IR 05000285/1989036

Insp Rept 50-285/89-36 on 890925-1006.No Violations or Deviations Noted.Major Areas Inspected:Normal Operating Instructions,Alarm Procedures,Abnormal Operating Procedures, Emergency Operating Procedures & Followup of Insp Items

ML19325E723
Person / Time
Site:	Fort Calhoun
Issue date:	10/31/1989
From:	Gagliardo J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19325E722	List: IR 05000285/1989036 ML19325E721
References
50-285-89-36, IEB-88-004, IEB-88-4, NUDOCS 8911080341
Download: ML19325E723 (13)

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APPENDIX j

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U.S. NUCLEAR REGULATORY COMMISSION f

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REGION IV

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NRC Inspection Report:. 50-285/89-36 Operating License:

DPR-40

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Docket:50-teh

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Licensee: ' Omaha Public Power District (DPPD)

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444 South 16th Street Mall

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Omaha, Nebraska 68102-2247

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. Facility Name: ForticalhounStation(FCS)

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n Inspection At:

FCS,'Blair.. Nebraska, and NRC Region l1V Office Arlington, Texas

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Inspection Conducted: September 25 through October 6, 1989

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Inspector:

DJ R.(HunytrT 5enior Reactor Inspector Date'

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Operations Program Section

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~ Approved:

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gg E(Garfiardo,TMief, Operations Program Date

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Sectich Division of Reactor Safety

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Inspection Sumary l

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InspectionConductedSeptember25through' October 6,1989(Feport5d-?85/89-36)

'. Areas inspected:

Routine, unannounced inspection of

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.. procedures, including nomal operating instructions ' plant operating.

z alarm procedures,'abnorma'.

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operating procedures, and emergency operating procedures; the followup of

previously identified inspection items; and actions associated with a licensee

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p event report (LER)..

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Within the three areas inspected, no violations or deviations were Results:

t identified. Several items were identified requiring prompt OPPD management

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attention. The classification of.the operating procedures and the overall

j adequacy of the alam/off-normal procedures require review and. evaluation'.

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TNeoverallprocedureupgradeprogramwas,withexceptions,onschedule.

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However, a number of operating procedures, which have an affect on nuclear safety (main steam system, main feedwater system, station electrical system),

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h1090341 891031

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were not included in the initial phase (categorized as safety-related-

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procedures) of the procedure upgrade program. Likewise, the alenn procedures, which also affect nuclear safety, were not included in the initial phase of the

procedure upgrade program.

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The review and control room walkdown of alann procedures revealed that the

alarm procedures were minimally acceptable, indicating the need for licensee i

actions to upgrade them.

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3-DETAILS 1.

Persons Contacted OPPD l

• K Morris, Division Manager, Nuclear Operations j

• G. Peterson, Manager, FCS

• A. Richard, Assistant Manager, FCS

• S. Gambhir, Division Manager, Production Engineering

• R. Andrews, Division Manager, Quality and Environmental Affairs i

• J. Gasper, Manager Training

• L. Kusek, Manager, Safety Review Group

• T. McIvor. Manage.', Nuclear Projects

• R. Jaworski, Manager, Station Engineering

• B. Hansher, Operating, Experience Review Coordinator i

• D. Ritter, Supervisor. Security Support Services i

• P. Sepcenko, Supervisor Outage Projects

• R. Short, Supervisor, Nuclear Projects

• R. Fellogg, Supervisor. Special Services

• J. O' Conner, Supervisor Electrical Engineering

• J. Chase Acting Manager Nuclear Licensing i

• D. Mathews, Supervisor. Station Licensing l

• C. Simmons, Station Licensing Engineer l

• E. Cook, Nuclear Licensing Engineer i

'*M. Graham, Nuclear Communications Specialist

• L. Borcherling, Operations Quality Assurance

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J. Shuck Operations Engineer

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D. Stading, Procedures Review Project

J. Fluehr Supervisor Technical Training (Simulator)

M. Lazar, Supervisor. Technical Training

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• J. Gagliardo, Chief Operational Programs Section

• T. Reis, Resident inspector, FCS

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• R. Azua, Reactor Inspector g

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• H. Bundy, Reactor Inspector i

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• R. Stewart, Reactor Inspector

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J Other members of the technical and administrative staff were also

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contacted.

