ML021010002
| ML021010002 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/10/2002 |
| From: | Marschall C NRC/RGN-IV/DRS/EMB |
| To: | Ridenoure R Omaha Public Power District |
| References | |
| EA-02-059 IR-02-003 | |
| Download: ML021010002 (32) | |
See also: IR 05000285/2002003
Text
April 10, 2002
R. T. Ridenoure
Division Manager - Nuclear Operations
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
SUBJECT:
FORT CALHOUN STATION - NRC INTEGRATED INSPECTION
REPORT 50-285/02-03
Dear Mr. Ridenoure:
On March 1, 2002, the NRC completed an inspection at your Fort Calhoun Station. The
enclosed report documents the inspection findings, which were discussed on March 1, 2002,
with Mr. D. Bannister and other members of your staff. A supplemental exit meeting was
conducted by telephone on March 11, 2002, with Mr. R. Ridenoure, Division Manager, Nuclear
Operations, and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
Within these areas, the inspection consisted of selected examination of procedures and
representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has identified six findings that were evaluated
under the risk significance determination process as having very low safety significance
(green). One finding involved the failure to take adequate corrective actions for defective
valves in the emergency diesel air starting system. The second finding involved the failure to
apply an adequate design analysis of emergency diesel generator fuel oil storage requirements.
The third finding involved an inadequate procedure associated with testing of the turbine-driven
auxiliary feedwater pump. The fourth finding involved an inadequate safety evaluation
associated with a change to a surveillance test procedure. The NRC has determined that
violations are associated with these issues. Because of the very low safety significance, the
violations are being treated as noncited violations, consistent with Section VI.A.1 of the
Enforcement Policy. Additionally, two findings were identified pertaining to the diesel-driven
auxiliary feedwater pump, involving day tank inventory and automatic fire suppression, but they
were not identified as violations. If you deny the noncited violations, you should provide a
response within 30 days of the date of this inspection report, with the basis for your denial, to
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the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC
20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission,
Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of
Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the
NRC Resident Inspector at the Fort Calhoun Station.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRCs
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Charles S. Marschall, Chief
Engineering and Maintenance Branch
Division of Reactor Safety
Docket: 50-285
License: DPR-40
cc:
Mark T. Frans, Manager
Nuclear Licensing
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
James W. Chase, Division Manager
Nuclear Assessments
Fort Calhoun Station
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
David J. Bannister, Manager - Fort Calhoun Station
Omaha Public Power District
Fort Calhoun Station FC-1-1 Plant
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
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James R. Curtiss
Winston & Strawn
1400 L. Street, N.W.
Washington, D.C. 20005-3502
Chairman
Washington County Board of Supervisors
Washington County Courthouse
P.O. Box 466
Blair, Nebraska 68008
Sue Semerena, Section Administrator
Nebraska Health and Human Services System
Division of Public Health Assurance
Consumer Services Section
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007
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Electronic distribution from ADAMS by RIV:
Regional Administrator (EWM)
DRP Director (KEB)
DRS Director (ATH)
Senior Resident Inspector (WCW)
Branch Chief, DRP/C (KMK)
Senior Project Engineer, DRP/C (vacant)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
Jim Isom, Pilot Plant Program (JAI)
RidsNrrDipmLipb
Scott Morris (SAM1)
FCS Site Secretary (NJC)
SRI:EMB
SRI:EMB
RI:EMB
RI:EMB
PE:PBD
MFRunyan/lmb
LEEllershaw
PAGoldberg
WMMcNeill
JFMelfi
/RA/
/RA/
/RA/
/RA/ T
/RA/ T
03/26/02
03/26/02
03/26/02
03/19/02
03/21/02
RI:EMB
OE:OLB
C:EMB
C:DRPC
C:EMB
CAClark
AASanchez
CSMarschall
CEJohnson
CSMarschall
/RA/
/RA/ E
/RA/
/RA/
/RA/
03/26/02
03/20/02
04/08/02
04/10/02
04/10/02
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-285
License:
EA No.
