IR 05000285/1993008
| ML20059H510 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/03/1993 |
| From: | Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059H508 | List: |
| References | |
| 50-285-93-08, 50-285-93-8, NUDOCS 9311100106 | |
| Download: ML20059H510 (11) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-285/93-08 l
License: DPR-40 l
Licensee:
Omaha Public Power District
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Fort Calhoun Station FC-2-4 Adm.
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P.O. Box 399, Hwy. 75 - North of Fort Calhoun
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Fort Calhoun, Nebraska Facility Name:
Fort Calhoun Station Inspection At:
Blair, Nebraska l
Inspection Conducted:
September 27 through October 1, 1993 Inspectors:
W. M. McNeill, Reactor Inspector, Engineering Section, Division of Reactor Safety l
Accompanying Personnel:
S. Bloom, Project Manager, Nuclear Reactor Regulation Approved:
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TKomas F. Westerman, Chief, Engineering Section Date Division of Reactor Safety
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Ir; pection Summarv Areas Inspected: Routine, announced inspection of the 10 CFR 50.59 safety evaluation program and its implementation.
Results:
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j The licensee has established a good program for performing safety
evaluations in accordance with 10 CFR 50.59 (Section 2.1).
The program's broad definition of licensing basis documents, the
adoption of an industry guideline, and the listing of accidents to be considered during evaluation in the procedure were considered strengths (Section 2.1.2).
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l Examples of incomplete evaluations (Section 2.2.1.1), evaluations that l
lacked attention to detail (Sections 2.2.1.2 through 2.2.1.5), and one screening that was not adequate (Section 2.2.2.1) were found during the inspection reviews. These issues were classified as a noncited violation of regulatory requirements (Section 2.3).
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The licensee issued a "Significant Corrective Action Request" based on
the inspection findings (Section 2.3).
Overall, the program for preparation and review of 10 CFR 50.59
screenings and evaluations was found to be good, with weaknesses noted in the program implementation (Section 2.3).
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Attachments:
Attachment 1 - Persons Contacted and Exit Meeting
Attachment 2 - Documents Reviewed
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DETAILS
1 PLANT STATUS During this inspection period, the plant was in days 11 through 14 of the 1993
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refueling outage.
2 SAFETY EVALUATION PROGRAM, 10 CFR 50.59 (37001)
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2.1 Procram The licensee has established a program (N0D-QP-3) for reviewing changes to the I
facility as described in the safety analysis report and tests and experiments
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to the facility not described by the safety analysis report. The scope of the
licensee's program for safety evaluations was considered to be broad and included consideration of other licensing basis documents such as surveillance
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tests, operating procedures, operating instructions, emergency operating procedures, abnormal operating procedures, radiological emergency response i
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plan, technical data book, maintenance procedures, preventive maintenance r
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procedures, special procedures, quality assurance plan, security plan, l
calibration procedures, Technical Specifications,. standing orders, special J
j order:, chemical procedures, health physics procedures, and reactor core physics test procedures.
The safety evaluation program (NOD-QP-3) implementation included a l
progressively detailed three-step process to determine if'an unresolved safety
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question could result from a change, test, or experiment. The first step of
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the process was a screening documented on Part A of Form FC-154 to determine
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if a safety evaluation was required.
If a change was determined to affect the facility as described in the safety analysis report or a test or experiment
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was not described in the safety analysis report, then the second step of the
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process required a safety evaluation to determine if the proposed activity
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involvM an unreviewed safety question. The safety evaluation was documented
on Part _ of Form FC-154.
If an unreviewed safety question was determined to l
exist, the third step was performed to assure that the change,' experiment, or test was t:t performed without prior NRC approval.
2.1.1 Trainina
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Program N0D-QP-3 required that all safety evaluations and screenings were to be prepared and approved by qualified and trained personnel. The program includes requirements and provisions for initial. qualification, and requalification of individuals biennially including written exams. The inspectors revi&ad the training plans and student handout for initial and
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requalification training and considered them to be acceptable.
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2.1.2 Strenaths and Weaknesses The licensee's program included a broad definition of licensing basis
documents, which was considered a strength. The licensee has defined their program to conform to the Nuclear Safety Analysis Center (NSAC) -125,
" Guidelines for 10 CFR 50.59 Safety Evaluations," which was a reference in the procedure. The safety evaluation procedure also included a list of accident
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events to be considered during performance of the required reviews. These were considered to be strengths of the program.
