IR 05000285/1989009

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Insp Rept 50-285/89-09 on 890201-28.Violations & Deviations Noted.Major Areas Inspected:Ler Followup,Operational Safety Verification,Plant Tours,Monthly Maint & Surveillance Observations & Security Observations
ML20248E236
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 03/24/1989
From: Westerman T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248E105 List:
References
50-285-89-09, 50-285-89-9, GL-88-17, IEB-88-003, IEB-88-004, IEB-88-3, IEB-88-4, NUDOCS 8904120173
Download: ML20248E236 (37)


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l I: APPENDIX C U. S. NUCLEAR REGULATORY COMMISSION L REGION IV NRC Inspection Report: 50-285/89-09 License: DPR-40 Docket: 50-285 '

Licensee: Omaha Public Power District (0 PPD)

1623 Harney Street Omaha, Nebraska 68102

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l Facility Name: Fort Calhoun Station (FCS)

Inspection At: FCS, Blair, Nebraska

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Inspection Conducted: February 1-28, 1989 Inspectors: P. H. Harrell, Senior Resident Inspector T. Reis, Resident Inspector

. R. P. Mullikin, Project Engineer, Project'Section B Approved: 7- .

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s/2 y/rr T. F. Westerman, Chief, Project Section B Date '

Division of Reactor Projects Inspection Summary Inspection Conducted February 1-28, 1989 (Report 50-285/89-09)

Areas Inspected: Routine, unannounced inspection including followup on previously identified items, licensee _ event report followup, operational safety verification, plant tours, monthly maintenance observations, monthly surveillance observations, security observations, radiological protection observations, in-office review of periodic and special reports, and review of cold weather preparation Results: During this inspection period, the NRC inspector noted that instrumentation located on the alternate shutdown panel was inoperable. 'The inoperable instrumentation included indication for pressurizer level and neutron flux level. The NRC considers this instrumentation to be critical equipment if a remote. shutdown would be require During followup on this concern, it appeared that the plant was started from a refueling outage with the instrumentation inoperable. This is an indication of the licensee's failure to take proactive actions to ensure the availability of vital plant instrumentation. Upon notification by the NRC inspector, the licensee repaired the instrumentation in a timely manne DR 890331 ADOCK 05000285 PDC

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- The licensee is currently in the process of issuing a Technical Specification (TS) amendment to address the operability of all instrumentation on the shutdown panels, since the licensee had not previously committed to maintaining the instrumentation operable. The NRC inspector discussed the need

.-to maintain the instrumentation operable with licensee management. The i licensee stated that daily checks of the instrumentation would be performed and i immediatt actions initiated if the instrumentation faile '

During tours of the plant, the NRC inspector identified numerous concerns as  ;

documented in paragraphs 6 and 10 of this inspection report. The concerns '

involved housekeeping and the control of the storage of safety-related materials in permanent storage areas.in the plant. When the initial concern was identified to the licensee, the specific items were addressed. However, the licensee did not demonstrate that proactive corrective action was taken due to additional concerns in the same areas being identified during subsequent tours of the plant by the NRC inspector. In the inspection period of December 1988 the NRC inspector identified problems related to the storage of safety-related materials in temporary storage areas. The licensee actively addressed the problems with temporary areas. However, it appeared that the licensee did not address materials stored in permanent storage area The NRC inspector identified numerous items of concern during tours of the plant as documented in paragraphs 6, 9, and 10 of this inspection repor Based on the number of concerns identified, it appeared that licensee personnel are not touring the plant at the frequency that would be expecte Based on observations and reviews performed during this inspection period, it appeared that the personnel in the operations and maintenance organizations continued to perform their duties in a professional manner. During past inspections by personnel from different organizations within the NRC, a number

. of concerns were identified with respect to the actions and performance of individuals in operations and maintenance. Observations of the performance of these individuals indicate that the previous concerns identified by NRC personnel are being corrected. Specific examples included following procedures, thoroughly documenting the work performed on maintenance orders, and controlling access to the control room boundary (i.e., the area encompassed by the control boards).

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DETAILS Persons Contacted

  • K. Morris, Division Manager, Nuclear Operations
  • Gates, Manager, Fort Calhoun Station

'J. Adams, Reactor Engineer

  • J. Bobba, Supervisor, Radiation Protection .

C. Brunnert, Supervisor, Operations Quality Assurance l

  • J. Fisicaro, Manager, Nuclear Licensing and Industry Affairs 1
  • J. Gasper, Manager, Training  !
  • S. Gambhir, Division Manager, Production Engineering l R. Jaworski, Manager, Station Engineering

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  • J. Kecy, Supervisor, System Engineering D. Lieber, Supervisor, Security
  • D. Matthews, Supervisor, Station Licensing K. Miller, Supervisor, Maintenance
  • Peterson, Assistant Manager, Fort Calhoun Station
  • S. Peterson, Manager, Mechanical Engineering  !
  • R. Phelps, Manager, Design Engineering Nuclear
  • A. Richard, Manager, Quality Assurance and Quality Control

'*B. Schmidt, Acting Plant Chemist

  • C. Simmons,' Station Licensing Engineer
  • J. Smith, Alternate Manager, Security Services
  • D. Trausch, Supervisor, Operations

'S.'Willrett, Supervisor, Administrative Services

  • Denotes attendance at the monthly exit interview.

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The NRC inspectors also contacted other plant personnel, including operators, technicians, and administrative personne Plant Status

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During this inspection period, the licensee brought the plant up from l 30 percent to 100 percent power. The power escalation was performed for a plant startup from a refueling outage that ended on January 30, 1989. The plant was held at 30 percent power for approximately 6 days for the performance of a boric acid soak of the secondary side of the steam generators.

! The licensee performed the boric acid soak to remove the dissolved solids from the secondary side ~of<the steam generator. The dissolved solids are considered to be a significant contributor to steam generator tube denting. Since the licensee initiated the soaking of the steam generators in 1986, no tubes in the steam generator have been plugge During this inspection period, the licensee:did not experience any abnormal or emergency events, or actuation of any safeguards equipment.

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-4-3. Followup on Previously Identified Items (92701 and 92702) N (Closed) Deficiency 285/8522-2.2-3: Incomplete installation and testing procedure for Modification Request (MR) FC-81-21 This deficiency was related to discrepancies that were identified with the installation and testing of Valves HCV-4388 and HCV-438 The discrepancies noted that the functional test was inadequate, no specific calculations were performed to verify the size of the accumulator assemblies for the valves, and the program for testing all accumulators had not been complete l In response to this deficiency, the licensea stated that the actions l discussed below would be taken:

(1) The air accumulator assemblies for Valves HCV-438B and HCV-4380 g would be removed and replaced by a permanent system connected to I nitrogen bottles. The bottles would provide an unlimited source of pressure for operation of the valve During the 1988 refueling outage, the licensee installed a permanent nitrogen system for valve operation. The NRC inspector reviewed the installation during followup on Licensee Event Report (LER)88-009. The details of the review are documented in paragraph 4.b of this inspection repor (2) A program for completion of testing and verification of the adequacy of the air accumulator assemblies for the other valves equipped with assemblies would be complete <

NRC inspectors have performed a review of the testing performed for accumulator assemblies. The results of the reviews are provided in paragraph 3.e of NRC Inspection Report 50-285/89-0 In addition, a review was performed of the testing of the safety injection and refueling water tank (SIRWT) level controllers, documented in paragraph 3.g of this inspection report, and the raw water pump discharge valves, documented in paragraph 3.i of this inspection repor (3) Training would be provided on the development of functional testing and test acceptance criteri I The licensee stated that the training would be provided to all appropriate system engineers by June 1989. In addition, Procedure GEI-28, " Preparation of Installation and Test Procedures," will be revised prior to May 198 This portion cf this deficiency has not been completed by the licensee. For this reason, this portion will remain open pending completion of the actions stated above by the license (285/8909-01)

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-5-b. (Closed) Deficiency 285/8522-3.2-7: Installation of a restraint fcr S Valve YCV-1045 This item involved deficiencies identified by an NRC inspector with respect to the calculation performed to verify the seismic analysis of Vahe YCV-10458 (steam supply valve to the auxiliary feedwater turb1..e pump). The actions taken by the licensee are discussed below:

(1) In response to this item, the licensee revised Drawing 0-4318, Sheet 1 of 3, to incorporate the node point for Valve YCV-1045 The drawing had not previously indicated that a node point existed for Valve YCV-1045B, even though the seismic calculation Indicatec' a node point existe An NRC inspector also noted that the licensee .. 4 not performed -

a design verification for Computer Run CFSR. The licensee verified the Computer Run CFSR and documented the completion of the verification activities on Design Modification Verification Record / Routing Sheet 97 The NRC inspector reviewed the completed documentation associated with the actions taken by the licensee, as discussed abov No problems were noted during the revie (2) In addition to the above items, an NRC inspector noted that the licensee nad not seismically qualified Valve YCV-1045B and other control valves to the current seismic requirements of Appendix F to the USA In response to this problem, the licensee stated, in a letter dated December 31, 1988, that the issue of the seismic qualification of Valve YCV-1045B would be resolved when the evaluation was completed as required by Unresolved Safety

