IR 05000285/1989034
| ML19324B369 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/23/1989 |
| From: | Ray Azua, Bundy F, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19324B364 | List: |
| References | |
| 50-285-89-34, GL-88-17, NUDOCS 8911060158 | |
| Download: ML19324B369 (11) | |
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,y APPENDIX i
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- i U.S. NUCLEAR REGULATORY _ COMMISSION
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NRC' Inspection. Report: 50-285/89-34-Operating License: DPR-40
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Docket: 50-285 i
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, Licensee: Omaha Public Power District (OPPD)
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444 South 16th Street Mall
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0maha, Nebraska.68102-2247 a
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.f Facility.Name:
FortCalhounStation(FCS)
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M, Inspection'At: "FCS, Blair, Nebraska.
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LInspection. Conducted: September 25-29 1989
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T/87 Inspectors:
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@ u',4vo, Ruo67 Inspector,. Test Programs.
y otiTTivision of Reactor Safety
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H. F. Bundyt. JReactor Inspector, Test Programs Date
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Section Dfvision of Reactor Safety Approved -
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'W. C. Seidle (Chl tor Safety lef, Test Programs Section Date
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, Inspection Summary-
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Inspection Conducted September 25-29, 1989 (Report f20-285/89-34)
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A'reas Inspected: Routine, unannounced inspection including licensee's actions
to prevent and. if necessary, respond to loss of decay heat removal (DHR) asb i'
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. described in Generic Letter (GL) 88-17.
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Results:
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'i The' licensee appeared to have implemented the recommendations for expeditious
s actions' contained in GL 88-17 except for resolution of the issue concerning
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' surveillance of the Tygen tube level indication system, prior to its use. This
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issuejis being tracked as Open Item 285/8934-02.
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CK 05000285'
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The progranened enhancerents that the licensee committed to in response to GL 88-17 had not been. fully developed at the time of the inspection. The folicwing items were identified by the inspectors as open items to be followed up prior to the licensee entering its next planned outage:
The implementation schedule did not address when the modifications such as
'the leve1' indication system, core exit thermocouples, and associated equipment would be installed, and when the modified procedures would be placed into effect. This item is being tracked as Open item P85/8934-01, No surveillance program was identified to assure that the new level
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indication system is operable. This item will be tracked as Open Item 285/8934-03.
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A question of insufficient DHR backup was raised when the containment
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spray pun?a are used as the DHR pumping source. This item will be tracked
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as Open Item 285/8934-04 Insufficient administrative guidance in the area of niaintenance planning
was found to be'a concern. This item will be tracked as Open Item ?85/8934-05.
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Details concerning the items identified for NRC followup are discussed in
. paragraph 2.1.
The lic.nsee committed to have the programmed enhancements fully addressed prior to, or curing their next scheouled outage.
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DETAILS a
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1.
Persons Contacted OPpD L
- K. J. Morris Division Manager - Nuclear Operations
- S. K. Gambhir, Division Manager - Production Engineering
- R. L. Andrews, Division Manager - Quality and Environmental Affairs b
- G. R. Peterson, Manager - FCS a
- T. J. Mcivor. Manager - Nuclear Projects t
- J. K. Gasper, Manager - Training
- L. T. Kusek, Manager - Safety Feview Group
- R. L. Jaworski, Manager - Station Engineering
- J. W. Chase Acting Manager - Nuclear Licensing i
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- A. W. Richard, Assistant Manager - FCS
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'P. Sepcenko, Supervisor - Outage Projects
- J. O' Conner.. Supervisor - PED 41ectrical Engineering
- R. W. Short, Supervisor - Nuclear Projects i
- D. J. Mathews, Supervisor - Station Licensing i
- B. R. Hansher. Operating Experience Review Coordinator - Nuclear Licensing
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- C, F. Simons, Station Licensing Engineer
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- B. W. Shubert, System Engineer - PED NRC
- T. Reis, Resident inspector t
The inspectors also interviewed other licensee employees during the j
inspection..
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- Denotes those attending exit interview on September 29, 1989.
2.
