ML20212B719

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $110,000.Violations Noted:On 970821,licensee Failed to Conduct Adequate Shift Turnover in That Oncoming Shift Did Not Identify That Control Switches Were Override

ML20212B719
Person / Time
Site:	Fort Calhoun
Issue date:	10/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212B703	List: ML20212B698 ML20212B719
References
EA-97-432, NUDOCS 9710280181
Download: ML20212B719 (5)

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 97 432 During an NRC inspection completed on August 29,'1997, violations of NRC requirements were identified. In accordance with the " Genera! Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the Nuclear Rcgubtory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and -

associated civil penalty are set forth below: ,

I. Violations Assessed a Civil Penalty A. Technical Specification 5.8.1 requires _that written procedures and administrative policies be established, implemented and maintained that meet or excoed the minimum requirements of Sections 5.1 and 5.3 of.

ANSI N18.71972 and Appendix A of Regulatory Guide 1.33. Regulatory

' Guide 1.33, Appendix A, Section 3.f(4) requires procedures for startup, operation, and shutdown of containment cooling systems.

Procedure OP ST-SI 3008, " Safety injection and Containment Spray Pump inservice Test and Valve Exercise Test," Revision 19, established, in part.

written procedures for testing the containmem spray system. Step 7.10 required that Containment Spray Valves HCV 344 and HCV 345 be placed in the closed position and that the containment spray valve test switches be placed in the test position.

Contrary to the above, on August 21,1997, Step 7.10 of Procedure OP-ST-SI-3008 was not properly implemented in that in addition to placing the containment spray valves and the containment spray valve test switches in the required position, the control switches for Containment Spray Valves

- HCV 344 and HCV 345 were placed in the override position. This step, which was not in the procedure, would have prevented the automatic actuation of either containment spray header, if required. (01013)

B. Technical Specification 2.4, " Containment Cooling," limiting condition for operation requires,-in part, that Containment Spray Pumps SI 3A, SI 38, and SI-3C and their associated valves, piping and interlocks-be operable dudng power operation. . The modif; cation of minimum requirements for the specification allows for two of these pumps to be inoperable at any one_ time during power operation.

Technical Specification 2.0.1 requires in part that, in the event that the limiting condition for operation cannot be satisfied because of circumstances in excess of those addressed in the specification, the unit shall be placed in 9710290181 971024 PDR ADOCK 05000295 g PDR

' Notice of Violation . . 2-at least hot shutdown within'6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least subcritical and < 300 F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above, on August 21,1997, the unit was not placed in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and was not in at least subcritical and

<300*F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> when the containment spray system was rendered inoperable from approximately 8 a.m. CST to 8:38 p.m. due to the 1 control switches for both containment spray header isolation valves being placed in the override position. (01023)

C. Technical Specification 5.8.1, requires that written procedures and administrative policies be established, implemented and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of Regulatory Guide 1,33. Regulatory Guide 1.33, Appendix A, Section 1.h requires procedures for shift and relief turnover.

Procedure S0-01, " Conduct of Operations," Revision 33, provides procedural requirements for the conduct of shift and relief turnover. These requirements include:- (1) the oncoming shift shall familiarize themselves with the conditions in areas for which they are responsible; (2) each person will brief his/her relief on the conditicn and status of that portion of the plant

, to which he/she is assigned, including abnorma! conditions or alignments and inoperable equipment; and (3) prior to assuming the shift, each operator shall-personally verify the status of important system operating parameters, especially those relating to safety systems.

Contrary to the above, on August 21,1997, the licensee failed to conduct an adequate shift turnover in that the oncom!ng shift did not identify that the control switches for both containment spray valves were in override, rendering the containment spray system inoperable, and that the off-going crew did not brief the oncoming crew about this condition. (01033)

These violations represent n Severity Level til problem (Supplement 1).

- Civil Penalty - $110,000

11. - Violation Not Assessed a Civil Penalty Technical Specification 5.8.1, requires that written procedures and administrative

- policies be established, implemented and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of Regulatory Guide 1.33.. Regulatory Guide 1.33, Appendix A,

_ Section 1.h requires procedures for log entries.

Standing Order S0-01, " Conduct'of Operations," Revision 33, required that log

. entries into the official control room log be made when major plant equipment / systems w3re place in or out of operation, and to document compliance with the requirements of a Technical Specification Limiting Condition for Operation.

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Notice of Violation Contrary to the above, on August 21,1997, operators failed to log that the containment spray header isolation valves had been rendered inoparable by placing the control switches in override, in addition, as of 7 p.m. on August 28, operators had failed to log that Containment Spray Pump SI-3C was operable per Technical Specification 2.4(1)b. The pump had been restored to an operable status on August 21.(02014)

This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective stops that 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, an order or a Demand for Information may be issued as 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. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalty in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in w* 3 or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violation (s) listed in this Notice, in whole or in part, (2) demonstrate extenuating i

circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed, in additien to p;otesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed pena'ty, the f actors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by j specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

4':

e Notice of Violation . 4 Upon failure to pay any civil penalty due which subsequently has been determined in .

accordance with the applicable provisions of 10 CFR 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 Soction 234c of the Act,42 U.S.C. 2282c. ,

The response noted above-(Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852 2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV,611 Ryan Plaza Drive,

• Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the

-facility that is the subject of this Notice..

Because your response will be placed in the NRC Public Document. Room (PDR), to the  ;

extent possible, it should not include any personal privacy, proprietary, or safeguards .

Information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be orotected <

and a redacted copy of your response that deletes such information if y:.a request withholding of such material, you mg.ld specifically identify the portions of your responso that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlingtoni Texas this 24th day of October 1997

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