ML20212B446
| ML20212B446 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/19/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8612290246 | |
| Download: ML20212B446 (1) | |
See also: IR 05000285/1986021
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DEC 19'1986
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In Reply. Refer To: .
Docket: 50-285/86-21
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- Omaha Public Power District
ATTN:. R. L. Andrews, Division Manager-
- Nuclear Production
.1623_Harney Street-
Omaha, Nebraska 68102-
. Gentlemen:
Thank you for your letters of October 2,1986,-and December 1,1986, in
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- response'to our letter and Notice of Violation dated September 2,1986.- We
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have reviewed your_ reply and find it responsive to the concerns raised in our-
- letter. We will review- the implementation of your corrective actions during a
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- future inspection to determine that full compliance has been achieved and will
be maintained.
Sincerely,
Original staned Cy
J. E. Gcs!!ardo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
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
Washington, DC 20036
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
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Omaha Public Power District
1623 Harney Omaha. Nebraska 68102 2247
402!536 4000
October 2, 1986
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LIC-86-505
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J. E. Gagliardo, Chief
Reactor Projects Branch
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U.S. Nuclear Regulatory Commission
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Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, Tx. 76011
References
1. Docket No. 50-285
2. Inspection Report 50-285/86-21, dated September 2, 1986
Dear Mr. Gagliardo:
Inspection Report 86-21
Omaha Public Power District (0 PPD) recently received Reference 2, con-
taining notice of two violations.
The violations involved the failure to
report a nonfunctional fire barrier and the failure to properly store
critical quality equipment (CQE) material. OPPD's response to these
violations is attached to this letter.
The attached responses are primarily intended to address the specifics of
the violations as cited in the inspection report.
OPPD management is also concerned about the more generic aspects of these
violations, as noted in your letter. An evaluation of some possible
courses of action to address these concerns is underway. Among options
being considered are enhancements to General Employee Training to in-
crease its effectiveness, further use of the Training Hotline process to
alert personnel to this sort of concern, and utilization of individual
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LIC-86-505
Page 2
personnel training to address concerns of the type noted.
OPPD will
notify you within 60 days of the course of action which will be pursued.
If you have any questions concerning this response, please do not
hesitate to contact us.
Sincerely,
/
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R. L. Andrews
Division Manager
Nuclear Production
RLA/DJM/me
Attachment
cc:
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Ave., N.W.
Washington, DC 20036
Mr. D. E. Sells, NRC Project Manager
Mr. P. H. Harrell, NRC Senior Resident Inspector
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ATTACHMENT
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During an NRC inspection conducted on July 1-31, 1986, two violations of NRC
requirements were identified. The violations involved the failure to report a
nonfunctional fire barrier and the failure to properly store critical quality
equipment (CQE) material.
In accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1985),
the violations are listed below:
Criterion XIII of Appendix B to 10 CFR Part 50 requires that measures be
a.
established to control storage of material to prevent damage or
deterioration.
Section 7.3, " Storage, Shipping, and Handling," of the licensee's Quality
Assurance Plan (QAP) has been established to implement the requirements of
Criterion XIII.
Contrary to the above, the licensee failed to properly store sacks of
boric acid in the plant to prevent possible damage or deterioration. As a
result, extraneous material was piled on top of the paper sacks containing
This is a Severity Level IV violation (Supplement I.D) (285/8621-01)
b.
Technical Specification (TS) 2.19(7) requires that a nonfunctional fire
barrier be restored within 7 days or a written report be prepared and
submitted to the NRC within an additional 30 days.
Contrary to the above, the fire barrier between the upper and lower elect-
rical penetration rooms was nonfunctional for greater than 30 days and the
licensee failed to prepare and submit a written report to the NRC.
