IR 05000285/1993011
| ML20056D802 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/11/1993 |
| From: | Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20056D799 | List: |
| References | |
| 50-285-93-11, NUDOCS 9308180034 | |
| Download: ML20056D802 (19) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-285/93-11 Operating License: DPR-40 Licensee: Omaha Public Power District 444 South 16th Street Mall Omaha, Nebraska 68102-2247
Facility Name:
Fort Calhoun Station Inspection At:
Blair, Nebraska l
Inspection Conducted: June 6 through July 17, 1993 Inspectors:
R. Mullikin, Senior Resident Inspector
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R. Azua, Resident Inspector J. Whittemore, Reactor Inspector Approved:
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. Harr 11, T;tlidf, Technical Support Staff Dafe'
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Inspection Summary Areas Inspected: Routine, unannounced inspection of onsite followup of events, operational safety verification, maintenance and surveillance observations, followup on corrective actions for violations, and onsite followup of licensee event reports.
Results:
Failure to adequately control switchyard activities resulted in a
turbine / reactor trip on June 24, 1993. This event is described in NRC Inspection Report 93-12 (Section 2.2).
Inadequate tagout resulted in steam release from Feedwater
Heater FW-15A. This event is described in NRC Inspection Report 93-12 (Section 3.8).
Licensee actions resulting from high river levels were considered to be
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p'rompt and proactive (Section 2.3).
Housekeeping was found to be declining and in need of management
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attention (Section 3.2).
9308180034 930812 PDR ADDCK 05000285 G
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-2-P Licensee transition to the new 10 CFR Part 20 requirements was noted to
occur without any concerns (Section 3.4).
System engineers were determined to be burdened by unnecessary duties.
- The licensee has taken actions to remove some of these duties.
Summary of Inspection Findings:
Inspection Followup Item 285/9311-01 was opened (Section 3.3)'
Violations 285/9211-01 and 285/9210-01 were closed (Section 6)
Licensee Event Reports92-030 and 93-003 were closed (Section 7).
- Attachment:
Attachment - Persons Contacted and Exit Meeting
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-3-DETAILS 1 PLANT STATUS At the beginning of this inspection period, the Fort Calhoun Station was operating at 100 percent power. The plant continued to operate at that level until June 24, 1993, when the plant experienced a reactor trip which followed a turbine trip on a loss-of-load signal. The trip resulted from switchyard activities that were being performed by Omaha Public Power District substation personnel. On June 26 the reactor obtained criticality. On July 1 the plant reached 100 percent power, where it remained throughout the rest of this inspection period.
2 ONSITE RESPONSE TO EVENTS (93702)
2.1 Engineered Safety Features Actuation On May 24,1993, at 8:15 p.m., a spurious signal from pressurizer level instrumentation (LC-10lX) caused both backup charging pumps (CH-1A and -1B) to automatically start.
Level Controller LC-10lX is part of the pressurizer level control system and the charging pumps were responding to an erroneous pressurizer low level signal.
Letdown Isolation Valve HCV-204 automatically closed due to the pressure oscillations from increased charging flow. The backup charging pumps are designed to automatically start when actual pressurizer level drops 3 percent below programmed level. The licensee
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determined that no such deviation existed at the time of the event. The plant response was as expected for increased charging and letdown. The letdown isolation valve closed and the backup charging pumps automatically stopped as pressurizer level returned to normal.
The charging pumps at the Fort Calhoun Station are designated, per the Updated Safety Analysis Report, as engineered safety' feature equipment used for
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boration. The operators did not consider the automatic starting of the backup charging pumps as reportable under 10 CFR 50.72 since the start. signal was derived from its normal chemical and volume control system function.
It was not until the following morning, during the plan-of-the-day meeting, that plant management became aware of the event and questioned the decision to not make a 10 CFR 50.72 report.
It was subsequently determined by the licensee that the event was reportable and the required report was made at 2:07 p.m. on May 25, 1993.
Subsequently, the licensee performed a further review of the reportability of this event. A licensee memorandum dated June 7, 1993, was presented to the Plant Review Committee on June 14 providing information both for and against reportability. The issue discussed was whether all automatic functions of engineered safety feature components require a report, or if there are some specific automatic functions that may be excluded from reportability on the basis of being part of normal system operation. The Plant Review Committee
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i decided that this event did constitute an automatic engineered safety feature
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actuation and was reportable.
l The licensee suspected deterioration of wiring in the level controller and a
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maintenance work order was written to inspect the wiring and perform an
instrument loop calibration. This is scheduled for the 1993 refueling outage.
l The inspectors will perform a review of this event during routine review of j
Licensee Event Report 93-009.
j 2.2 Reactor Trip f
i On June 24, 1993, the Fort Calhoun Station experienced a reactor trip due to a
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loss-of-load turbine trip. The turbine trip was caused.by Omaha Public Power j
District ~ (nonplant) personnel working in the Fort Calhoun Station switchyard.
l The substation personnel were in the process of performing relay work, and
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when a cabinet door was forcefully opened, a door mounted relay actuated.
