IR 05000285/1990006
| ML20012E920 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/20/1990 |
| From: | Barnes I, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20012E919 | List: |
| References | |
| 50-285-90-06, 50-285-90-6, NUDOCS 9004090089 | |
| Download: ML20012E920 (9) | |
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMIS$10N REGION !Y
NRC Inspection Report:
$0 28$/90 06 Operating License: DPR 40 i
Docket: $0 285 Licensee: Omaha Public Power District (OPPD)
444 South 16th Street Hall
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Omaha, Nebrasta 68102 2247 Facility Name:
FortCalhounStation(FCS)
Inspection At:
FCS, Blair, Nebraska inspection Conducted:
February 5-9, 14-16 and February 26 through March 2,
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1990.
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inspector: [ I 8 e J - :: o - m
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W. M. McNeill, Reactor Inspector, Materials Date
and Quality Programs Section Division of
Reactor Safety
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Approved:
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1. Barnes, Chief, Materials and Quality Date
Programs Section, Division of Reactor Safety i
Inspection Sumary inspection Conducted February 5-9, 14-16 and February 26 through March E. 1990 (Report 50 285/90-06)
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Areas inspected:
Routine, unannounced inspection of action on previous Tdentified inspection findings and self-assessment capability.
Results: The Safety Audit and Review Committee (SARC) meetings appeared to be
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well documented and resolution of concerns identified by SARC was effective.
Some minor errors were identified in the minutes of SARC activities. The SARC
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use and management of subcomittees appeared to be very effective with the exception of the failure of a subcomittee to review recent plant modifications and their associated safety evaluations. This failure was identified as a noncited violation. The Plant Review Comittee (PRC) activities meetings appeared to be not as detailed in its documentation, it appeared that the handling of action items could be improved. Two noncited violations were identified regarding the f ailure to enter action items into the station comitment tracking system and the
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results of reviews by the System Acceptance Subcomittee not being submitted to the PRC for approval. Safety Review Group ($RG) activities appeared to be well.
documented and resolution of concerns identified by SRG was effective.
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D_ETAILS E
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PERSONS CONTACTED OPPD
- R. L. Andrews, Quality and Environmental Affairs Division Manager W. J. Blessie, Plant Review Comittee (PRC) Technical Secr?tery
'J. P. Bobba, Radiological Protection Supervisor
- C, L. Brunnert, Operations Quality Assurance (QA) Supervisor M. G. Burggraf, Safety Review Group (SRG) Engineer
- J.W. Chase,NuclearLicensingendInternalAffairs(NL&lA) Manager
- S. K. Gambhir, Production Engineering Division Manager
- J. K. Gasper, Training Manager
- W. G. Gates, Nuclear Operations Division Manager
'C. K. Huang, Human Performance Evaluation System / Root Cause Analysis Supervisor
- R. L. Jaworski, Station Engineering Manager
- J. D. Kecy, Systems Engineering Supervisor
- L. T. Kusek, SRG Manager S. A. Lindquest, Licensing Engineer B. Lisowyj, Special Services Engineer
- D. J. Matthews, Station Licensing) Supervisor
- W. W. Orr, OA/ Quality Control (00 Manager
- C. F. Simons, Station Licensing Engineer
- R. E. Short, special Services Engineering Supervisor
- F. K. Smith, Chemistry Supervisor S. A. Swearngin, SRG Engineer D. E. Weaver L.C.Wigdahl, Instructor Technical Training Supervisor Stone and Webster Engineering Group R. Gardner, Safety Audit and Review Comittee (SARC) Subcomittee Member J. H. MacKinnon, SARC Subcomittee Chairman NRC
- l. Barnes, Section Chief
- P. H. Harrell Senior Resident inspector
- T. A. Reis, Resident inspector
- R. C. Stewart, Reactor Inspector
- Denotes those persons that attended the exit interview on March 2. 1990.
The inspectors also interviewed other licensee personnel during the inspectio.
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ACTION ON FtEV!0ti$lY 10ENT!FIED INSPECTION FINDINGS (92702)
l 2.1 _(Closed) Vio'fation (285/8825 01):
Visual inspection records were not prepared as required by procedures.
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The licensee found supporting records for the examinations in question.
l The standing orders have been revised to identify more clearly the records
to be prepared and a step has been added for the supervisor to check such l
records.