Report No:
50-285/ 02-03
Licensee:
Omaha Public Power District
Facility:
Fort Calhoun Station
Location:
Fort Calhoun Station FC-2-4 Adm
P.O. Box 399, Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska
Dates:
February 4 through March 1, 2001
Team Leader:
M. F. Runyan, Senior Reactor Inspector, Engineering Maintenance Branch
Inspectors:
L. E. Ellershaw, Senior Reactor Inspector, Engineering Maintenance Branch
P.A. Goldberg, Reactor Inspector, Engineering Maintenance Branch
J .F. Melfi, Reactor Inspector, Engineering Maintenance Branch
W. M. McNeill, Reactor Inspector, Engineering Maintenance Branch
C. A. Clark, Reactor Inspector, Engineering Maintenance Branch
A. A. Sanchez, Operations Engineer, Operator Licensing Branch
Approved By:
Charles S. Marschall, Chief
Engineering Maintenance Branch
Division of Reactor Safety
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SUMMARY OF FINDINGS
IR 05000285-02-03 on 02/04-03/01/20021; Omaha Public Power District; Fort Calhoun Station
safety system design and performance capability, evaluation of changes, tests, or experiments.
The inspections were conducted by six regional inspectors. The inspectors identified six green
findings, four of which were characterized as noncited violations. The significance of most
findings is indicated by their color (Green, White, Yellow, Red) and determined by using
Inspection Manual Chapter 0609, "Significance Determination Process (SDP)." Findings for
which the significance determination process does not apply are indicated by "No Color" or by
the severity level of the applicable violation. The NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described at its Reactor Oversight Process
website at http://www.nrc.gov/NRR/OVERSIGHT/index.html.
Cornerstone: Mitigating Systems
Green. The licensee failed to take adequate corrective actions following discovery of a
degraded emergency diesel generator air start system air relay valve in October 2001
and also failed to take adequate corrective actions following the operational failure of
this valve in December 2001. This was identified as a violation of Criterion XVI to
Appendix B of 10 CFR Part 50, Corrective Action.
This finding was of very low safety significance since there was no actual loss of
safety function (the emergency diesel generator started successfully on its backup air
starting system). Because of the low safety significance and the licensees action to
place the issue in their corrective action program (Condition Reports 2001-03772 and
2002-00475), this violation is being treated as a noncited violation in accordance with
Section VI.A.1 of the Enforcement Policy (50-285/0203-01) (Section 1R21.3.b).
Green. The six fire protection sprinklers in the diesel-driven auxiliary feedwater pump
room were located approximately 5 feet below the ceiling and would most likely not
actuate until a fire in the room reached a considerable strength. The delay in actuation
would result from the need for the hot gas layer to descend to the elevation of the
sprinklers, which are normally positioned very close to the ceiling. Because the issue
did not involve NRC regulations, a violation was not identified.
This finding was of very low safety significance because the diesel-driven pump is not
credited in the accident analysis (it is not safety-related, but has high risk significance),
sensors in the room would cause a control room alarm, and manual suppression would
be available. The licensee entered this issue into its corrective action program as
Condition Report 200200498 (Section 1R21.4.b).
Green. The fuel oil inventory in the day tank supplying the diesel-driven auxiliary
feedwater pump was not being directly verified by the licensees surveillance program.
Instrument drift could result in failure to meet the design intent of maintaining the tank
half full to provide a 4-hour run of the pump (which is not safety-related, but has a high
risk significance). Because the issue did not involve NRC regulations, a violation was
not identified.
-3-
This finding was of very low safety significance because there was no actual loss of
safety function and the diesel engine has a integral generator that can power a transfer
pump to replenish the day tank. The licensee entered this issue into its corrective action
program as Condition Report 200200496 (Section 1R21.4.b).
Green. The licensee staff had not accounted for several factors determining the
diesel fuel oil on hand to meet the Technical Specification 2.7(1)m. requirement of
16,000 gallons of fuel oil in FO-1, the diesel generator fuel oil storage tank, and an
additional 8,000 gallons of diesel fuel oil in FO-10, the auxiliary boiler fuel oil storage
tank. The basis for the limit was to maintain a 7-day supply of fuel oil. The factors not
accounted in the analysis were the effect of specific gravity on the loop uncertainties,
the effect of specific gravity on the fuel consumption formula, the effect of the operation
of the diesel driven auxiliary feedwater pump, the effect of errors in estimating volumes,
and other minor errors. This was identified as a violation of Criterion III of Appendix B to
10 CFR Part 50, Design Control, which requires that the design basis be correctly
translated into the technical specifications.
This finding was of very low safety significance as the licensee always maintained
additional inventory that would have provided a full 7-day supply of fuel oil, and the
safety evaluation report credited the sufficiency of a 6-day supply. Because of the very
low safety significance and that the licensee entered this finding into their corrective
action program in Condition Reports 200200464, 200200373, and 200200304, this
violation is being treated as a noncited violation in accordance with Section VI.A.1 of the
Enforcement Policy (50-285/0203-02) (Section 1R21.5.b).
