IR 05000285/1998005

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Insp Rept 50-285/98-05 on 980301-0411.Violations Noted. Major Areas Inspected:Operation,Maint,Engineering & Plant Support
ML20217E021
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 04/22/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217D997 List:
References
50-285-98-05, 50-285-98-5, NUDOCS 9804270163
Download: ML20217E021 (19)


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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-285 License No.: DPR-40 Report No.: 50-285/98-05 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: Fort Calhoun Station FC-2-4 Ad P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates: March 1 through April 11,1998 Inspectors: W. Walker, Senior Resident inspector V. Gaddy, Resident inspector Approved By: W. D. Johnson, Chief, Project Branch B ATTACHMENT: Supplemental information 9804270163 980422 PDR ADOCK 05000295 G PDR

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I EXECUTIVE SUMMARY l Fort Calhoun Station NRC Inspection Report 50-285/98-05 Ooerations

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The licensee conducted the safety-related activity of lowering the spent fuel pool level l without a procedure containing precautions and instructions. This is a violation of l 10 CFR Part 50, Appendix B, Criterion V (Section 01.2).

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Additional followup of plant cooldown activities will be performed regarding the failure of

, operations personnel to provide information on the reactor coolant pump cavitation in the

! control room log book, and the adequacy of procedures and operations personnel training related to plant cooldown (Section 01.3).

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Operations personnel failed to verify a danger tag series number to the danger tag sheet.

I Additionally, operations personnel did not verify the location of a tagged component prior i to removing the tag. Failing to perform self-checking and lack of attention to detail l resulted in operations personnel clearing the wrong tag. This nonrepetitive, licensee-identified and corrected violation is being treated as an noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (Section O4.1).

Maintenance

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The licensee continued to use radiography to inspect areas of pipe downstream of

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orifices, areas downstream of steam traps, heater vent nozzles, and areas downstream

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of heater dump valves and the heater drain tank vent valve for indications of flow induced l erosion corrosion. Based on the test results, the licensee has tentatively decided to

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replace all main and extraction steam trap locations from the pipe location just before the l'

bypass valve around the steam trap to the component (an elbow or pipe section) past the isolation valve immediately downstream of the check valve (Section M2.1).

i Engineering

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Failure to understand the requirements for use of engineering judgement and to properly l

document the use of engineering judgement resulted in a pipe vibrator being used on l 3-inch piping when it had only been evaluated for use on 4-inch piping. This failure is being treated as a noncited violation consistent with Section IV of the NRC Enforcement

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Po' icy (Section E1.1).

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The methods for qualifying new fuel receipt inspectors were inconsistent, resulting in a co-op student inspecting new fuel. New fuel receipt inspection by a co-op student did not meet licensee management's expectations and resulted in the reinspection of 24 new fuel bundles (Section E5.1).

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2-Plant Suonort a

Lack of proper posting by radiation protection personnel resulted in maintenance personnel entering into a high radiation area to erect scaffolding. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (Section R1.1).

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The licensee v/as self-critical in the identification of performance issues during the emergency training drill. The drill identified several emergency response areas that need improvement (Section P5.1).

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. 1 Reoort Details l

l Summarv of Plant Statu3 l

The plant began this inspection period operating at 100 percent power. On March 24, a reduction to 70 percent power was conducted and, on March 28, power was further reduced to 30 percent. The power reductions were in preparation for the refueling outage and were implemented to reduce radiation levels during the outage. The reactor was shut down on April 1,1998, for a scheduled refueling outag I. Operations i 01 Conduct of Operations

! 0 General Comments (71707)

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Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and

! safety conscious. Operations management and supervisors were frequently observed in the control room providing oversight of operational activities. Operations personnel

! were attentive to their indications. Communications among operations personnel were i generally complete and specific. An equipment operator was observed performing

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routine rounds in a thorough and attentive manne I

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0 Lowerina of Lewlin Soent Fuel Pool Insoection Secoe (71707)

i The inspectors assessed the actions performed by operations personnel while lowering i l levelin the spent fuel poo Observations and Findinos On February 26,1998, during a tour of the main control room, the inspectors noted that