The OC sersonnel have been made aware of this problem and have l
been trained in tie revised procedures.
l 2.2 Closed) Violation (285/8831-04):
The material listing in Design
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'ac : age B4-176 did not identify a valve's pressure boundary parts to be
critical quality elements (CQO.
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The inspector found that the licensee's planned corrective actions have l
been implemented. The material list in cuestion was revised to provide i
the correct classification of the parts. A team reviewed the 1988 outage
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modification packages and their material lists and also found additional
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problems. As a result of the review, the procedures on the use of stored items were further revised to assure that proper materials are used.
I 2.3 (Closed) Violation (285/8831-05): A purchase order for resistance temperature detectors did not include all the correct seismic floor response spectra.
The inspector found that the purchast order in question was reissued with the correct seismic requirements. A review was performed of 1988 outage modification packages, which found additional problems. As a result, i
standard purchasing specifications were revised and personnel were trained on the revised specifications.
2.4 (Closed) Violation (285/8835 01):
failure of the PRC to review procedure
changes by either serial reviews or by alternates, and the failure to recognize that a procedure change resulted in a change in the intent of the procedure, in regard to serial reviews, the inspector found that reviews of procedures were performed in either a subcomittee meeting or in a serial review by the subcommittee.
In either case, the subcommittee's recomendations end the procedures were acted on at a PRC meeting with a quorum of members present. A review of past minutes was performed to assure that a quorum was present at each meeting. The inspector noted that $ ARC has also been checking PRC meeting minutes in this regard. An internal memo was issued notifying PRC members and alternates that procedure changes would be reviewed in a PRC meeting with a quorum of members present.
In regard to improper reviews performed by alternates the limit on the number of alternatesusedwasfoundtobealsoverIfiedbySARC. A PRC technical secretary was hired to review the PRC activities and its documentation in this regard. The standing orders have been revised to provide guidance on how subcomittee's reviews will be accomplished.
In regard to the failure
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to recognize that a procedure change resulted in a change in the intent, a f
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review was performed of other *on the spotd type changes, and no further examples of this type of problem were found. The standing order was revised to expand the scope of PRC reviews in this area to include 'on the spot *
l type changes,
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l 3.
LICENSEE SELF-ASSESSMENT CAPABILITY (40500)
i The objective of this inspection was to evaluate the effectiveness of the l
licensee's self assessment programs.
In this regard, the inspector reviewed t
the activities of the SARC, PRC, and the SRG. The thrust of this inspection l
was to measure how effective these groups were in identification of concerns
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and following of such to resolution.
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3.1 SARC
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3.1.1 Details
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The activities of the SARC were governed by "SARC Charter,* Revision 12, dated
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May 18, 1989, and three SARC procedures. The SARC was found to meet regularly,
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once a quarter, and in special meetings as required. four regular meetings have i
been held in 1989.
Seven special meetings were held in 1989 with only one
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or two agenda items. Regular meetings differed from the special meetings in
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that a standard format of agenda items were reviewed. The SARC membership was found to be as described in the Technical Specifications (TS) with the addition
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of four consultants from outside OPPD and two additional OPPD members.
It was
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noted that TS were in need of an update to reficct the current title of the i
radiological services manager. The licensee has this identified as a
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commitment to be accomplished. The standard format meetings addressed such
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egenda items as:
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Approval of previous meeting minutes f
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Review of previous SARC action items i
Subcomittee reports which included TS and license changes; safety
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evaluations of plant modifications, procedures, tests, etc.; violations f
and abnormalities; and PRC activities
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Plant manager report
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0/./QC manager report NL&lA manager report
Strategic issues / items
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The inspector reviewed the meeting minutes of 1989 and 1990 in detail and attended a meeting of Subcommittee 2 on February 15, 1990.
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Observations by the inspector were as follows:
The SARC identified about 50 action items during 1989 of which 6 remained
open as of the inspection. Review indicated that action items were being handled appropriately,)although in some instances (because of inadequate closecut documentation this determination required additional information from licensee personnel.
It was also noted that some actions were identified and acted upon without being designated as action items.
- The detail found in the meeting minutes indicated a thorough review of the subjects. Some very minor errors were noted in the lack of correlation between minutes and agenda items such as in Meeting Minutes 4-89.
It was noted that, in addition to action items SARC also identified strategic issues / items. The procedures did not, however, define strategic issues / items or address how they were to be handled.