Green. Procedure SE-ST-AFW-3006, "Auxiliary Feedwater Pump FW-10, Steam
Isolation Valve and Check Valve Tests," Revision 5, was inadequate. The procedure
failed to identify that the motor-driven auxiliary feedwater pump was rendered inoperable
during a portion of the test. This was identified as violation of Criterion V to Appendix B
of 10 CFR Part 50, Instruction, Procedures, and Drawings.
The finding was of very low safety significance because there was no actual loss of
safety function as the turbine-driven pump remained operable and the dedicated
operators could be considered to be highly reliable. Because of the very low safety
significance, and because the licensee included the item in their corrective action
program as Condition Report 200200483, this violation is being treated as a noncited
violation in accordance with Section VI.A.1 of the Enforcement Policy (50-285/0203-03)
(Section 1R21.6.b).
Green. The licensee failed to assess Procedure Change Request 42290 to
Procedure SE-ST-AFW-3006, "Auxiliary Feedwater Pump FW-10, Steam Isolation
Valve and Check Valve Tests," under the provisions of 10 CFR 50.59, resulting in a
failure to comply with Technical Specification 2.5. The use of operator actions to
maintain operability was not adequately evaluated. This procedure change should not
have been made without prior NRC approval. This was identified as a violation of
This finding was of very low safety significance because the reliability of the operator
actions needed to restore system operability was very high. Because of the very low
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safety significance, and because the licensee included the item in their corrective
action program as Condition Report 200200632, this violation is being treated as a
noncited violation in accordance with Section VI.A.1 of the Enforcement Manual
(50-0203/0203-04) (EA-02-059) (Section 1R21.6.b).
Report Details
1
REACTOR SAFETY
Introduction
A team inspection was performed to verify that facility safety system design and
performance capability were adequate and that the initial design and subsequent
modifications have preserved the current design basis of the systems selected for
review. The scope of the review also included any necessary nonsafety-related
structures, systems, and components that provided functions to support safety
functions. The inspection effort also reviewed the licensees programs and methods for
monitoring the capability of the selected systems to perform the current design basis
functions. This inspection verified aspects of the initiating events, mitigating systems,
and barrier cornerstones.
The probabilistic risk assessment model for Fort Calhoun Station is based on the
capability of the as-built safety systems to perform their intended safety functions
successfully. The area and scope of the inspection were determined by reviewing the
licensees probabilistic risk analysis models to identify the most risk significant systems,
structures, and components according to their ranking and potential contribution to
dominant accident sequences and/or initiators. Deterministic effort was also applied in
the selection process by considering recent inspection history, recent problem area
history, and all modifications developed and implemented. The team reviewed in detail
the emergency diesel generators and the auxiliary feedwater system. The primary
review prompted parallel review and examination of support systems, such as, electrical
power, instrumentation, room cooling systems, and related structures and components.
The objective of this inspection was to assess the adequacy of calculations, analyses,
engineering processes, and engineering and operating practices that were used to
support the performance of the safety systems selected for review and the necessary
support systems during normal, abnormal, and accident conditions. Acceptance criteria
utilized by the NRC inspection team included NRC Regulations, the technical
specifications, applicable sections of the Final Safety Analysis Report, applicable
industry codes and standards, as well as industry initiatives implemented by the
licensees programs.
An inspection to assess the performance of the licensee's program to meet the
regulatory requirements of 10 CFR Part 50.59, "Changes, Tests, And Experiments," was
also conducted by one member of the team, during the first week of the inspection.
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1R02
Evaluation of Changes, Tests, and Experiments (71111.02)
a.
Inspection Scope
The inspectors reviewed a selected sample of 11 safety evaluations to verify that the
licensee had appropriately considered the conditions under which the licensee may
make changes to the facility or procedures or conduct tests or experiments without prior
NRC approval in accordance with 10 CFR 50.59.
The inspectors reviewed 11 screenings pertaining to modifications, and procedure and
calculation revisions, in which the licensee determined that evaluations were not
required, to ensure that the licensees exclusion of a full evaluation was consistent with
the requirements of 10 CFR 50.59.
The inspectors evaluated the effectiveness of the licensees corrective action process to
identify and correct problems concerning their performance associated with
10 CFR 50.59 requirements. In this effort, the inspectors reviewed four condition
reports. Further, the inspectors reviewed the most recent 10 CFR 50.59 program audit.
Additionally, the inspectors reviewed the 10 CFR 50.59 training curriculum and the
qualification records of a sample of independent technical reviewers identified in the
screening and evaluation forms.
b
Findings
No findings of significance were identified.