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the annunciator for the spent fuel pool level was lit. Control room operations personnel l stated the annunciator was lit because the level in the spent fuel pool was being lowered to move new fuel into the spent fuel pool. Specifically, the spent fuel pool level was to be lowered to a level equal to the fuel transfer canal to allow the transfer canal gate to be removed so new fuel could be moved from the new fuel storage area into the spent fuel pool. The low level annunciator came in at approximately 1033'-9" elevation, which was approximately 25 feet above the fuel in the spent fuel pool. With the low level annunciator locked in, operations personnel were monitoring the spent fuel pool level locally every 2 to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> The inspectors asked two senior reactor operators how low the spent fuel pool level was to be lowered. The response was that the level would be lowered until it was equal with the level in the fuel transfer canal. The inspectors asked what level this was. Operations personnel did not provide the inspectors with a satisfactory answer. The inspectors also (

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-2-asked if operations personnel had established a minimum level at which the evolution would be stopped. Operations personnel stated that a minimum level had not been established. A senior reactor operator again stated the spent fuel pool would be lowered .

until the two levels were equalized. Operations personnel also stated they would stop i i

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draining if radiation levels in the spent fuel pool area began to increase. The inspectors ,

asked what increase in radiation level would be used to stop lowering of the spent fuel poollevel. Operations personnel stated they would consider stopping the draining of the spent fuel pool if there was any increase in radiation levels. Operations personnel also stated that radiation protection personnel were monitoring radiation levels in the spent fuel pool are The inspectors asked radiation protection personnel what their target radiation level in the spent fuel pool area was while the spent fuel pool level was being lowere Radiation protection personnel stated they wanted radiation levels to remain in the radiation area range and they would recommend stopping the draining of the spent fuel poolif radiation levels increased above 20 mrem. The inspectors asked if radiation protection personnel provided continuous coverage while the level in the spent fuel pool l was being lowered. Radiation protection personnel stated they only provided intermittent coverag The inspectors learned that operations personnel were using a siphon hose to transfer water from the spent fuel pool to the transfer canal. However, there was no procedure that governed this evolution. The inspectors also learned that Procedure OP-12,

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" Fueling Operation," being referenced by operations personnel, did not provide any Guidance to operations personnel on how low to lower the spent fuel pool. Failing to have procedures to govern activities affecting quality is a violation (50-285/9805-01).

In response to the inspectors' questions, operations personnel established a minimum

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level of 1031'-6".

Although the inspectors raised the concern about the lit low level annunciator on l

February 26, the licensee operated with the spent fuel pool low level annunciator locked in until March 3, when the operations supervisor directed that the spent fuel pool level be raised to clear the low level annunciator. The operations supervisor identified operation with the low level annunciator in alarm with no alternate means of monitoring spent fuel pool level in the control room as nonconservative.

i in assessing the circumstances surrounding lowering level in the spent fuel pool, operations management interviewed other crews and identified the following deficiencies:

. No procedure existed to provide guidance to operations personnel on what level should be maintained in the spent fuel pool during lowerin . Nonconservatism on continuing to lower the spent fuel pool with the control room low level annunciator in alarm and no alternate alarm available for monitoring the spent fuel pool level.

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Knowledg3 of weakness of operations personnel on expected changes to spent l fuel pool level during the lowering operation.

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l As a corrective action, operations management developed Operating Instruction OI-F-5,

" Transferring Spent Fuel Pool Water to the Transfer Canal." This instruction provided guidance to operating crews on how to transfer water from the spent fuel pool to the transfer canal. This instruction also established a minimum level to which the spent fuel ,

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poollevel could be lowered. Operations management also stressed to shift managers the importance of not operating for extended periods with locked-in annunciator #

& Conclusion Yq The licensee conducwd the safety-related activity of lowering the spent fuel pool level without a procedure containing precautions and instructions. This is a violation of 10 CFR Part 50, Appendix B, Criterion V.

l l O1.3 Cavitation of Reactor Coolant Pumo RC-3C Insoection Scoce (71707)

The inspectors observed operations activities during plant cooldow Observations and Findinos

On Apnl 2,1998, the inspectors were observing operations personnel perform activities related to plant cooldown. The operations personnel were using Operations Procedure OP-3A, " Plant Shutdown," Revision 19, to cool down the plant. This j procedure directed the operations personnel to use pressurizer steam temperature to determine actual pressurizer pressure by correlating the pressurizer steam space temperature with the pressurizer pressure using steam tables. Operations personnel were using this method to determine reactor coolant system pressure to ensure j

