IR 05000285/1996016

Insp Rept 50-285/96-16 on 961117-1228.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20133P034
Person / Time
Site:	Fort Calhoun
Issue date:	01/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133P031	List: IR 05000285/1996016 ML20133P027
References
50-285-96-16, NUDOCS 9701240064
Download: ML20133P034 (27)

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. i ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket No: 50-285 i License No: DPR-40 l Report No: 50-285/96-16 Licensee: Omaha Public Power District l Fort Calhoun Station FC-2-4 Ad '

P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska ,

l Facility: Fort Calhoun Station Location: Blair, Nebraska

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Dates: November 17 through December 28,1996 inspectors: W. Walker, Senior Resident inspector V. Gaddy, Resident inspector G. Good, Senior Emergency Preparedness Analyst R. Mullikin, Acting Senior Resident inspector Approved: W. D. Johnson, Chief, Project Branch B ATTACHMENTS:

Attachment 1: Supplemental Information Attachment 2: Questions Related to 10 CFR Part 50, Appendix R Attachment 3: 10 CFR Part 50, Appendix R, Section lll.0, White Paper Review Attachment 4: FCS FP Configuration Report l

9701240064 970117 PDR ADOCK 05000285 G PDR

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EXECUTIVE SUMMARY l Fort Calhoun Station

NRC Inspection Report 50-285/96-16 l i This routine announced inspection included aspects of licensee operations, engineenng, maintenance and plant support. The report covers a 6-week period of resident inspection.

Ooerations *

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An unresolved item was identified regarding oil leakage in and around Reactor !

Coolant Pump RC-3D. The inspectors also identified three questions concerning the

!{ adequacy of the reactor coolant pump lubrication oil collection system and its

!- compliance with the requirements of Section 111.0, Appendix R,10 CFR 50

(Section 02.1).

! The inspectors determined appropriate controls were followed during performance i of a concurrent verification and that the licensee tagged out the proper components l to remove a containment cooling fan from service (Section 02.1 and 02.4).

• An inspection followup item was identified regarding the actions of the corrective

action review group and the corrective action program procedure requirements for i reportability. determinations (Section 06.1).

j' * The inspectors noted that several Technical Specification interpretations made reference to the NRC which may give the appearance of NRC endorsernent. The inspectors requested that the licensee remove any reference to NRC involvement from the Technical Specification interpretations (Section 08.1),

i Raintenance  ;

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• Maintenance activities observed were generally completed thoroughly and professionally. However, maintenance, engineering, and operations personnel exhibited a lack of a questioning attitude following a postmaintenance test on Auxiliary Feedwater Pump FW-6. The oil level in the external oil bulb reservoir was observed to be empty and no oil was immediately added (Sections M1.1 and M1.2).

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• The inspectors reviewed the temporary modifications to the component cooling I water system and verified, where possible, that actions required by the temporary modifications were implemented (Section E1.1)

Plant Support i

• Several maintenance workers were unf amiliar with the guidance for securing j vacuum cleaners that contain internal contamination (Section R1.1).

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The inspectors determined that the onshift dose assessment capability was not clearly described in the emergency plan and implementing procedures (Section P3.1).

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Report Details Summary of Plant Status j At the beginning of the inspection period the Fort Calhoun Station was near the end of its 16th refueling outage. On November 25 the reactor was made critical to start low power physics testing. The outage ended on November 27 with the closing of the output breakers. The plant reached 100 percent power on December 17 where it remained throughout the duration of the inspectio I. Operations 01 Conduct of Operations 01.1 General Comments (71707)

The inspectors frequently observed ongoing plant operations. In general, the conduct of operations was professional and safety-conscious. The inspectors noted effective implementation of management performance expectations during mcst observation Specific events and noteworthy observations are detailed in the sections belo O2 Operational Status of Facilities and Equipment

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O2.1 Containment Walkdown

Inspection Scoce (71707)

On November 11,1996, the inspectors performed a general walkdown of containment. Specific observations were made of the four reactor coolant pump oil collection system. . Additionally, the inspectors observed a concurrent verification performed by quality control personnel on a pressurizer valve manipulatio Observations and Findinos During the general containment walkdown, the inspectors observed what appeared to be a 2 foot by 2 foot piece of woolinsulation secured to a cable tray at the 1025 foot elevation of containment. The inspectors discussed this with design engineering and were informed that this insulation had been evaluated as part of a review conducted concerning NUREG-0897, Revision 1, " Containment Emergency Sump Performance" and no concerns were identifie Also, during th'e walkdown, the inspectors expressed concern regarding oil leakage in and around Reactor Coolant Pump RC-3D. The inspectors observed an oil film over most of the reactor coolant pump motor anc' in the area surrounding the reactor coolant pump motor. In addition, opproximately 1 qusrt of oil was pooled on the floor. The leakage was identified as coming from the upper oil reservoir which has a capacity of approximately 120 gallon The inspectors discussed the leakage mechanism with the system engineer and were informed that during the first several days of operation, the oil level was observed to drop rapidly from 78 percent to approximately 76 percent where it i

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! appeared to stabilize and then decrease more slowly. The licensee has

determined that the oil level can drop to 73 percent in the upper oil reservoir

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before oil must be added to protect the upper guide bearing. The licensee has

, issued instructions to add only 3 or 4 gallons of oil at a time to bring the level i up to 76 percent when the low level (73 percent) is reached. The system ,

l engineer stated that this would help reduce the rate of oilleakage and the fire I L loading inside containment caused by the leakage.