Licensee Actions to Prevent and Respond to loss of Decay Heat Removal (TI 2515/101)
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The purpose of this inspection ' as to verify licensee actions to prevent
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w and, if necessary, to respond to loss of decay heat removal (DHR) during operations with the reactor coolant system (RCS) partially drained.
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Licensee actions were in response to recommendations contained in
GL 88-17. " Loss of Decay Heat Removal." Recommendations were made by GL 88-17 in two categories:
Expeditious actions, which should be implemented prior to operating
in a reduced inventory condition; and
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Programmed enhancements, which should be developed in parallel with j
the expeditious actions and may replace, supplement, or add to the t
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expeditious actions.
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ior purposes of future reference, the recommendations are briefly paraphrased below (to avoid confusion, the numbers are identical to similar items contained in GL 88-17):
Expediti9us Actionj (1) Discuss related events and lessons learned with appropriate plant personnel.
Provide training shortly before entering a reduced inventory' condition.
(2)
Implement procedures and administrative controls for containment closure in the event of loss of DHR event. This should be
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accomplished. prior to entering a reduced RCS inventory condition for
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nuclear; steam supply systems.(NSSS$) supplied by Combustion v
Engineering.
(3) Provide at least two independent, continuous temperature indications that are representative of the core exit conditions whenever the RCS is in midloop condition and the reactor vessel (RV) head is 10cated on top of the RV.
(4) Provide at least two independent, continuous RCS water level
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indications whenever the RCS is in a reduced inventory condition.
Indications should be periodically checked and recorded by an operator or automatically and continuously monitored and alarmed.
(5)
Implement procedures and administrative controls that generally avoid operations that deliberately or knowingly lead to perturbations to the HCS and/or to systems that are necessary to maintain the RCS in a stable and controlled condition while that RCS is in a reduced inventory _ condition.
If avoidance of perturbations is impossible, compensatory measures should.be taken.
(6) Provide at least two available or operable means of adding inventory to the RCS that are in addition to pumps that are a part of the normal DHR systems.
(7)
Implement procedures and administrative controls that reasonably assure that both hot legs are not blocked simultaneously by nozzle dams unless a vent path is provided that is large enough to prevent pressurization of the upper plenum of the RV.
(8) Not applicable to FCS.
(Applies to units with loop stop valves)
Progransned Enhancements (1)
Instrumentation Provide reliable indication of parameters that describe the state of the RCS and the performance of systems normally used to cool the RCS
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i for both nomal and accident conditions. At a minimum, provide the
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following in the c(ntrol room.
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(a). two independent RCS level indicationst l
(b) at least'two independent temperature measurepents representative
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of the core exit whenever the RV head is located on top of the
RV;
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1 (c) the capability of continuously monitoring DHR system perfomance l
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whenever a DHR system is being used for cooling the RCS; and l
(d) visible and audible indications of abnomal conditions in
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temperature, level, and DHR performance.
t (2) Procedures i
l Develop and implement procedures that cover reduced inventory
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operation and that provide an adequate basis of entry into a reduced
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inventory condition. These include:
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(a) procedures that cover normal operation of the NSSS, the
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contairment, and supporting systens under conditions for which i
cooling would normally be provided by DHR systems;
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(b)' procedures that cover emergency, abnomal, off-normal, or the
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equivalent operation of the NSSS the containment, and
supporting systems if an off-normal condition occurs while
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operating under conditions for which cooling would normally be i
provided by DHR systems; and i
(c) administrative controls that support and supplement the f
procedures in items (a)
(b), and all other actions identified
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in this communication as appropriate.
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I (3) Equipment
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(a) provide equipment of high reliability for cooling the RCS and
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e avoiding loss of RCS cooling;
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(b) maintain equipment available to mitigate loss of DHR or loss of
RCS inventory should they occur including at least one high pressure injection pump and one other system, each sufficient to
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keep the core covered; and
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(c) provide adequate equipment for personnel communications involving activities related to the RCS or systems riecessary to maintain the RCS in a stable and controlled condition.
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(4) Analyses
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I Conduct analyses to supplesent existing infonnation and develop a
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basis for procedures, instrumentation installation and response, and j
equipment /NSSS interactions and response.
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(5) Technical Specifications i
Technical Specifications that restrict or limit the safety benefit of
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the actions identified in this letter, should be identified and
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appropriate changes should be submitted.