This, in turn, tripped lockout relays which opened the 345-kV plant output.
breakers, resulting in a turbine trip and a subsequent. reactor trip.
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the unexpected anomalies resulting from the trip were:the failures of the
fast-and slow-transfer features to transfer the nonenergized nonsafety-.
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related 4.16-kV buses to the safety-related buses.
In addition, one of the
nonsafety-related 4.16-kV buses failed to load shed. Also, a water hammer in
the condensate _ system occurred after the trip due to condensate and feedwater l
being shut down due to erroneous breaker indications in the control room from
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the failure to load shed. The inspection of this trip and resulting followup
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actions are documented in NRC Inspection Report 50-285/93-12.
f 2.3 Hiah Missouri River level On July 9,1993, due to unusually high precipitation'in the local area, the
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Missouri River reached an elevation of 1000 feet above mean sea level at the
Fort Calhoun Station. As a result, the licensee implemented Abnormal.
.i Operating Procedure A0P-1, " Acts of Nature," Section 1, " Flood." The licensee-
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held a management meeting to determine if there were any additional actions i
that needed to-be performed other than those prescribed by the abnormal operating procedure. One such action included monitoring the condition of the i
plant access road.and Route 75. Should any of these roads-be threatened by.
the rising river waters, the licensee had arranged to notify. emergency.
a response personnel as to alternate routes that-should be taken to evacuate the
plant in the event of-a plant emergency.
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In accordance with the requirements set forth in Abnormal Operating.-
l Procedure A0P-1, flood control panels designed for this eventuality wi.re-
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installed in the designated areas of. the intake structure, auxiliary building, t
and radwaste processing building.
In addition, some. areas that.did not.have-
flood control ~ panels,.such as the auxiliary building truck bay,: were sand
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bagged. The licensee made a decision not to' install, some panels because they t
would have impeded routine daily access and egress from such. areas as the.
- technical-support center and the radiological controlled area access to ~ the-
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As a result, the licensee prestaged the appropriate equipment needed to install these remaining flood panels should the conditions warrant it.
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The inspectors and the licensee maintained contact with the Army Corps of
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Engineers to obtain forecasts as to how fast the river level would rise and at what levels it was estimated that it would crest. When it was predicted that the river level would exceed 1001 feet 5 inches, the licensee made efforts to adjust the pH of the holding lagoons as close to neutral as possible. At
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approximately 3 p.m.. on the same day, the holding lagoons, which are located outside the protected area on the south side of the plant, were flooded by the river. The pH of the lagoons at the time was approximately 6.8.
As a result, no notifications were required to be made to the state agency for environmental protection. The river also began to overtake portions of the parking lot and was within 100 feet from the primary access point to the protected area of the plant. The licensee had placed sandbags in the vicinity of the primary access point in the event that the river waters were to reach
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the building.
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On the north side of the plant some river water reached portions of the sally-port, within 50 feet of the protected area's secondary access point.
The inspectors questioned if the water located in this portion of the isolation zone had any effect on the operability or effectiveness of the
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licensee's security equipment. The licensee stated that no negative effects had been noted.
The river crested on July 10 and reached a level of 1002 feet 4 inches.
River level then dropped slowly to a low of 999 feet 2 inches on July 12.
Since then the river has slowly risen to a level of 1001 feet 8 inches.
2.4 Conclusions Overall, the licensee's response to high river levels was considered prompt and proactive.
3 OPERATIONAL SAFETY VERIFICATION (71707)
3.1 Routine Control Room Observations The inspectors observed operational activities throughout this inspection period to verify that proper control room staffing and control room professionalism were maintained. Shift turnover meetings were conducted in a manner that provided for proper communication of plant status from one shift to the other. Discussions with operators indicated that they were aware of plant and equipment status and reasons for lit annunciators. The inspectors observed that Technical Specification limiting conditions for operation were properly documented and tracked. Operators were observed to properly control access into the control room operating area.
Plant management was observed in the control room on a daily basi._
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3.2 Plant Tours The inspectors routinely toured various areas of the plant to assess the
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safety conditions and adequacy of plant equipment. The inspectors verified
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that various valve and switch positions were correct for the current plant
conditions. Personnel were observed obeying rules for personnel safety and rules for escorts, visitors, entry, and exits into_ and out of vital areas.