. Issue (USI) A-46. The NRC's Office of Nuclear Reactor Regulation (NRR) is currently reviewing the licensee's proposal to delay the seismic c'alification of Valve YCV .LO45 This portion of this deficiency remains open pending the completion of the review of the licensee's proposal by NRR to delay seismic qualification until the resolution of USI A-4 (285/8909-02) (Closed) Deficiency 285/8522-4.3-1: Limit switch protection by fusin This deficiency concerned the isolation of electrical faults caused by postaccident submergence of limit switches for nine safety-related, solenoid-operated valves. The licensee had provided low-current, fast-acting fuses in the indicating light branch of the valve control circuits with the intent of. retaining valve operability

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i indications since theilimit switches had not

.~ _ been rigorously qualified for submergence. The NRC's cancern was that the fuses may not be properly coordinate The,lir ensee decided,. instead of determining fuse coordination, to extend the '11mit' switch seal (Conax) lead wires above;th '

postaccident flood level and qualify,the'NAMC0 limit switch /Conax seal assemblies _ remaining'below the flood level for ~ submergenc '

TheNRC, inspector reviewed the maintenance' orders (MO) for the installation of Raychem splices for,the limit switches for Valves HCV-238, HCV-438A, HCV-438C,.and HCV-467 In addition, the NRC-inspector ~ reviewed Electrical Equipment Qualification Documentation' File'EEQ-H-02.for the NAMC0 Limit Switch Model EA-18 The limit. switches were determined to have a qualified life of 40'ysar Based on the review performed by the NRC inspector,.the licensee's

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action appeared to-adequately address this concern.--

'd . (Closed). Unresolved Item 285/852'2-4.4-1: Design basis physical separation of cables within panel This deficiency involved, problems identified with respect to the physical separation of cables in cabinets and the use of wafer switches'as isolation devices between safety- and.nonsafety-related circuits. The problems were identified during the review of MR-FC-81-102, '" Bypass or Trip of ESF Channels without Jumpers."

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Based on the comments made by the NRC inspection team, the licensee cancelled the' installation of MR-FC-81-102 util an additional review could be performed. . Cancellation;of-the modification eliminated the

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immediate concern regarding separation criteri 'In response to this deficiency, the licensee stated'that Procedure EDC-1, " Electrical CQE Equipment' Independence. Criteria,"

would be' revised to include criteria for the separation of cables- 4 within panels. The licensee stated that Procedure EDC-1 would be i revised by' December 198 This item remains open pending the revision of Procedure EDC-1 by the Ilicensee. (285/8909-03) ' (0 pen)1 Open Item 285/8803-04: Testing of the controls on the alternate shutdown panel (ASP).

This item involved a question of whether or not the licensee was required to test the controls on the ASP. At the time this item was identified, the licensee stated that testing had been performed and documentation would be provided to indicate the results of the

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.In' subsequent discussions, the licensee determined that no' routine ~

surveillance testing'was performed on the ASP controls. The licensee j stated that an acceptance test had been performed after installation ~

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.of the~ panel in 1981. The. licensee also. stated that no plans'were being developed to test the, controls on the AS To establish whether.or not testing of the ASP controls was required, the NRC inspector _ forwarded a letter to NRR for determination of 'l whether or not: testing was required. In'a letter to the licensee, dated January 30, 1989, NRR stated that routine testing of the ASP .

was required. In addition, NRR stated that the licensee'shall submit to the NRC, within 60 days of receipt of the letter, a response addressing a schedule for completion of the appropriate TS changes, .

the completion of surveillance _ test procedures,'and the-

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accomplishment of the actual testin This item remains ~open pending receipt of'the licensee's schedule and revision of the TS to incorporate the testing requirement ' f .- (Closed) Open Item 285/8811-06: Modification to Radiation Monitor RM-065.

s This itv. concerned RM-065 which had to be manually initiated upon receipt of a ventilation isolation _ actuation signal (VIAS). Based upon'an NRC' concern, the licensee committed to modify actuation of RM-065, during the 1988 refueling outage,.to automatically initiate the' monitor when a VIAS is receive ,

The NRC inspector reviewed MR-FC-88-009 which covered the following work:

Automatic actuation of RM-065 upon receipt of..a VIA Provide annunciator panel indication,if P,Mi O65 is turned of Move the RM-065 to an area in the control room near the toxic gas monitor In addition, the NRC inspector reviewed the actual installation of l RM-065, and reviewed the postmodification test and applicable procedure change No problems were noted during the . review (Closed) Open Item 285/8815-05: . Performance of a functional test of the accumulator assemblies for the SIRWT level controller I i

This. item was related to the performance of a test to verify that the-l accumulator assemblies for the SIRWT level controllers were properly L

sized. The acceptance cri'eria established by the licensee stated

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that the volume in the accumulators shall be sufficient to supply air i to the level controllers for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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, LDuring the 1988 refueling outage. the' licensee' tested the accumulator

" assemblies inaccordance with Test Procedure T-1, " Functional Test of ,

' ",' -SIRWT Air Accumulators,"_which was'a part of MR-FC-88-3 ,

Procedure T-1;provided instructions for performance of a slow- and s

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a fast-leak test' to ' simulate a pressure ' decay in the instrument. air- '

? r system and to' simulate a'line rupture of the instrument air syste '

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The test'results indicated that all four accumulator assemblies were l capable of' performing their intended design functions'in the event that instrument air pressure was los The NRC inspector reviewed Procedure T-l' to verifylthat th'e . licensee had provided the appropriate instructions to verify the adequacy of the capacity of the accumulator assemblies. The NRC inspector also reviewed the.. test results to ascertain that the testing verified that the accumulators met the acceptance criteria. No problems were noted e> -during.the reviews, (Closed) Severity Level III Violation .285/8815-06: Level controllers ,

for the SIRWT.

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Thisiitem. involved the failure of the check valves"for the accumulator assemblies for the SIRWT level controllers (A/FIC-383, B/FIC-383, C/FIC-383, and D/FIC-383) to pass their functional tes The controllers are used to monitor the level in the SIRWT and automatically switch the suction'of-the safety-injection pumps from

,the-SIRWT to thel containment sump at a preset level. When the licensee performed the testing, it was noted that the check valves installed were~a misapplication of design. .The check valves were

' installed'in an air system,'bu.t were designed.for ste'am'or water servic To resolve this problem, the licensee, upon discovery of the deficient condition, immediately removed the old check valves and installed new check valves that were. designed'for air service. Prior to installation.'of the check valves, the licensee bench tested-the:

. valves to verify that they could pass the surveillance test for leak tightness. To ensure that the check valves would continue to operate

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satisfactorily, the licensee, in a letter dated December 17, 1987, included the check valves in the inservice testing (IST) program submitted to the NRC. The NRC reviewed and approved the inclusion of the valves in the plan on December 22, 198 To-provide a means of testing the valves during power operation, the air supply system for the air accumulators was modified during the 1988 refueling outage. The modification was performed in accordance with MR-FC-88-39, " Instrument Air Isolation Valves for SIRWT

. Bubblers." Tne modification installed isolation valves in the air supply line for each level controller so each controller could be taken out of service for testin "

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-9-The NRC inspector reviewed the actions taken by the licensee, as described above, and performed a walkdown of the air system modifications made by the licensee. No problems were noted._ Based on this review, in conjunction with the review discussed in paragraph 3.g above, it appeared that the licensee had taken appropriate action to ensure that the SIRWT level controllers would perform their intended safety function, when require . (0 pen) Open Item 285/8823-01: Up assemblies for the raw water (RW) grade pump of the valve discharge air accumulator The licensee added the RW pump discharge check valves (RW-115, RW-117, RW-121, and RW-125) to the inservice inspection program. The check valves were added to the program in order that the valve back leakage could be quantifie The valves were added to the program from a commitment made to the NRC in a letter from the licensee to NRR dated October 30, 198 The leakage was to be determined so that the licensee would not have to upgrade the air accumulator assemblies of the four RW pump discharge valves (HCV-2850, HCV-2851, HCV-2852, and HCV-2853) to a critical quality element (CQE) status. The testing of check valve leakage was first performed during July 1988 and was found to be excessiv The discharge flow from the RW pumps supply a common header. The pump discharge valves are normally open when the pump is running and normally shut when the pumps are secured. The valves are air operated and fail open on the loss of instrument air pressur Because the pump cht::k valves leaked excessively and because the pump-discharge valves fail open on a loss of instrument air, the licensee could not be certain that sufficient RW flow could be provided to the component cooling water (CCW) heat exchangers for plant shutdown in all possible scenarios. With the pump discharge valve failing open and the pump check valve leaking excessively, some of the flow needed- ;

by the CCW heat exchangers could be lost through an idle pum l l

To address the problem, the licensee issued MR-FC-88-61, " Air Check Valve for RW Discharge Valve," to upgrade the air systems on RW Block Valves HCV-2850, HCV-2851, HCV-2852, and HCV-2853, to safety grade to provide an alternate means of. isolating raw water backflow through an idle loop. The upgrade required seismic qualification of tubing, valves, and accumulator The NRC inspector reviewed the modification package and perfomed a field verification of the new installations. The completed modification package was found to encompass the necessary elements with regard to design, installation, and testing. In the field l verification, the NRC inspector noted that the new seismically installed air line to Valve HCV-2851 would exhibit excessive