(6) RCS Perturbations
.j Reexamine Item (5) of expeditious actions and refine operations as necessary to reasonably minimize the likelihood of loss of DHR.
Coments on the licensee's actions in response to GL 88-17 are provided below. The attachment is a tabulation of related documents reviewed by
the inspectors. When a document number is cited below, it will be the
number assigned in the attachntot. Also, in addition to reviewing the f
' listed documents and interviewing' appropriate personnel, the inspectors l
walked down the DHR instrumentation installed in the control room. The
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'following comments generally relate to licensee comitJnents containea in
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responses to GL 88-17 (Documents 1 and 2).
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With regard to Expeditious Action (3) and Progranmed Enhancenent (1)(b),
the reactor vessel (RV).is instrurented with 28 core exit
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thermocouples (CETs). These CETs input to control room displays and have
alann functions through the plant computer. However, the signal cables
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are removed prior to RV head removal and, therefore, this instrunentation i
is presently unavailable while the RV head is being removed..The licensee
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has initiated action to procure two temporary cables which can be l
connected to the installtd CETs to provide control room temperature
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indication while RV head removal preparations are in progress with the RCS j
level lower than the top of the botleg. Although the licensee plans on
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using this instrumentation during the 1990 (February) refueling and
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maintenance outage, procedures for installing these cables and using the temporary instrunentation were unavailable. There were preliminary plans to operate at midloop five times during the outage, but scheduling of i
temporary cable installation as well as a number of other GL 88-17 related
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instrument modifications had not been considered. Scheduling of these instrunent modifications together with appropriate revisions to operating procedures will be tracked as Open Item 285/8934-01. The licensee also
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committed to evaluate by the end of the 1990 outage the feasibility of i
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installing temporary temperature instrunentation while the RV head is
removed.
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With regard to Expeditious Action (4) and programmed Enhancement (1)(a),
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the licensee currently relies on a temporary Tygon tube, level indicator (LI-197) and level transmitter (LT-197).
LT-197 inputs to the
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computer for readout and trendin and a low level alam. The accuracy is
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approximately 22 inches. There s also input to the process computer from LI-197. However, L!-197 is of little value in midloop operation l
because only 8 percent of the meter range is used. The inspectors could
not identify a femal surveillan:;e procedure for the Tygon tube as suggested I
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by GL 87-12. Development of a surveillance procedure for the temporary
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Tygon tube will be tracked as Open Item 285/0934-02. The licensee has
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scheduled installation of a sight glass (LI-199) during the first midloop
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operation in the 1990 outage. Also the licensee has connitted to installing l
a second level transmitter (LT.119),off the same tap as LT-197 during the i
1990 outage. The point in the outage for this installation had not been i
established, in addition LT-197 and L1-197 will be upgraded. L1-197
will be rescaled and the' accuracy for both indicators will be 20.6 inch.
l Either indicator will actuate a low level alarm on the control panel. As
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discussed above, the sequencing of impleaentation of the instrument
modifications and implementation of revised procedures was a concern to I
the inspectors and will be tracked as a part of Open Item 205/0934-01.
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Also,'no provisions had been made to ensure the common level instrunent i
top will'not be plugged during midloop operation and, thereby, cause a
common mode instrunent failure. This concern will be tracked as Open i
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Item 285/8934-03, j
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With regard to Programmed Enhancenents (1)(c) and (1)(d), the proposed CET and RV level instrunentation are discussed above. Document No. 2 (see t
attachnent) did not adequately address further improvements. However,
during discussions with the electrical engineering supervisor, the e
inspector learned that'the following modifications are planned for i
t installation during the 1990 outage. A low DHR flow alam will be l
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l actuated by the present flow indicating controller.
It will have a valve
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I open pemissive from the DHR valves to prevent a nuisance alarm when not in midloop operation. There will be pressure transmitters (pts) installed j
on each suction line for the low pressure safety injection (LPSI) and r
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containment spray (CS) pumps, in that the design was not complete, it was
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not clear how these pts would be used. However, both the electrical
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engineering supervisor and the inspector assuned they would be used for I
i remote indication and trending in the control room.
