.nensurate with those applied to the original design.

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Notice of Violation Contrary to the above:

1. The calculation associated with modification MR-FC-81-21.8, regarding containment isolation valves (HCV-4388 and HCV-4380) in the component cooling water system supply and return lines, contained incorrect and inappropriate assumptions without

- identification of their sources or justification for their use. (IR50-285/85-22,02.2-1)

2. The plant design specifications used for plant piping and equipment were not controlled and subject to design control measures consensurate with those applied to the original design. (IR50-285/85-22.D3.1-1)

3. The design inputs for modificetion MR-FC-84-162 were not controlled nor the final design related and traceable back to the source of design. (IR50-285/85-22,D3.2-3)

4. The operating and accident temperatures developed as design input for piping analyses pursuant to IE Bulletin 79-14 were not subject to design control measures commensurate with those appliedtotheoriginaldesign, including (provisionsforIR50-285/85-22,D3.1-2 necessary control of design interfaces.

5. The support spacing criteria differed from the seismic design criteria detailed in the USAR for piping penetrating the containment. (IR50-285/85-22,U3.1-3)

6. An adequate design analysis was not performed to IRsupp(ort the sizing of air accumulators for valves YCV-1045A/8. 50-285/85-22, 02.1-1)

7. The support for the modification of junction box J8-432A, which supplies power for auxiliary feedwater turbine steam admission valve (YCV-10458), was not subject to design control measures commensurate with those applied to the original design in that the junction box was restrained by a pair of unistrut supports, which were in turn, supported by conduits. No seismic analysis for the configuration was performed. (IR 50-285/85-22 D3.2-4)

8. The design verifier did not ensure that the seismic requirements were correctly selected and incorporated for modification MR-FC-83-158. (IR50-285/85-22,D2.1-2)

9. ineering The design engineer organization in the did not refer to OPPD Generating the original design Station ana Eno'ysis when preparing modification MR-FC-81-218. This resulted in a safety evaluation based on an incorrect assumption and methodology for the com (IR50-285/85-22, D2.2-6)ponentcoolingwatersystemheatloading.

ThisisaSeverityLevelIVviolation(SupplementI).

Notice of Violation E. 10 C.F.R. Part 50, Appendix B, Criterion IV, Procurement Document Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in documents for procurement of equipment and services.

The OPPD QAP, Section A.5, " Procurement Document Control," implements this requirement, and specifies the establishment of procedures to ensure that quality data be included in procurement documents.

Contrary to the above:

1. The procurement document for services associated with valves HCV-4388 and HCV-438D (Modification MR-FC-81-21B completed in 1983) did not address seismic analysis requirements. (IR50-285/85-22,D2.2-2)

I 2. The procurement documents for the steam generator nozzle dans (ModificationMR-FC-84-92)didnotaddressseismicrequirements.

1 (IR50-285/85-22,D3.2-6) f ThisisaSeverityLevelVviolation(SupplementI).

i F. 10 C.F.R. Part 50, Appendix B, Criterion V, Instructions Procedures, and Drawings, requires, in part, that activities that affect quality

! shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be J

accomplished in accordance with these instructions, procedures, and drawings. Instructions, procedures, or drawings shall include appro-4, priate quantitative or qualitative acceptance criteria.

l OPPD QAP, Section A.6, " Instructions, Procedures, and Drawings,"

l implements this requirement, and specifies, in part, that

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quality-related activities for plant operations, fabrication, i

processing, assembly, inspection, and test be accomplished in i

accordance with the instructions, procedures, or drawings and i

that such documentation adequately reflects all applicable quality l

requirements and contain the appropriate quantitative acceptance l

criteria (suchasdimensions, tolerances,andsamples)for determining that important activities have been satisfactorily j accomplished.

Contrary to the above:

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l 1. Instructions, procedures, or drawings were not adequate or appropriate for controlling the fol;owing safety-related i activities.

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! a. The installation / testing procedures for modifications

! MR-FC-83-158 and MR-FC-81-218 were incomplete in that they j did not contain acceptance criteria for acceptable air

' leakage and would not have confirmed that the I modifications produced the expected results. (IR50-285/

f 85-22,D2.1-7andIR50-285/85-22,D2.2-3)

Notice of Violation b. The test procedure included in MR-84-119 (replacement of l instrument inverters) did not contain adequate '

requirements for verifying acceptance during load testing i of battery charger #3. (IR50-285/85-29,D2.8-1)

) c. The test procedures included in MR 84-74A (fuse protection

for limit switches) did not include adequate requirements

, for the testing of the fuse protection for the limit 4

switches. (IR50-285/85-29,D2.8-2) 4 d. TheinstallationprocedureforMR83-158(additionofair i

accumulators) did not contain adequate instructions

regarding tubing configuration and accumulator tank l ,

locations. (IR285/85-29,D2.5-2)

c. TheinstallationinstructionforMR84-94A(fuse i protection for limit switches) did not contain adequate i detail to ensure that a 10% random inspection of splices i was performed as required. This procedural problem was i also noted in MR 85-009 and MR 84-179. (IR50-285/85-29,D2.4-1)

! f. TheinstallationprocedureforMR84-61(union i installationofSITreliefvalves)didnotprovidea caution statement or a hold point for verification of the p(rotectionofthe. valve 0-ringsduringwelding.