. The inspectors questioned the licensee regarding the increased potential for a fire j inside containment due to the lube oillost from Pump RC-3D. The licensee i responded that the additional combustible materialinside containment was within the

. bounds of the containment analysis which took into account an additional 1 combustible loading of 395 gallons of _ oil. In addition, maintenance personnel

} observed during the outage that the oil lost during the last cycle had not soaked into

! the insulation around the pump casing or piping, which could expose it to high j temperatures in excess of the oil's flash point of 400 F.

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On December 20, a conference call was held between NRC staff and the  ;

j licennee and, based on that call, additionalinformation concerning reactor j j- coolant pump oilleakage and compliance with 10 CFR Part 50, Appendix R,  !

requirements was requested by the NRC staff. Attached to this report is a l

! summary of the issues leading up to and discussed during this conference cal ]

in addition, two OPPD documents which bear upon this issue are enclose l r Three questions concerning how OPPD complies with the requirements of ]

Section 111.0, Appendix R to 10 CFR Part 50 are included in Attachment 2. It is i

] requested that OPPD provide the NRC with a response to these concern l

i Additionally, during the walkdown the inspectors observed a concurrent j verification being performed during isolation of Pressurizer Pressure  !

Transmitter PT-103x. The inspectors reviewed Standing Order SO-O-37, '

i " Independent Verification of Critical Systems Component Positioning,"

! Revision 13, and determined that appropriate controls were used during the  ;

} isolation of the pressure transmitte i

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c. Conclusion l I l j The inspectors concluded that the licensee's increased monitoring and operating

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contingencies based on continual trending of Pump RC-3D oillevels would provide

information concerning amounts of oil collected inside containment. Pending NRC j staff review of additional information to be provided by the licensee, compliance with ( Section 111.0 of 10 CFR Part 50, Appendix R, will be tracked as an unresolved item

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02.4 Verification of Danaer Taaouts insoection Scope (71707J The inspectors verified that the danger tagouts established to perform maintenance '

on Containment Cooling Fan VA-7C were constructed to ensure the equipment was properly isolate Observations and Findinas The inspectors reviewed the tagouts that had been established to remove the cooling fan from service. The inspectors verified that the tagout had been properly prepared and authorized. The inspectors also verified that the tagged components were in their required positions with the appropriate tags in place. The licensee also had met all the Technical Specification requirements for the inoperable cooling fa Conclusions The inspectors concluded that the licensee had adequately prepared and tagged out l the proper components to remove the containment cooling fan from service.

l 06 Operations Organization and Administration 06.1 Untimelv Reportability Determinations Insoection Scope (71707)

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The inspectors reviewed a list of condition reports with open reportability determinations.

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On November 27,1996, the inspectors reviewed a list of open condition reports with outstanding reportability determinations and questioned why the determinations had l not been made. Condition Report 199601355, dated October 21,1996, requested a

! reportability determination on containment isolation actuation override switches that i did not spring return to normal as designed. Condition Report 199601392, dated November 5,1996, requested a reportability determination on the incorrect bolts installed on Heated Junction Thermecouple YE-116A/B. Condition '

Report 199601444, dated November 13,1996, questioned the seismic qualification of Class 1E 4160 VAC breakers while in the racked down position.

! The inspectors learned that Condition Reports 199601355 and 199601444were

! completed on November 5 and November 22,1996, respectively, and were

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determined not to be reportable. Engineering completed these reportability

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determinations but did not inform the corrective action group of the results. The

! inspectors also learned that the reportability determination for Condition l Report 199601392 was still ope .l

The inspectors reviewed Revision 6 of Procedure PED-OP-19, " Evaluation of I Potentially Reportability Conditions," and noted that the reportability determination j should be made in a timely, prr mpt manner. The licensee indicated that the j reportability determination for Condition Report 199601392Was not promptly

completed due to an oversight. This condition report was determined not to be - ,

j reportable on December 23,199 j a.

! After additional questions by the inspectors, the licensee initiated an investigation j

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and identified additional deficiencies in their reportability process. The licensee

identified that Procedure PED-OP-19 did not require that the plant review committee i

review reportability determination:. The licensee also determined that Standing Order SO-R-2, " Corrective Action Program," contained unclear guidance. The l l guidance stated that, in cases where reportability was unclear, the determination j

{' shall be presented to the plant review committee for a final determination. The !

} condition review group interpreted this step as a requirement for all reportability j

] determinations to be presented to the plant review committee for final revie '

Historically, both reportable and nonreportable determinations were presented to the j plant review committee for a final reportability decision. The licensee determined j that 18 reportability determinations had not been presented to the plant review i committee for a final reportability determination. Of the 18 identified by the licensee,

all were subsequently determined to be nonreportable.

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~ Standing Order SO-R-2 also required that in accordance with a commitment for I Licensee Event Report 93-05, a copy of open reportability issues would be routed to the plant review committee weekly. The licensee determined that this was not being l performed. In response, the licensce indicated that the basis for this commitment wculd be reviewed to determine if it still needed to be performe l l

An inspection followup item was opened pending additional NRC review of the I corrective action review group and the corrective action program requirements for i reportability determinations (50-285/96016-02).  ! Conclusions The inspectors concluded that the licensee was not prompt in performing a )

reportability determination for the incorrect bolts installed on a heated junction thermocouple. Following discussions with the inspectors, the licensee identified that all reportability determinations were not being provided to the plant revie'n committee for a final determination. Also, a commitment to provide open reportability issues to the plant review committee was not being performe Additional NRC review during the next inspection period will be perforrne ,. . -.. .. ~ . - - . - - . _ . - . - . - - - - - - - . - - - - ~ . - ~ . . .

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08 Miscellaneous Operations issues  !