- The SARC use of subcommittees appeared effective and documentation of subcomittee activities was very good. One exception noted was Subcomittee 1, which failed in some instances to identify whether its comments on certain facility license changes (FLCs) had been acted upon prior to subcommittee approval.
Examples of this were found in the subcomittee's November 14, 1989, report of FLC 89-07, and September 8, 1989, report of FLC 87-07.
- The SARC subcomittee chartered with the review of modifications and their assoicated safety evaluations had identified the month before this inspec-tion that it bad been failing to review modifications and evaluations since the last refueling outage in September 1988.
Review of a sample of 15 modifications by the inspector found no evidence of SARC review as required by TS. Some modifications in the sample had been reviewed by SRG.
However, the SRG reviews could not be clearly identified as independent reviews, in that SRG personnel often participated in the Station Modifica-tion Acceptance and Review Team (SMART) inline reviews of modifications, it was also not clear if the SRG reviews were of the modification package, the safety evaluation, or both. The failure of SARC to review modifica-tions and their associated safety evaluations is an apparent violation of TS 5.5.2.7.
A Notice of Violation is not being issued because the criteria of Section V.G.1 of the NRC's Enforcement policy have been met.
- In establishing the sample of 15 modifications, the inspector found FCS dio not issue an annual 10 CFR part 50.59 report, but identified in monthly operations reports modifications made under 10 CFR part 50.59.
However, the monthly operations reports failed to meet the requirements of 10 CFR part 50.59 in that there was not a sumary of the safety analysis for each modification in the report. The licensee changed its January monthly report, which was prepared in the course of this inspection to include a sumary of the safety analysis in that report. After the
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January report, the licensee has comitted to make an annual repor.
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-6-The SARC identified late in 1989 that it had not established and
implemented a training and qualification program for its nembers and sut comittee members. As a result, there were no records of SARC training and qualification in regard to root cause analysis, 10 CFR Part 50.59, and similar subjects. The SARC had established a draft program to address this shortcoming.
3.1.2 Sumary The SARC meetings appeared to be well documented and resolution of concerns identified by SARC was effective. Some minor weaknesses were identified in the minutes of SARC activities. The SARC use and nanagement of subcommittees appeared to be effective with the exception of the review of modifications and their associated safety evaluations.
The failure of SARC to review recent
plant modifications was identified as a noncited violation.
3.2 FRC 3.2.1 Details TheactivitiesofthePRCweregovernedbyastandingorder,G5,"FortCalhoun Station Plant Review Comittee, Revision 67, dated January 11, 1990. The PRC (
riet twice weekly in regular meetings and held special meeting as required by circumstances. During outages, PRC met daily. At regular meetings typically 25 to 30 agenda items were addressed and at special meetings typically 1 or 2 agenda items were addressed. As of this inspection, about 17 meetings (10 regular and 7 special) have been held this year. The PRC membership was found to be as described in the Technical Specifications and alternates were identified in the standing order. The meetings addressed such agenda items as:
Approval of procedures Incident Reports (irs)
Modifications, memoranda, and miscellaneous
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SRG concerns
Presentations and discussions The inspector reviewed Meeting Hinutes 89-247-251-253, -254 and -259 in detail and the training and qualification records of m-255 -258, embers. The inspector attended PRC Meetings 90-18 and 90-19.
Observations of the inspector were as follows:
The inspector found that 9 of 55 action items issued in 1989 remained open with the oldest being 9 months old.
In addition, there were almost 30 action items generated since December 1989 which had not been entered into the station comitment tracting system as required by the standing order.
The licensee identified this failure on Corrective Action Request 90-061.
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This is an apparent violation for f ailure to accomplish activities l
affecting quality in accordance with a prescribed procedure; however, the violation is not being cited, because it is of minor safety significance and meets the criteria specified in Section Y.A of the Enforcement Policy.
The in:pector found a number of apparent action items that were not
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identified es action items, such as the recommendation to issue a memo
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noting changes to Standing Orders 23 and 73 in Meeting 89-259. A number of other examples were identified to the PRC technical secretary.
i The PRC meeting minutes were not as detailed as SARC and were not issued
in a timely manner. The lack of tineliness was corrected during this inspection, in the meeting minutes it was not clear what was the status of some agenda items (e.g., Temporary Modification TM-89 E-026 in Hinutes 89-?54 and TM-89-M-054 and -055 in Minutes 89 255). One concern
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of the inspector was the mismatch between the proposed and actual agenda.