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maintaining net positive suction head for the operating Reactor Coolant Pump RC-3 Reactor coolant pressure was calculated to be 225 psia using the steam tables.

l The oncoming shift manager questioned whether the method being used to determine reactor coolant system pressure was accurate using pressurizer steam space temperature. Following shift turnover, the oncoming operations crew determined that j erroneous reactor coolant pressure readings were being used and the reactor coolant ,

temperature system pressure was raised using pressurizer heater l It appears that the reactor coolant pump was cavitatino for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The ,

licensee is performing a root cause analysis for this event. The inspectors will review the (

root cause analysis when it is completed. In addition, the inspectors identified that l

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-4-operations personnel failed to properly log the activities related to cavitation of the reactor coolant pump. This item is unresolved pending review of the root cause analysis (URI 50-285/9805-02). l Conclusion I Additional followup of plant cooldown activities will be performed regarding the failure of operations personnel to provide information on the reactor coolant pump cavitation in the j control room log book and the adequacy of procedures and operations personnel ;

training related to plant cooldow l 02 Operational Status of Facilities and Equipment O2.1 Review of Eauioment Taaouts (71707)

The inspectors reviewed the following tagout and the performance of independent verification:

. Serial Number 98-488, Replacement of Raw Water Pump AC-10A Discharge Pressure Switch The inspectors found that all tags were on the proper components and that components were in the required tagged position. The inspectors determined that appropriate independent verification was performed by operations personne .2 Enaineered Safety Feature System Walkdown The inspectors used Procedure 71707 to walk down the 125 VDC distribution syste The system was walked down using the following operating instruction and drawing:

. Operating Instruction Ol-GE-3,125 VDC System Normal Operation

. Drawing 11405-E-8,125 VDC Miscellaneous Power Distribution Diagra During the walkdown, the inspectors noted that all components were in their correct position as required by the operating instruction. The inspectors did note a discrepancy in a breaker load. The operating instruction indicated that Breaker 4 on DC-PNL-1, (Turbine Room 125 VDC Distribution Panel) was an open, spare breaker. However, the power distribution diagram indicated that Breaker 4 was connected to Secondary Plant Sampling Recorder Panel Al-125. The inspectors notified the system engineer of the difference. The system engineer verified that the breaker was closed and wrote a maintenance work request to verify the actual field condition. The system engineer also determined that other plant drawings listed the breaker as a spare and open. Following field verification, the licensee indicated that all necessary drawings would be corrected as appropriat .

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5-i O2.3 Confiauration of Control Room Eauioment

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l Insoection Scooe (71707)

l I l The inspectors observed two electrohydraulic turbine control system panel doors open ]

during a routine tour of the control roo j 1 Observations and Findinas On February 25,1998, during a tour of the control room, the inspectors observed that two doors to Panel Al-50 (electrohydraulic turbine Control Panels 1 and 2) were ope The doors were being secured by a plastic caution rope and duct tape. The inspectors determined that the doors were opened by operations personnel on February 19, when a i fan that cooled the circuitry inside the panel failed. Operations personnel opened the j doors to assist in cooling the circuitry to assure operability of the equipment.

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The inspectors discussed with system engineering personnel what effect opening the

! panel doors would have on cooling of the components inside the cabinet. The system engineer stated that opening the doors would have no effect on cooling due to the fact l that a modification had been performed to the panel doors several years ago which I

ensured adequate cooling of the cabinet even with the cooling fan inoperable. The l system engineer provided this information to the control room personnel and the cabinet l doors were closed.

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' Conclusion l Operations personnel did not adequately discuss with the system engineer the effects that opening of Panel Al-50 doors would have on cooling the cabinet prior to opening the doors.