1R21
Safety System Design and Performance Capability (71111.21)
.1
System Requirements
a.
Inspection Scope
The team reviewed the following attributes for the auxiliary feedwater system and the
emergency diesel generators: (1) process medium (water, steam, and air), (2) energy
sources, (3) control systems, and (4) equipment protection. The team verified that
procedural instructions to operators were consistent with operator actions required to
meet, prevent, and/or mitigate design basis accidents. The review also considered
requirements and commitments identified in the Final Safety Analysis Report, technical
specifications, design basis documents, and plant drawings. These reviews further
verified that required support functions for the emergency diesel generators and the
auxiliary feedwater system would be available.
b.
Findings
No findings of significance were identified.
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.2
System Condition and Capability
a.
Inspection Scope
The team reviewed the periodic testing procedures for the auxiliary feedwater system
and the emergency diesel generators to verify that the design requirements were
adequately demonstrated. The team reviewed the environmental qualification of a
sample of system components to verify the capability to operate under design
environmental conditions and the assumed operating parameters including: voltage,
speed, power, flow, temperature, and pressure.
The team also reviewed the systems operations by conducting system walkdowns;
reviewing normal, abnormal, and emergency operating procedures; and reviewing the
Final Safety Analysis Report, technical specifications, design calculations, drawings, and
procedures.
b.
Findings
No findings of significance were identified.
.3
Identification and Resolution of Problems
a.
Inspection Scope
The team reviewed a sample of problems identified by the licensee in the corrective
action program to evaluate the effectiveness of corrective actions related to design
issues. The sample included open and closed condition reports for the past three years
that identified issues related to or affecting the selected systems.
b.
Findings
Inadequate Corrective Action for Emergency Diesel Generator Air Relay Valves
The team identified two instances of inadequate corrective action related to maintenance
and testing of the air relay valves in the emergency diesel generator air start system.
The air start system for each diesel generator contained two air relay valves, one
designated as primary and the other as secondary. Absent other failures, both of the air
relay valves (primary and secondary) must fail in order for an emergency diesel
generator to fail to start.
On October 17, 2001, a work request was written to address a leaking air relay valve
(SA-196) that was discovered on the Division 2 emergency diesel generator air start
system. Initially given a high priority, the work request was later downgraded, given that
it still functioned, and assigned a completion date of January 28, 2002. The valve
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subsequently failed during a surveillance test on December 12, 2001. The secondary air
start system functioned as designed and successfully started the diesel. There was no
immediate effect on diesel generator operability because it was already declared
inoperable for maintenance. Starting air relay valve SA-196 was replaced on
December 12, 2001.
No condition reports were written following discovery of the leaking air relay valve in
October 2001. Three condition reports were generated concerning the December 2001
air relay valve failure. The cause of the failed valved was classified as an O-ring
aging/wear issue. Although mentioned, the potential for common cause failure was not
addressed in the condition reports. Neither before nor after the events mentioned were
the air relay valves (safety system components) incorporated in any preventative
maintenance or replacement program nor were they addressed from a rigorous
engineering standpoint. It was not until the team inquired into the preventative
maintenance of these valves that a condition report was generated to evaluate these
possible actions.
The team determined that these conditions had a credible impact on safety and that the
issue was more than minor since the air relay valves on the emergency diesel air start
system began to exhibit signs of degradation and one actual failure. The team also
concluded that this issue affected the mitigating system cornerstone since at least one of
the emergency diesel generators is required to mitigate a design basis event, and the
safety function could have been impacted.
Using Phase 1 of the Significance Determination Process, the team determined that only
the mitigation systems cornerstone was affected and that there was no actual loss of
safety function as the emergency diesel generators still started on demand. Therefore,
the problem had a very low safety significance (Green).
Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, that [m]easures shall be
established to assure that conditions adverse to quality . . . are promptly identified and
corrected. In contrast to the above, the team determined that the licensee missed the
opportunity to promptly identify the need for corrective action concerning the leaking air
relay valve (SA-196) in October 2001. The licensee also failed to implement proper
corrective action concerning the failure of that same valve in December 2001. However,
due to the low safety significance and the licensees action to place the issue in their
corrective action program (Condition Reports 200103772 and 200200475), this violation
is being treated as a noncited violation in accordance with Section VI.A.1 of the
Enforcement Policy (50-285/0203-01).
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.4
System Walkdowns
a.
Inspection Scope
The team performed walkdowns of the accessible portions of the auxiliary feedwater
system and the emergency diesel generators as well as the required support systems.