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.I vibration if it were induced. The NRC inspector questioned the

' seismicity of the line. The NRC inspector relayed this concern to i the licensee on February .28,1989, which was.the end of this inspection period. A response has not yet been receive The NRC inspector then reviewed the latest-submittal of the licensee's IST program for pumps and valves to verify the accumulator / check valve assemblies had been included. They had not yet been formerly included. The licensee is aware of their commitment to the IST of these components and has included this testing in Procedure ST-ISI-RW-1, " Raw Water Valves Inservice Testing?

This testing was successfully performed during the 1988 refueling outag The NRC inspector question the utilization of Valves HCV-2850, HCV-2851, HCV-2852, and HCV-2853 without performing backleakage testing. These valves serve as backup isolation for the check 'alves which did not' pass inservice testing. The licensee preliminar,iy agreed to the inclusion of a backleakage test of the discharge valves in the IST progra Due to the incompleteness of the IST program in regard to these assemblies and the concern of vibration with one of the lines, this item will remain open pending further licensee actio (Closed) Severity Level IV Violation 285/8832-01: Failure to issue a special report on an inoperable fire barrie TS 2.19(7) states that if a penetration fire barrier protecting safety-related areas is nonfunctional for more than 7 days, a special report to the NRC shall be submitted within the next 30 days. This violation involved the failure to issue a special report for inoperable Fire Door 1007-1 The licensee's corrective action involved the revision of Procedure 50-G-58, " Fire Barriers." The NRC inspector reviewed Procedure 50-G-58 and found the procedure to be clear and conciee n ;

to the requirement to issue a special repor (Closed)OpenItem 285/8832-04: Inadequate response by plant personnel to particulate, iodine, and noble gas (PING) monitor alarm This item involved the NRC inspector's finding that a PING monitor alarm was sounding for approximately 30 minutes in Room 69 wdhout any personnel contacting health physics' (HP) personnel. Ar.'iP technician was informed by the NRC inspector of the alarm. The HP technician responded that the alarm was due to a temperature inversion.

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l l-11- 1 The proper response to alarms is part of the general employee trainin However, it was apparent that some individuals were ignoring tnese instruction On January 26, 1989, after a violation of radiation protection practices in a high radiation area occurred, the plant manager issued a stop-work order for all nonessential activities in the radiological centrolled area (RCA) as discussed in NRC Inspection Report 50-285/89-04. The plant manager held, on that same afternoon, a meeting with all available onsite personnel to emphasize the absolute necessity of complying with all radiation protection requirements. It was also stressed that each individual would be held accountable for violations of radiological requirement In addition, that same evening, a training class was established to reemphasize the radiological requirements that each individual was required to follow when entering and working in the RCA. The plant maneger required all individuals with access to the RCA to complete i the training prior to being allowed to reenter the RC l The NRC inspector reviewed the radiological work practice guidelines presented at the training sessions. These guidelines included the proper response to PING monitor alarms. This appeared to adequately resolve this concer . (Closed)UnresolvedItem 285/8846-05: Concerns identified during l declaration of a Notice of Unusual Event (NOVE).

This item is related to concerns identified during an NOUE declared by the licensee when toxic gas was released due to the melting of the fusible plug in a chlorine bottle. Each concern, along with the l licensee's corrective action, is discussed below:

(1) The industrial safety engineer identified a problem with a large heater being located inside the chlorine gas bottle storage area. The licensee did not take immediate action to remove the heate The licensee, in followup on this item, noted that the industrial safety engineer did not express a concern with the overheating of the chlorine bottle, but expressed a concern with !

the heater not meeting explosion-proof fire code requirement The industrial safety engineer stated that he had not seen the heater and did not know how large it was. Therefore, based on the review performed by the licensee, the concern related to overheating of the chlorine bottles was not identified prior to the even The licensee has removed the large heater from the room where the chlorine bottles vere stored. A walkdown was performed by ;

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chlorine bottles are store .

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I The licensee instituted a program where safety concerns identified by the safety engineer will be provided immediate attentio The safety concerns will be identified at th plan-of-the-day meeting held eachimornin The licensee, in a proactive effort to strengthen their~ industrial safety program, requested that a team of personnel from outside of OPPD review the licensee's safety program and provide comments on how the program could be improved. The team visited the FCS during.the week of February 13, 1989, and provided the licensee with suggestions for program improvement. The licensee is currently implementing the improvement suggestions made by the tea The NRC inspector reviewed the actions taken by the licensee and 'i no problems were note I (2) When the control room announced that evacuation of the water plant building was required, the announcement failed to identify which direction to evacuate. As a result, individuals left the water plant building in the wrong direction and entered the chlorine gas plum To address this concern, the licensee revised and reissued Procedure EPIP-05C-2, " Emergency Plan Activation and Notifications." Prior to the revision, the procedure did not provide instructions to the user to specify which direction of evacuation was appropriate in'the event a NOUE was declare The procedure only addressed the need to specify the appropriate evacuation route in the event other emergency classifications were declare The revision to Procedure EPIP-0SC-2 provided instructions for the evacuation route to be given during all emergency classifications. In addition, the procedure revision provided the text of a formal announcement to be made on the .

public address system should an evacuation for any emergency l classification be declare l The NRC inspector reviewed the revision made by the licensee to Procedure EPIP-0SC-2. No problems were noted during the revie (3) The licensee experienced difficulty in contacting the state of Iowa. The difficulty resulted in the licensee not contacting the state until approximately 23 minutes after the NOUE was declare In review of this concern, the licensee determined that the sta b of Iowa used a call-forwarding telephone network. The call-forwarding network was designed to automatically forward

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the call to the Iowa Public Safety Office (PS0) if the call is

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not answered at the: Iowa Emergency Operations Center (E00). .

When the control' room initiated notification of the; state-of N Iowa,- the call-forwarding ~ network failed to function; therefore, R

< no one answered the call as no'one was:at the Iowa EOC.'

To permanently resolve this' problem, the telephone network.for ,

the state of Iowa E0C was c.odified. . The modification eliminated'

the call-forwarding feature and, replaced it with circuitry that

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' rings'the telephone at the IowaiE0C and the. Iowa PS0 simultaneously This modification will ensure that the state off Iowa an be' notified whenever the licensee declares an emergsic ,

-l To' ensure that the telep h e lines'and equipment at both locations are routinely tested, the licensee revised Procedure EPT-3, " Emergency Response Communications." The revision required that both locations answer the telephone to verify that the equipment is-functionin ~

The NRC inspector reviewed.the actions taken by the license <

No problems were note (4) The supplier of the chlorine bottle, Air Products, completed an evaluation of the failure of the gas' bottle to verify the-failure mechanism. In a letter dated December. 22, 1988, Air Products stated that the_ failure mechanism was overheating of the fusible plug. The letter stated that~no other problems were

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=The identification of the specific fai1ure' mechanism by the supplier eliminated the potential that the bottle had failed due to some other problem such as a defective bottle or bottle isolation valv Based on issuance of the evaluation, the NRC inspector had no further questions in this are (Closed) Open Item 285/8902-07: Electrical supply breaker for a 480-volt motor control center (MCC-4C1) tripped during plant startup with normal plant load This item concerned Breaker 184C-2 which is used to protect MCC-4C ,

This MCC normally hac a load of 6 amps, but during startup,' the use I-of backup pressurizer heaters results in a total load'of 296 amp This breaker is tested and calibrated during each refueling outag During previous outages, the long-term trip test for the breaker was performed using an' input current of 320 amps (the actual trip setpoint of.this breaker). If the. breaker did not trip after

300 seconds, this part of the test passed. However, Setpoint/ Procedure Change 21477 was made on February 11, 1988, to i

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chatge Calibration Procedure CP-MCC-4C This new procedure changed ~

the test input current from 320 amps to 288 amp This was done, due to vendor technical information, to help prolong the life of the breake On November 9,1988, Breaker-1B4C-2 failed its calibration tes The-licensee replaced the B-~~and C phase trip devices. .The breaker the passed its test using a test value of 288 amp During startup, on January 12, 1989, Breaker 1B4C-2 tripped with a load of 296 amps. The licensee initiated MO 890515 to investigate ;

the problem. It was found that the B phase trip device was fault '

