LIC-14-0055, Reply to a Notice of Violation 05000285-13-013

Reply to a Notice of Violation 05000285-13-013

ML14125A096
Person / Time
Site:	Fort Calhoun
Issue date:	05/02/2014
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, NRC Region 4
References
EA-13-201, IR-13-013, LIC-14-0055
Download: ML14125A096 (4)

Text

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jjjjjjjj Omaha Public Power District 444 South 16th Street Mall Omaha, NE 68102-2247 10 CFR 2.201 LI C-14-0055 May 2,2014 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No.1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Reference:

1. Letter from NRC (Michael Hay) to OPPD (Louis P. Cortopassi) dated April 3, 2014 (NRC-14-0028)

2. Letter from OPPD (Lou Cortopassi) to NRC (Document Control Desk) dated October 8,2013 (LlC-13-0118)

SUBJECT:

Reply to a Notice of Violation 05000285/2013013 In the reference letter, the Nuclear Regulatory Commission (NRC) transmitted a Notice of Violation (NOV) to the Omaha Public Power District (OPPD) that contained a cited Severity Level IV Violation .

We have evaluated these issues to ascertain the facts and determined the appropriate corrective actions. Enclosed please find the Fort Calhoun Station Response to this issue.

This letter contains no regulatory commitments. If you should have any questions, please contact Terrence Simpkin, Manager Regulatory Assurance, at 402-533-6263.

S7a Louis P. Cortopassi Site Vice President and CNO Enclosure LPC/epm c: M. L. Dapas, NRC Regional Administrator, Region IV J . M. Sebrosky, NRC Senior Project Manager J. C. Kirkland, NRC Senior Resident Inspector

II C-14-0055 Enclosure Page 1 REPLY TO A NOTICE OF VIOLATION Omaha Public Power District Docket No. 50-285 Fort Calhoun Station License No. DPR-40 EA-2013-201 During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from July 8 through December 16, 2013, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR 50.9(a), "Completeness and Accuracy of Information," requires in part that, "information provided to the Commission by a licensee shall be complete and accurate in all material respects."

Contrary to the above, on October 13, 2008, the licensee provided to the Commission documentation which contained information that was not complete and accurate in all material respects. Specifically, the licensee submitted a letter dated October 13, 2008, which stated that the pyrocrete enclosure remained in place to protect the cables associated with AC-10A and AC-10B from a fire in the intake structure. When in fact, the motor lead cables associated with raw water pump AC-10A were not protected by the pyrocrete enclosure. In a letter, dated February 6, 2009, the NRC granted an exemption from the specific requirements of Section III.G.1.b of 10 CFR Part 50, Appendix R, for the Fort Calhoun Station based in part, upon the NRC's review and evaluation of information provided by the licensee in its letter dated October 13, 2008. Therefore, this information was considered material to the NRC.

This is a Severity Level IV Violation (Section 6.9).

OPPD Response

1. Reason for the Violation During the July 2013 National Fire Protection Association (NFPA) 805 transition/Chapter 0350 inspection conducted at FCS, an NRC Region IV inspector questioned whether the Omaha Public Power District (OPPD) may have provided inaccurate information to the NRC about protection of raw water (RW) pumps, AC-10A and AC-10B, in the intake structure circulating water pump bay in the event of a fire. Specifically, the NRC regional inspector's question was based on the discrepancy between the current configuration ,

which did not identify any pyrocrete barrier protection surrounding the pull box housing the AC-1 OA RW pump power cable, and information provided in previous docketed correspondence in lIC-83-0219, lIC-83-0220 and lIC-08-0109.

Timeline July 9, 1979: OPPD stated which raw water pump and associated cables would be protected. (lIC-79-0192) November 3, 1980: Modification Request (MR)-FC-78-55 installed the pyrocrete in the plant, including the intake structure.