The LPSI and CS pumps can be used interchangeably as the pumping source
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for DHR.
Installation of a local pressure indicator (PI) on the suction
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i of each high pressure safety injection (HPSI) pump was planned. LPSI end j
l CS pump current meters were installed in the control room. The licensee
intended to route there signals to the computer to provide trending
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i capability.
No remote readout capability is planned for pump discharge
pressures. There are local P!s. Also, DHR header pressure is indicated
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in the control room. Noise monitoring of the pumps had not been considered. With the improvements discussed above, DHR performance l
monitoring and alarm functions appeared adequate. However, the sequencing i
of implementation of the instrument modifications and implenentation of revised procedures will be tracked as part of Open Item 285/8934-01.
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' With regard to Expeditious Av. ton (6) and Programmed Enhancenent (3),
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licensee procedures appeared to provide for adequate DHR pumping and t
inventory makeup capabilities. However, the draf t standing order titled j
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" Conduct of Shutdown Operations" (attachment to Document 9) appeared to.
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imply that one of the alternate RCS inventory makeup sources would elways t
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be a CS pump.- In the instance where two CS pumps are used as the DHR j
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pumping source, this would not satisfy GL 88-17 recommendations. Licensee l
clarification of alternate RCS inventory inekeup sources under all i
circumstances will be tracked as Open item 285/8934-04
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With regard to Programmed Enhancement (5), it appeared that the only l
Technical Specification change request will involve deletion of the
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DHR autoratic closure interlock (ACl). As stated in Document 8, deletion
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of the AC1 has been recommended by the Combustion Engineering Owners
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Group. The licensee's preliminary pl*ans called for deletion of the ACI l
during the 1991 refueling outage.
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The licensee's connitsent to EFpeditious Action (5) ar.d (7) and Frogranmed
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Enhancemants (2)(a), (b), and (c) were reviewed. The inspector looked at I
all of the operating and energency operating precedures that had been
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modified as a result of GL 87-12 and GL 88-17, in addition to other
procedures that already addretted some of the concerns set forth in the i
generic letters listed above. The procedures reviewed are listed in the
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report attachment, it was noted that the operating proceCure
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modifications that would address operator monitoring requirenents,
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following the installation of the new level indication equipment, had yet
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to be written. The licensee stated that this would be addressed prior to
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the February 1990 outage. As discussed before, the sequencing of
implementation of the revised procedures was a concern to the inspectors t
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and will be tracked as a part of Open Item 285/8934-01. Other than this
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item, the other operating and emergency operating procedures were found to j
adequately address the concerns raised by GL 83-17. One point of note was
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that the operating procedures require that containment building integrity l
be maintained during midloop operations. This precludes the requirement
for additional procedures to be developed to address rapid containment closure following a loss of DHR during midloop operations.
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standing order titled " Conduct of Shutdown Operations." This docunent was
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found to readdress the Technical Specification requirenents concerning backup sources for RCS residual heat removal and other requirements
already stated in either the nomal operating procedures, or the emergency operating procedures. Additional administrative requirements such as a list of equipnent that cannot be worked on while the plant is in midloop operation, were not addressed. Such a list would prevent personnel in the maintenance planning group from scheduling maintenance on equipment that may affect DHR during midloop operations. The licensee restated that this was a draft docurent and was still under review, lhe licensee assured that the final document would address the inspectors' concerns. The
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planned aaministrative requirenents will be tracked as Open i
E ltem 285/8934-05.
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F The licensee's training program was reviewed by the inspectors to verify the adequacy of the licensee's impleeentation of Expeditious Item (1).
In addition to this,'the inspectors reviewed the training records of several plantpersonnel(operations,maintenanceplanning,etc.). Following review of these two areas, it was detemined that the training program had addressed the requirenents of GL 88-17, and had been adequately r
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implemented. The only concern that the inspectors had in the area of training was with respect to the administrative and operating procedures that had not yet been developed and are part of the progranmed enhancements planned for the february 1990 outage.
It was not apparent if plant persot,nel were scheduled to be trained on these procedures once they were finali;:ed and ready for use. The implementation of training on these procedures will be tracked as part of Open Item ?85/E934-05.