The faulty trip device was replaced and Breaker 184C-2 passed its-calibration test. This test was performed using'an input current of 320 amps, which was changed by Setpoint/ Procedure Change 2632 Startup was then performed without Breaker 184C-2 trippin Breaker 184C-2 is a GE Model AK-2A-25 breaker. The licensee also changed the input test current to 320 amps for the other 480-volt GE Model AK-2A-25 breakers (1B3A-2 and 183C-1). These were also calibrated successfully during the 1988 refueling outag . LER Followup (92700) ,

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Through direct observation, discussions with licensee personnel, and review of records, the following event report. were reviewed.to dete'emine that reporteoility requirements were fulfilled, immediate corrective action' was a' accomplished, and corrective ection to prevent recurrence had

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been accomplished in accordance with the T The LERs listed'below are closed:

87-029 Surveillance Test Missed for Containment Lighting 88-009 Valves'Would Not Perform Their Design Function 88-010 Failure of the Air Accumulator Check Valves for the SIRWT Level Controllers88-012 Failure to Issue a Special Report for an Inoperable Fire Barrier i 88-017 Failure to Issue a Special Report for an Inoperable Fire Barrier 88-018 Failure to Conduct a Surveillance Test Within the Prescribed Interval 88-022 Failure to Issue a Special Report for an Inoperable Fire Barrier 88-024 Inadvertent Start of EDG No. 2 I

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.1 88-034 Inadvertent VIAS Due to Malfunction of Radiation Monitor RM-050 ,

Declaration.of a NOUE Due to a Leaking Gas. Cylinder

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88-035-88-002 Inadequate Instructions Provided in Surveillance Tests - 1 A discussion of the review performed by;the NRC inspectors for each LER is provided below:

. LER 87-029 reported that the TS surveillance requirement for the '

containment emergency lighting was not met in 1986. TS 3.7(3) and Surveillance Test ST-DC-4 require emergency lighting to-be tested once per year. Because the test requires a containment entry, the

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licensee was performing the test during refueling or forced outage Surveillance Test ST-DC-4 was not performed in 1986 since no refueling-or forced outages occurre :The licensee stated that, to ensure that the surveillance test is not

. overlooked again, Surveillance Test ST-DC-4 will be issued on the December surveillance test schedule. In addition, the licensee is

. examining the safety implications of changing the surveillance interval to refueling, rather. than once per year'. This will require a TS amendment if the surveillance interval.is to be change The NRC inspector verified that Surveillance ' Test ST-DC-4 was-performed in December 1988 and that the test revealed no problems with the containment emergency lightin . LER 88-009? reported six valves which would not perform their desig function during a design basis accident with a' concurrent loss of-instrument air. The valves in question were LCV-383-l'and LCV-383-2 (SIRWToutletvalves),HCV-238andHCV-239(chargingpumpheaderto-reactor coolant system isolation valves), and HCV-438B and HCV-438 '(isolation valves for component cooling water to reactor coolant pump

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seal coolers).

The.NRC inspector reviewed MR-FC-88-67 which provided for the installation of nitrogen bottles sized to provide an indefinite period of time for. valve actuation capability. The NRC inspector verified that the nitrogen bottles were installed. One item noted by the NRC inspector was that operator identification of the correct valve's nitrogen supply could be enhanced if labels were installed on the board located by the nitrogen bottles. The licensee subsequently ,

installed labels on the nitrogen bottle control board LER 88-010 reported an event where the check valves for the accumulator assemblies for the SIRWT failed to pass their IST. The failure of the check valves caused the accumulator assemblies to be-inoperable, which in turn caused the SIRWT level controllers to be inoperable during a loss of instrument air pressur If the level i

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f controllers were inoperable, th'e suction of the safty-injection pumps could be switched prematurely- from the SIRWT. to a dry containment sum The NRC insoector performed a review of Violation 285/8815-06 that was issued as a result of the review of this problem. The followup review of Violation 285/8815-06 is documented in paragraph 3.h of this inspection' report. Based on the review of the violation, this LER is considered close i LERs88-012, 88-017, and 88-022 reported the failure to issue a special report on fire barrier inoperabilit The TS requires a special report to be submitted to the NRC withic 30 days after a fire barrier has been' inoperable for more than 7 day As discussed in paragraph 3.j of this inspection report, the closure of Violation 285/8832-01 by issuance of a revision to Procedure 50-G-58 should eliminate or significantly reduce the number of missed special reports for inoperable fire barrier These LERs are considered close e. LER 88-018 reported the failure to conduct a surveillance test within the prescribed interva The surveillance missed was Test ST-CEA-1,

" Control Element Assemblies." This test required all regulating and shutdown control element assemblies (CEA) to be exercised a minimum of 6 inches every 2 weeks whenever the reactor is critical. On July 4, 1988, while performing the test ~, operations personnel i

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contacted the reactor engineer, as instructed by procedure, for additional guidance.because CEA regulating Group 4 was not in a fully withdrawn position. The reactor engineer errencously determined that !

Group 4 did~not need to be exercised since it was inserted in the ;

core for axial flux distribution contro '

The NRC inspector reviewed Revision 69 of Surveillance Test ST-CEA-1 which had a note added to help ensure that all CEA groups are exercise In addition, the surveillance test performed on 3 February 7, 1989, was reviewed since several groups were not fully i withdraw In all cases the test was satisfactorily performe Based on this corrective action, this LER is considered closed.

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f. LER 88-024 reported an event where Emergency Diesel Generator (EDG) No. 2 automatically started in idle speed. The event occurred when the plant was in a refueling shutdown mode (Mode 5).

As described in the USAR, the EDGs receive automatic start signals i from either a pressurizer pressure low signal, a containment pressure high signal, a reactor trip, or low voltage on diesel Buses 1A3 or 1A The licensee's investigation revealed that none of the above signals were generated and that EDG No. 2 started on an anticipatory signal of low voltage on Bus 1A2. Bus 1A2 is not a safeguards bus

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and the diesel start signal generated from a low voltage on. Bus 1A2 '

Lis not considered in the USA The--licensee reported that on October 3,1988, while in Mode 5, control room operators momentarily received alarms, "4160V Bus 1A2 Low Voltage" and "4160V-Bus IA4 Low Voltage."' EDG No.:2 then '

. automatically started to idle speed (500 rpm). Simultaneously, a ,

circulating water pump running on Bus 1A2, which is not the ,

safeguards bus, was shed from the bus. All loads operating.on the safeguards Bus IA4 remained running throughout the even ]

  • .The licensee has investigated this event to maximum extent possibl Without voltage recorders. installed on the buses, it is not possible to positively. ascertain whether this event was triggered by a momentary dip in system voltage or an anomaly with the Bus IA2 rela There appeared to-be nothing that would have precluded EDG No. 2 from performing.its designed safety functions. . This LER is considered close ~ LER 88-031 concerned two unexpected trips of 480-volt bus-tie Breaker BT-1B4C. Nonna11y, 4160-volt Bus.1A3 supplies. 480-volt 1 i

Buses 183C and 183C-4C. These two busses are connected to 480-volt Bus 1B4C by normally open bus-tie Breaker BT-184C. Due to maintenance on 4160-volt Bus'1A3, the loads on 480-volt Buses 183C and 183C-4C were supplied by 4160-volt Bus 1A4 by closing bus-tie .