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04.1 Hvdroaen Analyzer Panel Taaaina Error

! Insoection Scooe (71707)

l The inspectors followed up to assess the circumstances surrounding an equipment tagging error by operations personne Observations and Findinas On March 5,1998, operations personnel hung Danger Tag 98-319 to facilitate replacement of a solenoid in Hydrogen Analyzer VA-818. The danger tag removed power from the 480 volt breaker on Motor Control Center MCC-4A2. Motor Control Center MCC-4A2 was located in the radiologically controlled area (Corridor 26). On

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, -6-March 6,1998, operations personnel hung Danger Tag 98-320 on the 120 volt control power circuitry (labeled VA-81 B main) at Panel Al-408, which is located in the control room (Room 77).

On the afternoon of March 6, instrumentation and control technicians requested that a tag be removed from Breaker VA-818 so they could continue with a calibration procedure. Instrument and control technicians requested that Danger Tag 98-320 be removed. A control room operator processed the removal request and directed an auxiliary operator to remove the tag from Breaker VA-81B and called a second auxiliary operator to verify that the tag was removed and the breaker was closed. The control room faxed a copy of the tagout sheet to the auxiliary operator, the tag was removed, l and the breaker was closed. Once the breaker was closed, aad verified closed, the two

operators returned to the control roo Instrumentation and control technicians returned to the work location and noted that the hydrogen analyzer panel was not powered up as expected. An auxiliary operator was sent to verify the breaker was closed. During an investigation, the control room operator i read the location of the breaker and noted it was located in Room 77 at Panel Al-408, i not Corridor 26 at Motor Control Center MCC-4A2. The control room operator verified l

that the control power breaker at Panel Al-40B was still open. At this point, operations

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personnel realized they had removed the wrong tag and had closed the wrong VA-81B breaker.

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Control room operators immediately directed an auxiliary operator to reopen the VA-818 l breaker and rehang the danger tag. Auxiliary operators then removed Danger Tag 98-320 from Panel AI-40 The licensee performed an analysis of this incident and identified the following causes:

. operations personnel did not compare the danger tag series numbers to the series on the danger tag sheet, and

. information concerning the location of the tagged component on the tagout sheet was not reviewe In addition, the licensee identified several other factors that influenced the behavior of operations personnel:

. similarities between the two components descriptions,

- the performance of a tag release near the end of shift, and

- the mind set of the personnel involved in that they were removing a tag they had l

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hung the previous day.

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l -7-l Standing Order SO-G-20A on Equipment Tagging directs operations personnel who will be removing tags to properly verify the tag number and location according to the tagout sheet. Failing to verify the tag number and location prior to restoring the hydrogen analyzer to service is a violation. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the Enforcement Policy (50-285/9805-03).

As corrective action, the licensee will provide training on factors which lead personnel to circumvent established work practices, such as self-checking, and discussions were held with operations crews regarding how peer checking should be used to prevent similar event Conclusions Operations persorinel failed to verify a danger tag series number using the danger tag sheet. Additionally, operations personnel did not verify the location of a tagged component prior to removing the tag. Failing to perform self-checking and lack of attention to detail resulted in operations personnel clearing the wrong tag. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vil.B.1 of the Enforcement Polic ;

07 Quality Assurance in Operations 07 Institute of Nuclear Power Ooerations Plant Evaluation The inspectors reviewed the institute of Nuclear Power Operations' plant evaluation report that had been performed at Fort Calhoun the weeks of December 8 and 15,199 The interim report was forwarded to the licensee by a letter dated February 11,1998, and did not reveal any significant problems not previously known to the NRC. The areas reviewed were: operations, maintenance, radiological protection, chemistry, human ;

performance, training, work management, equipment performance, and material conditio Miscellaneous Operations issues (92901)

O8.1 (Closed) Violation 50-285/9604-01: exceeding plant staff working hours. To correct this j violation, the licensee counseled the individual involved on the importance of not exceeding plant working hour limitations. Operations personnel were briefed on the circumstance surrounding this violation and retrained on the administrative guidance for working hours. Additionally, operations management issued a memorandum to I l cperations personnel that indicated each individual was accountable for tracking their

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j 11. Maintenance M1 Conduct of Maintenance M1.1 General Comments ( Insoection Scoce (62707)

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- Replacement of Rod Control Mechanical Interlocks for each Control Element Assembly

! - Inspection and Rebuilding of Waste Gas Compressor

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. Redesign of Ground Fault System to Monitor the Control Rod Drive Cabinets l

. Disassembly and Overhaul of Turbine Generator Observations and Findinas The inspectors found the work performed under these activities to be professional and i thorough. All work observed was performed with the work package present and in active use. Maintenance technicians were experienced and knowledgeable of their assigned tasks. The inspectors frequently observed supervisors and system engineers monitoring job progress, and quality control personnel were present when required by procedure.

l Conclusions The maintenance activities observed were conducted in a controlled and professional manner.