LI C-14-0055 Enclosure Page 2 July 1, 1983: The NRC issued a violation to OPPD which stated, in part, "These conduits are routed through a common fire barrier enclosure, located above the circulating water pump bay, such that the cables inside the barrier do not meet the Section IILG fire protection requirements of separation, detection and suppression." The finding was "Failure to provide approved fire protection measures and repair procedures to ensure capability to achieve and maintain cold shutdown is an apparent violation of 10 CFR 50, Appendix R, Sections IILG and IILL." (NRC-83-0202)

August 30, 1983: OPPD requested an exemption from requirements of Sections III.G and III.L of 10 CFR 50 Appendix R. OPPD also stated that both raw water pumps AC-10A and AC-10B would be protected by pyrocrete. This was the first mention of both pumps being protected. (LlC-83-0219)

August 31, 1983: OPPD documents the responses to the violations documented in NRC-83-0202. The letter explains that OPPD is sending an exemption request to the NRC, documented in LlC-83-0219. (UC-83-0220)

July 3, 1985: Safety Evaluation Report (SER) granted an exemption for the fire area 31 for the intake structure and pull boxes, stating, in part, "requested an exemption from section III.G.2 to the extent that requires that systems associated with redundant shutdown divisions be completely separated by a continuous 1-hour fire-rated barrier and the fire area containing these systems be protected by an area-wide automatic fire suppression system." The SER identified two primary considerations in the exemption evaluation for Fire Area 31. The SER states: "The fire loading within these areas is limited. Combustible materials are widely dispersed. Consequently, any potential fire would be within the capabilities of the plant fire brigade to extinguish with manual firefighting equipment before significant levels of damage occurred." The SER also considered that "if a fire were to occur at the raw water pumps," ... two of the pumps would be shielded from the effects of the fire by the concrete wall." (NRC-85-0200)

February 4, 2008: OPPD requested an exemption from 10 CFR 50 Appendix R, Section III.G.1.b, which addressed the power and control cables for the four RW pumps that are routed from the Auxiliary Building through the outside cable pull boxes (128T and 129T) into the underground duct bank and manhole vaults MH-5 and MH-31 and into the intake structure. (LlC-08-0006)

September 17, 2008: The NRC required more information to process this exemption.

NRC transmitted via email a request for additional information (RAI), the third RAI of which asked OPPD to confirm that both RW pumps AC-1 OA and AC-1 OB were protected with pyrocrete from fire. (ML083360264)

October 13, 2008: OPPD responded stating that both RW pumps AC-10A and AC-10B are protected with pyrocrete from a fire. (LlC-08-0109)

February 6,2009: NRC granted an exemption which mentioned that both RW pumps AC-10A and AC-10B are protected with pyrocrete from a fire. (NRC-09-0007)

September 28, 2011: OPPD submits the National Fire Protection Association (NFPA) 805 License Amendment Request. Attachment T provides clarification for protected cables and raw water pumps within the Intake Structure. This clarification is part of Prior

LlC-14-0055 Enclosure Page 3 Approval Clarification Request 7 which specifies that one RW pump (AC-108) is protected for a fire at Intake Structure elevation 985' (at the CW pump elevation).

(UC-11-0099)

July 2013: During an NFPA 805 transition/Chapter 0350 inspection conducted at FCS, an NRC Region IV inspector questioned whether the OPPD may have provided inaccurate information to the NRC about protection of RW pumps, AC-10A and AC-108, in the intake structure in the event of a fire. Specifically, the NRC regional inspector's question was based on the discrepancy between the current field configuration, which did not identify any pyrocrete barrier protection surrounding the pull box housing the AC-10A RW pump power cable, and information provided in previous docketed correspondence in LlC-83-0219, LlC-83-0220 and LlC-08-0109.

The cause analysis determined that FCS personnel did not use human performance tools (validate assumptions and technical rigor) to ensure correct information was supplied to the NRC.

2. Corrective Steps Taken and the Results Achieved October 8,2013: OPPD submitted letter LlC-13-0118, "Clarification of Information Regarding Protection of the Raw Water Pumps in the Event of a Fire in the Intake Structure at Fort Calhoun Station," to ensure the NRC has the correct information. This letter provided clarification to information previously provided to the NRC (reference 2).

Validation and Verification process was set up in April 2011 by Regulatory Assurance for NRC correspondence. Note: this process was not in place at the time of the 2008 correspondence.

3. Corrective Steps That Will be Taken No additional actions are required.

4. Date When Full Compliance Will be Achieved The Fort Calhoun Station is currently in full compliance.