During these tours, five air hoses were found coupled to compressed air lines._
I but were not secured with cotter pins which are designed to prevent their
inadvertent disconnection and possible injury. This condition was of'further concern because three of the five hoses identified had cotter pins attached to i
the hoses via a chain or other lanyard material. The inspectors notified _the-e safety coordinator of this condition. The safety coordinator stated that.the i
conditions identified would be corrected and that further corrective actions
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would be taken to preclude their recurrence.
I The inspectors concluded that overall plant housekeeping was good but in need
of management attention. Some specific areas noted to'the licensee were the accumulation of dirt on the floors in the switchgear, diesel generator, and electrical penetration rooms.
In-addition to dirt, the inspectors noted to i
the licensee that cottonwood seeds had accumulated on the floor in certain l
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areas of the Diesel Generator 2 room.
j On July 6,1993, while touring the auxiliary building, the inspectors came upon two technicians working in Room 59 (upper mechanical penetration _ room).
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The technicians were working on top of a scaffold to decontaminate-.the upper portions of that room.. The room contained three' scaffolds, each with its own
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individual ladder. While in the area, the inspectors observed the technician
travel from one scaffold to another by crawling'across an 8-foot. span of round
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ventilation ductwork which was located approximately 11 feet.from the ground
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floor. This was done instead of climbing down from the scaffold and climbing j
up to the other scaffold. Even'though-the technician wore a safety harness,
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as required for work over 10-feet, it was not-secured, and as a result would-not have performed its safety function. This was considered.aLpoor and unsafe work practice. The inspectors raised this concern with the technicians and j
then notified the safety coordinator of this condition; The _ safety, e
coordinator responded that corrective actions had been taken which included verbal instructions to maintenance and. modification work crews.
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l the inspectors verified that an engineering evaluation had been performed and
that the technicians had been given permission to walk on the' ventilation j
ductwork in Room 59.
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3.3 Technical Specification 2.15 l
The inspectors, while reviewing the Fort Calhoun St'ation Technical l
Specifications,'noted that one of the requirements set; forth in the limiting l
conditions for operation for Technical Specification 2.15 may place the plant l
'in a less conservative condition. Technical Specification 2.15, Table.2-3, l
Section 3B(f) states, _ with regard to the operability of the. individual.
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channels of the safety injection and refueling water tank level control system, that if one channel becomes inoperable, that channel must be placed-in
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the tripped or bypassed condition within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from time of discovery of loss of operability.
If bypassed and that channel is not returned to operable
status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from time of discovery of loss of operability, that channel must be placed in the tripped condition within the following 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
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The engineered safety features system at the Fort Calhoun Station relies on a l
2-out-of-4 logic to initiate an engineered safety feature. The effect of
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placing an inoperable channel in the trip position satisfies one of the two required signals and the logic becomes 1-out-of-3, which is less conservative l
for this particular application.
l A less of coolant accident at the Fort Calhoun Station could be postulated that, if the recirculation actuation signal were to occur before sufficient reactor coolant had accumulated in the containment sump, there may not be sufficient net positive suction head to adequately supply the safety injection pumps. This condition could result in air binding or overheating of the pumps.
The inspectors believe that the requirement.to place an inoperable channel of the recirculation actuation signal, or its associated input signals,-in the trip position as required by the Technical Specifications is nonconservative.
Such requirements may place the Fort Calhoun Station in a condition for which plant operators are not trained, difficult to recover from, and may affect plant safety. This issue is being discussed with the Office of Nuclear Reactor Regulation. The resolution of this issue with the Office of Nuclear Reactor Regulation will be an Inspection Followup Item (285/9311-01).
3.4 Radiological Protection Program Observations
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During this inspection period, the inspectors verified that selected activities of the licensee's radiological protection program were properly implemented. This effort had increased significance due to the fact that on July 1,1993, the licensee implemented the new 10 CFR Part 20 regulations.
Tours of the radiological controlled area after July 1 identified that the licensee had made the transition to the new posting requirements.
Radiation and contaminated areas wet e properly posted and controlled. The inspectors randomly verified that doors to restricted high radiation areas were locked.
The inspectors accompanied a number of health physics personnel while they
were performing their weekly and monthly surveys of the areas within the radiological controlled area.
It was noted that prior to the July 1 deadline, radiation protection management had required that technicians begin performing surveys using the old and new methods. This was done so that the technicians would be more familiar and comfortable with the new method once it became a f
requirement. This effort was determined to be proactive, reducing the chances for confusion when _the'new 10 CFR Part 20 regulations were implemented. When questioned, the health physics technicians were found to have a good -
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understanding of the old and new regulations and none appeared confused with
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l either. The technicians. performing the surveys were found to be knowledgeable
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of their responsibilities and performed a thorough effort maintaining good
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ALARA practices.