L M1.2 Surveillance Tests Insoection Scooe (61726)

. IC-CP-01-0007, " Calibration of Power Range Safety Channel C," Revision 7;

- IC-ST-RC-0003, " Monthly Functional Test of Pressurizer Level Instrument Channels L-101X and L-101Y," Revision 15;

. OP-ST-FP-0001C, " Fire Protection System inspection and Test," Revision 6;

. SS-ST-MS-3005, " Main Steam Safety Valves Set Pressure Testing Using Furmanite's Equipment," Revision 2;

- OP-ST-CEA-0005, " Control Element Assemblies Drive System Interlock Checks,"

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. . OP-ST-RC-3004, " Power Operated Relief Valves (PORVs! Low Temperature Low Pressure Exercise Test (PCV-102-1 and PCV-102-1)," Revision 1 Observations and Findinas Surveillance activities were generally completed thoroughly and professionall Conclusions The surveillance activities observed by the inspectors were completed in a controlled manner and in accordance v/ith procedure M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Evaluation of Radicaraohv Results On April 21,1997, a sweep elbow in the fourth stage extraction line of the Fort Calhoun Nuclear Power Plant ruptured. The cause of the rupture was determined to be flow accelerated corrosion. Following the rupture, a flow accelerated corrosion program assessment team was formed and made recommendations of further piping sites to be inspected. This inspection, started in February 1998, used phosphorus screen radiography to inspect the various piping location The initial scope of the inspection included areas of pipe downstream of orifices, areas downstream of steam traps, heater vent nozzles, and areas downstream of heater dump valves and the heater drain tank vent valve. The radiography technology used was limited to small bore piping (6 inches or less). The following results were obtained:

. All three orifices on the feedwater pump warmup lines were above 70 percent nominal wall thickness, indicating minor wear which will continue to be monitored;

. Blowdown transfer pump recirculation line orifices were above 70 percent of nominal wall thickness and will continue to be monitored;

. Minimal wear was noted on steam seal system piping and control valves;

. Six low pressure heater vent nozzles and piping components were radiographe No wear was found on the vent from Heater 1 A; however, Heaters 2A and 3B showed substantial wear just downstream of the vent nozzle at 34 percent (.053")

and 32 percent (.050") of nominal wall thickness (.154"), respectively. These lines are being evaluated for replacement;

. Originally four main and extraction steam traps and associated downstream components were included in the inspection. After significant wear was observed, an additional three traps were radiographed. The most significant I

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-10-wear was detected in the piping immediately downstream of the globe valves and check valves located in the piping downstream of the steam traps. Two components were found to be below minimum wall thickness (as calculated using design pressure from the piping specification). These sites were both 1-inch q check valves and downstream piping. The first site was 8 percent (.015") and i

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the second site was 21 percent (.037") of nominal wall thickness (.179").

The licensee evaluated the results and decided to replace all main and extraction steam trap locations from the pipe location just before the bypass valve, around the steam trap I

to the component (an elbow or pipe section), past the iso'ation valve immediately downstream of the check valve. This includes seven site Ill. Enaineerina E1 Conduct of Engineering E Pioe Vibrator Use en Letdown Strainer Pioina Insoection Scooe (37551)

The inspection reviewed the circumstances surrounding the use of a mechanical pipe vibrator to unclog the letdown straine l

