EA-96-204 - Fort Calhoun (Omaha Public Power District)
T. L. Patterson, Division Manager
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399, Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska 68023-0399
SUBJECT: NOTICE OF VIOLATION (NRC Inspection Report No. 50-285/96-05)
Dear Mr. Patterson:
This refers to the predecisional enforcement conference held on July 22, 1996, in the NRC Region IV office in Arlington, Texas. The purpose of the conference was to discuss the apparent violations identified in the subject inspection report involving operator actions which disabled the Low Temperature Overpressure Protection (LTOP) function of the Pressurizer Power Operated Relief Valves (PORVs). The LTOP function is provided to protect the reactor vessel from brittle fracture when at low temperatures. The inspection report identified three apparent violations: (1) providing inadequate procedural guidance for pressurizer cooldown evolutions, (2) failing to follow procedures by not taking adequate compensatory measures for disabling the LTOP function, and (3) failing to follow procedures by not logging abnormal plant conditions and by not conducting proper shift turnovers.
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. The violations are cited in the enclosed Notice of Violation and the circumstances surrounding them are described in detail in the subject inspection report. In summary, the violations were identified after plant operations staff recognized that they had disabled the LTOP function on several occasions during pressurizer cooldown on March 18, 1996. Plant procedures had called for cooling down the pressurizer by, among other actions, cycling the PORVs. Although the procedure was specific in requiring that PORVs be opened by pulling, and thus disconnecting, two reactor protection system (RPS) pressurizer pressure trip units, the procedure was not specific in discussing how the PORVs would be closed. During the cooldown evolution on March 18, operators closed the PORVs by manually switching the PORV hand control switches from AUTO to CLOSE without reinstalling the RPS pressurizer pressure trip units. This disabled the LTOP function.
The PORVs were cycled over a period of two shifts, without the operations staff recognizing that LTOP had been disabled and that it remained disabled after the cooldown evolution had been completed. During the subsequent afternoon shift, operators did not notice that the pressurizer pressure trip units were disconnected (pulled out) nor that the associated annunciator lights were lit. Evaluation of the issue indicated that there was inadequate supervision and oversight, inadequate procedures, inadequate shift turnover from the day shift to the afternoon shift, a lack of a questioning attitude, inadequate logkeeping, training deficiencies, and weaknesses in the plant's initial review of the event.
In reviewing the safety significance of the issues, we noted that the actual and potential safety significance of this problem were limited by design features of the system and by the fact that operations staff had used a dedicated operator to oversee pressurizer cooldown. (It is important to note the distinction that the dedicated operator was not assigned to manually perform the necessary actions to restore LTOP in the event it was needed and was not fully cognizant that the LTOP function had been disabled.) However, the number and fundamental nature of the issues identified collectively represent a potentially significant lack of attention toward licensed responsibilities. Therefore, these violations are classified in the aggregate in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III problem. Because your facility has not been the subject of escalated enforcement actions within the last 2 years, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. The NRC evaluated your short term and longer term corrective actions, in addition to the adequacy of the root cause analysis. Although there were deficiencies in the initial root cause analysis, which NRC inspectors later discussed with plant management, these deficiencies did not provide a sufficient basis for denying corrective action credit. As a result, the NRC staff concluded that credit for the Corrective Action factor was warranted. After discussions with NRC inspectors, plant personnel re-evaluated the event and improved the initial root cause analysis and the corrective actions. The corrective actions included revising the applicable procedure, training on the procedure, crew briefings by the shift supervisor, discussing the event and the root causes with all crews, conducting refresher training on LTOP/PORV circuitry, emphasizing the importance of questioning attitude and quality procedure verifications, better defining the purpose and expectations of a dedicated operator, reemphasizing management expectations for logkeeping and shift turnover, and improving the formality of shift turnovers, board walkdowns, and annunciator responses. Longer term corrective actions included further procedure revisions, upgrading the PORV control switches, and evaluating the potential for unique marking of normally lit annunciators during shutdowns and out-of-normal switch positions.
Therefore, in recognition of the absence of escalated enforcement action within 2 years and of your comprehensive corrective actions, I have been authorized not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
Sincerely, L. J. Callan Regional Administrator
Docket No. 50-285
License No. DPR-40
Enclosure: Notice of Violation
Mr. James R. Curtiss
Winston & Strawn
1400 L. Street, N.W.
Washington, D.C. 20005-3502
Jack Jensen, Chairman
Washington County Board of Supervisors
Blair, Nebraska 68008
Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
Nebraska Department of Health
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007
Dr. Mark B. Horton, M.S.P.H.