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08.1 Review of Technical Specification Interpretations f

Recent observations of licensee Technical Specification interpretations and some !

particular practices concerning implementation have highlighted the need for a review '

of Technical Specification interpretations and clarification regarding the NRC l recognition of Technical Specification interpretations. The NRC considers a Technical i

, Specification interpretation as an interpretation developed by the licensee without '

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l consent or review by the NRC.

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The NRC does not endorse or recognize licensee Technical Specification interpretations since Technical Specification interpretations are not legal documents and have no legal authority regarding plant operations. Based on the inspectors review, two Technical Specification interpretations were identified which may have i the appearance of NRC endorsemen * Technical Specification Reference 2.7, Technical Specification >

Interpretation 92-13 f

• Technical Specification Reference 2.10.1(4), Technical Specification Interpretation 94-13 '

! These Technical Specification interpretations may give the appearance of NRC endorsement which is not an acceptable practice. The inspectors requested that the hcensee remove any references to NRC involvement from the Technical Specification interpretations, 11. Maintenance M1 Conduct of Maintenance M 1.1 Raw Water Strainer inspection Inspection Scone (62707) l On December 5, the inspectors observed portions of the following maintenance I activities performed on Raw Water Strainer AC-12A: )

• Inspection of strainer cones for plugging j * Adjustment of strainer to housing clearance i

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l-6- Observations and Findinas The inspectors observed that the work packages were present at the job locatio Specifically, the inspectors noted that Preventive Maintenance Order 9600701 work package included a description of the as found condition of the strainer cones, the tagout, and the as found strainer to basket housing clearanc With regard to the strainer, no clogging or damage was observed. The inspectors

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noted that the technicians rotated the strainer basket one full revolution to observe

all strainer cones. The technicians also adjusted the strainer basket to housing ;

clearance as specified in the work instruction l l Conclusions l

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The inspectors found that the work activities were conducted in accordance l with procedures. The work packages provided to the technicians were I

complete and the as found and as left conditions were properly documente j i

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M1.2 Auxiliary Feedwater Pomo Decreased Oil Level inspection Scoce (62702) l The inspectors performed an investigation into the decreased oil level on the motor l

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driven auxiliary feedwater pump following routine preventive maintenance.

a Observations and Findinas On December 5,1996, the licensee performed two preventive maintenance activities

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on Motor Driven Auxiliary Feedwater Pump FW-6. Maintenance personnel changed and analyzed the pump oil and lubricated the pump couplings. The activities were authorized by Preventive Maintenance Orders 9600039 and 9600047,respectively.

i Following the completion of these activities, the licensee performed a postmaintenance test. Following the postmaintenance test, which lasted approximately 42 minutes, licensee personnel noticed that the external oil bulb reservoir was empty. However, oil still remained in the reservoir tube. After observing this <.ondition, neither maintenance nor operations personnel present added oil to bring the level to within its normal operating band. There also appeared to be some confusion between operations and maintenance as to which group was responsible for adding oil to the pump. After performing an inspection of the pump to verify no external oil leaks, the pump was declared operable and operations initiated a maintenance work request to add oil to the pum The following day, while reviewing the maintenance work request, the plant manager requested that an investigation be performed to determine why the oillevel had decreased during the postmaintenance test. During the investigation, the licensee

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-7-determined that the decrease in oillevel was caused by an air bubble that had shifted from inside the pump to the external oil bulb during the test. The licensee subsequently added oil to the pump and satisfactorily performed the postmaintenance tes The inspectors discussed this incident with the licensee. The licensee indicated that the preventive maintenance order used to perform the postmaintenance test would be changed to require that oil be added, as needed, following the postmaintenance tes Conclusions The inspectors concluded that maintenance, engineering, and operations personnel demonstrated a poor questioning attitude and accepted the oillevel being below the normal operating level. The licensee did not immediately initiate a condition report to document the reduced oil level. The plant manager exhibited leadership in directing that the cause of the decrease in oil level be determine M1.3 Surveillance Activities Inspection Scope (61726)

The inspectors observed portions of the following surveillance activity:

• OI ST-10, Attachment 14, " Turbine Tests, Control Valves" Observations and Findinas The inspectors noted that the surveillance was performed in accordance with procedures. The inspectors noted that the system engineer for the turbine was actively involved in monitoring the performance of the tes Conclusions The surveillance activity observed by the inspectors was completed in a controlled manner and in accordance with procedure M8 Miscellaneous Maintenance issues (92700) i f

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M1.1 (Closed) LER 50-285/96-002: manual reactor trip due to lowering I condenser vacuum. On March 29,1996, the plant was manually tripped due to a {

condenser tube leak. The damaged condenser tube had been discovered during a previous maintenance outage on March 15-25,1996. However, the tube was not repaired at that time. The licensee determined that the personnelinvolved in the discovery did not fully investigate the tube leak. The maintenance procedure used did not provido adequate instructions for documenting tube leaks. In addition, the

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postmaintenance test and provide direction on the actions to take if a tube is found l to be leaking. The inspectors reviewed the licensee's actions and found them to be l appropriat Ill. Enaineerina l

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E1 Conduct of Engineering E1.1 Containment Air Cooler Operabi!ity l Inspection Scope (37551)

On November 11,1996, during the refueling outage, a determination was made that the containment air coolers potentially would not function as required during a loss of coolant accident or main steam line break event coincident with loss of offsite power. The potential existed for an internal steam bubble to form in the containment coolers and upon restart of the component cooling water pumps the steam bubble l

would collapse and generate a water hammer inside the component cooling water piping, j Observations and Findinas Based on the licensee's analysis of the above event, a determination was made that component cooling water piping could potentially exceed the design limits for the piping and supports. The licensee was alerted to the potential for this event in Generic Letter 96-06, " Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Conditions," issued September 30,1996.