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• Denotes those attending the management exit on September 29, 1989.

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2.

Followup on Previously identified Inspection Findings (92701)

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l 2.1 (Closed)UnresolvedItem(28S/8831-03): Design Procedures and Practice

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Dis >arity - The item concerned the apparent difference between the design

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1-paccage requirements specified in Procedure B-2, " Production of Design l

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Description and Evaluation of Nuclear Modifications," and Procedure GEG-3, i

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• Preparation of Design Packages.

l The licenses provided a' new division-level procedure.. PEG-0P-2, " Nuclear l

DCP Control for Modifications," Revision 0, dated June 1989, to ensure-l

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uniform controls of modifications. The inspector reviewed the procedure

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and verified that.all modifications, with exception of temporary s

modifications, were addressed by PED-QP-2.

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The inspector had no further questions regarding this matter and this '

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unresolved item is considered closed.

2.2 (Closed) Violation (285/88201-10):

Inadecuate Documentation and

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Evaluation of Non-COE parts - The specific item (Violation B.5) concerned

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Die Tailure to document the evaluation of parts used to repair the l

. charging pump (CH-10) electrical breaker.

• The licensee's response to Violation B.5 noted that the Standing-Order G 17, " Maintenance Orders " did not specifically address non-00E subcomponents, which were acceptable for use. The licensee stated that the standing orders would be revised by June 30, 1989, to provide clear

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instructions regarding documentation of non-CQE parts utilized in COE components.

The inspector reviewed the newly issued Standing Order 50-M 101,

• Maintenance Work Control," Revision 1 dated June 23, 1989.

Step 6.6.12.0 (non-CQE Part) of the procedure required that non-CQE parts

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be documented and initialed by the procurement engineer. The inspector

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found that Step 5.9.9, of Procedure 50-G-17, ' Maintenance Orders "

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Revision 56,_had apparently not been revised to address this issue.

Licensee representative interviewed stated that 50-G-17 was superseded by 50-M-101 with regard to all future act.ivities; however. 50-G-17, was still

..g i being used for certain outstanding work orders.

The licensee reviewed the e

identified' discrepancy,and issued Procedure Revision 30022, dated September 27, 1989, to revise 50-G-17, to require the documentation and

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evaluation of.non-CQE parts used in COE components. The failure to revise 50-G-17 was apparently an oversight.

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The inspector had no further questior. regarding this matter and this item 4is considered closed.

No violations or deviations were identified.

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3.

Followup of Licensee Event Peport (LER)

(92702)

LERj88-32 was reviewed to verify that the specified corrective actions had i

been completed and to ensure the actions were effective in preventing recurrence of the event.

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L The LER reported that during the process of responding to NRC

Bulletin 88-04, regarding safety-related pump minimum flow peths, a design

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deficiency in the common minimum recirculation header of the safety i

p injection and containment spray pumps was identified. Calculations (

indicated that the conanon minimum recirculation header was not adequetely

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' sized to pass the minimua, required recirculation flow expected when all eight pumps (three high pressure safety injection, two low pressure safety

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injection, and three containment spray pumps) were running in the recirculation mode simultaneously.

o Yhe licensee performed a'special tet.t (SP-SI/CS-3, " Simultaneous Operation of LPSI/HPSI Pumps in Minimum Recirculation Mode") on November 73, 1988, and determined that the recirculation piping was Mequate for the simultaneous operation of the LPSI and HPSI pumps in the minimum

, recirculation rode. The licensee modified the containment spray pump initiation logic to start the containment spray pump after the initiation of the containment spray actuation signal and opening of the containment spray valves. The modification eliminated the condition under which the containment spray pumps could operate in the recirculation mode with the high pressure injection and low pressure injection pumps. The flow tests

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L and circuit modification were previously reviewed by the NRC (NRC Inspection Reports 50-285/88-36 and 50-?85/89-05) and appear 0d to be acceptable.

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The inspector also reviewed the licensee responses to the NRL Bulletin 88-04 (LIC-88-929) dated November 4, 1988, and February 10, 1989 (LIC-89-046), which addressed this matter. The NRC responded to the-licensee's letters.regarding NRC Bulletin 88-04 by letter, dated

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February 17, 1989, accepting the licensee's responses to the NRC Bulletin subject to future audit.