Nebraska Department of Health
P.O. Box 950070
Lincoln, Nebraska 68509-5007
James W. Chase, Manager
Fort Calhoun Station
P.O. Box 399
Fort Calhoun, Nebraska 68023
Omaha Public Power District Docket No. 50-285 Fort Calhoun Station License No. DPR-40 EA 96-204
During an NRC inspection conducted on May 20 through June 13, 1996, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
A. Technical Specification 5.8.1 states, in part, that written procedures and administrative policies shall be established and implemented that meet or exceed the minimum requirements of Appendix A of Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, Section 1.j, requires procedures for the bypass of safety functions.
Procedure SO-G-100, "Operability Dispositions When Calibrating or Testing Safety Related Equipment," Revision 1, provides procedural requirements for the bypass of safety functions. Specifically, when safety related equipment is configured such that without manual operator action the equipment would be unable to perform its intended design function, procedure requirements include: (a) declaring the piece of equipment inoperable, (b) rescheduling to such a time when the limiting conditions for operation (LCO) action statement or safety system would not be challenged, (c) reconfiguring such that the equipment is not impaired, the LCO action statmenent is not entered and/or the safety systems are not challenged, or (d) changing the activity to incorporate the use of a dedicated operator to take manual actions to fulfill the automatic action.
Contrary to the above, on March 18, 1996, the licensee failed to implement Procedure SO-G-100 by taking no actions when safety related equipment, specifically the reactor protection system (RPS) pressurizer pressure trip units and the pressurizer power operated relief valves (PORVs), were configured such that without manual operator action the equipment would have been unable to perform its intended design function. Specifically, the RPS pressurizer pressure trip units were disconnected (pulled) and the hand switches for the pressurizer PORVs were moved to the CLOSE position, disabling the low temperature overpressure protection (LTOP) function, and none of the required actions were taken. (01013)
B. Technical Specification 5.8.1 states, in part, that written procedures and administrative policies shall be implemented that meet or exceed the minimum requirements of Appendix A of Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, Sections 1.g and 1.h, require procedures for shift and relief turnover and log entries.
Procedure SO-O-1, "Conduct of Operations," Revision 29, provides procedural requirements for the conduct of shift and relief turnover and log entries. Those requirements include: (1) the oncoming shift shall familiarize themselves with the conditions in areas to which they are responsible; (2) each person will brief his/her relief on the condition and status of that portion of the plant to which he/she is assigned, including abnormal conditions or alignments and inoperable equipment; (3) prior to assuming the shift, each operator shall personally verify the status of important system operating parameters, especially those relating to safety systems; and (4) log entries into the official control room log shall be made when major equipment/systems placed in or out of operation.
Contrary to the above, on March 18, 1996, the licensee failed to implement Procedure SO-O-1 with regard to the disabling of the LTOP function when the PORV hand switches were moved to the CLOSE position and the RPS pressurizer pressure trip units were disconnected. Specifically, (1) the appropriate oncoming (afternoon) shift operators did not familiarize themselves with the conditions regarding the LTOP functional status; (2) the appropriate (day shift) operators did not brief his/her reliefs on the condition and (inoperable) status of the LTOP function; (3) prior to assuming the afternoon shift, the appropriate operators did not adequately verify the status of important safety systems, specifically the RPS pressurizer pressure trip units and the pressurizer PORV hand switch positions; and (4) log entries into the official control room log were not made each time major equipment/systems (charging pumps and PORV hand switches) were placed in or out of operation. (01023)
C. Technical Specification 5.8.1 states, in part, that written procedures shall be established that meet or exceed the minimum requirements of Appendix A of Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, Sections 3.a and 3.u, require procedures for startup, operation, and shutdown of safety related systems, specifically the reactor coolant system and the reactor protection system.
Contrary to the above, on March 18, 1996, adequate procedures were not provided for the operation and shutdown of safety related equipment affecting the LTOP function, part of the reactor protection system. Specifically, Procedure OI-RC-4A, Attachment 1, "Pressurizer Cooldown," Revision 1, did not provide adequate guidance to prevent the disabling of the LTOP function of the pressurizer PORVs without taking appropriate compensatory measures, nor did the procedure provide guidance to ensure system restoration to an operable status following the completion of pressurizer cooldown. (01033)
These violations represent a Severity Level III problem. (Supplement I)
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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, 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, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. 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 to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Because the 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. However, if it necessary to include such information, it should clearly indicate the specific information that should not be placed in the PDR, and provide the legal basis to support the request for withholding the information from the public.
Dated at Arlington, Texas
this 31st day of July 1996