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The licensee reviewed the current component cooling water configuration and l determined several modifications were necessary prior to restart of the facilit These modifications were necessary to prevent the potential for flashing of water to l steam in the containment cooler The licensee determined that the potential for flashing in the coolers was bounded by the loss of coolant accident event, and that if the component cooling water surge tank pressure was maintained above 32 psig no flashing of water would occur. As a l result of maintaining a higher surge tank pressure, the setpoints of the component l cooling water surge tank relief valves were increased. The component cooling water surge tank high pressure alarm in the control room was changed to a tank low pressure alarm and a local surge tank pressure gauge was added to provide a l redundant indication of tank pressure, in addition, ten thermal relici valves which were identified as being susceptible to lifting at the increased surge tank pressure were gagge . . - . , - . - _ -- .-~ -.- - - - - - -. _ -._ -.-..

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-9-The inspectors discussed the Safety Analysis for Operability 96-02-00 with the lic.ensee. In addition, a partial walkdown of the component cooling water system was performed to verify that actions required by Temporary Modification 96-042 were implemented. No discrepancies were noted during the walkdown. The safety l analysis for operability remains in effect until a permanent resolution is implemented I prior to startup from the 1998 refueling outage. In addition,'the licensee is required to provide a response to Generic Letter 96-06 by January 199 ;

Conclusions i

The inspectors performed a preliminary review of the safety analysis for operability and the changes implemented by the temporary modification. The safety analysis for l operability and the related temporary modification appeared to constitute an appropriate temporary resolutio E2 Engineering Support of Facilities and Equipment

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! E2.1 Review of Uodated Safety Analysis Report Commitments A recent discovery of a licensee operating their facility in a manner contrary to the

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Updated Safety Analysis Report description highlights the need for a special focused I review that compares plant practices, procedures, and/or parameters to the Updated ;

! Safety Analysis Report descriptions. While performing the inspections discussed in 1 l

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this report, the inspectors reviewed the applicable portions of the Updated Safety ,

Analysis Report that related to the areas inspected. The inspectors verified that the !

Updated Safety Analysis Report wording was consistent with the observed plant practices, procedures and/or parameter E8 Miscellaneous Engineering issues (92903)

E8.1 (Closed) Violation 50-285/95024-02: inadequate design control measures resulted in an inadequate amount of trisodium phosphate (TSP) installed to meet the postaccident containment sump water design basis of a pH greater than 7.0. The licensee performed a root cause analysis and found that several opportunities had existed over time to discover that the amount of TSP was not in accordance with the design basis. The licensee attributed this to a lack of a

, questioning attitude. However, the licensee performed an operability analysis and I found that the amount of TSP installed was sufficient and that the TSP baskets were operable. The licensee's corrective actions included establishing a formal calculation I to apply to future TSP issues and adding the required amount of TSP during the recent refueling outage to establish a pH of 7.0. The inspectors concluded that the licensee had performed an excellent root cause analysis of the issue and had taken appropriate corrective actions.

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j IV. Plant Support ~

R1 Radiological Protection and Chemistry Controls l l I l R1.1 Tours of Radioloaically Controlled Area

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l Inspection Scope (71750)

) Throughout the inspection period, the inspectors performed routine tours of the

{ radiologically controlled area l

Observations and Findinas i

During routine tours of the radiologically controlled areas, the inspectors noted that licensee personnel were following all the radiological requirements. The inspectors

! questioned certain individuals regarding the contents of the radiation work permit

! that they were covered by while inside the radiologically controlled area. All-

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personnel were familiar with these requirements. Radiation protection personnel l were observed to be performing their jobs in a professional manner.

t i On November 26,1996, the inspectors noted that a large vacuum cleaner had been left unattended. The vacuum was labeled with an internal contamination sticker.

, The inspectors also noted that the end of the vacuum hose was not sealed. The i inspectors informed the licensee. The licensee informed the inspectors that the j vacuum cleaner was being used by maintenance personnel and that it should be

sealed when it was not in use. Rad ation protection personnel informed the

maintenance personnel of these requirements and the condition was corrected. No other similar incidents were observed during this report period.

1 Conclusions

! The inspectors concluded that the licensee personnel were knowledgeable of the l

, requirements of their radiation work permits and the radiation protection personnel j effectively performed their functions. The inspectors also concluded that several l i maintenance workers were unfamiliar with the requirements for securing vacuum I cleaners that contain internal contaminatio i \

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P3 Emergency Preparedness Procedures and Documentation l

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P3.1 Licensee Onshift Dose Assessment Capabilities (Tl 2515/134)

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l Using Temporary Instruction 2515/134,the inspectors gathered information l regarding: *

l Dose assessment commitment in emergency plan  ;

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Onshift dose assessment emergency plan implementing procedure

! * Onshift dose assessment training

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On December 17,1996, the inspectors conducted an in-office review of the j emergency plan and implementing procedures to obtain the information requested by

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the temporary instruction. The inspectors conducted a telephone interview with the i

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licensee on December 18,1996, to verify the results of the review. Based on the documentation review and licensee interview, the inspectors determined that the licensee had the capability to perform onshift dose assessments using real-time effluent monitor and meteorological data; however, the commitment was not clearly described in the emergency plan and implementing procedures, Conclusion