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While touring the radiological controlled area, the inspectors identified
l licensee personnel working in the overhead spaces which at' Fort Calhoun are considered contaminated unless specifically surveyed. The licensee-personnel
were found to be working under the appropriate radiation work permit and were i
knowledgeable of their responsibilities.
In addition, it was noted that the j
licensee had assigned health physics personnel as spotters under those
. activities where falling debris, such as dust, was a concern. These spotters j
redirected traffic, periodically wiped the area below, and took' surveys to
determine that no contamination was being spread to otherwise clean areas.
The inspectors determined this precaution to be appropriate. On two occasions l
the inspectors noted personnel working in the overhead area in street clothes.
i The inspectors verified that these overhead areas had been surveyed and were L
considered a clean area by the licensee.
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3.5 Security Program Observations The inspectors observed various aspects of the licensee's security program.
Personnel and packages entering the protected area were observed to be
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properly searched. Vehicles were properly controlled or escorted within the i
protected area. Designated vehicles parked and. unattended within the
protected area were. found to be locked and the keys removed. The inspectors routinely toured the protected area perimeter and found it maintained at an j
excellent level. Also noted was that proper compensatory measures were taken
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when a security barrier was inoperable.
The inspectors toured the central alarm station and the secondary alarm station. The security personnel stationed at these locations were observed
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for a period of time while they performed their duties. The overall'
l assessment of their duties was very good'
The inspectors then observed as the
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security personnel performed a shift turnover.
Proper communication of j
security status-from one shift to-the other was noted.
The security personnel
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interviewed were knowledgeable of their responsibilities and of the present condition of the-security system.-
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3.6 Review of System Enoineerina procram i
The inspectors discussed the current state of thel system engineering program with the licensee. During routine _ contact with system engineers on various t
issues, the inspectors observed that an increase in the engineers'
responsibilities had occurred since the initial inception of the program. The'
-inspectors concluded that some unnecessary administrative duties may prevent-
-l system engineers from getting into the plant and inspecting' their systems on a J
l routine basis.
In fact, interviews with system engineers indicated that some are burdened with what could be considered duties not. required to be performed by the engineers. However, there were no instances noted where system-
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engineering performance had declined.
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-9-The inspectors' observations have been that the system engineering program has been a valuable asset to the licensee. There has been observed good communication and coordination between system engineers and operations personnel.
It has been apparent to the inspectors that plant operators have a great degree of confidence in the abilities of the system engineers.
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noted that some of the systems within the program have new system engineers.
This was mainly accomplished by transferring engineers from one system to another. The inspectors expressed concern to the licensee that if engineers on new systems are administratively burdened and hampered in the learning process, that the confidence plant operators have in the system engineers may erode. This could reduce the effectiveness of the system engineers and this confidence could be slow in returning.
The licensee stated that they were also concerned with the increased workload of the system engineers. The inspectors were informed of various system engineering responsibilities that have been removed. These included:
Revising the incident report and nonconformance report process to
eliminate some administrative burdens.
Assigning a full time individual in the system engineering department
(not a system engineer) to perform the task of document updates from modifications and engineering change notices. However, the system engineers would still review the updated documents.
The chairmanship of the system modification and review team was taken
from the system engineers.
Being the chairman created time consuming administrative burdens.
The amount of detail required for system engineering weekly status e
reports to engineering management was reduced.
The licensee performed a quality assurance surveillance of the system engineering workload and the results were documented in a memorandum dated '
June 16, 1993. The results of this surveillance indicated that some system engineers felt they were unable to spend the time in the field necessary to identify and pursue reliability issues.
Their time in the field occurred almost exclusively when notified by maintenance or operations that significant work or testing was going to occur. They felt their availability to work with other personnel to solve problems was curtailed by a paperwork schedule in which priority was driven by due date rather than by impact on system reliability or cost. The surveillance did note that some progress has been made towards regaining control over system engineering workload. Quality assurance did not have any corrective action reports or recommendations as a
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result of this surveillance. This information was presented for licensee management's consideration only. Another quality assurance surveillance on this issue is scheduled in another 6 months.
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One observation noted by the inspectors during discussions with the licensee was that the certification process for new system engineers was different for engineers transferring to another system. A new system engineer receives approximately 4 months of classroom training which encompasses all the engineering disciplines. After this training, the engineers receive on-the-job-training on their assigned system. To become certified the engineer must complete a qualification card and an oral board. The inspectors were informed that when a system engineer transfers from one system to another they do not issue a new qualification card for that system.
Licensee management relies on the work produced to be evidence that they are qualified on the new system. The inspectors questioned the effectiveness of this process.
It was stated that the process in place was sufficient. The inspectors have not observed any performance problems due to the system engineering training procedures.
The inspectors concluded that no major problems have been noticed with the system engineering training process or with performance. However, it was determined that the potential existed for the program to decline.
