IR 05000285/1989042

Insp Rept 50-285/89-42 on 891030-1103.No Violations Noted. Major Areas Inspected:Licensee Actions on Previously Identified Insp Findings & Review of Licensee Surveillance Procedures & Records

ML19332C511
Person / Time
Site:	Fort Calhoun
Issue date:	11/14/1989
From:	Bundy H, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19332C507	List: IR 05000285/1989042 ML19332C506
References
50-285-89-42, NUDOCS 8911280210
Download: ML19332C511 (7)

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APPENDIX ~A

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U.S. NUCLEAR REGULATORY. COMMISSION d

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REGION IV

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NRC Inspection' Report:; 50-285/89-42

.Operatin'g.Licensei'_DPR-40'

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' Docket: ~50-285J

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' Licensee: Omaha.Public Power District (OPTD)

'444 South 16th Street' Mall

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10maha, Nebraska 68102-2247

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acility'Name:

FortCalhounStation(FCS)

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Inspection At:

FCS, Blair, Nebraska Inspection Conducted: _: October-30 through November 3, 1989

</[f7-Inspector _:'

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H., F.Muif. Reactor Insptctor, Test Programs" Defe /

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Sectioi Division of Rehetor Safety

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Approved;'

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// /V W. C. Se14'l(E Chief,7est{yPrograms Section Date~ /'~

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Division oWReactor Safet

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Inspection Summary e

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Inspection Conducted October 30 through November 3, 1989 (Report 50-285/89-42)

q, Areas Inspected:' Routine, unannounced inspection including licensee's actions ~

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with regard to previously identified inspection findings and review of the

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licensee's surveillance procedures and records.

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Results: -The' inspector closed Violation 285/8902-01. The inspector found that

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surveillance, tests were being scheduled and performed as required by. Technical-

.? i 1 Specifications.(TS) in accordance,with approved procedures. The procedures.

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reviewed contained specific weaknesses which are discussed in paragraph 3. -It

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was found that' justification for waiving procedural steps and acceptance

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' criteria;was'not-always given. This was of concern because the systems a

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.m'wengineer had unilateral. authority' to waive acceptance criteria. Testing of the

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icontrol element. assembly withdrawal prohibit (CWP) function was routinely El.

waived,in monthly' Surveillance Test (ST) RPS-1. Although a technical basis

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exist'ed, personnel routinely involved in approving the waivers could not

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. identify it.

An apparent weakness in following up on procedures delinquent for B

T completion of reviews and filing was noted in that one ST package had been

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-trackedias missing for many months and no apparent action was taken. No a

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, violations or deviations were identified.

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DETAILS

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Persons Contac'ted

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OPPD :

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• K. 'J. Morris,' Division Manager - Nuclear. Operations i

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W. G. Gates, Executive Assistant to the President

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. *G. R. Peterson,-Manager - Fort Calhoun Station (FCS)

• T. -J. Mcivor. Manager - Nuclear Projects

• R. L. Jaworski, Manager - Station Engineering

• W. W. Orr, Manager - Quality Assurance / Quality Control

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W.~Richard, Assistant Manager - FCS

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• R. W. Short, Supervisor - Special Services

• D. J. Mathews, Supervisor - Station Licensing y"

• J. D. Kecy. Supervisor - Systems Engineering

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a M.:W Butt, Supervisor - Instrumentation and Control F

-*R. C. DeMeulumeester, Supervisor - Operations

• J. L. Skites,: Supervisor - Nuclear Projects

• K. R. Henry, Lead Systems Engineer - Primary Systems

• C. F. Sinnons, Station Licensing Engineer

• T. C. Matthews,- Station Licensing Engineer.

• K. Boston, Systems Engineer: - Surveillance Test' Administration

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'J. Tucker, Systems Engineer J.'C. Adams, Reactor Engineer NRC, P. Harrell. Senior Resident Inspector

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• T. Reis, Resident Inspector The inspector also interviewed other licensee employees'during the inspection.-

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• Denotes'those attending exit interview on November 3, 1989.

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2.

Licensee Actions -on Previous inspection Findinos (92701)

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(Closed) Violation 285/8902-01, " Failure to Perfonn Sufficient Evaluations

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'of Test Results" - This violation involved two examples of erroneous

preliminary test-result calculations relating to FCS Cycle 12, low power

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physics testing. The inspector reviewed Memorandum PED-N-89-70B, K. C.

Holthans to Plant Review Consittee (PRC) Chairman, " Revised Preliminary Cycle 12 Low Power Physics Test Results " dated February 27, 1989.