The walkdowns focused on the installation and configuration of power supplies, piping,
components, and instruments. During the walkdowns, the team assessed:
The placement of protective barriers and systems,
The susceptibility to flooding, fire, or environmental conditions,
The physical separation of trains and the provisions for seismic concerns,
Accessibility and lighting for any required local operator action,
The materiel condition and preservation of systems and equipment, and
the conformance of the currently installed system configurations to the current
design and licensing bases.
b.
Findings
Fire Protection of Diesel-Driven Auxiliary Feedwater Pump
The team identified an issue related to the location of fire protection sprinkler heads in
the room that houses the nonsafety-related diesel-driven auxiliary feedwater pump
(FW-54). This pump was included in the scope of the inspection because it has
significant risk importance. Six sprinkler heads were positioned approximately 5 feet
below the ceiling of the room and approximately 4 feet to the side of the pump. A
horizontal 12X12-inch square sheet metal heat collector was located directly above each
sprinkler head .
Fire codes typically require sprinkler heads to be located within 1 or 2 feet of the ceiling
to ensure that they can respond quickly to the formation of a hot gas layer in the room.
Also, some industry testing has shown that heat collectors of the type described above
can retard activation by preventing the free flow of hot gases in the vicinity of the fusible
links in the heads. The team considered the off-ceiling location of the sprinkler heads to
render the diesel-driven auxiliary feedwater pump vulnerable to a small fire that would, in
all likelihood, activate the control room fire alarm sensor, but which could burn for a
considerable time before either manual suppression methods were applied or the hot gas
layer descended to the elevation of the fusible links. This scenario would potentially
extend the length of time needed to recover the pump in case it was needed as a
contingency (if the other auxiliary feedwater pumps were unavailable).
Because the issue did not involve NRC regulations, a violation was not identified.
However, the team determined that this finding was of more than minor significance
because it had a credible impact on safety. That is, the survival or recovery of a risk-
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significant component could be affected. Using Phase I of the significance determination
process, the team determined that the issue affected the mitigating systems cornerstone,
because the pump provides risk mitigation for the auxiliary feedwater system and the
condition potentially impacted the timing at which automatic suppression would
extinguish a fire in the pump room. However, the finding had very low risk significance
(green) because sensors in the room would cause a control room alarm, manual
suppression would be available, and there was not an actual loss of safety function.
Because the issue did not involve NRC regulations, a violation was not identified. The
licensee initiated Condition Report 200200498 to examine this concern.
Inventory of Diesel-Driven Auxiliary Feedwater Pump Fuel Oil Day Tank
The 150-gallon fuel oil day tank for the diesel-driven auxiliary feedwater pump had three
level instruments: level sensors LS-2120 and LS-2121 which control (start and stop) the
transfer pump used to refill the day tank and cause a low level alarm in the control room,
respectively; and LI-2120, which is a local dial indicator of tank level. The tank was kept
by procedure at least half full to ensure the capability of the pump to run for at least 4
hours. This run time was provided, in part, for a station blackout situation, where the
diesel-driven pump functions as a backup to the turbine-driven pump. The level
instruments were not calibrated but were functionally tested every two years under
Preventive Maintenance Procedure IC-PM-FW-0900, Operational Verification of FW-54
Fuel Oil Day Tank FO-38 Controls, Revision 1. This test procedure did not require that
the actual level in the tank be verified. Therefore, instrument drift over a long period of
time could result in tank levels deviating from the design objective.
The team postulated the following scenario: the level sensors and level indicator drift in
tandem over time to a lower setpoint, but still appear to be functioning normally during
the preventive maintenance functional tests. The drift continues following a test to a
point where the tank is actually less than half full and the low-level sensor of LI-2120
does not come in when the pump is started and expends the available fuel (in response
to an event). The pump runs for less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and then runs out of fuel oil as the
transfer pump fails to start and replenish the inventory.
Because the issue did not involve NRC regulations, a violation was not identified.
However, the team determined that this finding was of more than minor significance
because it had a credible impact on safety. That is, the design function of a risk-
significant component could be affected. Using Phase I of the significance determination
process, the team determined that the issue affected the mitigating systems cornerstone,
because it potentially impacted core decay heat removal. However, the finding had very
low risk significance (green) because there was not an actual loss of safety function and
the diesel engine powering the pump has a generator that can power a transfer pump to
replenish the day tank inventory. Because the issue did not involve NRC regulations, a
violation was not identified. The licensee initiated Condition Report 200200496 to review
this concern.
-7-
.5
Design Review
a.