A computerized data base had been established by the licensing organization, which contained the safety analysis report and the Technical Specification text, to provide word search capability.
This initiative was viewed as a strength; however, some of the engineering staff were not aware of this capability.
2.2 Implementation The inspectors reviewed the "1993 Safety Analysis Report Update and 10 CFR 50.59 Report for Fort Calhoun Station." During 1992, the licensee made 46
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changes of which 17 were procedure changes, 10 were design changes, 10 were
temporary modifications, 3 were maintenance work orders, 2 were safety analysis report chm ges, and 4 were miscellaneous. Since the 1992 report, 6 evaluations had been performed.
Three were procedure changes, 2 were design
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changes, and I was a corrective action.
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The inspectors attended an "on site review comn.its N" meeting conducted on
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September 29, 1993, and verified by observation that evaluations were being
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reviewed and approved by the committee as required by the Technical
Specifications (Section 5.5.1.6) and Procedure N00-QP-3.
2.2.1 Evaluations The inspectors reviewed the evaluations identified in " Document Reviewed,"
Attachment 2, for conformance to 10 CFR 50.59 and the licensee's procedure requirements including the qualification and training of approvers and
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preparers and changes to the safety analysis report.
The inspectors reviewed seven design changes, six temporary modifications, four procedure changes, one i
safety analysis report change, and one miscellaneous change.
2.2.1.1 Modification Reouest No. FC-88-017 (Field Desian Chanae Reouest No.92-486). Miscellaneous closeout items This change consisted of nine different tasks associated with the closecut of the installation of a third auxiliary feedwater pump. The tasks were to:
(1) replace a pressure indicator; (2) install a manifold; (3) install a flow
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transmitter; (4) install snubbers; (5) reposition battery cable; (6) install a i
cover over an outlet muffler; (7) install correct valve position indicators; (8) insulate exhaust drain line; and (9) reroute gear box oil drain. The J
scope of the safety evaluation for this modification was limited, in that, the
-5-evaluation answers often did not address more than one of the nine proposed changes.
For example, Question No. 10.6 on Form FC-157, "Could the proposed activity increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the safety analysis report?" was answered in respect to the third task only, flow transmitter installation and was not applied to the other eight facility changes.
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2.2.1.2 Modification Recuest No. FC-91-026. Replace An Old Set of Station Batteries and Racks The documentation of this evaluation was not consistent with the instructions at Question No. 8.7 on Form FC-154. The preparer continued to answer Question No. 8.7.
2.2.1.3 Procedure Chance No. 38212 to Procedure No. 01-WDL-1. Collection and Transfer of Licuid Waste. Was Revised To Chance A Valve Status From Seal Wired Closed To locked Closed Question No. 9.6 on Form FC-154 reauested the preparer to identify "What are the safety analysis report sections involved with this change?" The inspectors found that the response documented did not list the applicable safety analysis report sections.
2.2.1.4 Procedure Chance No. 38228 to Procedure No. CH-ST-RM-0052. Auxiliary Buildino Exhaust Stack / Containment Particulate Radiation Monitor.
RM-050 Primary Calibration. Was Revised To Add New Calibratica Ecuation Question No. 9.7 on Form FC-154 requested the preparer to identify "What are the safety analysis report sections that address the previously anticipated test / experiment." The inspectors found that the response documented did not
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list the applicable safety analysis report sections.
2.2.1.5 Procedure Chance No. 38316 to Procedure No. A0P-7. Evacuation Of the Control Room. Was Revised To Incorporate New Writer's Guide This evaluation did not have pages B-1 and B-2 on Form FC-154 completely filled out.
Page B-1 was missing the list of applicable accidents and page B-2 was missing the identification of the applicable system interactions.
2.2.1.6 Temocrary Modification No.90-022. Lockino Closed 32 Component
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Coolina Water and Raw Water Interface Valves. and Modification Reauest No. FC-90-023. Addition of Breaker 110 in the 161kV Electrical Distribution System The inspectors observed that the text of these two evaluations was incomplete.
There was information missing in the evaluation of Temporary Modification No.90-022, such as reference to the applicable Licensee Event Report 90-25 and a design calculation. The licensee event report identified that the temporary modification was the corrective action for the event. The
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calculation established that component cooling water was not necessary to prevent containment over pressurization, only containment spray. The evaluation for Modification Request No. FC-90-023 did not clearly identify which breakers and relays were being considered in the answers to the various questions.
