ML20141C454

Discusses Insp Rept 50-285/85-09 on 850429-0503 & Forwards Notice of Violation.Further Response Necessary to Document Actions Taken on Each Specific Item.Civil Penalty Not Proposed Due to Opportunity for Extension of Item

ML20141C454
Person / Time
Site:	Fort Calhoun
Issue date:	04/02/1986
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20141C460	List: IR 05000429/2005003 ML20141C454
References
EA-86-029, EA-86-29, NUDOCS 8604070251
Download: ML20141C454 (3)

See also: IR 05000285/1985009

Text

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APR 2 EE6

Docket No. 50-285' ,

-License No. DPR-40

'IUL 86-29-

Omaha Public Power District

~ ATTN: R. L. Andrews, Division Manager-

Nuclear Production

1623 Harney Street-

Omaha, Nebraska 68102

Gentlemen:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT No. 50-255/85-09)

This refers to the special team inspection conducted by the NRC April 29 -

- May 3,1985 of activities authorized by Operating License No. DPR-40 for the

Fort Calhoun Station. The results of this inspection were previously sent to you

by our letter of July 26, 1985. The inspection team identified six deficiencies

classified as Potential Enforcement / Unresolved Items. We have determined from a

further. review of these matters during a followup inspection by Region IV on-

November 18-22, 1985 and meetings with your staff in the Region IV office on

December 12-13, 1985 that five of the six Potential Enforcement / Unresolved Items

were in violation of NRC requirements. Since you waived your opportunity to

hold an enforcement conference, one was not conducted.

We consider Violation A in the enclosed Notice of Violation involving

qualification of Conax Electrical Penetration Assemblies within the scope of

10 CFR 50.49 requirements to be of significant concern. The modification devised

by Omaha Public Power District (OPPD), after it was discovered that Teflon seals

and conductor insulation in the penetration assemblies had failed qualification

tests, consisted of potting the junction between the penetration assembly bodies

and the related pigtail wires using room temperature vulcanizing (RTV) silicone

rubber. Since you failed to test the penetration assemblies after making

the modification, the ability of the RTV material to remain bonded through

the differential expansions and the severe environment of a LOCA was not

assured in this application. Thus, the penetration units still were not

appropriately qualified. The extent 6f the deficiency is very broad in

that the electrical circuits for all equipment located inside containment

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must pass through the penetration assemblies; power, control, and

instrumentation wiring for both safety-related and non-safety-related equipment

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inside containment potentially could be affected.

CERTIFIED MAIL

RETURN RECEIPT REOUESTED

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PDR ADOCK 05000285

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Omaha Public Power District -2-

In accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions," 10 CFR Part 2 Appendix C (1985), Violation A described

in the enclosed Notice has been classified at a Severity Level III. The other

violations have each been classified at a Severity Level IV. Normally, a civil

! penalty is considered for a Severity Level III violation. However, after

consultation with the Director, Office of Inspection and Enforcement, I have

i decided that a civil penalty will not be proposed in this case because the

violations were identified prior to November 30, 1983 and this item is of the

type for which an extension prior to November 30, 1985 could have been granted

if requested before the deadline. We also recognize that following identification

of this problem by the NRC, you provided complete and timely reports concerning

your evaluation and corrective actions and you took extensive corrective action,

including the replacement of all penetration assemblies with units that have

been appropriately qualified.

You are required to respond to this letter and you should follow the instructions

specified in the enclosed Notice when preparing your response. Our inspection

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activities and your letter dated January 11, 1986 indicate that corrective

actions are now complete. However, further response from you is necessary to

document the actions you have taken on each specific iten and to address any

other actions you plan to take to ensure that other deficiencies similar to those

noted do not adversely affect any other safety-related equipment. Where you have

already responded in writing to these findings (such as your letter of October 11,

1985), you do not need to repeat that information but need only reference

earlier communications and add additional detail not already contained therein.

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 1

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will be placed in the NRC Public Document Room.

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The responses directed by this letter and the enclosed Notice are not subject

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to the clearance procedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely,

Original signed by:

R.4 tert D. Martin

Robert D. Martin

Regional Administrator

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Enclosure:

Notice of Violation

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