This is a Severity Level V violation (Supplement I.E) (285/8621-02)
Pursuant to the provisions of 10 CFR Part 2.201, Omaha Public Power District is
hereby required to submit to this Office within 30 days of the date of the
letter transmitting this Notice, a written statement or explanation in reply,
including for each violation:
(1) the reason for the violaticn if admitted,
(2) the corrective steps which have been taken and the results achieved, (3)
the corrective steps which will be taken to avoid further violations, and (4)
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the date when full compliance will be achieved. Where good cause is shown.
consideration will be given to extending the response time.
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OPPD Response to Violation a.
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(1) Reason for the Violation
OPPD agrees that a violation occurred with the following mitigating
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circumstances.
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Attachment to LIC-8
05 (continued)
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10 CFR 50, Appendix B, Criterion XIII states in whole: " Measures shall be
established to control the handling, storage, shipping, cleaning and pres-
ervation of. material and equipment in accordance with work and inspection
instructions to prevent damage or deterioration. When necessary for par-
ticular products, special protective environments, such as as inert gas
atmosphere, specific moisture content levels, and temperature levels,
shall be specified and provided."
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Section 7.3 of OPPD's Quality Assurance Plan states, in part:
" Levels and
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methods of storage necessary shall be defined to minimize the possibility
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of damage or lowering of quality due to corrosion, contamination, deter-
ioration, or physical damage from the time an item is stored upon receipt
until the time the item is removed from storage and placed in its final
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location."
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Boric acid is procured by 0 PPD as a quality component and therefore, is
handled as such.
It is stored as ANSI N45.2.2 Level C in accordance with
plant Standing Order G-22. After the resident inspector brought this mat-
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ter to the attention of plant management, a temporary CQE storage area was
erected in accordance with plant standing orders. Subsequent to this
action, boric acid storage was specifically addressed by plant management
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and it was deemed that boric acid stored in the auxiliary building met the
requirements of ANSI N45.2.2, Level C storage. This change was incorpor-
ated into the Standing Order on July 10, 1986. Therefore OPPD believes
that the intent of 10 CFR 50, Appendix B and OPPD's QA plan was met.
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(2) Corrective steos which have been taken and the results achieved.
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A review of the present method of storage indicates that a permanent struc-
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ture would afford more protection and further limit access to the storage
area.
Since that time, OPPD management has decided that yet a more con-
servative approach to the storage of boric acid would be to build a cage
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wall around the storage area and thus, further limit access. OPPD has
issued a letter to operations and maintenance personnel to explain to them
the status of boric acid as a quality component and that it is stored in
conformance with plant Standing Order G-22.
Additionally, supervisory
tours have been increased in this area and no other anomalies, other than
those discovered by the NRC inspector, have been discovered.
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(3)
Corrective steos taken to avoid further violations.
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OPPD will increase the protection of the boric acid storage area by erect-
ing a cage _ structure in the storage area and further limit access to the
It should be noted that this conservative action may be changed in
area.
the future should any construction projects at the Fort Calhoun Station
currently in progress or planned for the future provide better storage
locations for boric acid.
(4) The date when full comoliance eill be achieved.
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OPPD is currently in full compliance.
The additional measures will be
completed by November 15, 1986.
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Attachment to LIC-86-505 (continued)
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OPPD Response to Violation b.
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(1) Reason for the Violation
The fire barrier was made nonfunctional when a removable concrete floor
slab was removed to facilitate the installation of modification MR-FC-
.81-092, " Emergency Exit." At the time that the modification construction
package was being approved, it was the understanding of plant staff that
the contractor would restore the fire barriers at the end of each working
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day. Therefore, the only requirements regarding fire barrier operability
were for the compensatory measures of verifying fire detector operability
in the area and establishing an hourly fire watch patrol for those periods
of time when the fire barrier was degraded. Shortly after work started,
the plant was informed that the fire barrier could not be restored at the
end of each working day and that a fire watch patrol was required around
the clock.
The fire barrier was inoperable in excess of seven days on May
23, 1986. During the following 30 days, no special report was issued to
the NRC.