Although the onshift dose assessment capability existed, the commitment was not '

clearly described in the emergency plan and implementing procedures. Further evaluation of the inforrnation obtained using the temporary instruction will be conducted by NRC headquarters personne V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the exit meeting on January 2,1997. While licensee management acknowledged the findings presented, several clarifying questions were asked regarding Technical Specification Interpretations and the appearance of NRC endorsemen The inspectors asked the licensee whether any materials examined during the

' inspection shou'd be considered proprietary. No proprietary information was identifie I

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ATTACHMENT 1

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

i Licensee

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R. Andrews, Division Manager, Nuclear Services

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G. Bishop, Assistant Plant Manager j C. Brunnert, Manager, Quality Assurance and Quality Control j 1 G. Cook, Supervisor, Station Licensing  !

i R. DeMeulmeester Jr, Shift Supervisor i i D. Dryden, Licensing Engineer l

l T. Dukarski, Acting Manager, Chemistry

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H. Faulhaber, Manager, Maintenance

S. Gambhir, Division Manager, Production Engineering

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R. Jaworski, Manager, Design Engineering, Nuclear D. Leiber, Supervisor, Security Support Services R. Phelps, Manager, Station Engineering R. Short, Manager, Operations M. Tesar, Manager, Corrective Action Group J. Tills, Manager, Nuclear Licensing D. Trausch, Manager, Nuclear Safety Review Group R. Wylie, Manager, Nuclear Construction NRC V. Gaddy, Resident Inspector '

W. Walker, Senior Resident Inspector j INSPECTION PROCEDURES USED Tl 2515/134: Licensee Onshift Dose Assessment Capabilities IP 37551: Onsite Engineering IP 61726: Surveillance Observations IP 62703: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92902: Followup - Maintenance IP 92903: Followup - Engineering

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-2-LIST OF DOCUMENTS REVIEWED Emeraency Plan Imolementina Procedures EPIP-OSC-2 Command and Control Position Actions / Notifications Revision 31 EPlP-EOF-6 Dose Assessment Revision 26 EPIP-EO F-7 Protective Action Guidelines Revision 12 EPIP-RR-25 TSC/ EOF Dose Assessment Coordinator Actions Revision 17 l Other Documents Fort Calhoun Radiological Emergency Response Plan, Revision 21R1 ITEMS OPENED AND CLOSED i

Opened '

50-285/96016-01 URI Reactor Coolant Pump RC-3D lube oil leakage (Section 02.1)

l 50/285/96016-02 IFl corrective action program procedure requirements for i reportability determinations (Section 06.1)

Closed 50-285/96002 LER manual reactor trip due to lowering condenser vacuum (Section M1.1)

50-285/95024-02 VIO Inadequate design control as pertains to amount of trisodium phosphate inside containment (Section E8.1)

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ATTACHMENT 2 OUESTIONS RELATED TO 10 CFR PART 50, APPENDIX R Backaround Coring a routine walkdown of containment, the resident inspector identified a concern regarding the pooling of tube oil beneath Reactor Coolant Pump D. As followup to this concern, the resident inspector obtained a copy of two Omaha Public Power District documents - a " White Paper Review of the Requirements of 10 CFR Part 50, Appendix R, Section lil.0," dated August 9,1996, and a " Fire Protection Configuration Report for the Lube Oil Leak on Reactor Coolant Pump D," dated July 6,1995. The first document described the OPPD investigation into the reactor coolant pump lube oil collection system configuration and summarized the current design basis of the existing reactor coolant pumps. The second document addressed the loss of tube oil inventory from Reactor Coolant Pump D during power operation The NRC's review of these documents was discussed with the OPPD staff in a telephone conversation between Mr. Chris VanDenburgh, of the NRC, and Mr. Goeff Cook, of OPPD, on December 20,1996. During that telephone call, OPPD staff indicated that Fort Calhoun Station had been granted an exemption to the lube oil collection requirements of 10 CFR Part 50, Appendix R, Section 111.0, for the upper and lower oil reservoirs. The OPPD staff explained that the basis for the exemption was that the upper reservoir was internal to the ;

reactor cooiant pump and could not be easily collected and the lower reservoir was of low 1 pressure design and, therefore, was unlikely to leak. The white paper indicated that this I condition was accepted by the NRC in a Safety Evaluation Report that approved I Amendment No. 53, dated November 17,198 In addition, the white paper indicated that the NRC had opened an unresolved item in a 1988 resident inspection report concerning whether the present system complied with Section 111.0 of Appendix R and whether an exemption was required. The white paper indicated that the Omaha Public Power Division had submitted an exemption request which addressed this issue on November 28,1988, in LIC-88-1066. Attachment 2 to that request responded to verbal questions regarding the requirement to contain lobe oil from unpressurized points. These responses indicated that Omaha Public Power District did not believe they were required to collect leakage from unpressurized internal sources or from high pressure piping where lube oilleakage was not considered credibl Current Problem i

10 CFR Part 50, Appendix R, Section Ill.O requires the collection of all potential

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pressurized and unpressurized leakage sites in the reactor coolant pump lube oil syste The lack of oil collection capability for the upper and lower reactor coolant pumps oil

, bearing reservoirs and the observed leakage of oil onto the reactor building floor from l

! reactor Coolant Pump D does not appear to comply with Appendix R. Separately, it

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appears that Omaha Public Power District misinterpreted the Safety Evaluation Report for

! Amendment 53,in that the exemption which was approved was only to limit the volume of i

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l-2-the oil collection tank to that of one ceactor coolant pump. It did not approve a total exemption from the oil collection requv nients for high pressure and low pressure leakage point Finally, the white paper indicated that a recent modification to Reactor Coolant Pump B had 4 modified the physical configuration of the lube oil system as described in LIC-88-106 l The difference is that there is now a larger lower bearing tube oil reservoir, and the new l configuration uses a sightglass on the lower motor bearing reservoir that is not collecte '