With regard to Expeditious Action (2) the licensee's operating procedure requires that containment integrity be maintained during midloop operations. The only noted exception to this requirement was sone electrical penetrations, but their rapid closure in the event of a loss of DHR was addressed in Operating Instructions 01-00-4 and in Operating Procedure OP-6.
Also reviewed by the inspectors was the site specific analysis perforwed by Combustion Engineering for Fort Calhoun on the " Loss of Shutdown Cooling at Mid-loop Conditions." This analysis responds to the i
requirenents set forth in GL 68-17 for Programed Enhancement (4).
No violations or deviations were identified in this program area.
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Exit Interview The inspectors met with the licensee representatives denoted in paragraph 1 on September 29, 1989, and summarized the scope of this inspection. The licensee did not identify as proprietary any of the information provided to, or reviewed by the inspectors.
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ATTACHMENT Documents Reviewed f
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1.
Letter LIC48-1106, OPPD to NRC, "Pesponse to GL 88-17," dated January 4 l
1989
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Letter LIC-89 045, OPPD to hRC, " Response to GL 88-17," dated February 10, 1989 (
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Letter, NRC to OPPD, "Connents on OPPD Response to GL 88-17, FCS." dated May 18, 1989 l
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Memorandum PED-SYE-89-490J. "PRC Meeting Minutes of May 25, 1989 - SMART Membership for Modification Request (MR)-FC-89-025. RCS Level Indication "
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dated May 19, 1989 i
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MR-FC-89-025. "RCS Narrow Range Level Instrument,' approved by Plant
l Manager (PM) on February 25, 1989
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MR-FC-89-026, *RCS Level Tubing Modification " approved by PM on
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February 25, 1989
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MR-FC-89-019. " Shutdown Cooling Flow and Safety injection Pressure and
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Pump Amperage Upgrade " approved by PM on February 17, 1989 8.
Memorandum PED-SYE-89-833J. Production Engineering Division to Licensing.
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"CID 850495/02. RHR Valve Closure Reconenendation No. 5, Closure " dated j
August 29, 1989
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Memorandum PED-SYE-89-590J Production Engineering Division to Licensing,
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"NRC Comitinents to GL 88-17. TAF No. 890014.' dated June 22, 1989
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10. Ope *ating Procedures OP-6, ' Hot Shutdown to Cold Condition " Revision 6, t
dated June 16, 1989 i
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11. Operating Instructions 01-5C-1, " Initiation of Shutdown Cooling,'
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Revision 32, dated May 23, 1989 12. Operating Instructions 01-RC-5, " Reactor Coolant System Draining,"
Revision 34, dated January 24, 1989 j
13. Operating Instructions 01-RC-4, " Reactor Coolant System Normal Shutdown "
f Revision 52, dated January 17, 1989
14. Operating Instructions 01-RC-2A, " Reactor Coolant Fill Instruction,"
Revision 42, dated March 24, 1989 15. Operating Instructions 01-00-4, " Establishing Modified Containment i
Integrity " Revision 19. dated September 7, 1989 16. Maintenance Procedute MP-RC-2-1-A, " Steam Generator Primary Manway
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Removal " Revision 21 dated November 18, 1988 i
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17. Maintenance Procedure MP-N0ZDAM 1, " Steam Generator Norzle Dam Installation Procedure," Revision 9, dated October 10, 1989 18. Surveillance Test ST-SDC-1. Shutdown Cooling Valve Interlock Test,"
Revision 12, dated September 27, 1 % 8 19. Lesson Plan MPS-10 * Nuclear Operations Divisicm Maintenance Supervisors and Planners Training Program - Control of Activities Affecting Shutdown Cooling," Revision 0, dated July 25, 1989 20. Lesson Plan SESY-05, ' Nuclear Operations Division System Engineer Training Program - Shutdown Cooling System," Revision 0, dated December 7, 1988 21. Lesson Plan 7-17-19,c.". Nuclear Operations division R0 and SRO Training Program - Loss of Shutdown Cooling AOP 19," Revision 1, dated October 4, 1968 22. Abnormal Operating Procedures AOP-19, ' Loss of Shutdown Cooling.
Revision 5, dated May 6,1989.
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