Inspection Scope
The team reviewed the current as-built instrument and control, electrical, and mechanical
design of the auxiliary feedwater system and the emergency diesel generators. These
reviews included a review of design assumptions, calculations, required system thermal-
hydraulic performance, electrical power system performance, protective relaying, and
instrument setpoints and uncertainties. The team also performed a single failure review
of individual components to determine the effects of such failures on the capability of the
systems to perform their design safety functions.
The team reviewed calculations, drawings, specifications, vendor documents, Final
Safety Analysis Report, technical specifications, emergency operating procedures, and
temporary and permanent modifications.
b.
Findings
Failure to Account Adequately for Diesel Generator Fuel Oil Inventory
The team found that licensee staff had not accounted for several factors in the
determination of the diesel fuel oil on hand to meet the Technical Specification 2.7(1)m.
limit of 16,000 gallons of fuel oil in FO-1, the diesel generator fuel oil storage tank, and
an additional 8,000 gallons of diesel fuel oil in FO-10, the auxiliary boiler fuel oil storage
tank. The basis for the limit was to maintain a 7-day supply of fuel oil.
Calculation FC03382, Diesel Generator LOCA Loads ETS-2.08N-L1, Revision 15,
established 24,280 gallons as the required inventory of fuel oil. The design calculations,
combined with the technical specification limits, assured a minimum fuel oil inventory of
25,220 gallons (940 gallon margin). This information was detailed in a licensee
application for "Amendment of the Operating License," dated September 17, 1993. The
amendment was approved by a safety evaluation report, dated March 29, 1994. The
NRC staff found that the proposed fuel oil inventory was actually below a seven-day
supply, but above a six-day supply and that this situation was acceptable because
replacement oil could be obtained with high confidence within a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
The team reviewed Calculation FC06289, Diesel Generator Fuel Oil Storage Tanks
Level TLU Calculation, Revision 0. The team found that the licensee had not assessed
possible variations in specific gravity in the total loop uncertainty calculation. The
licensee can accept diesel fuel with a range of specific gravities between 0.8762 and
0.8156 or 30 to 42 American Petroleum Institute (API) units, a variation of a little more
than 7 percent. The level indicators assumed a specific gravity of 0.8550. Use of the
densest permissible fuel oil would result in a measured volume discrepancy of
approximately 2.5 percent. The team considered the total loop uncertainty calculation
(FC06289) to be inadequate. The licensee staff documented this concern in Condition
Report 200200464.
-8-
The level indicators for the main and auxiliary boiler tank were mechanically scribed with
an indication ranging from 250 -18130 gallons. The licensees calculation for the volume
of the fuel oil tanks, FC06289, calculated a volume of 240 -18050 gallons. This resulted
in a non-conservative zero shift of the indication. The licensee identified this as
Condition Report 200200373.
The team reviewed Engineering Analysis92-047, Diesel Generator Fuel Oil
Requirements, Revision 0. This calculation established a formula relating fuel
consumption to load demand on the diesel generator based on some test runs. The
formula was used in subsequent calculations, such as Calculation FC03382. The team
found that specific gravity had not been used as a variable in establishing the formula for
fuel consumption. Text book data (Diesel Engine Reference Book by L. R. C. Lilly,
published by Butterworths in 1984) indicated that the energy level of the fuel oil could
vary across the permissible range of American Petroleum Institute units by 2.34 percent.
The licensee staff documented the failure to consider this within the analysis in Condition
Report 200200464.
The team found that the licensee staff had not considered the consumption of fuel oil by
the diesel-driven auxiliary feedwater pump (FW-54) in the depletion of oil reserves. The
fuel oil transfer pump (FO-37) on the diesel-driven auxiliary feedwater pump was used
under certain conditions to transfer fuel oil from the auxiliary boiler tank to the fuel oil
tank. The team estimated the effect of operation of Pump FW-54 for the time to transfer
8,000 gallons to be 286 gallons, or 1.18 percent of 24,280 gallons. Procedure EPIP-RR-
17A, TSC Administrative Logistics Coordinator Actions, Revision 19, did not identify the
impact of Pump FW-54 consumption on the fuel oil inventory. The licensee staff
documented this analytical oversight in Condition Report 200200464.
The team questioned the volume used in calculations for the diesel generator engine
tank. The team measured and calculated the volume of the tank to be a maximum of
520 gallons per diesel generator, not the 550 gallons assumed. The licensee staff did
not have documentation of the unusable volume below the suction pipe of the fuel pumps
in the diesel engine base tank. The licensee estimated the unusable volume in the diesel
generator engine tank to be 30 gallons per tank. Together, the two errors were
120 gallons, or 0.50 percent of 24,280 gallons. The licensee staff documented this
concern in Condition Report 200200304.