2.2.1.7 Modification Reouest No. FC-90-002. Install Backup Heatless Air Dryer _
and Remove Old Dyer in the Instrument Air System The inspectors observed that the evaluation of this modification of the instrument air system had statements in it such as:
"The entire system is non-CQE and does not alter any safe shutdown functions. There is no adverse impact on procedures, structures, systems or components which contribute to nuclear safety." This statement did not appear to recognize the importance of the instrument air system at Fort Calhoun.
2.2.2 Screeninas The inspectors reviewed the screenings identified in " Documents Reviewed,"
Attachment 2, for conformtnce to the procedure requirements and verified the
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qualification and training of preparers and approvers. The screenings reviewed consisted of seven design changes, two temporary modific""ons, and one incident report.
2.2.2.1 Modification Reouest No. FC-89-074. Electrical Supply Chances To
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Packino Coolant Pumps
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The inspectors found by using the word search capability of the licensing department computerized data base that Section 14.24 was changed by this modification. The screening performed by engineering did not identify this change as required by Procedure N0D-QP-3.
Section 14.24 described the power supply to the packing coolant pump motors. This screening should have identified that an evaluation of this change impact was necessary.
2.3 Summary Examples of incomplete evaluations, the inadequate screening and the lack of attention to detail were identified. The evaluations and screening (see Sections 2.2.1.1 and 2.2.2.1 above) in question were found by the inspectors to not constitute unreviewed safety questions. The issues were considered by the inspectors as examples of a failure to properly implement Procedure N0D-QP-3 and Criterion V of 10 CFR 50, Appendix B,.
In response to these findings, the licensee issued "Significant Corrective Action Request,"
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No.93-209. This violation is not being cited because the criteria in paragraph VII.B(1) of Appendix C to 10 CFR Part 2 of the NRC's " Rules of l
Practice" were satisfied in that the issues were of minimum safety i
significance and the licensee took prompt actions to correct the problem.
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Overall, the program for preparation and review of 10 CFR 50.59 screenings and evaluations was found to be good with weaknesses noted in he program implementation.
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ATTACHMENT 1
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1 PERSONNEL CONTACTED
1.1 Licensee Personnel
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- R. Andrews, Division Manager Nuclear Services
- C. Bloyd, Special Services Engineering
G. Cavanaugh, Engineer Licensing i
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- J. Chase, Plant Manager
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- G. Cook, Supervisor Station Licensing
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l M. Core, Supervisor Electrical / Instrument and Control Engineering
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- S. Gambhir, Division Manager - Production Engineering
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- J. Gasper, Manager Training j
W. Hansher, Nuclear Licensing Engineer
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- J. Herman, Acting Manager Nuclear Licensing and Industrial Affairs
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- R. Jaworski, Manager-Station Engineering
- L. Kusek, Manger - Nuclear Safety Review Group
L. Lester, Senior Engineer
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- R. Lippy, Inservice Inspection Coordinator
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J. McManis, Nuclear Design Engineer
- T. Patterson, Division Manager - Nuclear Operations l
R. Phelps, Manager Design Engineering
- J. O'Connor, Manager Electrical Engineering
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- W. Orr, Manager - Quality Assurance / Quality Control
- R. Phelps, Manager Design Engineering Nuclear t
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J. Ressler, Nuclear Design Engineer
B. VanSant, Supervisor Nuclear Design Engineer
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l L. Wigdal, Supervisor Technical training
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1.2 NRC Personnel
A. Azua, Resident Inspector
- P. Harrell, Chief, Technical Support Staff
- C. Johnson, Reactor Inspector
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- R. Mullikin, Senior Resident Inspector In addition to the personnel listed above, the inspectors contacted other
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personnel during this inspection period.
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- Denotes personnel that attended the exit meeting, i
2 EXIT MEETING An exit meeting was conducted on October 8, 1993. During this meeting, the inspectors reviewed the scope and findings of the report. The licensee did.
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express a position on the inspection findings documented in this report. The licensee expressed concurrence with the inspections findings. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.