3.7 Emergency Preparedness Exercise On June 29, 1993, the inspectors participated in the Fort Calhoun Station emergency exercise. This was a full scale participation exercise and was followed by the Federal Radiological Monitoring and Assessment Center exercise on June 30 through July 1, 1993. The results of the emergency exercise are documented in NRC Inspection Report 50-285/93-05.
3.8 Feedwater Heater FW-15A Steam Release On June 27, 1993, the inspectors were touring the turbine building when a noise was heard coming from the north end of the building. The inspectors were in route to the control room to inform the shift supervisor of the noise when steam was noticed blowing several feet above the turbine deck through the floor grating. The inspectors knew that the steam was coming from the area of.
Feedwater Heater FW-15 which was having its relief valve replaced. The inspectors immediately went to the control room. The turbine building operator was calling in the steam leak as the inspectors entered. The
inspectors went with the shift supervisor to the feedwater heater _and watched
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the activities to isolate the steam leak. This was successfully accomplished.
This event is discussed in detail in NRC Inspection Report 50-285/93-12.
3.9 Conclusions Operations, radiological protection, and security personnel performed their duties in a professional manner.
Licensee transition to the new 10 CFR Part 20 regulations occurred without any apparent problems. Actions taken by radiological protection personnel in preparation for the transition to the new 10 CFR Part 20 regulations were proactive.
Plant housekeeping was found to be in need of management attention.
System engineers were determined to be administrative 1y burdened which the licensee was taking actions to help
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4 MAINTENANCE OBSERVATIONS (62703)
4.1 Emergency Diesel Generator 1 Primary Air Receiver Drain Line Replacement On July 12-14, 1993, the inspectors witnessed portions of the licensee's maintenance activity to replace Emergency Diesel Generator 1 primary air receiver drain line. This effort was being performed as a result of Engineering Change Notice 93-152, which required that the carbon steel drain lines be replaced with chrome-molybdenum piping. This engineering change notice was written following the identification of a pinhole leak, due to corrosion, in the drain line off of Emergency Diesel Generator 2 Primary Air Receiver Drain Line SA-4A-2.
The inspectors witnessed the beginning of this effort, which included the construction of the scaffolding around safety-related equipment. This portion of the maintenance activity was performed under Maintenance Work Order 931804.
The other half of this effort, which included the manufacture and installation of the drain line piping for Emergency Diesel Engine 1 Primary Starting Air Receivers SA-4A-1 and SA-48-1, was addressed under Maintenance Work Orders 931082 and 931097. The inspectors reviewed the maintenance work orders and associated procedures and instructions, and verified that they had been reviewed and approved as noted by the appropriate signatures.
In addition, the maintenance work orders were found to have sufficient information for craft personnel to identify the equipment that was to be worked on and the type of work that was to be performed.
The inspectors reviewed the approved scaffold design because the scaffold was located near safety-related equipment. The inspectors noted that the height-to-base width ratio of the scaffold exceeded the 4-to-1 requirement for a freestanding p1atform, as specified in-the-licensee's Civil Standard Specification CSS-12, " Standard Specification for Tube and Coupler Scaffold
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l Construction." The inspectors verified that the licensee had braced the structure against the opposite wall, thus supporting the scaffold against
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displacement in the weak direction.
In addition, the inspectors reviewed the I
engineering evaluation that was performed when it was noted that a portion of the scaffold was within 6 inches of safety-related equipment, contrary to the requirements of Civil Standard Specification CSS-12. The evaluation, documented in a memo dated July 8,1993, made note that the scaffold configuration with the horizontal braces, as described above, complied with the intent of Fort Calhoun Station Calculation FC05434 and eliminated the
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spacing requirement in Civil Standard Specification CSS-12 in the direction of j
lateral support. The memo did specify that a minimum spacing of 1/2 inch
between the scaffold and any safety related equipment should be maintained.
Following the review, the inspectors concurred with the licensee's
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l The inspectors witnessed the erection of the scaffold and verified that it was in agreement with the design and guidance provided in the maintenance work
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order and per the requirements of Standing Order 50-M-35, " Scaffolding l
l Installation Control." No errors were noted.
t During the installation of the new drain piping, the inspectors interviewed
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I the craft personnel involved in the effort.
The inspectors noted that the knowledge of the maintenance personnel was very good with reference to their l
understanding as to the importance of this effort.
In addition, the l
licensee's adherence to personnel safety was notable. A review of the instructions provided in the maintenance work orders indicated that they were t
l general in nature but were well within the skill of the craft. Valve ~and equipment tagouts were verified to be accurate and complete. The maintenance l
personnel were observed to stop and contact quality control personnel when
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they reached quality control hold points in the procedure. The inspectors
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independently reviewed the final installation and concurred that both drain
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lines had been installed in accordance with the maintenance work order instructions. No errors were noted.