For example, in Meeting 90-19 one procedure was on the agenda for approval;
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however, in the meeting there were 45 procedures reviewed.
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The PRC used several standing subcomittees to review agenda items such as
operations, maintenance, radiation protection, engineering, and systems acceptance. The reviews performed by these subcomittees were found to be
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documented, but not attached to PRC minutes. The engineering
subcomittee's format of keeping a log of coments and the resolution of coments could be used as a model for the other subcomittees.
A training and qualification program had been established for PRC members
and alternates. A review of the training and qualification records found
that one PRC member was not fully trained and qualified.
It was also noted that three alternates had been given reading assignments in lieu of
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classroom training on safety analysis for operation (SAO)Iate corrective which is not allowed by the training program. The licensee took immed
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action on both of these issues.
- The PRC used one, interim subcomittee which was the Station Modification AcceptanceandReviewTeam(SMART). The same sample of 15 modifications used in the review of SARC activities was used by the inspector to verify PRC review of modifications.
It was found that there was evidence of PRC review of the sample of modifications. Modifications are changeo with field design change requests (FDCRs) which are subject to review by ).
another subcommittee of PRC, the System Acceptance Subcomittee (SAC The inspector noted that SAC did not fully follow standing order requirements, in that it did not report to the PRC the results of its reviews and dispositions of modifications and their associated FDCRs. The licensee comitted to correct this problem and have the SAC report its, reviews and dispositions to the PRC for the PRC approval. This is an apparent violation for failure to accomplish activities affecting quality in accordance with a prescribed procedure; however, the violation is not being cited because it meets the criteria specified in Section V.A. of the Enforcement Policy.
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3.2.2 Sumary The PRC meetings appeared to be not as detailed in its documentation as was the SARC, and it appeared that the handling of action items could be improved.
The f ailure to enter action items into the station commitment tracking system and the f ailure of a subcomittee to report the results of its reviews to the PRC were identified as noncited violations.
3.3 SRG
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3.3.1 Details The activities of SRG, the OPPD name for an independent safety engineering group, were found to be governed by a charter, NSRG-1 Revision 1, dated
November 28, 1969, and two procedures NSRG-2, " Administrative Controls "
Revision 1, dated November 28, 1989, and NSRG-3, " Reviews and Investigations,"
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Revision 3, dated November 28, 1989.
SRG was found to be staffed with five engineers, two senior reactor operators and a manager. SRG reported to the Division Manager of Quality and Environmental Affairs. The SRG's activities included:
Investigations of subjects, such as, root cause analysis of station irs
Reviews of subjects such as Licensee Event Reports (LERs), modifications, and irs
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Plant tours / observations
Long-term projects The inspector reviewed a sample of three investigations, three reviews of LERs, three reviews of NRC Bulletins and a Generic Letter, three reviews of modifications, three reviews of irs, and three tours of the station. The
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inspector also reviewed the SRG recomendation log and a sample of six closed recomendations. The sempics for all of the above were drawn from the last
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l 3 months activities of SRG.
Observations by the inspector were as follows:
The SRG investigations and reviews appeared to be detailed and thorough in character.
- About 150 recommendations were issued in 1989, with 50 remaining open at the time of this inspection and none overdue.
There appeared to be no controls of tours activities that would assure areas would not be missed or reinspected unnecessarily. The inspector noted that Tour 90-21 covered the same area as a previous Tour 90-19,
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which took place only 5 days before, and it did not address the status of a deficiency identified in the 90-19 tour, l
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- The $RG reviewed all $A0s, LERs, Fits, and res>onses to NRC violations.
Reviews of other types of documents (such as NRC Bulletins, Generic Letters, and Information Noticest Institute of Nuclear Power Operations significant Event Reports, significant Operating Experience Reports, and Operating and Maintenance Reminders were performed on a request basis.
3.3.? Sumary The $RG activities appeared to be well documented and concerns and recomendations were identified and effectively followed up.
IKli MEETING An exit meeting was held on March 2,1990, with those individuals denoted in paragraph 1 of this report. At this meeting, the scope of the inspection and the findings were sumarized. The licensee did not identify as proprietary any of the information provided to or reviewed by the inspector.
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