Thus, the Safety Evaluation Report for Amendment 53 does not address the current reactor coolant pump configuratio Action i l

In light of the above information, the NRC questions whether the reactor coolant pumps have adequate fire protection. In order to further assess the acceptability of the existing configuration, additional information is neede j l

NRC's understanding of the fire protection requirements of Appendix R appears to differ from OPPD's as it relates to the potential reactor coolant pump lube oilleakage sources )

that must be collected. The white paper and associated documentation on this subject l does not clearly articulate how the Fort Calhoun Station meets these regulatory requirement The NRC staff proposes the following questions: Provide a comprehensive discussion of how Omaha Public Power District meets the fire protection requirements of Appendix R as it relates to lube oil collection systems in the reactor coolant pumps. This discussion should describe the previous and current plant configuration and detail the scope and basis of any regulatory exemptions that have been grante . The white paper indicates that Omaha Public Power District has recently modified Reactor Coolant Pump B, which has resulted in a physical configuration of the lube oil system that is different from the other pumps. Provide a description of the new configuration of the lube oil systern for reactor coolant Pump B and how Omaha Public Power District has addressed the differences as they relate to the applicability of the exemption request in LIC-88-106 . Describe the compensatory measures that Omaha Public Power District has taken (or plans to take) to prevent any further lube oil leakage from the upper bearing of Reactor Coolant Pump D. In addition, provide a detailed description of the present fire hazard that exists in this pump due to the previous uncollected lobe oil leakag . . . . . _ . _ . _ _ _.. -_. _ _._ ___., . _ _ _. _ __ __ _....-.. _ . _ - _ _ . _ - . _

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ATTACHMENT 3

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10 CFR 50, APPENDIX R, SECTION 11 .

WHITE PAPER REVIEW  :

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10CFR50, APPENDIX R, SECTION II WHITE PAPER REVIEW August 9,1996

Issue Statement

, While performing a fire protection interaction review for MR-95-022, RCP Motor Replacement, existing FP license basis documents were examined for impact. SER (LIC88-G457, dated l

12/20/88) regarding an exemption to 10CFR50, Appendix R, Section III.O (RCP Lube Oil Collection) appears to contain an error. An excerpt from section 3.0 of the Safety Evaluation reads:

"The licensee indicated that oil piping that is unpressurized is either internal to the reactor coolant pump (RCP) motor bearing assembly or qualified to withstand the elevated pressures anticipated during a seismic event."

This appears to be a read back combination of OPPD responses to Staff concerns regarding the exemption request. The purpose of this document is to determine the current status of RCP Lube Oil design basis and any impacts due to MR-95-022.

Scope This document will be limited to the following:

• investigate and summadze the original RCP Lube Oil Collection configuration e summarize the current design basis on the existing RCP's e evaluate MR-95-022 impacts to the existing configuration / exemption basis e recommend a course of action regarding 10CFR50, Appendix R section II existing design basis-MR-95-022 impacts

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Actions Taken Reference Documents Reviewed:

1) 10CFR50, Appendix R, Section II ) Original FP Program Submittal, LIC-76-0180, dated 12/31R6 3) Original Program SER, LIC-78-0104, dated 8/23D8 4) Design Package Submittal, LIC-79-0059, dated 6/6D9 5) NRC Triennial Inspection Report, LIC-88-880, dated 9/23/88 6) OPPD Exemption Request, LIC-88-1066, dated 11/28/88 7) NRC Exemption to Appendix R, III.0, LIC88-457, dated 12/20/88 8) MR-95-022. " Reactor Coolant Pump Motor Replacement"

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RCP motor lube oil collection requirements date back at least to the NRC's Fire Protection Guidelines of Appendix A to APCSB 9.5-1 (1976). OPPD's original FP program submittal j (12/31n6) acknowledges RCP lube oil as a ' major combustible'. The submittal goes on to j

evaluate a 15 minute fire burn in Containment resulting from the combustion of the total inventory of lube oil from one RCP (150 gal.). The evaluation concludes that a burn of this magnitude would not jeopardize safe shutdown. This evaluation is referenced by OPPD as meeting the l Appendix A, ' Control of Combustibles' mandate [per section D.2(a)]. *

The SER granted to OPPD in regard to the 1976 submittal, dated 8/23R8, lists the RCP Lube Oil Collection System as an ' Incomplete Item'. The SER went on to document that OPPD committed to respond to the issue by June 1979. It is assumed that correspondence between OPPD and the NRC took place between the 1976 submittal and the 1978 SER. Documentation of this communication has not been retrieve OPPD submitted a Final Design Package of MR-78-057,"RC Pump Lube Oil Collection" to the NRC 6/6n9 (LIC-79-0059). The key passage in this submittal is as follows:

"The lower oil reservoir is not being collected since it contains only four (4) gallons, has an internal oil cooler and there are no pressurized lines, sight glasses, etc. Also, the oil level transmitter is not contained since the transmitter housing has a pressure rating of 500 psig and it is only exposed to 17 inches of oil.".

The cover letter to this submittal indicates the NRC was to review and approve the modification prior to installation. The NRC documented acceptance of this configuration in Amendment # 53 to the FCS license dated i1/17/8 The RCP Lube Oil Collection System was again reviewed by the NRC in 1988 during a triennial FP inspection. The results of this inspection (LIC-88-880) once again listed the oil collection system as an " unresolved item" The following excerpt was taken from Section 4. of the report:

"Since the oil collection system, including collection pans, drain lines, and collection tanks has enough capacity to hold all of the oil from the pumps, there appears to not be a safety concern. However, the present system does not comply with Section III.O of Appendix R and an exemption is required."