The, inspector had no further questions regarding this matter and L

LER 88-032 is considered closed.

No violations or deviations were identified in the review of this program

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area.

~ 4.

Procedures Review (42700)

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The inspector reviewed and evaluated selected plant administrative and operating procedures to verify that the procedures for safety-related

p activities were in confonnance with the overall regulatory requirements

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(including Appendix A to Regulatory Guide 1.33 and ANSI N18.7-1972) and

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the' Technical Specifications and that the selected procedures were technically adequate to accomplish the specified activities. Selected proceiures and administrative controls in the following areas were reviewed:

Administrative Procedures (50)

General Plant Operating Procedures (0P)

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Alarm Procedures (ARP)

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, Abnorma'l' Operating Procedures (A0P),

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!f Emergency Operating Procedures'(EOP)'

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. The inspector also reviewed selected parts of the' procedures upgradef I

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4.1 Procedures Upgrade Project.

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L 'y ' i The inspector reviewd the status of the procedures upgrade project.

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! procedures upgrade project has been divided into two groups

" safety-related"

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and<"nonsafety-related" procedures. Document reviews and discussions with'

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licensee personnel revealed that the licensee was concentrating review and ppgradeeffortsontheproceduresclassifiedas" safety-related."

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The; inspector found an apparent lack of definitive procedure classification criteria.and noted that the upgrade project listing of

" safety-related" procedures did not include a number of procedures which

.have an affect on nuclear safety, such as main feedwater (01-FW-1), main -

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core refueling procedure (OP-11)ponse procedures (0P-10), and the reactor steam-(01-MS-1),annunciatorres i

Interviews with licensee.

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representatives also revealed that the licensee hadtfailed to include the f

1 electrical. procedures (e.g., 01-EE-1,.01-EE-2, 01-EE-3, and 01-EE-4) as J

part of the " safety-related" procedures upgrade project. This.had been

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recently, identified by the upgrade project, but the inspector noted that no program corrective action document had been initiated by licensee

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'personne). The failure to include all procedures affecting nuclear safety

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within the " safety-related" procedures upgrade project may affect the timeliness of.the specific procedure upgrade. Licensee representatives

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stated that all the procedures (safety and nonsafety-related) would

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receive the same level.of review as part.of the overall project but the

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safety-related procedures would generally be revised first. The inspector

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discussed with 1icensee management the need to develop acceptance criteria

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for classification of pro:edures as safety-related or nonsafety-related, the need to review the procedures upgrade project considering the newly.

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developed acceptance criteria, and the need to initiate corrective action e

documents when a program deficiency was identified. The licensee r

representatives indicated that this matter would be evaluated ~ and the appropriate changes would be made if necessary. This matter is considered m

as'an inspector followup item and will be reviewed during a subsequent

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(285/8936-01)

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Administrative Procc ;res The inspector' selected a number of administrative proce%res for review.

.The procedures reviewedtare identified in the attachme'

to this report.

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Procedure S0-G-73, " Fort Calhoun Station Pre.edure Writer's Guide,"

provided'the guidelines associated with the Fort Calhoun Station Operating

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' > Manual Procedures to ensure procedure consistency, technical content, and Wtechnical verification and validation. During the review of the

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C ' procedure, the inspector noted that Attachment 13. " Abnormal. Operating

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E0Ps had bcon recently rewritten (July 31,'1989) and the,AOPs were i. Ni 9 currently being rewritten as a part of the procedure upgrade project

(completion scheduled for November 30,1989).' Discussions revealed that

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an E0P writer's guide had been utilized for the upgrade of both the E0Ps

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and A0Ps. However, the EOP and A0P writer's guide was not included as part of 50-G-73, Attachment 13. This matter was discussed with licensee

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representatives for further consideration and will be considered an

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inspector followup. item.- (285/8936-02).

4.3 Operating Procedures

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The inspector selected a number of operating procedures for review. The

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procedures reviewed are identified in the attachment to this report.

The inspector noted that the September 22, 1989, status report issued by the licensee indicated that OP-7, " Reactor Startup," and OP-8, " Reactor

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Shutdown " were undergoing the procedure validation process.. OP-11. " Reactor Core Refueling Procedure," was not included on the " safety-related"

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procedureslistingasdiscussedpreviously(paragraph 4.1).