Breaker BT-184C. Thus, during this alignment, the loads on two buses were being supplied via one bus tie breaker (BT-1B4C). This overload caused bus-tie..Breaur BT-1B4C to tri The licensee's corrective action was to revise Operating Instruction 01-EE-28, " Hot Bus Transfer of 480V Buses," to insert a caution to operators to monitor the loads on bus-tie breakers before transferring loads. The NRC inspector felt this procedure: change should resolve this problem. This LER is considered close LER 88-034 reported an inadvertent VIAS initiated by Radiation Monitor RM-050. The licensee determined that the cause of the event

.was due to the failure of the RM-050 filter paper to properly feed into the monitor. Adding to this problem was the higher background levels caused by a temperature inversion and a very small spike of unknown origi The licensee previously replaced the filter paper on an as-needed basis. However .due to this event, the licensee put the replacement '

of the filter paper for RM-050 and the other monitor using filter i

paper (RM-061) on a biweekly preventive maintenance schedule. This action appears to adequately resolve the problem. This LER is .i considered close l LER 88-035 reported an event where a "N0UE was declared due to the release of toxic gas. Due to overheating of a chlorine gas bottle,

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-18-the fusible link melted causing the toxic chlorine gas to be released. The release resulted in 24 individuals being transported to the hospital. None of the individuals were hur The NRC inspector performed a detailed review of the event at the time of occurrence. The review is documented in paragraph 12.d of NRC Inspection Report 50-285/88-46. During the review, three concerns were identified related to the actions taken by the licensee. These concerns are addressed in paragraph 3.1 of this inspection report. Based on the review already performed by the NRC inspector, this LER is considered close j. LER 89-002 reported two surveillance tests associated with demonstratingtheintegrityoftheshutdowncoolingsystem(SDC)

which had not been performed correctly over a period of years. The tests are TS requirements performed at a frequency of every refueling and not to exceed 2 year The tests were originally designed to test the portion of the SDC system outside of containment to 250 psig and to test the piping from the containment sump isolation valves to the discharge valves of the low-pressure safety injection and containment spray puups to 100 psi The test concerning the 100 psig hydrostatic test, Procedure ST-RHRS-1,

" Recirculation Heat Removal Hydrostatic Test," as originally written, provided appropriate instructions for the test to meet the TS requirement. However, a revision was made to the procedure in 1982 which changed the location of the input test rig from upstream of the containment sump discharge check valves to downstream of these valves. This change precluded the section of piping from the sump aischarge isolation valves to the downstream check valves being exposed to the hydrostatic test pressure. In reviewing the system, the licensee's system engineer discovered this testing deficienc To correct the problem, the procedure was changed by the system engineer to ensure that deficiencies identified during the review were satisfactorily addressed. The revised procedure was successfully completed during the 1988 refueling outag The test concerning the 250 psig test, ST-RHRS-2, " Recirculation Heat Removal Leak Rate," was originally designed to utilize normal SDC system operation to pressurize SDC pipin However, in 1975 an interlock was installed on SDC primary isolation valves to prevent them from opening when reactor coolant system (RCS)

pressure is above 235 psig and 300 F. This interlock is designed to protect the integrity of the low pressure SDC system. The surveillance test was never revised to reflect the logic of the isolation valves. Therefore, performance of the test as originally

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. written'could'not have satisfied the TS requirement to check-system leakage at.250Tpsi ' To correct 1the, problem and ensure that requirements of.the TS are

. satisfied, the procedure was' rewritten by the system engineer. .The:

revised procedure was successfully completed during.the 1988 refueling outag '

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The licensee identified,. reported, and corrected the problems associated with these deficient tests. To prevent recurrence of ,

similar events, the licensee has'in place or has instituted periodi review requirements. Licensee Procedures 50-G-23, " Surveillance Te'st Program'," and S0-G-36, " Operating Manuals Review Documentatiois," are

' designed tofensure that surveillance tests demonstrate compliance

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lwith the'TS. The' licensee has developed a procedures upgrade project

'that'should provide additional assurance that ~ surveillance tests have-received a thorough review'and are technically. adequate. The licensee.has recently instituted a' system engineering program. The system. engineers are currently in training on the technical requirements of their assigned systems. Upon completion in June 1990 these engineers will have cognizance of the surveillance tests and'

will be responsible for their adequac Based on this event being licensee identified, reported, and corrected and the successful completion of the tests and^the. programs in~ place to preclude recurrence, this item may be closed.without further actio Based on the' reviews performed by the NRC. inspectors, as described above,

, it appears that the . licensee took appropriate ~ actions in response to the

. identified events to provide timely' corrective actions and implementation of controls to prevent recurrence of the even No violations or deviations were identifie < Operational Safety Verification (71707)

The NRC inspectors conducted reviews and observations'of selected activities to verify that facility operations were performed in conformance.with the requirements established under 10 CFR, the licensee's administrative procedures, and the TS. The NRC inspectors made several control room observations to verify the following:

Proper shift staffing was maintained and conduct of control. room personnel was appropriat Operator adherence to approved procedures and TS requirements was eviden i

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Operability of' reactor protective system,-engineere'd safeguards o+ '

, equipment, and the; safety. parameter display system was. maintaine ,

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If not,.the appropriate TS-limiting condition for' operation was~ me ,., Logs,. records,: recorder traces, annunciators, panel indications, an l switch' positions complied with'the appropriate requirement ~

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  • Proper feturn to service.of components was performe e

M0s were initiated for equipment in need of maintenanc '

Management personnel toured the control room on a regular basis'.

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Control room annunciator status was reviewed to' verify operator awareness of plant' condition l

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Mechanical and ' electrical temporary modification logs were properly' !

maintaine '

Engineered safeguards systems were properly aligned for the specific plant conditio During observation of the above items, the NRC inspectors noted no o problems with the performance of the licensee's operations staff. .It-appeared that the licensee's operations staff was adequately perfo'rming their duties.to ensure safe operation of the plan No violations or deviations were identifie . ' Plant Tours (71707)

The.NRC inspectors conducted plant tours at various times to assess plant and equipment conditions. The following items were observed during the; tours:

General plant conditions', including operability of standby equipment, were satisfactor Equipment'was being maintained in proper condition, without fluid

', leaks and excessive vibratio Valves and/or switches for safety-related systems were in the proper positio Plant housekeeping and cleanliness practices were observed, including q no fire hazards and the control of combustible materia '

Performance of work activities.was in accordance with approved procedure j

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' Portable gas cyl_inders-were' properly stored to prevent possible-missile hazard ,

. Tag out of~ equipment was performed properl Management. personnel toured the operating: spaces on~h regular basi . ,

During-tours of the plant, the NRC inspector.noted the items listej below: The'NRC inspector toured the' plant..on February 13, 1989,' and noted .

that'two supports for the fire water line directly over the generator.:

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for EDG No,',l'had been. remove The NRC inspector was concerned that,,durin'g a= seismic event, the. line could fail and spray water into the generator of EDG No. 1, resulting in a failure of the

, . generator to perform its intended safety functio The NRC inspector notified.the licenseeof the concer The licensee determined that EDG~No. 1 remained operable based'on-engineering-judgemen On February 14, 1989,Lthe' licensee reinstalled the:

seismic supports in accordance.with-M0 890025 to eliminate the concer .The licensee' prepared a' calculation to verify that the line remained'

in an acceptable seismic' condition even though the two_ supports were-remove The results of.the calculation indicated that the

, installation of the.line was satisfactor ' JThe NRC inspector will forwardithe calculation to NRR for revie '

This item remains unresolved pending review of the calculation'by '

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NR (285/8909-04)

During review of this concern, the NRC inspector established that no approved. documentation had been issued to authorize removal of the two hangers on the fire water line. The' licensee performed an extensive documentation review and.'could not produce >the document that authorized removal of the hanger Criterion V of Appendix B to 10 CFR Part 50 and the. licensee's NRC-approved quality assurance plan state, in part, that activities affecting quality shall be prescribed by documented, instructions and ,

shall be accomplished'in accordance with these instruction l Procedure S0-G-21, " Station Modification Control," states, in part, that' modification of equipment shall be performed in accordance with written: procedure Contrary to the above, the lL insee modified equipment without written instructions in that two hangers on the fire water system were removed without written procedures and removal of the supports potentially affected the operability of EDG No. Thi' is an i apparent violation. (285/8909-05)

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.b.. During a tour on February 16, 1989, the NRC inspector.noted that'it ,

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appeared that the fire protection system valves for the water-curtain -

' headers had not been tested. . The water-curtain . headers are installed .

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over:the' doors that connect the auxiliary and. turbine: buildings;and are designed to protect the auxiliary building from any fire that may?

occur in the turbine buildin Each header is equipped with_a' valve '

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that is held shut by a fusible link. The valve is designed'so that-the heat from the fire will melt the link, causing the valve to open '

and initiate the. fire water flow. There are a total: of Leight ~

water-curtain headers installed in the plan '

l The NRC inspector requested the licensee-to' provide ' documentation that the' water-curtain valves had been tested. The licensee stated that the valves had not been tested since the' valves were originally ' '1 '

installed in approximately 1982. -

In reviewing the requirements for installation of water curtains and i

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testing of the fusible-link valves, the NRC inspector noted tiat the licensee apparently failed to meet commitments stated in the USA .

The licensee's deviations from the commitments are discussed below: j (1) Section 9.11.3 of the USAR states, in part, that a safe shutdown- ,

analysis has been performed on an area-by-area basis to satisfy-the provisions of Appendix R to 10 CFR Part 50. Evaluation of i fire protection for safe shutdown is contained in the Safety Evaluation Report (SER), " Fort Calhoun Power Station Unit 1,"

dated August 23, 197 Section 4.9 of the SER states, in part, that water curt'ains will be installed to reinforce protection by 3-hour. fire doors at'

doorway openings- between the _ turbine and the auxiliary building In deviation from the above, the licensee did not install a water curtain at the doorway opening between' the fan room (in the turbine building) and Room 81 (in the auxiliary building).