During the month of July,1986, the resident inspector requested
a copy of the special report that was supposed to have been submitted to
the NRC regarding the inoperable fire barrier. At that time it was veri-
fied that a special report had not been submitted. The plant immediately
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completed and transmitted the special report to the NRC. The report was
not submitted within the 30 day limit due to an oversight by plant staff.
(2) Corrective steos which have been taken and the results achieved.
Upon verifying that a special report had not been submitted within 30
days, a special report was completed and transmitted to the NRC as quickly
as possible. A final report was submitted to the NRC on August 12, 1986.
(3) Corrective steos taken to avoid further violations.
Fort Calhoun Station Standing Order G-58, " Fire Barriers," was updated per
Procedure Change No.18029 to explain in detail the reporting requirements
regarding fire barrier inoperability. A training hotline was then issued
to plant employees notifying them of the changes in the procedure. The
procedure utilized by Generating Station Engineering in preparing con-
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struction packages that require altering fire barriers (MGS-303) is being
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changed to include making provisions for reporting extended periods of
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fire barrier inoperability to Fort Calhoun Station plant staff so that
proper NRC notification can be made.
The above changes in administrative
controls wM L ensure that the NRC is notified within the 30 day limit
specified.
(4) The date when full como11ance will be achieved.
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OPPD is presently in full compliance.
Full complianck was achieved with
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the submittal of the final revision of the special report on August 12,
1986.
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Omaha Public Power District
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1623 Harney Omaha. Nebraska 68102-2247
402 536 4000
December 1, 1986
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LIC-86-623
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DEO I i 1986
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Mr. J. E. Gagliardo, Cliief
Reactor Projects Esranch
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U. S. Nuclear Regulatory Cunmission
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas. 76011
References:
1. Docket No. 50-285
2. Inspection Report 50-2fj5/86-21 dated September 2,1986
3. .OND Letter (R. L. Andrews) to NRC (J. E. Gagliardo)
LIL-86-505, dated October 2, 1986
Dear Mr. Gagliardo:
As committed in Reference 3, the following is the course of action OPPD intends
to utilize concerning the violations reported in Reference 2.
OPPD management is concerned about the generic aspects of violations which have
resulted from failure of personnel to conply with astablished procedures. An
increased level of consciousness and attention to detail by dl personnel is
needed to minimize procedural violition<..
In order to improve the level of
awareness, a training document hai been issued to personnel in thc-Nuclear
Production Division and Generating Statior; Engineering to make them ware of
the situation and to request their increased attention to detail in the area of
procedural compliance.
In addition. supervisory involvement in the field will
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continue to be emphasized by managtment.
In order to better address human performance problems on an argoing basis, OPPD
plans on becoming a full participant in INP0's Human Performance Evaluation
System (HPES).
HPES is a problem-solving methodology used to identify the root
causes of human performance problems, and to select appropriate corrective
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actions.
Selected-District personnel will attend a training session at INP0
during December 1986.
Implementation of the programs at the Fort Calhoun Sta-
tion will begi,1 in early H87, with full implementation planr.ed by June 1987.
OPPD management is also concerned abCut the apparent lack of responsiveness to
issues raised by the Senior Resident' Inspector.
In order to provide improved
interface and coordination between the station staff and licensing, a licensing
engineer has been assigned to the Fort Calhoun Station on a tull-time basis.
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LIC-86-623
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Page Two
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This action will-enhance the District's responsiveness in address'ing the Senior
Resident Inspector's concerns and will provide for better tracking of
commitments.
It is expected that these actions by 0 PPD will substantially reduce the number
of instances of failure of personnel to- follow procedures and will better
ensure adherence to NRC commitments.
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Sincerely,
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R. L. Andrews
Division Manager
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Nuclear Production
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LeBoeuf, Lamb, Leiby & MacRae
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1333 New Hampshire Avenue, N.W.
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Washington, D. C.
20036
A. C. Thadani, NRC Project Director
D. E. Sells, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
R. G. Ellis (Ft. Calhoun Correspondence File)
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