4.4 Operating Instructions

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The inspector selected a number of operating instructions for review. The instructions reviewed are identified in the attachment to this report.

l The operating instructions reviewed by the inspector appeared to be

' acceptable; however, as noted previously, a number of instructions (t;e feeedwater -system, the main steam system, and the. reactor regulating instruction) were not addressed on the " safety-related" procedures upgraded

proj ect' listing. The inspector noted,that toe licensee had recently

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identified'the failure to include.the electrical instructions within the scope of the " safety-related" procedures upgrade project.

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This matter is discussed in more detail in paragraph 4 above.

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4.5 ' Abnormal Operating'(A0P) and Alarm Response (ARP) Procedures l

n The: inspector reviewed a number of abnormal operating procedures and alarm response procedures. The procedures reviewed are listed in the attachnent

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to'this report.

4.5.1 The A0P procedures were in the process of being rewritten and were scheduled to be complete in November 1989. The A0Ps will require further review subsequent to the completion of the rewrite.

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'2 4.5.2 The following ARPs were selected for' review and walkdown with-

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. Pressurizer Pressure Off-Normal' Hi-lo Channel 1/CB-1-2-3/A4/B-4 (A-4)

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f The review of the procedure and control board walkdown revealed the

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'The procedure steps did not address the need for selecting the

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operable' channel (X or Y), as the control. channel. The-

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procedure did:not reference' Technical Specification (TS) 2.10.4

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.regarding'thelimitingcanditionforoperation(LCO)when f

l pressure decreased to 2075 psig', even'though the setpoint for

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s the-channel X or Y trip, devices for this alarm procedure was

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2080 psig, within:5 psi of:the TS LCO.

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t Pressurizer Safety Injection Signal Lo-Lo Pressure B/102 _Y

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CB-1-F-3/A4/B-5 (A-5, C-5, and D-5)

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The review of_the procedure and the' control baard walkdown identified i'

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a number of apparent procedure weaknesses:

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The failure of a: single channel,did nos provide any automatic

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actions 1The channel was one of the channels.which initiated

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safety injection upon the tripping of two of four of the

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The procedure steps which addressed a "cooldown in progress" did

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,not indicate a normal or planned cooldown and the direction to i

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" check'the PPLS blocking circuit" were' confusing. -If the

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cooldown in progress was the result of an actual event. the

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blocking of the PPLS would be nonconservative.

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_The procedure referenced Emergency Operating Procedure E0P-01

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which was not correct. The reference should have been E0P-00.

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The procedure did not address the actions for bypassing the I

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failed reactor protection channel to meet the Technical.

t Specifications..The procedure did' not address similarly l

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required actions associated with the engineered safeguard (ESF)

cabinets. Additionally, the ESF. channels required the

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installation.of an electrical jumper to bypass a channel.

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S0-0-2B, " Requirements for Administratively Bypassing Reactor

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Protection System (RPS) Trip Units," addressed the RPS bypass j

- s key, management notification, and document action, however,' no

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administrative procedure similar to the 50 regarding the RPS was

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provided for the'e activities. The operations personnel i

s interviewed by the. inspector were very ex perienced and

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knowledgeable of the requirements, even t1ough the actions were not specifically addressed in the procedure.

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The procedure did not address the manual initiation'(or the p

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verificat1on of the automatic initiation) of safety injections

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"if.the system pressure is actually low."

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' Pressurizer level Lo-Lo Channel'X (Y) CB-1-2-3/A4/C8 (D8)'

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The review of the procedure and the control board walkdown. revealed that the procedure < steps did not address the operation of the n

pressurizer level 10-10 override bypass switch (HC-101-1).

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Interviews.' revealed.that'the operator was knowledgeable reg'arding the

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P switch operation. Additionally, the procedure referenced Emergency

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Operating Procedure E0P-01 which was not correct. The reference should have been to E0P-00..

