IR 05000285/1990034

Insp Rept 50-285/90-34 on 900730-0803.Fire Protection/ Prevention Program Satisfatory.Unresolved Item Re Proper Fire Rating Noted.Major Areas Inspected:Fire Protection/ Prevention Program & Emergency Diesel Generator Problems

ML20056B409
Person / Time
Site:	Fort Calhoun
Issue date:	08/16/1990
From:	Murphy M, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20056B408	List: IR 05000285/1990034 ML20056B407
References
50-285-90-34, NUDOCS 9008280249
Download: ML20056B409 (8)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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HRC Inspection Report: 50-285/90-34 Operating License: DPR-40

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Docket: 50-205 Licensee: Omaha Pubile Power District (OPPD)

r 444 South 16th Street Hall Mail Stop 8E/EP4 Omaha, Nebraska 68102-2247 Facility Name: FortCalhounStation(FCS)

U . Inspection At: FCS, Blair, Nebraska Inspection Conducted: July 30 through August 3,1990 Inspector: [h M.~ E; Murptiy / ReattgV Inspector. Test Programs 6ht.//g Date

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Section, Division of P,eactor Safety

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Accompanied By: Frank Ashe, Nuclear Reactor Regulation, July 30 through August 1, 1990 ,

W. C. Seidle, Chief, Test Program Section, Division of Reactor Safety, August 2-3, 1990 Approved:- A / M /#

W. C. Seidle', Chief Test Programs Section Date 3 Division of Reactor Safety Inspection Summary i

, BspectionConductedJuly30throughAugust3,1990(Recort50-2P5/90-34)

Areas. Inspected: Unannounced inspection of the fire protection / prevention program and recent emergency diesel generator problem ,

Results: The licensee has a satisfactory fire protection / prevention progra F unresolved item was identified involving the lack of proper fire rating 9008280249 900820 PDR O ADOCK 05000285 )

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';1abels on the' control. room access. doors and the'. lack of supporting documentation

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, for'these doors, in accordance with Generic Letter 86-10. The licensee ha ,

u? ' instituted a procedures improvement program which will. strengthen Mhe surve111ence  ;

. test program. A second unresolved item was identified involvingi f.e possible ')

4:: incomplete testing-of relay contact circuits'in the automatic emergency diesel 6

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igenerator start circuits.- ,;

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L DETAILS PERSONS CONTACTED OPPD

• R. L. Andrews, Division Manager, Nuclear Services

• C. Fritts, Fire Protection System Engineer

• S. K. Gambhir, Division Manager, Production Engineering

< * C. Gartner, Systems Engineer

• J. K. Gasper, Acting Division Manager, Nuclear Division

• K. R. Henry, Supervisor, System Engineering D. Johnson, System Engineer ,

J. D. Kecy, Supervisor, System Engineering J. Lechner, Lead Fire Protection Engineer

• D. J. Matthews, Supervisor, Station Licensing

• T. C. Matthews, ',tation Licensing Engineer

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

• T. L. Patterson, Manager, Fort Calhoun Station

• A. L. Rogado, Specialist, Nuclear Safety Review Group R. R. Ronning, System Engineer

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D. Schweiger, Instructional Technologist '

• H. J. Sefick, Manager, Security Services

"R. W. Short, Supervisor, Special Services Engineering C. Simmons, Station Licensing Engineer NRC

• R. Muliikin, Senior Resident Inspector .