(285/8909-06)

(2) Section 9.11.4 of the USAR states, in part, that testing is performed and^ verified by inspection and audit to demonstrate conformance~with subsequent design and system readiness  ;

requirement In deviation from the above, the licensee failed to test the eight fusible-link valves that supply the water curtain ;

(285/8909-06)

During a review of this problem, the NRC inspector reviewed Piping and Instrumentation Diagram 11405-M-266 and noted that the valves that supply the water curtain. swere not shown on the drawing. In addition, the NRC inspector.also noted during plant tours that the

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valves had not.been assigned a valve numbe These two' facts P appeared to have contributed to the licensee not testing the valve In' response to this deviation, the. licensee stated that a review is e currently in process to determine what actions will be taken. The review will include verification that the water curtains are required j for safe shutdown and that the fusible-link valves are testabl Duringa plant tour on February 13 1989, the NRC inspector identified a 3/4-inch copper line in the battery rooms that appeared not to be seismically installe The copper line is joined by soldered joints and is used to supply potable water to the eyewash / shower stations located in both battery rooms. The copper ' ;,

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line is approximately 10 feet from the batter The NRC inspector's concern was that, during a seismic event, the nonseismically l installed line could fail at a joint or the line itself could fail, spray water on the battery, and affect battery operability. Since the line traverses both battery rooms, the potential existed that :

multiple line breaks could affect the operability of both batteries, j i

The licensee' installed the copper line in accordance with MR-FC-79-116 in 198 The review and evaluation completed by the licensee for the modification stated that the plant staff should ensure that the piping is not run above the batteries. This way, seismic analysis and seismic supports will not be require After notification of this concern to the licensee by the NRC inspector, the licensee immediately shut the water supply valve to the eyewash / shower stations. After reviewing the available documentation, the licensee provided the NRC inspector with a ,

calculation to indicate that the copper line was seismically 1 installed. Based on the documentation, the licensee reopened the water supply valve. The NRC inspector reviewed the calculation and noted that the calculation did not address the copper.lin The

' calculation indicated that the eyewash / shower station was seismically installed and would not fall over on the batterie The NRC inspector provided the licensee with the information identified during review of the calculation. The licensee concurred j with the results of the review. The licensee stated that, whether or l not the line was seismically qualified, the line would not affect l operability of both batteries concurrently. The licensee's statement !

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was based on engineering judgement and the basis of the judgement was

' that operability of the battery would not be affected unless a large l break occurred. . The licensee stated that a large break would have to '

occur to spray a sufficient amount of water on the battery to affect j battery operability. Based on the assumption that a large break would be required, the licensee stated that both batteries could not be affected since a large break would preclude sufficient pressure and flow in a break anywhere else in the line to affect the other batter ,

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Because the resolution of the concern identified by the NRC inspector was based on engineering judgeinent made-by the: licensee,. the'NRC inspector could not reach a conclusion as to the acceptability of th installatio ,

For-this reason, thisLconcern'will be forwarded to NRR for review. This item remains: unresolved'pending a review of this issue by NR (285/8909-07),

After discussing this c'oncern and the'results of the review with the plant manager, the valve was tagged shut by a caution tag. The tag stated that the valve shall remain shut unless maintenance or testing activitiesare in progress in the battery rooms, During a tour of Room 19 on February 13, 1989, the NRC inspector noted that an individual was walking on the piping that was installed

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to supply' steam to the auxiliary feedwater (AFW) turbine-driven pum The individual was part of the crew that was in the process'of painting-all. spaces in the plant. The NRC inspector was concerned ,

that the weight of the. individual may have overstressed the piping '

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and/or supports for the AFW steam lin The NRC inspector notified the licensee of the concern. The licensee .

immediately stopped the. work being done by the painting crew in ,

Room 19. This crew, and all other crews working in the plant, were H instructed that walking on any piping or in any cable trays was prohibited. The crews were to use ladders instead of piping as a means of obtaining access to areas in the' plan During followup on this concern, the NRC inspector established that ,

crews had been previously instructed that they could walk on plant piping as long as the piping was greater than 2 inches in diamete The piping for the AFW turbine is 2 inches in diameter; however, since the line is encased in insulation and thus gives the appearance that- the line is greater than 2 inches in diameter, it was not

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apparent to the NRC inspector how individuals in the painting crew could readily determine the actual size of the pipin '

The licensee stated that their present position of not walking on any lines would remain in effect until this issue is adequately resolve This item remains open pending a review, by the NRC inspector, of th '

licensee's position on allowing individuals to wa'1k on system pipin (285/8909-08)  :

j The licensee is also performing a calculation to verify that the weight of the individual on the AFW steam line did not overstress the i pipe and/or pipe supports. At the end of this inspection period, the l E licensee had not completed a formal calculation. .This item remains l f unresolved pending issuance of the calculation by the licensee and a review of the calculation by NRR. (285/8909-09) ,

With respect to operability of the steam lins, the licensee stated  ;

that, based on _their engineering judgement, ~no overstressing problems t

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were created when the individual walked on the AFW steam line. The i judgement was based on the piping being a 2-inch line and the pipe .]

being installed as a Class I seismic installation, j During tours of the auxiliary building, the NRC inspector noted the

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following. items related to storage of material in permanent CQE storage areas:

-(1) On February 14,1989, the NRC inspector noted that a ladder, trash, and hand tools were stored in the permanent CQE storage l cage in Corridor 4. None of the items identified were i designated as CQE material as no green tag (the method of J identification used'by the licensee to designate CQE material) !

was attached to the item The NRC inspector notified the licensee and the licensee removed

.the specific material identified by the NRC inspector from the storage cage. The licensee notified the NRC inspector that the problem with.' storage of material had been adequately resolve On- February . 20,1989, the NRC inspector toured the auxiliary building to verify that the licensee had removed the material ;

without the green tags. During this tour, the NRC inspector noted that the licensee had removed the trash and tools from the storage area. The NRC inspector also noted that the licensee had not addressed the storage of charcoal filters in the storage area. See paragraph 6.f below for a discussion on the disposition of the filter (2) On February 20, 1989, the NRC inspector, dur.ing a tour of the auxiliary building, noted that the permanent CQE storage cage in Room 69 contained plastic bags with components stored inside that did not have a green tag attached to the bag to readily identify the bags and contents as CQE material. The NRC inspector also noted that two bags of boric acid stored in the area had' broken open. The boric acid was spilled on the floor ,

and on components in the cage. The NRC inspector observed that the bags were not tagged to indicate that they should not be used. The NRC inspector was concerned that the boric acid in the bags may have potentially been contaminated with foreign material and the material may be inadvertently introduced into the primary coolant syste The NRC inspector relayed the concerns identified above to the licensee. The licensee subsequently notified the NRC inspector that the concerns had been satisfactorily addresse On February 26, 1989, the NRC inspector inspected the condition of the material in the CQE storage cage in Room 69. The NRC inspector noted that there were plastic bags in the cage that

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were not tagged with a green tag. The NRC inspector notified the licensee. The licensee stated tha+ +5e material in the CQE cage was properly dispositione The licensee has continued to demonstrate the inability to properly ~  ;

store CQE material in the areas located in the plant. During the l inspection period of December 1988, the 'NRC inspector identified an

apparent violation involving storage of material in temporary CQE storage areas. The violation is documented in NRC Inspection Report 50-285/88-4 Normally, a violation for failure to follow procedures would'be cited for a lack of control of permanent CQE storage areas. However, since the licensee was in the process of implementing corrective actions for the previous violation, an additional violation was not issue In discussions with the licensee, management made a' commitment to address the concerns identit led in this inspection report with respect to control of material in permanent CQE storage areas when responding to the violation' issued in NRC Inspection Report 50-285/88-46. With concurrence of HRC Region IV management, the licensee was given an extension to March 31, 1989, to provide a response to the violatio During a tour on February 20, 1989, the NRC inspector noted that charcoal-impregnated air. filters were stored in the permanent CQE storage cage located in Corridor 4. The filters were stored inside plastic bags and the bags were marked to indicate that HP had performed a radiological survey of the filters. The survey was dated November 198 Because the filters had been su meyed by HP, it was an indication that the filters had previously been in service. The licensee's fire hazards analysis states that; contaminated charcoal filters shall be placed in metal drums immediately after removal from service. It appeared that the licensee did not comply with this requiremen The NRC inspector notified the licensee of the potential proble The licensee removed the filters from the CQE storage cage. The charcoal was then removed from the filters and a radiological survey performed on the charcoal to determine whether or not the charcoal vas contaminated. The results of the survey indicated no contamination of the charcoal. Therefore, no problem existed with respect to the requirement stated in the fire hazards analysis for storage of contaminated filter During an inspection performed in January 1989, as documented in NRC Inspection Report 50-285/89-03, the NRC inspector noted problems with the licensee's storage of contaminated filters in Room 59. Based on that observation and the discovery of additional filters stored in Corridor 4, it appeared that the licensee did not provide the l appropriate corrective action in response to a concern identified by the NRC inspector. Although the filters stored in Corridor 4 were