Observations and Findinas On March 31,1998, the licensee used a mechanical pipe vibrator to clear resin that was clogging Letdown Strainer CH-24. The inspectors also learned that on several prior occasions the licensee had used a pipe vibrator to clear Strainer CH-24. With the strainer clogged, an elevated pressure differential hampered the licensee's ability to use two charging pumps to help clean up the reactor coolant syste On March 16,1998, design engineering personnel completed an analysis that allowed the pipe vibrator to be used on the pipe. This analysis was reviewed by the inspectors on March 31,1998. Engineering Assistance Request 98-066 allowed the use of the vibrator on Strainer CH-24 piping because the method of agitation was previously evaluated in Engineering Assistance Request 90-150. Engineering Assistance Request 90-150 evaluated the use of a pipe vibrator on safety injection piping to clear hot spots from the piping. Engineering Assistance Request 90-150 concluded that the vibrator could be used to eliminate hot spots in piping provided its use was limited to 4-inch and larger pipe. The inspectors noted that the piping for Strainer CH-24 was l 3-inch pipin The inspectors asked if it was acceptable to use the vibrator on 3-inch piping since the previous analysis restricted the vibrator's use to 4-inch and larger piping. Design engineering personnel stated that they allowed the vibrator to be used on 3-inch pipe based on engineering judgement. Design engineering personnel stated that, based on

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-11-the opinion and experience of the piping engineer, this was acceptable. The inspectors l noted that the basis for the engineering judgement, which provided the basis for acceptability, was not documented in Engineering Assistance Request 98-06 The inspectors reviewed Procedure PED-QP-14, "Use of Engineering Judgement."

Step 5.1 of this procedure stated that an engineer may make use of engineering judgement, provided that the basis for the judgement is clearly identified. The step also l states that documentation shall be included within the analysis. Failing to document the basis of the engineering judgement that allowed the use of a pipe vibrator on 3-inch pipe is a minor violation (50-285/9805-04). Conclusion Failure to understand the requirements for use of engineering judgement and to properly document the use of engineering judgement resulted in a pipe vibrator being used on 3-inch piping when it had only been evaluated for use on 4-inch piping. This failure is being treated as a noncited violation consistent with Section IV of the NRC Enforcement Polic ES Engineering Staff Training and Qualification E New Fuel Receiot insoections Insoection Scoce (37551)

The inspectors followed up on the use of a co-op student to perform new fuel receipt inspection i

! Observations and Findinas On February 25,1998, quality assurance personnel identified that engineering personnel had allowed a co-op student that had not been qualified by the training department to perform new fuel receipt inspection During their followup, the licensee determined they had two methods for qualifying fuel receipt inspectors. One qualification method was governed by the training department and the other method was controlled by a stand alone form, Form FC-31. This form listed the criteria for qualifying new fuel receipt inspectors. The co-op student was qualified using Form FC-31 and not by the training department. In addition to the criteria outlined on Form FC-31, the training department also required personnel to complete Training Lesson Plan 2212-01. The licensee determined that the co-op student was not properly qualified since Training Plan 2212-01 was not completed. The licensee l reinspected 24 fuel bundles that the co-op student had inspected and found no anomalies during the reinspection.

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-12-The licensee planned to change their procedures to clarify the training requirements for new fuel receipt inspectors. Additionally, in the future, reactor engineers and shift technical advisors will perform new fuel receipt inspection Conclusion )

The methods for qualifying new fuel receipt inspectors were inconsistent, resulting in a co-op student inspecting new fuel. New fuel receipt inspection by a co-op student did not meet licensee management's expectations and resulted in the reinspection of 24 new l fuel bundle IV. Plant Suncort l

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I R1.1 Entrv Into A Hiah Radiation Area l Insoection Scone (71750)

The inspectors followed up on an entry into a high radiation area without signing onto the

proper radiation work permit. Radiation protection personnel directed maintenance l personnel to sign onto Radiation Work Permit 101; however, this radiation work permit

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did not allow entry into high radiation area Observations and Findinas On March 25,1998, during a tour of the radiologically controlled area, a radiation protection technician observed that the boundaries in Room 13 (mechanical penetration room) had been incorrectly posted. The area was posted as a contaminated area. The

! areas should also have been posted as a high radiation area.