IR 50-285/85-29, D2.4-1)

g. The installation procedure for MR-84-105 (replacement of 4160/480 volttransformers)didnotprovideadequate i inspection requirements and hold points for visual inspections of the base welds by QC. (IR 50-285/85-29, D2.4-1) ,

I l h. The installation procedure for MR 85-42 (replace valve MS-100) did not provide sufficient detailed instructions to assure adequate conduct of the safety-related maintenance activities. (IR50-285/85-29,D2.4-1) i

) 1. TheinstallationprocedureforMR83-158(additionofair accumulators) regarding safety-related seismic instrument tubing did not provide installation criteria for the l tubing or seismic supports and did not reference the

applicable Stone and Webster guideline for the installation of seismic tubing and supports. (IR50-285/85-29, D2.4-1)

! j. TheinstallationprocedureforMR85-62(replacementof CCWflowelement)didnotprovideinstructionsorprovide i reference to another instruction for the proper makeup of a j flanged joint which was found to be out of parallel by i approximately .030" and was leaking. (IR50-285/85-29,D2.4-1 l

andIR50-285/85-29,D2.5-5)

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9 Notice of Violation ,

k. The installation instructions for MC 84-140 (delta T power process loops) were inadequate in that safety-related cables EC10483 and ED10484 were tie-wrapped to nonsafety-related cables in two electrical panels (AI-216 and A-217), contrary to USAR, Section 8.5.1.1.

-(IR50-285/85-29,D2.5-6)

1. TheflowdiagramfortheMainSteamSystem(11405-M-252) was not correct or current with the as-installed arrangement in the plant. (IR50-285/85-22,D2.1-8)

m. The system descriptions for the Auxiliary Feedwater System (III-4),CompressedAirSystem(III-10),andComponent CoolingWaterSystem(I-7)wereincorrectandnotupdated

. following completion of modifications as required by the Station Systems Acceptance fomat. (IR50-285/85-22,D2.1-9)

2. Instructions, procedures, or drawings were not followed regarding the following safety-related activities:

a. The seismic restraint for valve YCV-10458 was not completed in accordance with the specifications for MR-FC-81-127. (IR50-285/85-22,D3.2-7)

b. TheinstallationprocedureforMR81-80(seismicsupports -

on masonry wall) was not followed in that work was allowed to proceed without the verification of material adequacy required by a QC hold point and the shift supervisor was notnotifiedpriortoproceeding(withdrillingholesIR50-285/85-29,D2.4 through the battery room wall.

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c. Station Procedures 50 G21 " Station Modification Control "

and 50 G26A, " Quality Control Program," were not followed in that inspectors, who were not Level III certified, reviewed and approved procedures for adequacy of QC hold points. Also the engineers writing the procedures were not Level III certified. (IR50-285/85-29,02.4-2)

d. The controlling procedure Standing Order 0-20, " Equipment Tagging," was not followed in that the documented shift supervisor review was not provided for work in progress for tagging out breakers BKR C8-5 and CK4-33 during the performanceofMR84-119(replacementofinstrument inverters). (IR50-285/85-29,D2.4-2)

e. The maximum unsupported span requirement of 4 feet 6 inches specified in Section 4.2.2 of the Stone and Webster guideline for seismic tubing (was violated in four instances in modification MR 83-158 addition of air i

accumulators). (IR50-285/85-29,D2.5-2) l t

f Notice of Violation ) f. TheinstallationprocedureforMR84-61(union 4 installationonSITreliefvalves)wasnotfollowedin i

that the unions were installed incorrectly. (IR50-285/85-29, l i

D2.4-2)

g. The installation requirements for MR 84-61 (Union i l

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f installationonSITreliefvalves)wasnotfollowedin

that the installed relief valves on SI tank 6B were i incorrectly identified. (IR50-285/85-29,D2.5-4)  ;

f h. The Station Procedure 50 G-30 "Setpoint/ Procedure

! Changes," requirements were not followed in that training  !

associated with procedure change 13494 was not provided i prior to implementing the change. The procedure change l l

was dated on November 2, 1984, and the training sheets [

! were not issued to operators until November 5, 1984

! (IR50-285/85-29,D2.3-4) ,

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. 1. ThedesignverificationreviewforMR-FC-85-158(addition f ofairaccumulators)wasnotprovidedfortheinstallation of these items as required by GSE Design Procedure B-2.