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memorandum' stated that the revised test results continued to meet acceptance criteria. The inspector also' reviewed Memorandum CID 890341/01,which

documented PRC approval on June 30, 1989, of revised Procedure SP-PRCPT-1,

"FCS Unit No. 1 Post Refueling Core Physics Testing and Power Ascension."

The preliminary results comparison, in which errors had been fcund, had

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been incorporated into Procedure SP-PRCPT-1 as Appendix G'with the requirement that the accuracy,be certified by an analyst and'a checker.

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Also, an independent check of all calculations and.results was required.

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These actionst satisfy.the independent verification' concerns and should-

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L, provide reasonable assurance that future test results are accurate.

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-Surveillance Procedures and Records (61700)

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The purpose of this part of the inspec' tion was to ascertain'whether the-surveillance of safety-related systems:and components was being conducted ~

in accordance with approved procedures as rcquired by the TS.

Pursuant to:

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this objective, the inspector reviewed:the:following licensee documents:

g StandingOrder"(S0)G-23. Revision 1."SurveillanceTestProgram"-

SO G-30, Revision 31 "Setpoint/ Procedure Changes and Generation"

S0 R-4, Revision 21. " Station Incident Reports"

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The inspector then selected certain:TS survaillance requirements and

- reviewed the associated licensee ST procedure and an appropriate number of.

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test result records for each procedu_re.' Also. selected test personnel were verified to have appropriate qualifications. The TS surveillance i

requirements, together with the associated procedures reviewed by the inspector, are tabulated in the attachment.

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l The inspector determined that the required surveillance tests were being

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scheduled and' performed as required in accordance with approved

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procedures. Notwithstanding these positive findings, some weaknesses were l

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identified., References to satisfaction of TS requirements were not specific.< It was often difficult to determine to what extent the ST

l1 satisfied the TS requirements without detailed review. Acceptance criteria were generally specified in the procedures ~ but.were not always

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easily discernible'from other data. Likewise, test result, statements did

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.not clearly reference the acceptance criteria. Although the procedures

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- appeared to return-the tested equipment to the appropriate operating or standby status, this status was not always clearly stated. While the test j

m-instructions were generally responsive to the. applicable TS, there was not

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i always' sufficient guidance to ensure individual component response was verified.. The review and approval process for ST results appeared

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generally adequate. ?However, the technical bases for waiver of procedural j

steps;6nd meeting acceptance criteria were not always given. This was of.

particular. concern to the inspector because the system engineer was authorized to authorize one waiver.of an acceptance criterion in accordance

with Procedure 50 R-4.

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Specific details and comments associated with weaknesses involving procedures and test results are as follows:

In reviewing the June to

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September 1989 results for ST-RPS-1, " Power Range Safety Channels," the inspector noted that Steps F.3(41) to (45) were routinely waived. They related to verifying the control element assembly withdrawal prohibit (CWP)

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function. The inspector pursued the waiver of this test with maintenance,

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W operations, andfsystems engineering personnel in order to establish a y

technical basis. After 2' days,'a-licensee management representative

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stated that the CWP.' function was not within the scope of TS 3.1 Table 3-1,

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Item 1.C (required monthly), and, therefore, should not have been included

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cin ST-RPS-1.. Rather, it was within the scope of TSJ3.1. Table 3-3,

-Item 7.a(requiredatrefueling)b The inspector independently verified y-that the CWP function was. tested in ST-CEA-1, which was responsive to TS 3.1 Table 3-3, Item 7.a.

In that the CWP function was tested in m#

January 1989 pursuant to ST-RPS-1, it appears that the CWP function was.

' tested twice in that timeframe.

It was not clear if licensee personnel were' aware of the possible test duplication. The licensee's response to

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this issue appeared technically sound to the inspector. However, the manner in which it was handled raised the following concerns

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Have operations and maintenance personnel been given authority to

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waive tests required by TS in other instances?

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How often are ST steps waived without test personnel knowing and

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Why was an apparent procedural error tolerated for many years?

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In reviewing the results for ST-RPS-1 performed on September 8, 1989, the

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inspector noted that Steps F.3.10, 11, 13, 19, 20, and~26 did not meet the

- acceptance criterion. They involved the variable over power trip meter reading for Channel D of the power range safety channels. The system engineer waived the acceptance criterion as nonsafety affecting in

accordance with Step 2.8 of Procedure S0 R-4.

A technical basis was not:

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given or referenced in the remarks'. Another licensee staff engineer assured the inspector that this waiver was technically justifiable. The inspector expressed the following concerns regarding this waiver:

Is it a common practice not to provide an adequate technical basis

for acceptance criteria waivers?