In summation, the errors identified (only the major sources are discussed above)
amounted to a negative 5.23 percent or 1,271 gallons (well in excess of the analyzed
margin). Therefore, the team concluded that the technical specification limits for the
storage of emergency diesel generator fuel oil were not adequately supported by the
design calculations.
The team evaluated this finding using the significance determination process. The
finding did not have a credible impact on safety because the technical specification
storage limits provided more than a six-day supply of fuel oil, which was a sufficient
amount according to the safety evaluation report. However, inadequate design control
resulted in a technical specification limit that failed to assure that the assumed
operational requirement was met. This is important, because both the licensee and the
NRC depend on accurate technical specifications to ensure that operation of the plant is
-9-
consistent with design assumptions. The safety significance of the finding was found to
be very low (Green) because the 6-day requirement accepted in the safety evaluation
report was met.
The team identified this finding as a violation of Criterion III of Appendix B to
10 CFR Part 50, Design Control, which requires that the design basis be correctly
translated into the technical specifications. Because of the very low safety significance
and the licensees documentation of this issue into their corrective action program
(Condition Reports 200200464, 200200373, and 200200304), this violation is being
treated as a noncited violation in accordance with Section VI.A.1 of the Enforcement
Policy (50-285/0203-02).
.6
Safety System Inspection and Testing
a.
Inspection Scope
The team reviewed the program and procedures for testing and inspecting selected
components in the auxiliary feedwater system and the emergency diesel generators.
The review included the results of surveillance tests required by the technical
specifications.
During the week of February 25, 2002, the team observed the quarterly performance test
of the turbine-driven auxiliary feedwater pump, using Procedure SE-ST-AFW-3006,
"Auxiliary Feedwater Pump FW-10, Steam Isolation Valve, and Check Valve Tests,"
Revision 26.
b.
Findings
Issues Related to Testing of Turbine-Driven Auxiliary Feedwater Pump
The team identified two green noncited violations related to periodic testing of the
turbine-driven auxiliary feedwater pumps. Both of these issues involved crediting
operator actions in lieu of automatic actions or realigning equipment that normally only
maintains its standby configuration in response to an accident condition. These issues
may apply to additional testing or maintenance conducted at Fort Calhoun Station.
The NRC issued guidance concerning operator actions in Information Notice (IN) 97-28,
Crediting of Operator Actions in Place of Automatic Actions and Modifications of
Operator Actions, Including Response Times. The following is an excerpt from this
Notice:
"The original design of nuclear power plant safety systems and their ability to
respond to design-basis accidents were described in licensees' FSARs and were
reviewed and approved by the NRC. Most safety systems were designed to rely
on automatic system actuation to ensure that the safety systems were capable of
carrying out their intended functions. In a few cases, limited operator actions,
when appropriately justified, were approved. Proposed changes that substitute
manual action for automatic system actuation or modify existing operator actions,
including operator response times, previously reviewed and approved during the
-10-
original licensing review of the plant will, in all likelihood, raise the possibility of a
USQ. Such changes must be evaluated under the criteria of 10 CFR 50.59 to
determine whether a USQ is involved and whether NRC review and approval is
required before implementation. A licensee may not make such changes before it
receives approval from the NRC when the change, test, or experiment may
(1) increase the probability of occurrence or the consequences of an accident or a
malfunction of equipment important to safety previously analyzed in the FSAR,
(2) create the possibility of an accident or a malfunction of a different type than
any previously evaluated in the FSAR, or (3) reduce the margin of safety as
defined in the basis for any TS. In the NRC staffs experience, many of the
changes of the type described above proposed by licensees do involve a USQ."
In the two examples that follow, the licensee failed to determine properly whether
changes involving the substitution of manual for automatic actions created an inoperable
condition or a licensing issue requiring NRC approval.