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4.2 4160 Volt Breaker Fast Transfer Voltage Measurement On July 16, 1993, the inspectors witnessed preventive maintenance activities being performed on the 4160 volt breaker fast transfer. This maintenance i
activity was controlled by Preventive Maintenance Order 9306159 and the associated procedure. The preventive maintenance order had been reviewed and approved as noted by the appropriate signatures.
The inspectors reviewed Procedure PM-EE-7-1, "4160 Breaker Fast Transfer Voltage Measurement," for technical adequacy and found it to be within the skill of the craft.
The work effort was performed in the control room and in each switchgear room.
The inspectors interviewed the licensee personnel and found them to be cognizant of their responsibilities. Good communications ~were noted between the technicians and control room operators. Good procedural compliance was noted throughout the activity.
4.3 Conclusions l
Communications and procedural compliance were found to be good. Knowledge
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displayed by the maintenance personnel in performing this effort clearly indicated that these activities were within the skill of the craft.
5 SURVEILLANCE OBSERVATIONS (61726)
5.1 Station Battery Chargers On June 21, 1993, the inspectors monitored the licensee's electrical maintenance personnel while they performed a monthly surveillance test on the
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l station battery chargers. This effort was being performed with the use of
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Surveillance Test Procedure EM-ST-EE-0009, " Monthly Surveillance Test for Station Battery Chargers." The inspectors reviewed the procedure for L
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-13-technical adequacy and verified that it had been reviewed and approved as noted by the appropriate signatures.
The surveillance test procedure was found to be very detailed and prescriptive in nature. The detail provided did not preclude the need for skill of the craft, for it did not provide instructions on the use of the instrumentation being used to take the appropriate measurements. The inspectors questioned the technicians and determined that they were knowledgeable on the proper use of the instrumentation being used and on the purpose of the test. The inspectors verified the calibration due date for the digital multimeter being used and reviewed the instrument's calibration documentation.
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One of the technicians performing the surveillance was a trainee, obtaining on-tha-job-training through the other technician who was qualified to perform this surveillance on this system, as noted by his training records. The
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inspectors noted that each step was being performed properly and in sequence with the qualified technician verifying-the actions taken by the trainee.
This continued until the technicians reached Section 7.30.2, which required that the power supply breaker for Battery Charger 3 be closed or that it be i
verified closed. This particular section of the procedure was a repetition of the same instructions provided in Section 7.7.2.
The location of the power
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supply breaker was not contiguous to the area where the technicians were working. The qualified technician explained to the trainee that they would not need to verify that the breaker was closed because they had already done it before and that there was no chance ti;at it had been altered in the
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meantime. The inspectors question the technician as to whether that would be
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contrary to the procedure instructions. The technician explained that in actuality there was local indication at the battery charger cabinet that provided him the capability to verify that the power supply breaker was closed without having to visually inspect the breaker. The inspectors raised the concern that this explanation is the one that should have been provided to the
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trainee because the previous explanation may lead the trainee to believe that there are procedural steps where it is acceptable for.a technician -to do,
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something other than what is instructed. This observation was discussed with licensee management for their review and any actions they deemed necessary.
The inspectors reviewed the control room operators log, noting that the appropriate Technical Specification limiting condition for operation had been entered during the performance of the surveillance test.
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5.2 Conclusions Procedural compliance was found to be very good.
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F 6 FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS AND A DEVIATION (92702)
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6.1 (Closed) Violation 285/9211-01:
Licensee Personnel Standina l
on Critical Quality Element Piping l
This violation resulted from the licensee's failure to take adequate
corrective action after a similar event. On February 27, 1992, while removing i
pipe insulation from the chemical and volume control system, licensee contract-
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personnel were found to be using lower system piping as a support to reach
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piping located at a higher level. This was' contrary to the instructions provided in Standing Order 50-M-100, " Conduct of Maintenance," and the Fort.
Calhoun Station Safety Manual. The licensee documented the event in
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Corrective Action Report 92-044 and provided' verbal instruction to all
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licensee and contract craft personnel on the Fort Calhoun Station policy
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regarding walking on piping. On May 12, 1992, a licensee contract personnel
working on the chemical and volume control system installing insulation on piping was identified using piping as a support structure to reach a higher l
pipe.
i The licensee determined that the root cause of this event'was carelessness by
the craftsman in question. He' had been fully aware of plant policy and i
limitations for stepping on piping through receipt of a briefing on i
February 28, 1992.
In addition, the licensee identified as a possible contributing factor the Fort Calhoun Station policies and procedures that
contain the limitations for standing and climbing on piping..Upon review,
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these policies and procedures were found to provide inconsistent guidance on
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when it was appropriate to stand on piping or cable trays.
j The immediate corrective actions taken by the licensee included counseling the craftsman and his direct supervisor and performing an engineering evaluation l
to determine the condition of the piping that the craftsman had stepped on.