(IR50-285/85-22,D2.1-6) l' 1

The verification or checking of the adequacy of the design l I j.

j i inputs, such as load tables used and the reliance on ear ,ier i nonverifiedcalculations,forMR-FC-84-119(battery ,

! chargerandinverterreplacement)werenotprovidedas l 1

required by 0 PPD Procedure GSE-8-11. (IR50-285/85-22,D5.1-1) (

j k.- Changes to drawings 11405-M-1, " Containment Heating, Ventilation, and Cooling," and 11405-2, " Auxiliary i

Building Heating and Ventilation " were not adequately j controlled in accordance with OPPD Procedure GSE-A-9 in i

that changes were made to the drawings contained in i l

j modification package MR-FC-82-178 based only on engineering sketches. (IR 50-285/85-22 D4.5-1)

1. Computer calculations associated with cable derating

,l factors resulting from installing a fire wrapping system  !

for modification MR-FC-85-25 were not verified in l 1

accordance with OPPD Procedure GSE-B-11. (IR50-285/85-22,  ;

j D5.2-1)  ;

! m. Weld inspections were not accomplished by QC as required [

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by Section 5.22 of GSEE-0517 for the transformer base weldstoembedmontsformodificationMR84-105(replacement I of 4160/480 volttransformers). (IR50-285/85-29,D2.5-7) i i

This is a Severity Level IV violation (Supplement I). ,

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Notice of Violation G. 10 C.F.R. Part 50, Appendix B, Criterion VI, " Document Control,"

requires, in part, that measures be established to control the issuance of documents, including changes thereto, which prescribe all activities affecting quality.

The OPPD QAP, Section A.7, " Document Control," implements this requirement and requires, in part, that document control requirements are to be established to assure that documents, including changes and documents related to contractors and subcontractors activities, are reviewed for adequacy and approved for release by authorized wrsonnel and are distributed to the location where the prescri>ed activity is performed.

Contrary to the above:

1. The control of construction drawings in the following construction packages was inadequate in that:

(IR50-285/85-29,D2.3-1)

a. MR85-009(replacepenetrationsubassemblies)and MR 84-119 (replace inverters) contained construction drawings not on the drawing list.

b. MR84-119(replaceinverters)containeddrawingswith incorrect revision numbers, a wrong number'in the drawing list,andtwodrawings(samerevisionanddate)with different information.

c. MR83-158(additionofaccumulators)hadnoPipingand Installation Diagrams (P81Ds) in the construction package.

2. Drawingfilenumber39881forMR84-105(replacementof 4160/480 volt transformers) contained pen and ink markups and changestoindicateclarificationtotheweldsy(mbolismandno field change number was entered and approved. IR 50-285/85-29, D2.3-5)

3. InstallationproceduresforMR84-96(replaceHFArela MR 84-51 (replace Dresser-Hancock valves), MR 83-158 (ys),

addition of air accumulators), and MR 84-61 (union installation on SIT reliefvalves)containedpenandinkchangesandadditions without approved field changes or procedure changes being provided in accordance with 50 G-30. (IR50-285/85-29,D2.3-2)

4. Loop calibration procedures for CP-X/905 and CP-X/902 associatedwithMR85-009(replacementofpenetration subassemblies) contained seven procedure revisions without approved field changes being provided in accordance with 50 G-30. (IR50-285/85-29,D2.3-6)

ThisiseSeverityLevelIVviolation(SupplementI).

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Notice of Violation H. 10 C.F.R. Part 50, Appendix 8, Criterion IX, Control of Special '

i Processes, requires, in part, that measures shall be established to assure special processes are controlled. .

4 OPPD QAP, Section A.10, " Control of Special Processes," implements this requirement and requires, in part, that written procedures and controls be prepared to assure that special processes, including welding and nondestructive testing, are accomplished by qualified personnel using qualified procedures in accordance with the appli-cable codes, standards, specifications, criteria, and other special requirements.

' Contrary to the above, the control of welding and nondestructive examination was inadequate in that:

1. The weld on SIT 68 relief valve unions (MR 84-061) contained an

unacceptable crater pit in the lower pipe weld and had been 1 previously accepted by QC. (IR50-285/85-29,D2.6-1) i i 2.