T. Reis, Resident ~1nspector

• Denotes those attencing the exit nieeting on August 3,199 The-inspectors also interviewed other licensee personnel during the inspectio . EMERGENCY DIESEL GENERATORS (61726)

This area of the inspection reviewed recent problems the licensee had experienced with the emergency diesel generators. Inspection activities included review of schematic drawings for the control circuitry provided for engine starting and governor operation, surveillance tests, and related sections of the Technical Specifications.- Surveillance Test Procedures OP-ST-DG-0001,

, " Diesel Generator 1 Check," and OP-ST-4G-0002, " Diesel Generator 2 Check," were

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reviewed as well as test results from required monthly testing of diesel-generator No. I for the months of May and June 1990. The inspector also reviewed operating experiences involving concerns related to diesel engine jacket water and cutdoor ambient air high temperatures. The inspector

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4 conducted a walk through of the surveillance procedure to identify installed hardware and obtain a clear understanding of procedure actions necessny to perform the monthly emergency diesel generator surveillance testin :

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l 2.1 Emergency Diesel Cenerator Surveillance Testing and Related Technical Sptcification Requirements The Fort Calhoun Technical Specifications for the monthly cmergency diesel generator surveillance tests requires that the signal initiated to start the diesel shall be varied from one test to another to verify all manual ard auto start circuits. The Jiesel generator control circuitry design includes i numerous signals for automatic idle speed (500 rpm) starts in addition to j automatic full speed (900 rpm) starts initiated by low voltage on the 4160 volt '

emergency buses and/or the power transformer supplying these buses. The i control circuitry design also includes features for manually initiating each

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emergency diesel generator in either a normal or an emergency operating mode, i For each of the two emergency diesel generators, the manual initiating design '

feature is implemented by four pushbuttons, two of which are located on a panel in the control room and two at the local control panel in the attendant diesel generator room. One of the two pushbuttons, for each diesel generator, at each of the two locations iranually initiates the normal diesel generator operating

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mode; the other pushbutton initiates the emergency operating mode. The

! inspector confirmed by procedure review and walkdown that the monthly l surveillance testing clearly requires varying, from one test to another, the

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manual initiating start signals such that all four means are periodically I tested.

l Diring this review, the inspector noted that for the manually initiated diesel

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ge,serator emergency operating mode the procedure required the installation of a

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jumper in the control circuitry such that bypassing the normal system feature of the diesel generator protective trips is precluded. Thus, proper operation i of tle diesel generator protective trip bypass circuitry is not verified. The

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licensee has recognized this concern and had documented it in a memorandum dated February 10, 1989, from Supervisor-Special Services to Supervisor-System Engineering. This memorandum was in response to NRC Information Notice 88-83,

"inadecuate Testing of Relay Contacts in Safety-Related Logic Systems," dated

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October 19, 1988. The licensee is currently in the process of revising the emergency diesel generator surveillance test procedures. This revision should ensure taat the protective trip bypass circuitry is verified to operate properly during periodic surveillance testin With regard to the automatic start circuits, there are approximately twenty-six initiating signals, which should result in an automatic idle and/or fast speed start of each of the two diesel generators. While it was clearly established during th* s inspection that some of these signals have a safety-related function and are wt tested while performing the monthly diesel generator surveillance testing procedure, it was not established if all of these initiating circuits i

are tested to verify proper circuit operation while performing some other l

surveillance procedur In response to this item, the licensee noted that additional time would be required in order to provide information addressing proper circuit operatio The inspector requested the licensee to identify explicitly the automatic initiating idle and/or fast speed start circuits which are periodically tested.

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-5-t A request was also made to provide associated test frequencies along with a description of the testing used to verify proper circuit operations. The licensee was also requested to provide justification for any automatic initiating start circuit that is not tested. The licensee comitted to provide the requested information. This will be considered an unresolved item pending receipt and review cf the information. (50-285/9034-01)

