ML20212B698

Discusses 971007 Predecisional Enforcement Conference Re Four Apparent Violations of NRC Requirements Related to 970821 Incident & Forwards NOV & Proposed Imposition of Civil Penalty

ML20212B698
Person / Time
Site:	Fort Calhoun
Issue date:	10/24/1997
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20212B703	List: ML20212B698 ML20212B719
References
50-285-97-17, EA-97-432, NUDOCS 9710280173
Download: ML20212B698 (4)

Text

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October 24, 1997 0,'y '*

EA 97-432 v

S. K. Gambhir, Division Manager r Engineering and Operations Support Omaha Public Power District

• Fort Calhoun Station FC-2-4 Adm. '

u P.O. Box 399 f Hwy,75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023 0399 h -

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY - N

$110,000 (NRC SPECIAL INSPECTION REPORT 50-285/97-17) ^ b. ,

Dear Mr. Gambhir:

s This is in reference to the predecisional enforcement conference conducted in the NRC's '

Arlington, Texas office on October 7,1997, with representatives of Omaha Public Power District (OPPD). The conference was conducted to discuss four apparent violations of NRC requirements related to an August 21,1997 incident which resulted in the disabling of the containment spray system at the Fort Calhoun Station (Fort Calhoun) reactor facility. The NRC's inspection of this was completed on August 29,1997, and an inspection report was issued September 19,1997. A conference summary document, which included the information OPPD provided to the NRC at the conference, was issued October 4,1997.

Based on the information developed during the inspection and the information that you provided during the conference, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed Impositien of Civil Penalty; the circumstances surrounding them were described in detail in the subject inspection report. In brief, the violations involve: 1) a licensed operator's mispositioning of containment spray valve control switches during a surveillance test: 2) a f ailure to shut down the unit as required when both trains of containment spray '

were disabled by this error; 3) a failure by licensed operators to conduct a proper shift turnover which should have revealed that the untainment spray system was inoperable;

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and 4) a failure by licensed operators to make proper log entries.

The containment spray system was rendered inoperable when an operator erroneously placed the control switches for containment spray header isolation valves in the " override" position during a surveillance test. These switches remained in this position for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, with the plant operating at 100 percent power. Had a loss-of-coolant accident occurred during this time, the containment spray system would not have operated automatically, as designed, to spray down containment and help minimize pressure buildup in the containment building. The NRC acknowledges that a licensed operator (other than the one who made the error) discovered the mispositioned control switches for the containment spray valves approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the initial error 9710280173 971024 t DR ADOCK0500g2S l

Omaha Public Power District 2-was made, and promptly restored containment spray to an operable status. We also acknowledge that OPPD promptly reported this incident to the NRC, and that t.gnificant corrective act'ons were taken as a result.

A!though other systems at Fort Calhoun also are designed to minimize containment pressure in the event of an accident, the NRC views the August 21,1997, event seriously because licensed operating personnel defeated a safety system and then missed several opportunities to detect it. The primary missed opportunities invohred: 1) a failure to determine the cause of spray valve "off normal" alarms which occurred when the valve switches were placed in override; and 2) a failure to recognize or question the presence of this annunciator or abno. mal switch positions and indicating lights during a subsequent shift turnover and periodic control board observations. In addition, this is the second time an incident of this type has occurred at Fort Calhoun in 18 months. As OPPD acknowledged at the conference, there were similanties between this incident and a previous incident in March 1996 (EA 96-204)', The corrective actions you took for the previous incident included actions (e.g., shift turnover and alarm response enhancements) that should have prevented or resulted in the prompt detection of the August 21,1997, j disabling of containment spray, Both incidents involved a lack of attention to detail and L poor questioning attitude, a f ailure to recognize that safety features were defeated, weaknesses in responding to annunciators in the control room, poor supervisory oversight, and inadequate shift turnover.

The first three violations discussed above have been classified in the aggregato at Severity Level :11 in accordance with the " General Stater., a of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600, because they involve defeating a safety system for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and violating plant Technical Specifications as a result.

Although classification at Severity Level ll was considered, in that containment spray would not have functioned if called upon, the NRC determined that classification at Severity Levelill was more appropriate based on plant des!gn and the contribution that the containment cooiing system would make to maintain containment pressures below design assumptions. Nonetheless, the NRC's r:oncern is focused on the root causes of these violations, in that errors of a similar naturt, could result in defeating safety sys', ems that could have a greater impact on reactor safety.