OPPD filed an exemption request with the NRC 11/28/88 (LIC-88-1066). Attachment 2 to the exemption request responded to three questions raised during a phone conversation held 11/25/88. The third question / answer is as follows:

"OPPD states that the system will contain oil from pressurized points. What about unpressurized points?

Answer The oil piping that is unpressurized is either internal to the motor bearing assembly or of such a high pressure rating that oil leakage is not considered a credible event. The total volume of the unpressurized oil system in the lower bearing assembly is only four gallons

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e per pump. The entire upper bearing assembly is provided with collection capacity with the exception of the level transmitters which are rated at 500 psig."

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It should be noted that question # 2 regarded seismic design capability of the collection system.

i The responding NRC exemption SER contained the read back error as discussed in the introduction of this documen l l liv _ahalis l l

l Key Points

• RCP Oil Collection System installed per MR-78-057 was reviewed and approved by the l

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• l l NRC Appendix R audit repon categorized the FCS RCP oil collection system ,

l configuration deviations as 'not safety significant* l

• The new pump has a larger lower bearing lube oil reservoir (11 gallons vs 4 gallons),

e The new pump contains less lube oil (total) than existing pump * The new pump configuration has a sight glass on the lower motor bearing reservoir.

l l Conclusions l

l 1) The existing SER on the RCP lube oil contains a misstatement that should be correcte ) The new pump motor lube oil system differs in capacity and fittings (sight glass) from the l ,

current exempted configuration.

l l Recommendations l

• removal of the new motor lower bearing sight glass if possible to more closely emulate the existing pump configuration and verify fill / drain p: ping and level transmitter as equivalent l

• perform FP evaluation regarding the remaining configuration differences as " insignificant" l

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• conduct NRC notification of configuration change (including documentation as not fire safety significant) and request clarification / update of the SER l

Ken Erdman l Nuclear Design Engineer

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ATTACHMENT 4

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I FCS FP CONFIGURATION REPORT

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Fcs FP CONFIGURATION REPORT Reactor coolant Pump "D"' Lube oil Leak July 6, 1995

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i l The purpose of this document is to address the loss of I approximately 10-gal. of "D" RCP lube oil inventory during power j operation This white paper will evaluate two concern The

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first concern is the. fire hazard and 10CFR50 App. R compliance

! and the second-concern is the operability of the RCP motors under t- this condition.

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Descrintion of the Leak

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. The lube oil system on the RCP motors consists of two oil

! reservoirs internal to the motors and an external lube oil ,

i cooling syste The loss of oil has been from the upper oil 1 l reservoir. The upper oil reservoir surrounds the motor shaft and i acts as an oil bath for the upper guide and thrust bearings on l 1 the moto j

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The decreasing oil level trend for RC-3D motor upper oil j reservoir was observed on ERFCS computer point L316 The i indicated oil level rapidly decreased from ~82% (" full" using the .

local level indicator), but the leak rate reduces as the oil level approaches an indicated 74% (approximately 1 1/4" below

" full"). The rate of level decrease undergoes a rather dramatic change as the oil level decrease At ~82% the oil level decreases about 3% the first day, then less and less over the next week. Following the May outage for the lube oil cooler replacement, it lost 1 1/4" of level (approx. 7 gal.) over the first three weeks. Oil was then added to the pum The following week the oil level dropped 7/8" (approx. five gallons).

HISTORICAL INFORMATION Fort Calhoun Station Reactor Coolant Pump motors in general and RC-3D-M in particular tend to leak oil internally when

" overfilled". Often RC-3D-M has lost oil on initial startup following an outage until the oil level decreased to a point to where it stabilized. The shaft of the motor passes up through the reservoir and is sleeved to prevent oil from contacting the shaf However the sleeve does not extend very f ar above the level of the oil in the reservoir and when overfilled the oil will go over the top of the sleeve and leak down the inside of the sleeve along the motor shaf It is believed that a similar phenomenon is occurring at this time, however oil usage is higher than what has been seen in the pas Over the next several weeks the oil level will be monitored to see if it will stabiliz _ _ - _ . - _ _ - -

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OIL COLLECTION SYSTEM DESIGN BASIS ,

l Internal oil leakage from the upper reservoir results in the bearing lubricating oil migrating internally in the motor to the cooling fan and also to the lower reservoir. The oil which reaches the cooling fan is atomized and discharged to the RCP bay This finely atomized oil then collects on the exposed surfaces inside the ba Other than reducing or stopping the internal oil leak and wiping up the mess, there is little that can be done during operation to collect this oi The motors were designed not to leak and can't be configured to collect this type of internal oil lea External oil leaks are a different matter. Here, external oil l leakage (meaning leaks from the external oil piping, pumps and cooler) is collected by pans that totally enclose all external piping, pumps, instrumentation, etc. associated with the RCP motor's upper oil reservoi The collection and storage of chis !