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[ erect scaffolding. The root cause of this incident was identified as failure to post the area ( as a high radiation area.10 CFR 20.1902(b) requires, in part, that the licensee shall post l each high radiation area with a conspicuous sign. Failure to post the high radiation area is a violation. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-285/9805-05).

l As corrective action, the licensee property posted the area as a high radiation area and counseled radiation protection personnel on the importance of properly posting areas throughout the radiologically controlled are I i

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-13- Conclusion Lack of proper posting by radiation protection personnel resulted in maintenance personnel entering into a high radiation area to erect scaffolding. This resulted in a noncited violatio R1.2 Soent Fuel Pool Demineralizer Resin Sluice Insoection Scoce (71750)

The inspectors followed up on the licensee's efforts to sluice resin from the spent fuel pool demineralize Observations and Findinos l

On January 27,1998, the licensee attempted to sluice resin from Spent Fuel Pool Demineralizer AC-7 to the spent resin storage tank using Operating instruction Ol-SFP-3A, " Spent Fuel Pool Cooling Spent Resin Sluicing." Although some I resin flow was reported, radiation surveys indicated that only a small amount of resin had been transferred. Over the next 2 months, the licensee made additional attempts to transfer resin from Demineralizer AC-7, none of which were completely successful. The licensee did manage to sluice most of the resin from Demineralizer AC- During the sluice attempts, licensee personnel received more that 2 rem dose. The initial dose projection was significantly lower than the actual dose receive The licensee determined that several problems prevented sluicing the demineralize Some of these were inadequate planning and scheduling, inadequate support, and lack of defined leadership. In response, the licensee informed the inspectors that an evaluation of the circumstances surrounding the failure to successfully transfer the resin would be performed. The licensee indicated that all deficiencies would be identified and resolved so future Demineralizer AC-7 resin sluice activities would be more successfu This item will remain open until the licensee has completed their evaluation ;

(50-285/9805-06). Conclusions Planning and scheduling deficiencies, lack of defined leadership, and inadequate support were several reasons that the sluicing of the resin for the spent fuel pool demineralizer were not completely successful. Licensee personnel received more than 2 rem dose during the resin sluice attempts.

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I l-14-P5 Staff Training and Qualification in EP P5.1 Emergency Planning Drill Insoection Scope (71750)

l The inspectors reviewed the Fort Calhoun Emergency Plan and the emergency plan training drill critique. In addition, the inspectors attended a quality assurance audit debrief of the emergency dril Observations and Findinos On March 5,1998, the licensee conducted an emergency planning training dril The drill was conducted as a training evolution with coaches. As a result, no l weaknesses or strengths were identified. The licensee characterized the training drill overall as a failure. Areas that contributed to the poor performance were drill preparation, drill controlling, very little coaching by coaches, poor performance by participants, and some interactive notification system equipment problem Because of the poor performance, the licensee wil! conduct a remedial drill using the same scenario, players, coaches, and controller. Additional training will be given to all control room communicators on potential problems in the use of the interactive notification system. Also, changes will be made to the use and assignment of tornado shelter Conclusions The licensee was self critical in the identification of performance issues during the emergency training drill. The drill identified several emergency response areas that need improvemen V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to the members of licensee management at the exit meeting on April 13,1998. The licensee acknowledged the findings l presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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e ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee J. Tills, Manager, Nuclear Licensing D. Spires, Manager, Quality Assurance, Quality Control S. Gebers, Manager, Radiation Protection R. Clemens, Manager, Maintenance J. Chase, Plant Manager R. Short, Assistant Plant Manager E. Matzke, Station Licensing R. Jaworski, Manager, Design Engineering Nuclear R. Phelps, Manager, Station Engineering R. Hamilton, Manager, Chemistry S. Gambhir, Division Manager, Engineering and Operations Support INSPECTION PROCEDURES USED IP37551: Onsite Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support Activities

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IP 92901: Followup - Plant Operations l

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ITEMS OPENED. CLOSED. AND DISCUSSED Ooened 50-285/9805-02 URI cavitation of Reactor Coolant Pump RC-3C (Section 01.3)

50-285/9805-06 IFl spent fuel pool demineralizer resin sluice (Section R1.2)

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w e-2-Closed 50-285/9604-01 VIO exceeding plant staff working hours (Section 08.1)

Ooened and Closed 50-285/9705-01 VIO failure to ensure a procedure existed for lowering the spent fuel poollevel(Section 01.2)

50-285/9805-03 NCV hydrogen analyzer panel tagging error (Section O4.1).

50-285/9805-04 NCV inadequate documentation of the use of engineering judgement (Section E1.1)

50-285/9805-05 NCV failure to properly post a high radiation area (Section R1.1)

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