2.2 Emergency Diesel Generator Voltage Regulators As a result of emergency diesel generator testing performed during slune 1990, the licensee established high internal cabinet' temperatures as a contributing f actor for the ' occurrence of a failure of the attendant generator voltage rcgulator. The failure of the generatot voltage regulator occurred near completion of the emergency diesel generator testing, when ambient air temperature within the diesel generator room and temperatures internal to the voltage regulator cabinet (located in the diesel generator rooin) were expected to be near their highest values. Using this type c' reasoning, the licensee established c link between high temperatures internal to the voltage regulator cabinet and the failure which occurred. As a result of establishing this link, the licensee removed the doors to the previously unventilated cabinet, which encloses the solid state electronic circuitry for the generator voltage regulator. By design, the voltage regulator cabinet for each emergency diesel generator is a totally enclosed metal Dox with no ventilation installed and, as such, high internal temperatures have common cause implications. On this basis, the licensee removed the associated voltage regulator cabinet doors for emergency diesel generators 1 and 2. These corrective actions were taken as temporary modifications. Such a modification, as defined by tFe licensee, appears to be an action taken which may remain in place for less than cr equal to 6 months. At the time ins >ection activities were conducted, the licensee was not certain as to what the perm 6hent modification for this problem will b This being the case and considering the length of time required for completing design changes with supporting eralyses and obtaining and/or installing nece sary related hardware, the permanent modifications may not be installed r %nin the next 6 months. Thus, increased justification for long-term (greater that 6 months) operation with the current arrangement should be considere The primary concern regarding this item is the specific measures to be taken to preclude the accumulation of dust and dirt within these cabinets or to prevent the spray of a licuid in to them and onto the internal hardware components with the doors removed. The licensee agreed to address this concern in the subnittal scheduled to be provided to the Office of fluclear Reactor Regulation during the latter part of August 1990. This submittal is being provided to primarily address recently identified concerns relating to high temperatures for the emergency diesel generators jacket coolant flui , SURVEILLANCE TESTlilG OF COMPLEX RELAY CIRCUlTS (61726)

As a result of the review of the diesel generator surveillance tests and the apparent prob 1 cms with testing'of all relay contacts, the inspectors reviewed other selected surveillance tests for possible lack of relay contact testin * *

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-6-The item selected for review was recirculation actuation. The recirculation actuation signal (RAS) logic is actuated by a combination of either o pressurizer pressure low signal (PPLS) or containment pressure high signal (CPHS) along with a coincident safety injection refueling water tank low level signal (STLS).

The inspectors reviewed the surveillance tests for all RAS actuations.,

Surveillance Test ST-ESF-13 (F.3), " Recirculation Actuation Logic" has been '

replaced by OP-ST-ESF-0019 (same title) as a result of the licensee's procedures improvement program. This procedure checks all circuits by test switche Elements of other circuits that feed RAS are tested by separate test procedure The PPLS is checked by Procedures IC-ST-RC-0026 through 0030. The CPHS is checked by Procedure ST-ESF-3 (F.2 and F.3). The STLS is checked by Procedure ST-ESF-7 (F.3 and F.4). These procedures test all circuit elements such as SIRWT level sensors, pressure sensors and circuit relays and contact ,

No violations or deviations were found in this area of the inspectio FIRE PROTECTION / PREVENTION PROGRAM (64704)

This part of the ir,spection was conducted to determine that the licensee had established and was implementing a program for fire protection and prevention in conformance witt regulatory requirements, Technical Specifications, and Industry Guides and Standard The inspector reviewed the licensee's " Station Fire Protection Plan" (50-G-28)

and selected referenctd procedures. There have.been no significant changes to the licensee's program since the last inspection in August 1988. The licensee was in the process of implementing a new procedure improvement program. The most significant changes were in the surveillance testing area. All surveillance tests are being reviewed, revised, and reissued with new procedure numbers assigned to each department. The inspector reviewed Procedure 01-FP-6, " Fire Protection System Inspection and Test," Revision 79, dated May 14, 1990. This procedure pruides instructions for the performance of the weekly and monthly fire protection system inspections and tests. The procedure makes extensive '

use of 01-Fr-1, " Fire Protection System - Water System" as a reference. Thir procedure provides the operators with the details for normal operation # the fire pumps and procedures necessary to remove sections of the fire tr; from service. The procedure also provides the steps and nrecautions for aterning isolated sections of:the system to service. The precautions include locki out both fire puirps, it was noted that this procedure does not advise the operator of the limiting conditions for operation (LCO) in the Technical Specifications; however, the parent document that directs the test, Procedure 01-FP-6, does refer the operators to the applicable Technical SpecificationSection,2.19(4). ,