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ATTACHMENT 2 l
DOCUMENTS REVIEWED j
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Procedures l
Quality Procedure No. N00-QP-3, "10 CFR 50.59 Safety Evaluations,"
Revision 11, August 27, 1992 j
Nuclear Licensing & Industry Affairs Procedure No. NL-14, " Instructions for l
Processing Proposed Changes to the Updated Safety Analysis Report and i
inclusion in to the 50.59 Report," Revision 1, July 30, 1993 l
Lesson Plan, 2327-07, "10 CFR 50.59 Safety' Evaluations," Revision 5 with student handout lesson Plan, 2327-20, "10 CFR 50.59 Safety Evaluation Biennial Requalification
Training," Revision 3, June 17, 1993 Evaluations l
Modification Request No. FC-88-017 (Field Design Change Request No.92-485),
Miscellaneous closecut items, August 25, 1993
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Modification Request No. FC-90-002, Install backup heatless air dryer and j
remove old dyer in the instrument air system, September 3 and 4,1993 Modification Request No. FC-90-023, Addition of Breaker 110 in the 161kV electrical distribution system, February 3,1992 Modification Request No. FC-90-038, Code qualifying and upgrading of piping and pipe supports of the main steam and main feedwater systems, November 21, 1991 Modification Request No. FC-90-067, Change circuitry to have Vacuum Pumps FW-8B and FW-8C load shed, February 14, 1992 Modification Request No. FC-91-008, Change under voltage' set points of offsite power low signal, November 13, 1991 Modification Request No. FC-91-026, Replace an old set of station batteries and racks, April 15, 1993 Temporary Modification No.90-022, Locking closed 32 component cooling water and raw water interface valves, November 1,1990 Temporary Hodification No.91-034, Jumpering out of 2 cells in the station battery, September 12, 1991 j
l Temporary Modification No.92-043, Replace cables to resistance temperature detectors on the Loop 2 hot leg, July 10, 1992
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Temporary Modification No.92-053, Replace a 12 inch butterfly valve in the raw water system with an equivalent but non safety related class valve, l
June 19, 1992
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Temporary Modification No.92-058, Change the supply power to breakers for the
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Gai-tronics and nuclear emergency alarm system while the plant was in cold shutdown, July 7, 1993 l
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i Temporary Modification No.92-078, Exchanging nuclear instrumentation excore i
safety channel detectors, November 30, 1992 l
Engineering Assistance Request No.92-049, Revised Section 10.2.5 to delete routing of a release path, September 14, 1992 Updated Safety Analysis Report, Revision of Appendix N of the safety analysis
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report to clarify safety class of various components and systems, May 13, 1993
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Procedure Change No. 38316 to Procedure No. A0P-7, " Evacuation of the Control
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Room," was revised to incorporate new writer's guide, April 20, 1992
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Procedure Change Nos. 38228 and 38229 to Procedure Nos. CH-ST-RM-0052,
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" Auxiliary Building Exhaust Stack / Containment Particulate Radiation Monitor,
RM-050 Primary Calibration," and CH-ST-RM-0053, " Auxiliary Building Exhaust
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Stack / Containment Gas Radiation Monitor, RM-051 Primary Calibration," were
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revised to add a new calibration equation, April 9,15, and 27,1993 Procedure Change No. 38212 to Procedure No. 01-WDL-1, " Collection and Transfer of Liquid Waste," was revised to change a valve status from seal wired closed r
to locked closed, April 22, 1992 j
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Procedure Change No. 38230 to Procedure No. OP-1, " Master Check List For Startup Or Trip Recovery," was revised to provide guidance on leakage, April 9, 14, 23, 1992 Screeninas
Temparary Modification No.92-013, Removal of pipe support from waste gas vent header in containment, February 8, 1992 Temporary Modification No.92-078 (Revision 1), Reland cables of the nuclear instrumentation system, March 1, 1993 Incident Report No. 920143, Inadequate safety evaluation performed on Procedure Change No. 26681 to Procedure No. 01-CH-6, CVCS Resin Transfer, April 20,1993 i
Modification Request No. FC-89-074, Electrical supply changes to packing coolant pumps, February 6,1992
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Modification Request No. FC-89-081, Steam supply break protection, September 10, and 28, 1991 Modification Request No. FC-90-025, Unions for the component cooling water pump oil coolers relief valves, February 20, 1992 Modification Request No. FC-90-068, Nuclear instrumentation cable separation,
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February 27, 1993 Modification Request No. FC-91-013, Reactor protection system Delta T power fluctuation, September 26,1992 Modification Request No. FC-91-030, Replacement of charging pump relief valves, February 28, 1992 Modification Request No. FC-92-002, Extension pipe for the personnel air lock door equalizing valve, February 25, 1992 l
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