type of leakage was required by 10CFR50 App. R which states that I the following points be protected (ie. collect all oil frou the ,

pump and route away from potential ignition sources); oil lift l pumps, piping, overflow lines, lube oil coolet, oil fill and drain lines, flanged connections on oil lines and lube oil reservoir The oil collection pans on RC-3A-M and RC-3B-M each drain into one 150 gallon tank in the basement under the RC-2 Likewise, The oil collection pans on RC-3C-M and RC-3D-M each drain into a 150 gallon tank under RC-2 Since each RCP motor holds about 140 gallons of oil in the upper oil reservoir, piping, and oil coolor; the system is capable of containing any single RCP motor external oil lea Fort Calhoun holds an NRC exemption to Appendix R,Section III O in regards to the collection storage tank serving two pumps but with only enough capacity for one pump (150 gal.). At FCS all four RCPs must be running for the reactor to be critical (low RCS flow trip units automatically shutdown the reactor at ~95% of full flow), The probability that two RCP motors could spill their oil into the oil collection tank such that the tank would overflow is incredibly smal The lube oil collection system is performing as designed and meets the requirement of 10CFR50 Ap The oil leakage is internal and cannot be captured per 10CFR50 App. R requirements for a lube oil collection syste This system was reviewed by the NRC and accepted with the stated exemption in 1988. In reviewing the collection system DEN has detenmined that the system is meeting the requirement to collect and remove oil in accordance with the 10CFR50 Ap _ _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ -_ , _ . _ _ _ .

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FIRE MAZARD While the Lube oil collection system meets its design requirements, the intent of Appendix R must also be considere The fact that lube oil is escaping from the pump and being deposited around the bay is not acceptable just because the collection system is meeting its design requirements. The intent of Appendix R is that oil would not be released from the RCP and allowed to come into contact with hot process piping which could initiate a fire. It is therefore a condition which must be evaluated from a fire risk aspect to determine the acceptability of the condition. To gain further insight into the consequences of leaking oil DEN reviewed recent events similar in natur NRC-IEN 94-058: " Reactor Coolant Pump Lube Oil Fire" Haddam Neck and Millstone NPS experienced RCP lube oil leak events in July of 199 Haddam Neck had a fire resulting from a pressurized lube oil component failur The fire was in the oil soaked insulation on the pump casing and piping and was manually extinguished by the unit fire brigade. Millstone experienced undefined motor leaks that resulted in a low flow alarm on the l lube oil system and several gallons of oil accumulating outside  !

the pump and collection system in t.he pump ba Based on the observed fire hazard in containment, the licenses shut down the plan No fire occurred. The IEN included the following clarification by the NRC;

" Oil leaking from the [RCP) lube oil system may come in contact with either (1) surfaces that are hot enough to ignite the. oil, or (2) an electrical source of ignitio Appendix R to Part 50 of Title 10 of the Code of Federal Regulations requires the installation of an oil collection system to collect oil from all potential pressurized and unpressurized leakage site An adequately designed, installed, and maintained oil collection system is necessary to contain any oil released because of leakage failure of the lubrication system and to minimize fire  ;

hazards by draining the oil to a safe location."

IMPACT ON PUMP OPERATION L3161 should not decrease markedly if the indicated oil level is maintained in the mid to lower 70s. However, if the level

continued to drop, then the upper guide bearing will begin to l lose lubrication and temperature will begin to rise and perhaps l

} motor vibration will increase as bearing stiffness decrease If

! this were allowed to continue unchecked, then the plant would

! have to be taken off-line and the RCP secured at a bearing i temperature of 2030F per OI-RC-9.

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The leak appears to be internal and cannot be captured by a backfit oil collection syste The existing system is adequately

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designed to capture all leaks external to the motor. This type

] of leakage is outside the scope of what the Appendix R system was

] intended to d The additional lube oil to RCP "D" has been evaluated by Systems Engineering (attached) and does not represent an unanalyzed

] condition for combustible loading. DEN concurs with this I evaluatio The additional combustible material in the bay is j not significan The combustible loading for containment is analyzed for an additional 395 gallons of oil (Per Standing Order G-91 for transient loads). The oil lost to date has not soaked >

into the insulation around the pump casing or piping which would

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expose it to the high temperatures as occurred at Haddam and the

flow of oil in the system is normal unlike Millston The majority of the oil is being atomized and spread around the bay

{ with some minor pooling and with some oil going to the lower 3 reservoi This condition, while not desirable, doesn't j represent a fire hazard at this time.

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A review of the PRA IPEEE for fire shows that based on compliance

! with the Design Basis and Appendix R requirements the Core Damage i Frequency from a containment fire is 3.14E-7/yr. Based on this information the consequences of a containment fire are not j considered risk significant.

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} The rules here are clear, leakace from the RCP Lube oil system is to be collected and removed from the area (ignition sources).

Any accumulation of lube oil in an unsafe location, i.e. in the

insulation of hot piping (i.e. piping temperature exceeding the 1 flash point of the oil, 400 degrees F) is unacceptable and

! outside the requirements of Appendix R. Additional loss of oil

must be evaluated against this criteria to insure no safety i impact, as has been done for the 10 gallons leaked out to date.

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RECOMMENDATIONS FOR CONTINUED PUMP OPERATIOli Because the oil level will be lower than normal it is recorrmended that the upper guide bearing temperature be closely watched for any temperature increas The alarm setting for T3167 should be set slightly above the current running temperature (T3167 now reads 1530F). Pump vibration should also be closely monitored by Operation Next outage the oil in the RC- 3D-M lower guide bearing should be changed as there is evidence that Mobil "DTE" Heavy Medium oil has leaked from the upper bearing reservoir to the lower reservoi The oil level was 119% in the lower reservoir. Soune oil has been drained out and is being analyzed. Currently the oil level is 89%. The lower reservoir uses 4 gallons of Mobil 797 oil which has a viscosity of 150 SSU at 1000F compared to 300 SSU for the Heavy Mediu A detailed plan should be developed to trouble shoot and correct the leak at the next outag Prepared by:. /d W -

Date: 7 f (

Reviewed by: M

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