t Thesafety-)relatednonisolablesocketweldonMS-100had (MR85-042 been inspecte i- to be unacceptable and had to be repaired. (IR50-285/85-29,D2.5-1

andIR50-285/85-?9,D2.6-1) l 3. DyepenetrantinspectionsforMR85-062(replacementofCCW i

flow element) were t'und to have been accomplished and l

! accepted at surface temperatures below the minimum allowed by i procedures. The inspections were redone and two of four welds i

examined were found to be unacceptable because of linear

! Indications. (IR50-285/85-29,D2.6-1) i 4. A procedure for standard flat plate 90* fillet welds was used to accomplish skewed fillet welds, plug welds, pipe boss l

i attac ment welds, and seal welds for modification packages MR84-162(containmentHVACsupports)andMR85-62(replacement i

of CCW flow element) installed during the 1985 outage, i (IR50-285/85-29,D2.6-2) l 5. Welds completed during the outage on seismic conduit supports i and installation of the conduit and supports for MR 84-140 ,

I (deltaTpowerprocessloops)didnotconformtothe j installation procedure design details. (IR50-285/85-29,D2.5-6)

I ThisisaSeverityLevelIVviolation(SupplementI).

l  !. 10 C.F.R. Part 50, Appendix 8, Criterion XI!!, Handling, Storage and i Shipping, requires, in part, that measures shall be established to i control the handling, storage, shipping, cleaning and preservation

of material and equipment. ,

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Notice of Violation OPPD QAP, Section A.14, " Handling, Storage, and Shipping," implements this and requires, in part, that instructions or guidance for plant handling, preservation, storage, and control (including identification andsegregation)ofproductsarepreparedandapprovedpriorto arrival of the products at the plant.

Contrary to the aboy?, the program for the control of material in storage was inadequate in that:

1. Level B safety-related material was stored in a Level C storage

> area for up to 19 months. (IR50-285/85-29,D2.9-2)

2. Examples were found of safety-related material for which identification tags did not agree with material markings or other material documentation. (IR50-285/85-29,D2.9-2)

3. Quality control surveillance of temporary safety-related storage areas were not accomplished on the reouired monthly basis. (IR50-285/85-29,02.9-3)

4. Damaged safety-related cable was stored in Temporary CQE Storage Area 4 (IR50-285/85-29,D2.9-1)

5. Nonsafety related material was stored in safety-related temporary CQE Storage Area 17. (IR50-285/85-29,D2.9-1)

6. Safety-related material was found in Temporary Storage Area 14 without the required quality assurance acceptance tags.

(IR50-285/85-29,D2.9-1)

ThisisaSeverityLevelVviolation(SupplementI). ,

! J. 10 C.F.R. Part 50, A)pendix B, Criterion XVI, Corrective Action,

! requires, in part, tiat measures be established to assure that conditions adverse to quality are promptly identified and corrected. ,

The OPPD QAP, Section A.17. " Corrective Action," implements this j and requires, in part, that conditions adverse to quality are promptly identified, reported, and corrected.

Contrary to the above adequate corrective actions were not taken

! for two areas:

, 1. The installation of lead shielding continued without adequate controls after inspections by INP0 in 1982 and 1984 had identified difficulties in the program, and after an IE Information Notice had been issued in 1983 addressing '

' installation of lead shielding. (!R 50-285/85-29 D2.10-1)

2. No program existed for the resolution of discrepancies identified by the System Acceptance Comittee for those plant modifications which were accepted for system operation by the comittee with outstanding discrepancies. (IR50-285/85-29,02.10-2)

ThisisaSeverityLevelIVviolation(Supplement!)

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Notice of Violation Pursuant to the provisions of 10 C.F.R. 5 2.201, Omaha Public Power District is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 1000, Arlington, Texas 76011, within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. I 2232, this response shall be submitted under oath or affirmation.

Within the same time a's provided for the response required above under 10 C.F.R. I 2.201, Omaha Public Power District may pay the civil penalty by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the cumulative amount of fif ty Thousand Dollars ($50,000) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should Omaha Public Power District fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty in the amount proposed above. Should Omaha Pubite Power District elect to file an answer in accordance with 10 C.F.R. 6 2.205 protesting the civil penalty, such answer may: (1) deny the violations listed in this Notice in whole or in part, (2)demonstrateextenuatingcircumstances,(3)showerrorinthisNotice,or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 C.F.R. Part 2, Appendix C should be addressed. Any written answer in accordance with 10 C.F.R. 6 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 C.F.R. I 2.201 but may incorpnrate parts of the 10 C.F.R. I 2.201 reply by specific reference (e.g., citing page and paragraphnumbers)toavoidrepetition. Omaha Public Power District's attention is directed to the other provisions of 10 C.F.R. I 2.205, regarding the procedure for imposing a civil penalty.

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Notice of Violation Upon failure to pay any civil penalty due which has been subsecuently determined in accordance with the applicable provisions of 10 C.F.R. I 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the ACT, 42 U.S.C. 5 2282.

FOR THE NUCLEAR REGULATORY COMMISSION h" WA l kN -

Robert D. Martin Regional Administrator Dated at Arlington, Texas, thisg%ayofJanuary1987.

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