In accordance with the Ei forcement Policy, a civil penalty at a base value of $55,000 is considered for a Severity Levellli problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years, as previously discussed, the NRC considered whether credit was warranted for / dent'// cation and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy,

'The March 1996 incident involved disabling the low-temperature, over-pressure

, protection affordeo by the pressurizer power operated relief valves. A severity le el lli l

violation, with no civil penalty (EA 96-204), was issued to OPPD on July 31,1996.

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Omaha Public Power District +3-The NRC has determined that credit for identification is not warranted because the condition was discovered when an annunciator failed to clear after operators attempted to restore the containment spray system to normal following the completion of the-surveillance test. Thus, the inoperable condition of the containment spray system was revealed by the annunciator, At the conference, OPPD suggested that identification credit was_ warranted because the problem was identified during a surveillance test (NRC Enforcement Manual, 5.5.2.3). Credit would be considered if the problem was pre-existmg I (not caused by improper performance of the test) and not apparent for the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by virtue of the annunciator being lit. In summary, credit is not warranted because the problem was self revealing and because there were missed opportunities to have discovered the problem earlier.

Credit for corrective action was found to be warranted based on the numerous corrective actions you have taken or are planning to take, which were described at the conference.

These include, but are not limited to: 1) requiring additional oversight of surveillance tests; 2)i *antifying and marking annunciators that are expected during tests; 3) requiring senior reactor operator concurrence before disabling safety related equipment: 4) requiring per./ c review prior to operating key switches; 5) requiring four-hour "standdowns" for crews returning from long breaks; 6) requiring individual control board walkdowns during shift turnover; 7) improving alarm response procedures; and 8) a formal program to assess the effectiveness rd arrective actions for significant events.

While the normal civil penalty assessment would have resulted in a base civil penalty being proposed, the NRC determined that discretion as provided for in Section Vll.A.1 of the Enforcement Policy should be applied to assess a penalty at twice the base value. The basis for exercising this discretion is the similarity of this incident to the March 1996 incident and the significance of two such events occurring within 18 months. In addition, we considered the f act that your corrective actions for the previous incident should have prevented this error or caught this error soon after it occurred.

Therefore, to emphasize the significance of disabling plant safety features and the failure to assure that corrective actions for a previous escalated enforcement action were effective, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regulatory Effectiveness, to issue the enclosed Notice of Violaticn and Proposed Imposition of C;vi: Penalty (Notice) in the amount of $110,000.

The fourth violation, involving inadequate log entries, was not deemed to be a cordributing

. cause of the disabling of the containment spray system, and was not a missed opportunity to have discovered the incident, Therefore, this violation is not among those assessed a civil penalty and has been separately classified at Severity Level IV.

You are required to_ respond to this letter and should follow the instructions specified in the encio.ed Notice when preparing your response. In your response, you should documer't the specific actions taken and any additional actions you plan to prevent recurrence lhe NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

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r Omaha Pub.ic Power District - -

t in accedance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy ot this letter, its encloswe, and yt'or response will be placed in the NRC Publ::: Document Room (PDR). .

Sincerely, Ellis W. Merscho Regional Admin strator Do;ket No.: 5 0 2 8 .-

License No.: DPR 40

Enclosure:

Notice cf Violation and Proposed impositio i of Civil Penalty cc w/

Enclosure:

Jarr s W. Tills, Manager Nucicar Lionsing Omahe Public Power District Fort Calhoun Stet;un FC 2 4 Adm.

P.O. Box 399 4

Hwy. 75 - No~th of Fort Calhoun Fort Calhou% Nebraska 68023-0399 James W, Chase, Manager Fort Calhoun Station

-P.O. Box 399 Fort Calhoun, Nebraska 68023 Perry D. Robinson, Esq.

Winston & Strawn 1400 L. Street, N.W.

- Washington, D.C. 20005 3502- -

Chairman

- Washington County Board of Supervisors Blair, Nebraska .:68008

'Chery'l Rogers, LLRW ' Program Manager Environment'al Protection Section Nebraska Department of Health -

-301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 4

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