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L Reactor Protection Channel Comparisons j

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During the review of the annunciator response procedures and control

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board walkvown,'the inspector noted that certain protection channels-

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(e.g., steam generator levels) were being compared each shift as

required by the. Technical Specification; however, no. specific w

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acceptance criteria was-provided to the operators for the comparison'

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i'"7 of.the channels to cause corrective actions to be initiated by w

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operationsTpersonnel.s This item was brought to'the attention of

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licensee representatives who noted that the matter would reviewed.

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Although the sample size was limited, the review of the ARPs,

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revealed that the procedures.were only marginally (A0Ps and ARPs) isacceptab cases.. The continuing review of the procedures l

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. considered to be an inspector followup item pending further L

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(285/8936-03)

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u The overall conclusion of the inspector was that the alarm procedures r

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effectively reviewed. This area will require extensive and timely

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. management attention in order to upgrade these procedures.

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l 4.6 Emergency Operating Procedures (EOP)

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'The' inspector reviewed selected E0Ps. The procedures reviewed are listed

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P in.the attachment of this report.

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The review of E0P-02, " Loss of Off-Site Power / Loss of Forced Circulation,"

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revealed the apparent need to strengthen the procedures in the area of the-

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degradation or loss of electrical power to the vital AC buses (4160 V AC

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Land 480/V AC) and associated load distribution centers. This matter was

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. discussed with licensee representatives as a concern needing management

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attention to ensure that the available procedures (ARPs, AOPs, and/or

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E0Ps) addressed all of the expected conditions and actions necessary to

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deal'with a loss of vital AC buses. The need for these procedures is

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discussed in Appendix A to Regulatory Guide 1.33 (Sections 5 and 6). This

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matter is an inspector followup item and will be reviewed during a

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subsequent inspection.

(?85/8936-04)-

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4.7 ' Quality Assurance Audits

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The inspector reviewed a number of licensee audits and surveillance

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reports associated with procedurc compliance. The reports reviewed are

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listed in the attachment to this reoort.

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The inspector' reviewed audit and surveillance reports regarding specific l

activities such as key controls, shift turnover, surveillance

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. test / calibration observation, tinservice inspection -temporary i

modifications, and valve lineups.

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A specific audit of the overall operations procedures adequacy, as

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required by.the. Technical Specifications, Regulatory Guide 1.33,

. procedures generation package and other requirements, associated with the

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. emergency operating procedures"(EOPs) and abnormal operating ).

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~ procedures (A0Ps).was scheduled for January 1990'(QA Audit 67

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it was noted that this' audit was planned to begin after the completion of.

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a substantial portion of the~ safety-related procedure upgrade program.

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The E0Ps had been completed; the A0Ps were scheduled for completion in

November 1989, and other safety-related procedures / instructions were to be

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completed in early 1990.

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No violations or deviations were identified during the review of this i

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program area.

~5.

Exit Interview q

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TheinspectorsummArizedtheinspectionscopeandfindingswiththe.

individuals identified in paragraph 1.

Specific concerns regarding the

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classification of procedures as " safety-related;" the adequacy of the

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-alarm response and the need for E0P and A0P' procedures to handle a vital AC bus were presented to the licensee. The licensee acknowledge the

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concerns, and noted that the concerns would be evaluated and appropriate action would be taken.

No information reviewed by the inspector was i

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identified by the licensee as' proprietary.

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ATTACHMENT i

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13 '1989

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S0-G-7, " Operating Manual " Revision 15 dated June

50 0-17 " Maintenance' Orders," Revision 56 dated November 5, 1988

$0-M-101, " Maintenance Work Control." Revision 1 dated June. 23, 1989 v

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50-G-30,MSetpoint/ Procedure Changes and Generation," Revision 31 deted

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L May 9, 1989

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50-G-73, " Fort Calhoun Station Procedure Writer's Guide " Revision 0 dated

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February 25, 1989

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Operating Procedures OP-1, " Master Checklist for Startup or Trip Recovery," Revision 40 dated

June 30, 1989

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OP-'7, " Reactor Startup, Revision 31 dated May 9, 1989

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OP-8, " Reactor Shutdown, Revision 11 dated September 27, 1988

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OP-10. " Annunciator Response Procedure," Revision 16 dated July.13, 1989

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OP-11. " Reactor Core Refueling Procedure," Revision 29 dated May 19, 1989 l

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Operating Instructions

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l 01-CH-8, " Chemical Addition," Revision 6 dated August 8, 1989 l