Other corrective actions taken by the licensee included:
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The Fort Calhoun Safety Manual was revised to provide a clear policy for
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personnel climbing and standing on piping, conduit, and cable trays.
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Standing Order M-100, " Conduct of Maintenance," and Standing Order 0-1,-
" Conduct of Operations," were revised to reference the directions given
in the Fort Calhoun Station Safety Manual.
l Standing Order G-6, " Housekeeping," and Standing Order G-78,
" Observation Program," were revised to add direction for supervisors.to increase their awareness on expectations related to this issue.
Following the changes made to the standing orders listed above, the
training department issued required reading."Hotlines." Also, followup
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training wus provided to appropriate personnel.
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P Station policy for climbing and standing on piping, conduit, and cable
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trays was incorporated into general employee training.
The inspectors reviewed documentation for the completion of the corrective actions taken by the licensee.
Based on the review performed by the inspectors, it appeared the licensee had taken appropriate actions to preclude repetition of this event.
6.2 (Closed) Violation 285/9210-01:
Failure to Maintain Adeauate Procedures for Containment Sump Level Calibration An NRC inspection in April 1992 determined that narrow-range containment sump level instruments, LT-599 and LT-600, had not been calibrated by the method stated in the Technical Specifications.
In 1990 an NRC inspection had identified the same concern with the calibration of these instruments. The calibration procedures were revised in response to that inspection finding to include the Technical Specification requirement. However, during the 1992 refueling outage, the procedures were revised again and the Technical Specification requirement that had been previously added was deleted.
During the April 1992 inspection, Surveillance Procedures IC-ST-WDL-0001,
" Channel Calibration of Containment Sump Level Loop L-599," and Procedure IC-ST-WDL-0002, " Channel Calibration of Containment Sump Level Loop L-600," were revised (Revisions 11 and 8) to once again incorporate physical measurement of the containment sump level. The licensee also added a caution note to the procedures stating that changes should not be made without Plant Review Committee review of the Technical Specification requirement.
Ia addition, the licensee performed the surveillance test to the revised procedures.
The licensee's response to the Notice of Violation dated June 22, 1992, contained corrective action steps to ensure the violation would-not recur.
The corrective actions included:
(1) performing a root cause analysis; (2) issuing a memorandum to all members of the Plant Review Committee and Nuclear Safety Review Group emphasizing-the need to perform a thorough review-of procedure revisions to insure compliance with the Technical Specifications; (3) revising Procedure NOD-QP-3, "10 CFR 50.59 Safety Evaluations," to provide additional guidance in determining Technical Specification compliance; and (4) revizw of other float level calibration procedures to determine if revisions were necessary to clarify the method of calibration required by the Technical Specifications.
NRC Inspection Report 50-285/92-30 reviewed the status of corrective actions to address the conditions leading to the violation and determined that the first three actions stated above had been implemented satisfactorily.
The last corrective action item included a review of all other float level calibration procedures to ensure Technical Specification compliance.
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Action Item 4 above was tracked by the licensee as Commitment
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Identification 920573 and had a scheduled completion date of December 31, t
1992. During this inspection period, the licensee provided documentation in i
the form of a letter from a contractor dated December 22, 1992, stating that this review had been performed. The review determined that float level type r
indicators or alarms were installed for the safety injection and refueling water tank, safety injection tanks, boric acid tanks, and the containment
i sump. After the applicable installations were determined, the review identified all applicable surveillance. test and calibration procedures and determined that these procedures were in compliance with the facility license requirements. The inspector reviewed the licensee's. corrective actions and four.d them acceptable.
7 ONSITE REVIEW OF i.ICENSEE EVENT REPORTS (92700)
7.1 (Closed) Licensee Event Report-92-030:
Failure to Satisfy Fire Watch Reauirements for Inoperable Fire Barrier-This licensee event report addressed an event in which a member of-the licensee's craft personnel. failed to adequately complete Fire Protection Impairment Permit 2938 for an inoperable fire barrier. :The craft personnel posted the permit at the fire barrier, as required, without all the appropriate approval signatures and with its attendant copies.
Fire. Barrier-Penetration 19-E-30, connecting the turbine ~ building and Room 19 of the auxiliary building, was breached to support maintenance on a component cooling water / raw water heat exchanger. The documentation error resulted in a failure to notify the operations shift supervisor and the security shift supervisor, i
who were to sign.and. receive the attendant copies of Fire Protection Impairment Permit 2938, of the existence of an. inoperable fire barrier. Thus, an hourly fire watch was not assigned to monitor that specific fire barrier,
as required by the Technical Specifications. An hourly fire watch patrol
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assigned to monitor an inoperable fire barrier between Room 18 and Room 19, which was in the direct vicinity of: Fire Barrier Penetration 19-E-30; did not-
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i identify the permit for Fire Barrier Penetration 19-E-30.