A waiver of an acceptance criterion circumvents the normal process for dispositioning nonconformances.

l Giving the system engineer authority to ultimately waive ST

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acceptance criteria raises the question as to whether one individual should in deed have such authority.

In reviewing results for Sections F.1A, B, and E of-ST-FH-1, " Refueling System Interlocks," completed in December 1988, the inspector noted that the technical reviews had not been completed. The inspector was told that these test results were being tracked as missing when he requested them l -

and were subsequently found. The inspector informed licensee management that the failure to pursue and disposition this problem aggressively prior

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N to the inspector's-involvement'was an apparent programmatic weakness.- The L

Division' Manager Nuclear _ Operations, acknowledged this apparent weakness and i

. initiated action to have it corrected during the exit interview.

Review of I,

. licensee actions to address the issue of waivers of surveillance

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,requirementsisaninspector-followupitem'(285/8942-01).

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Inipursuing' satis' faction of TS 3.6(5)a,'the inspector noted it is

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necessary to perform ST-VA-1, " Containment Air Cooling and Filtering

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System " and'ST-RWS-1, " Raw Water System Valve Actuation." Although both

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. procedures referenced the TS, neither stated that it provided only partial

,e satisfaction. Also, as in other instances, it was not stated what parts

, of the' procedures were responsive to the TS requirement.

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In reviewing ST-FP-10. "Halon systems Surveillance," it was noted that the s

performer'was directed to verify air flow through Halon nozzles in various rooms. However, no' checklist, nozzle plan, or flow diagram was provided or referenced by the procedure to ensure that each nozzle was actually checked.

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There were no violations or deviations identified during~ this inspection.

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Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 on November 3, 1989, and summarized the scope and findings,of this-inspection. - The licensee did not identify,- as proprietary, any of the-materials provided to, or reviewed by, the inspector during this inspection..The' inspector together with the Chief, Test Programs Section, Region IV, telephoned the OPPD Division Manager - Nuclear Operations', on November 7, 1989, to.further discuss the concerns detailed above.

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- ATTACHMENT-

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i* PROCEDURES AND RECORDS REVIEWED

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V-E Description ST Number

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% 3;1[ Table ~3-1, Calibrate and Test Power RPS-1, R43

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-Item 1.C~

Range-Safety Channels y

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3.1,: Table,3-1, '

1 Test High. Pressure RPS-5, R16 Item 5.C

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Pressure-RPS Channels

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3.1, Table 3-1,-

Trip Test Known Axial

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RPS-12, R35

' Item 13.C Shape Index-Applied to Input of Axial Shape Calculator 3.1 Table 3-2, Test Containment Pressure ESF-3, R24 High Signal.

Item 4.6'

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3.1l Table 3-3,

' Calibrate Core Exit-HJTC-1, R3-

Item 30.b Thermocouple

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3.2 Table 3'-5, Functionally Test Refueling FH-1, R34

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. Item 5 System Interlocks:

,m L3.2, Table 3-5, Verify Flow Thru Reactor RCGV-1, R9

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-Item 16.3 Coolant Vent System Vent Paths

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3.6(5)a-Check Containment Recirculating VA-1, R24

. Air Cooling and Filtering System.

RWS-1, R16

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Components for Operability

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3.7(1)6.1'

Start EDG and Accelerate to Rated ESF-6, R91

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Speed and Voltage in Less Than or Equal to 10 Sec.

3.7(2)d'

Demonstrate Correct Function of All DC-3, R14 DC Emergency Transfer. Switches

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. Verify " Correct Functioning of DC-4, R13

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Emergency L10hting 3.8 -

. Test MSIVs to Demonstrate a Closure ISI-MS-1, R16

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Time of 4 Sec. or Less Under No-Flow

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.3.9(6)b Verify Each AFW Pump Starts as FW-3, R24 l Designed Automatically Upon Receipt-of Each AFW Test Signal t

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i3.10(1)b'

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' Compare'Overall~ Core Reactivity'

RA-1, R18

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Balance to' Predicted Values

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13.10(7)b' -

~ Determine _RV Coolant > Total Flow Rate RCF-1, R15:

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'3.15(4)b.

Verify Fire Hose Stations Operable FP-6, R9 m

by. Removing Hose for Inspection and Reracking and-Replacing any Degraded I

Coupling Gaskets'

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3.15(8)d Demonstrate Halon FP' Systems FP-10, R10 T c Operable by. Performing an Air'

Flow Test Thru Each Header and

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Nozzle to Assure-No Blockage 3.16(1)

Pressure Test Recirculation RHRS-2, R9 Heat Removal System

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