01-C0-1, " Containment Closure," Revision 18 dated August 4,1989 l

01-RP3-1, " Reactor Protection System - Normal Operation," Revision 11

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l dated May 11, 1989

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L Cl-RPS-2, "RPS - RM/LP Tcold Cal Calibration," Revision 5 dated l

September 19, 1989

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01-50-3, " Alternate Shutdown Cooling Utilizing Containment Spray Pumps "

Revision 2 dated May 16, 1989 L

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01-EE-1-1, " Normal Operation of 4.16 KV System," Revision 17 dated May 13, 1989

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01-EE-1A-1, "4160 Volt Circuit Breaker / Control Switch Operation,"

Revision 2 dated June 7, 1989

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01-EE-2, " Normal' Operation of the 480 Volt System," Revision 18 i

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01-EE-2A', "480 Volt Circuit Dreaker/ Control Switch Operation;"

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Revision 2 dated.May 13, 1989

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.i ya 01-EE-28, " Hot. Bus Transfer of 480 V Buses," Revision 1 dated M

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November 26, 1988 l

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L 01-EE-3-1,'" Normal' Operation of 125 Volt D. C. System,'!. Revision 28

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6'.y dated January 27, 1988 01-EE-4-1 t" Normal Operation of 120 Volt AC System," Rbision 40..

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dated February 3, 1989.

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. '01-FW-3-1, " Steam Generator, Level Control." Revision 11 dated -

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June 16, 1989

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01-FW-2-1, "Feedwater' System - Normal Operation," Revision 24 Dated l

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Jbne 6,'1989

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01-MS-1, " Main Steam - Normal'0perations," Revision 16 dated

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W October 29, 1988'

O iOI-RR-1, " Reactor Regulating - Normal Operation " Revision 16 dated

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December 3,*1988

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Surveillance Test Procedures

, OP-ST-CWL-001, " Containment Water Level Narrow Range Channel Check "

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Revision 0 dated. June 15, 1989 0P-ST-RX-0013. " Core Exit Themocouple Operability Check," Revision 1

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dated July'25, 1989

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Abnormal Ope' rating Procedures

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I A0P-16, " Loss of Instrument Bus Power " Draft Revision dated August 24, 1989 A0P-28, " Auxiliary Feedwater.. System Malfunctions " Draft Revision dated

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September 22, 1989 i

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Emergency Operating Procedures

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s E0P-00, " Standard Post Trip Action," Revision 0 dated July 31, 1989

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E0P-02, " Loss of Off-Site Power / Loss of Forced Circulation," Revision 6 dated yy

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E0P,-06, " Loss of All Feedwater," Revision 4 dated July 31, 1989

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Mc' T SARC Audit No. 4-89, "Conformance of facility Operations," dated June 12, 1989

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0A Audit No. 29 " Equipment Status Control 6nd Tagout " dated November 5, 1986~

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QA Audit No. 35 " Inservice Inspection," dated June 15, 1989

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QA Surveillance N6. 06-89-1, " Technical Specification LCOs," dated June 22,

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I QA Surveillance No. 05-89-2, " Plant Key Control," dated July 31, 1989

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. QA Surveillance No.' 01-89-1, " Plant Keys," dated February 8, 1989

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QA Surveillance No. 04-89-2, " Valve Lineup," dated August 25, 1989 e

QA' Surveillance No. 03-89-3, " Valve Lineup," dated March 22, 1989 f

QA Surveillance No. 03-89-2, " Danger Tags," dated July 11, 1989

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QA Surveillance No. 03-89-7, " Danger Tags / Temporary Modifications," dated April.11, 1989

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QA Surveillance No. 02-89-3, " Operator Staffing Turnover Duties," dated

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August 23, 1989

QA Surveillance No. 02-89-2, " Operator Staffing Turnover Duties," dated

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June 9, 1989 l

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QA'~ Surveillance No. 01-89-7, " Surveillance. Test / Calibration Observation,"

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L, dated August 15, 1989

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QA Surveillance No. 01-89-5, " Surveillance Test / Calibration Observation,"-

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dated June 21, 1989 L

QA! Surveillance No. 04-89-5, " Control Room Drawings," dated May 3. 1939

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