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This event was not determined to be significant with respect to plant safety.
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During the event, the fire detection and alarm and suppression systems were operable for the areas.in which the fire barrier was breached. The hourly fire watch specified in Technical Specification 2.19(7)1provides a means of supplementing this system sinc _e the breach included a ~ safety-related area.
However, the primary means of detection, the installed fire detection system, remained available and provided continuous-monitoring of the affected area.
The licensee. determined that the root cause of this event was inappropriate actions and a lack.of attention to detail.
The licensee's corrective actions included:
i The responsible crafts person was counselled on the ~ event.
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j Refresher training was provided to fire watch qualified personnel, which
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discussed the specific responsibilities.of the fire watch with respect'
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to Standing Order G-58 " Control of Fire Protection System Impairments-"
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The inspectors reviewed documentation for the completion of the corrective l
l actions taken by the licensee. Based on the review performed by the j
l inspectors, the licensee had taken appropriate actions to preclude repetition
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7.2 (Closed) Licensee Event Report 285/93-03:
Failure to Satisfy Inservice
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Testino Requirement for Raw Water Pump l
l The licensee submitted this report to document a failure of. the Inservice
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Testing Program to implement more frequent-testing when required.,0n -
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November 2,1992, the quarterly test of Raw Water. Pump AC-10A determined that'
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the pump was performing in the alert range'.
For test values'in the alert
i range, the inservice testing program required that.the test frequency be j
doubled until the cause of deviation was determined and the condition.
corrected. On January 26, 1993, the licensee. discovered that the time limit -
for performing the next. test (in accordance with the increased frequency
requirement), or completing corrective actions, had been exceeded.
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A root cause analysis for this event determined that there were inadequate l
administrative controls to ensure that test frequency was adjusted.or-
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corrective maintenance implemented to resolve the problem in a timely manner.
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A review of records revealed that licensee personnel had. initiated a
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maintenance work request to correct the deviation. However,-the corrective-
maintenance was scheduled for performance on January 25,.1993.. Surveillance f
testing or corrective maintenance and retesting should have been completed by
December 29,.1992.
To preclude recurrence of missed surveillances because of inadequate j
administrative controls, the licensee revised two procedures and instituted-
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- new policy regarding the database used by the surveillance. test. coordinator to l
L schedule surveillance testing.
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Standing Order M-101, " Maintenance Work' Control," was revised to require-a.,
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review of applicable work-requests by a technical reviewer to! address special requirements and precautions to ensure compliance with license limiting l
condition for operation. requirements and ASME Section XI requirements.
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Station Engineering Instruction SEI-14, " Surveillance' Testing," was revis'ed to i
require system engineering to provide guidance.on~ meeting-limiting conditions
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for operation and ASME Section XI requirements for-anomalies identified.during-
~ testing. Additionally,- a step was added 'to. Instruction SEI-14.that instructed the surveillance test coordinator to increase!the surveillance testing frequency whenever an ASME Section XI component's performance' test data falls;
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in the alert range. - This requirement was implemented by requiring the.
surveillance testing frequency to be changed in the tracking data as-soon as the condition was identified. This action will automatically' result in
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testing being scheduled at the increased frequency until such time that corrective action addressing the component performance is completed and documented.
The inspectors concluded that the licensee's actions would preclude future missed surveillances when ASME Section XI testing performance data falls into the alert range.
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O ATTACHMENT
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I 1 PERSONS CONTACTED 1.1 Licensee Personnel
- R. Andrews, Division Manager, Nuclear Services J. Chase, Manager, Fort Calhoun Station
- G. Cook, Supervisor, Station Licensing
M. Frans, Supervisor, System Engineering
- S. Gambhir, Division Manager, Production Engineering
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- J. Gasper, Manager, Training
- K. Holthaus, Manager, Nuclear Engineering
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- R. Jaworski, Manager, Station Engineering
- T. Patterson, Division Manager, Nuclear Operations
- W. Ponec, Manager, Nuclear Administrative Services
- A. Richard, Assistant Manager, Fort Calhoun Station
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- J. Sefick, Manager, Security Services
- R. Short, Manager, Nuclear Licensing and Industry Affairs C. Simmons, Station Licensing Engineer J. Tills, Operations Supervisor
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- Denotes personnel that attended the exit meeting.
In addition to the personnel listed above, the ;. spectors contacted other personnel during this inspection period.
2 EXIT MEETING An exit meeting was conducted on July 20, 1993. During this meeting, the inspectors reviewed the scope and findings of the report.
The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.
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