The licensee has had interpretation problems with this section and recently issued a " Technical Specification Interpretation." This interpretation elimirates unnecessary entry into the LC0 and impairment reports to both the insurer and NRC. The inspector found that the interpretation was consistent

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with the definition of operability under the Technical Specification

" Definitions" and with the analysis contained in the Updated Safety Analysis

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, This' procedure review verified that ti.:; i;&nsee had technically adequate i procedures to implement the. fire protection program. Procedurdi guidance was i provided to control combustible material and reduce fire hazard Administrative procedures provide for maintenance and curve 111ances on fire suppression,~ detection, and support equipment. personnel training, cualifications, and responsibilities were adequately provided. Maintenance evolutions that significantly increase fire risk were properly controlle ,

The' inspector conducted a walkdown of the fire suppression water system and verified that it was operable as required by the Technical Spe:ification .

A tour of accessible areas of the plant was conducted to assess general area condition, work activities in progress, and the visual conditions of fire protection systems and equipment. Combustible materials and flamable and combustible licuid and gas usage were restricted or properly controlled in areas containing safety-related equipment and components. Items checked included positions of selected valves, fire barrier conditions, hose stations, hose houses, Italon system lineups, fire lockers, and fire extinguishers for type, location, and conditio 'There were no construction activities in process in the toured areas. There was some maintenance work and surveillance testing noted. General ho sekeeping conditions were found to be very goo Fire protection syster:s and equipment installed for protection of safety-related areas were found to be functional and tested in accordance with requirements specified in the Technical Specifications. Fire brigade equipment, including emergency breathing apparatus, was found to be properly stored and maintaine During this tour, the inspector noted that the recently completed control room modification had resulted in the fire area and security area boundaries being the same. Due to prior generic industry problems with fire doors carrying dual labels for security and fire barriers, the inspector requested the licensee to provide the supporting documentation for the fire rating of the doors when no underwriters label for fire rating was found on the doors. The specific doors in question were 1011-28, 1036-1, and 1036-2. The licensee subsequently provided the inspector a " Certificate of Fire Label Construction" from the manufacturer. This document specifically stated that the units could not bear an Underwriter Laboratories label because the openings exceeded the size requirements of Underwriter Laboratories proce%res. The document did certify that the doors in question had been fabricated to the proper procedures in accordance with flational Fire Protection Association Standards 80 and 252. The licensee did not have any engineering evaluation documentation to support the lack of proper labels as stipulated in Generic Letter 06-10. The licensee committed to provide this documentation. Pending development and availability of the supporting documentation as per Generic Letter 86-10 by the licensee for

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followup NRC review, this will be considered an unresolved ite (50-285/9034-02) l The inspector also reviewed fire brigade' training and drill records. The

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records were in order and confirmed that training and drills were being conducted at the specified interval Quality Assurance annual audits for the last 3 years were reviewed by the :*

inspector. These audits were identified as: 88-QA-170, dated April 21, 1988; '

89-CQA-091, dated April 6, 1989;.and, 90-00A-166, dated June 22, '990. System and equipment alterations, tests, surveillances,_ maintenance..rt..rds,-and j overall program procedures were addressed. Discrepancies identified vere formally presented to the affected organization. Responses were tracked to

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close out, and actions taken were reviewed for adequac . EXIT HEETING 1An exit meeting was held August ,, 1990, with the individuals identified in paragraph 1 of this report.- At this meeting, the scope of the inspection and -

the findings were summarized. The licensee did not identify es proprietary'any-of the_information provided to, or reviewed by, the inspector ,

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