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! not contaminated, the licensee did not estab!ish the condition of'the filters until the concern was brought to the attention of the-licensee by the NRC inspecto ;

g. On February 13, 1989, the NRC inspector noted that not all instrumentation located on the remote-shutdown panels was operabl On Panel AI-212, the instrumentation for the neutron flux level was inoperable. On Panel AI-185, the pressurizer level instrument was pegged low. The NRC inspector notified the licensee of the observation The licensee' initiated repairs on the instrumentation. On February 16, 1989, the licensee repaired the neutron flux level indication in accordance with the instructions on M0 890904. The instrumentation was repaired by replacing the 250-volt power supply, i The licensee repaired the pressurizer level instrument by removing the defective instrument and replacing it with another instrumen The instrument was replaced in accordance with Temporary Modification 89-E3. A temporary modification was used because the 4 licensee did not have a like-for-like replacement for the meter. The meter replacement was completed on February .17, 198 The licensee has not implemented a commitment for maintaining the instrumentation on the alternate shutdown panels operable. However, the . licensee could not properly perform the appropriate steps of Procedure A0P-6, " Forced Evacuation of the~ Control Room'Due to Fire,"

without the instrumentation. The NRC considers the instrumentation vital to being'able to perform a remote shutdown of the plant. In paragraph 3.e of this inspection report, a discussion is provided regarding issuance of a TS amendment to address the operability of the instrumentation. Since this issue has been previously identified, no further action will be -taken at this tim In response to this issue, licensee management stated that they share the NRC's concern with respect to maintaining the instrumentation on the alternate shutdown panels in an operable condition. Licensee management stated that they will take whatever actions are necessary to ensure operability of the instrumentation, h. During plant tours, the NRC inspector identified problems with the licensee's housekeeping activities. The problems identified are discussed below: ,

i (1) On February 2,1989, the NRC inspector noted that tools had been l left in the area of Containment Spray Pump SI-3C. It appeared l that the tools remained from previous maintenance work in the 1 area. The NRC inspector notified the licensee of the {

observatio On February 13, 1989, the NRC inspector again observed that tools remained unattended in the area of Pump SI-3C. It i

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-28-appeared that the tools were the same ones that were identified on February 2,1989. The NRC inspector notified the licensee of the observation. The licensee stated, on February 14, 1989, that the tools in the area had been cleaned u On February .20,1989, the NRC inspector noted that a mop bucket, a plastic bag of clean rags, a ladder, and two air hoses had been left in the area of Pump SI-3C. The tools previously identified in the area had been cleaned up. However, it appeared that the licensee had only picked up the tools and not the other items since the items were ia the area when the NRC inspector toured on February 13, 198 .a NRC inspector notified the licensee and the area was cl e 3d of all item The clean up of the area was verified by thc NRC inspector on February 28, 198 (2) During a tour of Room 69 on February 14, 1989, the NRC inspector observed a large amount of trash in the area where pump DW-46 had been replaced. The trash consisted of paperwork, tools, and  ;

discarded parts. Pump DW-46 was replaced in the latter part of )

198 I The NRC inspector notified the licensee of the observation. The licensee cleaned up the area and this was confirmed by the NRC inspector on February 20, 198 . Monthly Maintenance Observations (62703)

The NRC inspectors observed selected station maintenance activities on l'

safety-related systems and components to verify that the maintenance was conducted in accordance with approved procedures, regulatory requirements, and the TS. The following items were considered during observations:

The TS limiting conditions for operation were met while systems or j components were removed from servic t Approvals were obtained prior to initiating the wor '

  • Activities were accomplished using approved M0s and were inspected, as applicabl Functional testing and/or calibrations were performed prior to returning components or systems to servic ,

Quality control records were maintaine Activities were accomplished by qualified personne Parts and materials used were properly certifie Radiological and fire prevention controls were implemente ,s ,

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The NRC inspectors observed the following maintenance activities:

RepairofRadiationMonitorRM-063H(M0884441)

Installation of a Fire Door for 1011-2 (M0 875823)

Replacement of the power supply for a neutron flux detector (M0890904)

Replacement of hangers on the fire water system (M0 890025)

A discussion of each item is provided below: On February 28, 1989, the NRC inspector witnessed a portion of the calibration of RM-063H, Stack Gas Monitor. The work was found to be performed by a qualified technician with the use of an approved procedu re. The procedure was CP-063H, " Electronic Secondary and Primary Calibration Procedure for Stack Gas High Accident Monitor."

The NRC inspector verified the monitor had been logged as out of service in both the control room and equipment cut-of-service log No problems were noted in the performance of this procedur On February 16, 1989, the NRC inspector observed licensee personnel remove Fire Door 1011-2 and replace it with a new one. The replacement of the door was performed in accordance with M0 S7582 New door hardware (i.e. , hinges, latch, and closing mechanism) was also installed. The hardware was installed in accordance with MO 87582 The NRC inspector verified that the shift supervisor had authorized replacement of the door and that an hourly fire patrol had been assigned while the door was nonfunctiona The NRC inspector also verified that the personnel installing the door properly followed the procedure as written and used approved materials. No problems were note i On February 16, 1989, the licensee replaced the power supply for the neutron flux detector on the remote shutdown panels. The replacement of the power supply was performed in accordance with the instructions provided on M0 89090 The NRC inspector reviewed the completed M0 to verify that the work was adequately documented. The NRC inspector verified that the neutron detector was calibrated after the new power supply was installed and that the purchase order number for the power supply was appropriately recorded. No problems were noted, On February 15, 1989, the licensee replaced two hangers on the fire water header in accordance with the instructions provided on

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-30-M0 89002 The hangers were replaced to ensure seismic' installation

of the fire water pipin The NRC inspector reviewed the completed M0 to verify that the work performed by the licensee was properly documented on .the M0. During review of the M0, no problems were note . Based.on observation of maintenance activities by:the NRC inspectors, it appeared that maintenance personnel satisfactorily performed maintenance duties in accordance with the appropriate, requirement No violations or deviations were identifie . Monthly Surveillance Observations (61726)

The NRC inspectors observed selected portions of the performance of, and/or reviewed. completed documentation for the TS-required surveillance testing on safety-related systems and components. The NRC inspectors

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verified the following items during the testing:

. Testing was performed by-qualified personnel using approved procedure Test instrumentation was calibrate The-TS limiting conditions for operation were me Removal and restoration of the affected system and/or component were accomplishe * Test results conformed with TS and procedure requirements.

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Test results were reviewed by personnel other than the individual directing the tes " Deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne Test was performed on schedule and comp; I with the TS required frequenc The NRC inspectors observed the following surveillance test activitie The procedures used for the test activities are noted in parenthesis: Monthly check of the indication for PORV and safety valve tailpipe temperatures (ST-SVTEMP-1) Monthly test of the auxiliary feedwater pumps (ST-FW-1) Monthly test of EDG-2 (ST-ESF-6)

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-31-A discussion of each surveillance observed;is provided below: On February 16, 1989, the NRC inspector observed operations personnel perform a check of.the indication of the tailpipe temperatures .for thepower-operatedreliefvalve(PORV)andsafetyvalves. The check was performed to verify .that the temperature indication.was j functioning properl j

The NRC inspector observed the performance of this surveillance test l

1 and noted that the operator performed the test in accordance with the - -l I

l instructions as written. The operator also immediately verified that the reading complied with the acceptance criteria.

i No problems were noted during observation of the tes On February 22, 1989, the NRC inspector witnessed portions of the performance of Procedure ST-FW-1. This procedure provides the instructions for the functional test of the remotely-operated valves and both the motor- and turbine-driven pumps of the AFW system. The NRC inspector specifically witnessed the start of the motor-driven auxiliary feed pump by the control room operator and the subsequent measurement of bearing vibration and' temperature by machinists. The NRC inspector then witnessed the start of the steam-driven auxiliary feed pump and the measurement of the stroke time of the inlet valve (YCV-1045). The NRC inspector noted all of the above to have been  !

performed in accordance with the procedure.and noted' good coordination and communication between the control room and the ,

operators and machinists in the auxiliary building, On February 22, 1989, the NRC inspector observed the monthly test of EDG No. Observations of this test included starting of EDG No. 2 from the control room, synchronizing the EDG to the bus, and a walkdown of the EDG during operatio During observation of the testing, the NRC inspector noted that the control room operator performed the testing in accordance with the procedure, followed the step-by-step instructions as written, and demonstrated an understanding of the evolution that he was performing. No problems were noted while observing the actions of the operator or with the operation of EDG No. During review of surveillance activities, the NRC inspectors noted that it appeared that all personnel involved with the performance of testing performed the testing in accordance with the appropriate requirement l No violations or deviations were identifie . Security Observations (71707)

