NOED-00-4-002 - Fort Calhoun (Omaha Public Power District)

611 Ryan Plaza Drive, Suite 400
Arlington, Texas 76011-8064

November 28, 2000

S. K. Gambhir, Division Manager
Nuclear Operations
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


Dear Mr. Gambhir:

During a telephone conservation on November 24, 2000, you requested that the NRC exercise discretion not to enforce compliance with the actions required by Technical Specification (TS) 2.4(1)b, "Containment Cooling." Specifically, you requested approval of an extension, from 7 to 21 days, of the allowed time to restore to operability Component Cooling Water Pump AC-3A. Your request was documented in a letter dated November 22, 2000, and supplemented in a subsequent letter dated November 24. The November 22 letter was previously discussed with the NRC in telephone conversations on November 21 and 22. Additionally, during a followup telephone conversation on November 27, Mr. Mark Frans, of your organization, informed the NRC that repair and testing of the pump had been completed within the original 7-day completion time allowed by TS 3.4(1)b and, therefore, the enforcement discretion did not have to be exercised. This letter documents the circumstances and considerations that resulted in your request for and the NRC's granting of enforcement discretion.

During the November 24 telephone conversation, Mr. Ralph Phelps of your staff stated that, due to a ground on the pump motor stator, Component Cooling Water Pump AC-3A had failed. Because of the age of the failed motor, an identical replacement motor was not available. Your primary plan was to procure a new motor and dedicate it for safety-related service through a third-party vendor. Your staff had determined, however, that potential problems inherent in the dedication of a commercial grade motor could prevent completion of repairs within the 7-day TS allowed outage time. Had such problems occurred, your staff intended to ship the failed Pump AC-3A motor to a vendor who was properly licensed to handle contaminated material for teardown, rewinding, and testing. Your staff estimated total repair time of 10 to 13 days with this repair methodology.

Your request for a Notice of Enforcement Discretion (NOED) was reviewed by the NRC staff, in accordance with the Section VII.c, of the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600.

The safety basis for the request for enforcement discretion was that extending the allowed outage time for Pump AC-3A for an additional 14 days resulted in a minimal increase in core damage frequency. This minimal increase was primarily the result of redundancy and diversity in the design of containment cooling systems at Fort Calhoun Station. When compared to the qualitative risk associated with a reactor shutdown and restart, you stated that continued operation was the prudent and risk-appropriate action to pursue.

Compensatory measures proposed by your staff for the duration of the NOED and considered in the NRC staff's evaluation included:

  1. Avoiding activities that could jeopardize the reliability of redundant Pumps AC-3B or AC-3C,
  2. Emphasizing the elevated importance of redundant equipment by posting signs on the circuit breakers for Pumps AC-3B and AC-3C,
  3. Suspending the normal equipment rotation of component cooling water pumps until Pump AC-3A has been returned to service, and
  4. Training shift operating crews on the use of the abnormal operating procedure for loss of component cooling water. The training would emphasize the actions needed to align the raw water system as a backup and the criteria for tripping the reactor coolant pumps on a loss of component cooling water.

On the basis of the NRC staff's evaluation of your request, including the compensatory measures described above, the NRC staff concluded that an NOED would be warranted because we were clearly satisfied that this action involved minimal or no safety impact and had no adverse radiological impact on public health and safety. Additionally, we determined that the request satisfied the NRC's policy for enforcement discretion. As a result, the NRC was prepared to exercise discretion not to enforce compliance with TS 2.4(1)b by granting approval of an extension of the allowed outage time specified in the specification from 7 days to 21 days to complete repair and testing of Component Cooling Water Pump AC-3A.

This NOED was orally approved on November 24, 2000, at 11:40 a.m. (CST). In the November 27, 2000, telephone conversation, Mr. Frans of your staff informed the NRC that repair and testing of the pump had been completed within the 7-day completion time allowed by TS 2.4(1)b. This resulted in the enforcement discretion not being needed or applied.

  Ellis W. Merschoff
Regional Administrator

Docket No.: 50-285
License No.: DPR-40

Mark T. Frans, Manager
Nuclear Licensing
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

James W. Chase, Division Manager
Nuclear Assessments
Fort Calhoun Station
P.O. Box 399
Fort Calhoun, Nebraska 68023

Richard P. Clemens, Manager - Fort Calhoun Station
Omaha Public Power District
Fort Calhoun Station FC-1-1 Plant
P.O. Box 399
Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska 68023

James R. Curtiss
Winston & Strawn
1400 L. Street, N.W.
Washington, D.C. 20005-3502

Washington County Board of Supervisors
Washington County Courthouse
P.O. Box 466
Blair, Nebraska 68008

Cheryl K. Rogers, Program Manager
Nebraska Health and Human Services System
Division of Public Health Assurance
Consumer Services Section
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007


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