The NRC inspectors verified that the physical security plan was being 3

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implemented by selected observation of the following items:

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The security organization was properly manne *

Personnel within the protected area (PA) displayed their identification badge Vehicles were properly authorized, searched, and escorted or controlled within the P Persons and packages were properly cleared and checked before entry into the PA was permitte The effectiveness of the security program was maintained when security equipment failure or impairment required compensatory measures to be employe The PA barrier was maintained and the isolation zone kept free of transient materia The vital area barriers were maintained and not compromised by breaches or weaknesse Illumination in the PA was adequate to observe the appropriate areas at nigh Security monitors at the secondary and central alarm stations were functioning properly for assessment of possible intrusion During this inspection period, the NRC inspector noted the following items: During observation of activities in the security building, the NRC inspector noted that the security force failed to properly implement the requirements for access control of personnel. A discussion of this observation is documented in NRC Inspection Report 50-285/89-10 as an apparent violation, During the discussion of security events with security specialist from the NRC Region IV office, the NRC inspector established that the plant manager was unaware of two serious security events that occurred within the last 6 months. The plant manager was unaware of the events because the security manager failed to notify the plant manager of the occurrence of the events. The two events are discussed in NRC Inspection Report 50-285/89-10. The NRC inspector was concerned that there appears to be a very weak communications link between the two manager In response to this concern, the plant manager stated that the communication link between the plant manager and security organization would be immediately upgraded. The plant manager instituted action that requires the security organization to brief plant management of all apprcariate security events at the i

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' plan-of-the-da'y meeting that is held each morning. The briefing by

' the security. organization will also increase,the plant supervisor s awareness of ongoing security problems and concern The'NRC inspector observed that the licensee's control of access to the. control room area (i.e., the area not directly in front of the-  !

control boards) is less than acceptable.. On two occasions, the NRC inspector observed that contract maintenance. personnel entered the-control room area', walked around, and then exited. It'did not appear that the individuals had a specific reason for entering the control room area. The NRC . inspector discussed this concern with various onshift operations personnel. These personnel indicated that they were uncomfortable with the unnecessary personnel traffic in the control room are The NRC inspector. notified licensee management of this concern. In response. the . licensee stated that a review would be. performed to verify that personnel with access to the control room actually required routine access. . This item remains open pending a completion of the review by the licensee and a review by the NRC of.the actions  !

taken by the licensee to reduce unnecessary personnel traffic in the control room. '(285/8909-10)

~ No violations or. deviations were identifie i 1 Radiological Protection Observations (71707)

The NRC inspectors ' verified that selected activities of the licensee's radiological protection program were implemented in conformance with the ;i facility policies and procedures and in compliance with regulatory  !

requirements. The activities listed below were observed and/or reviewed:

HP supervisory personnel conducted plant tours to check on activities in progres HP technicians were using calibrated instrumentatio Radiation work permits contained the appropriate information to ensure that work was performed in a safe and controlled manner, y

  • Personnel in the RCA were wearing the required personnel monitoring equipment and protective clothing and were properly frisked prior to exiting an RC ,

' Radiation and/or contaminated areas were proper'- posted and j

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controlled based on the activity levels within toe are During review of HP activities, the NRC' inspector noted the following l

concerns:

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-34- On January 26, 1989, the plant manager issued a stop-work order for all activities in the RCA. The stop-work order was issued due to an event where personnel entered a high radiation area without proper dosimetry. The details of the event are provided in NRC Inspection Report 50-285/89-0 As a result of the stop-work order, all personnel were required to complete a training class on JP practices prior to being allowed to reenter the radiologically controlled area (RCA). During the training class, the instructor stated that each individual must perform a radiological survey (frisk) after leaving a contaminated area at one of the frisking stations located in the RCA. The instructor also stated that, if an individual finds that he/she is  ;

contaminated, he/she shall notify the HP technician and follow i iutructions posted at the frisking station to prevent the spread of contaminatio During a tour of the RCA on February 13, 1989, the NRC inspector noted that the licensee had not provided adequate instructions to follow in the event contamination was detected. At two of the frisker stations, the instructions were posted; however, the instructions were not readable due 'o the paper being excessively i worn. At the third frisker station, the instructions were not poste .

The NRC inspector notified the licensee of the identified concer The licensee posted all frisker stations with the appropriate instructions on February 14, 198 During a tour of the RCA on February 16, 1989, the NRC inspector noted that the method used by the licensee for posting of radiologically-controlled areas within the RCA was not consisten For some areas, the licensee posted the radiological controls that existed for an area inside the room on the door for the room. In other cases, even though radiological controls were required in an area inside the room, the door for the room was not posted to indicate what the requirements were needed. It appeared that the licensee's inconsistency in posting of areas may lead to confusion for the radiation worker in deciding whether the radiological controls were effective at the door to the room or at the area established inside the roo The NRC inspector notified the licensee of the concern. The licensee reviewed the placement of posting in the RCA and concluded that the postings were not consistent. The licensee revised the postings of some area The NRC inspector toured the RCA on February 28, 198 During the tour, the NRC inspector noted no problems with the area posting No violations or deviations were identified.

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,g' t'8 g-35-11. In-office Review of Periodic and Special Reports (90713)

In-office review of periodic and special reports was performed by the NRC inspectors to verify the following, as appropriate:

Correspondence included the information required by appropriate NRC requirement Test results and supporting information were consistent with design predictions and specification Planned corrective actions were adequate for resolution of identified problem Whether any information contained in the correspondence report should be classified as an abnormal occurrenc Correspondence did not contain incorrect, 'cadeuate, or incomplete  !

informatio The NRC inspectors reviewed the following correspondence:

Loss of Decay Heat Removal, dated January 31, 1989 Steam Generator Tube Rupture Supplemental Information, January 25, 1989 Special Report on InoperaSility of Main Steam Line Radiation Monitor RM-064, and Wide Range Noble Gas Stack Monitors RM-063L and RM-C53H for Postaccident Monitoring, February 7,1989 Special Report on Inoperability of Fire Barriers, dated February 10, 1989 Fort Calhoun Station Radiation Protection Enhancement Program Bimonthly Status Report, dated February 10, 1989 Response to Generic Letter 88-17, dated Februp.y 10, 1989 Response to NRC Bulletin 88-04, dated February 10, 1989 Update of Response to NRC Bulletin 88-03, dated February 14, 1989 Compliance with Requirements of ATWS Rule,1C CFR 50.62, for the Fort Calhoun Station, dated February 14, 1989 January Monthly Operating Report, dated February 15, 1989 Monthly Operations Report for January 1989, undated

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Req"est for Alternate Seismic Criteria Review, Approval, and Safety Evaluation Report, dated February 21, 1989

Response to Generic Letter 88-14. "Instruinent Air Supply' System j Problems Affecting Safety-Related Equipment," dated February 21, 1989 l Special Report on Iboperability of Wide-Range Noble Gas Stack-Monitor RM-063M for Postaccident Monitoring, dated February 23,.1989 No violations or deviations were identifie . Cold Weather Preparations (71714)

The NRC inspector toured various plant areas and reviewed documentation to verify that the licensee had taken measures to ensure that systems affected by extreme cold weather were properly protected. The items observed and/or reviewed by the NRC inspector are listed below:

The freezing point of the cooling systems for the plant emergency, .

security, fire water pump, and technical support center diesels had been tested and actions taken, if appropriat *

The steam supply to the condensate storage tank had been initiate . Fire water system piping had been recovered with earth following modifications to the syste *

The stop log used te divert the plant cooling water outflow from downstream to upstream of the intake structure was installed. The flow is diverted to prevent ice floes from clogging the intake structure grid During review of the above items, the NRC inspector noted no problem Based on a review of the physical plant and documentation, it appeared that the licensee had taken action to ensure that plant equipment was winterized. The weather had been extremely cold over the past few weeks and the licensee has not experienced any equipment problem No violations or deviations were identifie . Unresolved Items An unresolved item is a matter about which more information is required in order to determine whether it is acceptable, a violation, or a deviatio Three unresolved items discussed in this inspection report are listed below:

Paragraph Subject Item 6 Seismic 285/8909-04

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Qualification of

.the Fire Watar Line

, Over EDG No. 1 i

285/8909-07- 6 . Adequacy of. Water-

'Line for Eyewas o Stations in the:

Battery Rooms 285/8909-09 6 Review of Calculation for

~PotentialL

- 1 Overstressing o the AFW Pump Steam Supply Line

14. -Exit Interview-

~The NRC inspectors met with Mr. W. G. Gates (Plant Manager) and' other members of, the-licensee staff on March 3. -1989. The. meeting attendees are listed in. paragraph 1 of this inspection report. At this meeting,'the NRC:

inspectors.. summarized the. scope of the inspection and the finding *

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