Inadequate Test Procedure
While observing the quarterly performance test of the turbine-driven auxiliary feedwater
pump, FW-10, in accordance with Procedure SE-ST-AFW-3006, "Auxiliary Feedwater
Pump FW-10, Steam Isolation Valve and Check Valve Tests," Revision 5, the team noted
that, in Steps 7.16 through 7.23 of the procedure, the normally locked-open manual
suction valve, FW-350, of the motor-driven auxiliary feedwater pump was closed by an
operator and the control room switch for this pump was placed in pull-to-lock. While in
this configuration, the turbine-driven auxiliary feedwater pump, FW-6, as well as the
motor-driven pump discharge check valve were tested. The test procedure prescribed
that dedicated operators be stationed at the closed motor-driven pump suction valve and
at the pump switch in the control room ready to restore the normal configuration if so
directed. The procedure considered the motor-driven pump to be operable in this
configuration as long as the operators were stationed and ready to perform actions as
prescribed. The team disagreed and stated that the motor-driven pump should have
been declared inoperable while in this configuration and that the licensee should have
entered Technical Specification 2.5(1) limiting condition for operation, which permits up
to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operation with one of the two safety-related auxiliary feedwater pumps
inoperable. The basis for the teams position was that the technical specifications and
the Final Safety Analysis Report, as well as any other regulatory document, did not
permit operator actions to be used as a condition to establish equipment operability
during surveillance testing. The team considered the cause of this problem to be an
inadequate test procedure, for failing to identify an instance of inoperability.
This finding was determined to have a credible impact on safety, in that, the failure to
open the suction valve or restore the switch position of the motor-driven pump could
potentially cause damage to the pump or preclude the flow of auxiliary feedwater to the
-11-
Using Phase 1 of the Significance Determination Process, the team determined that only
the mitigation systems cornerstone was affected and there was no actual loss of safety
function as the turbine-driven pump remained operable and the dedicated operators
could be considered to be highly reliable. Therefore, the problem had a very low safety
significance (Green).
The team determined that the test procedure was inadequate and identified this as a
violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and
Drawings. Because of the very low safety significance, and because the licensee
included the finding in their corrective action program as Condition Report 200200483,
this violation is being treated as a noncited violation (50-285/0203-03) in accordance with
Section VI.A.1 of the Enforcement Policy.
Inadequate Safety Evaluation for Change to Surveillance Test Procedure
The team noted that, during a portion of Procedure SE-ST-AFW-3006, both of the safety-
related auxiliary feedwater pumps (the turbine-driven and the motor-driven) were
rendered inoperable at the same time. Step 7.29 of the procedure declared the turbine-
driven pump inoperable since pump discharge flow was about to be directed to the
emergency feedwater storage tank and operators were to take control of the pump speed
control loop. In Step 7.34, the locked-open manual feedwater valve, FW-170, was
closed and normally-closed motor-operated valve, HCV-1384, the main and auxiliary
feedwater cross-connect valve, was opened. In step 7.36, the normally locked-closed
discharge valve to the emergency feedwater storage tank, FW-1049, was opened. The
effect of changing the positions of these three valves was to direct flow to the emergency
feedwater storage tank and block the alternate auxiliary feedwater flow path to the steam
generator feed rings (where normal feedwater enters the steam generators). The normal
auxiliary feedwater discharge path to the steam generators remained open, but the flow
from both the turbine-driven pump and the motor-driven pump was diverted to the
auxiliary feedwater storage tank. At this time, the licensee did not declare the motor-
driven feedwater pump inoperable even though the flow from this pump would take the
same path as the turbine pump to the emergency feedwater storage tank. The team
noted that the non-safety-related diesel-driven feedwater pump, FW-54, would be
inoperable as well, since its flow would also go to the emergency feedwater storage tank
instead of the steam generator. With flowpaths open both to the steam generators and
to the storage tank, it was uncertain (the licensee had not performed an evaluation) if
sufficient flow would be available to the steam generators in this configuration (even if all
pumps were running). The licensee credited operator actions in the control room to
restore Motor-Operated Valve HCV-1384 to its normal closed position, which would
permit the motor-driven pump to deliver its entire flow to the steam generators. The
team concluded that the use of operator actions as a condition for operability was not
permitted for surveillance testing.
Technical Specification 2.5, "Steam and Feedwater Systems," states, "(1) during
Modes 1 and 2, one auxiliary feedwater pump may be inoperable for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,
provided that the redundant component shall be tested to demonstrate operability", and
"(3) All valves, interlocks and piping associated with the above components required to
function during accident conditions are operable. Manual valves that could interrupt
auxiliary feedwater flow to the steam generators shall be locked in the required position
-12-
to ensure a flow path to the steam generators." The team determined that the failure of
the licensee to maintain the motor-driven auxiliary feedwater pump operable while the
turbine-driven pump was declared inoperable during the test and, in addition, the failure
to maintain the manual valves in the required locked position to ensure a flow path to the
steam generators was contrary to Technical Specification 2.5.
The team reviewed Procedure Change Request 42290, dated April 21, 1994. This
procedure change revised the auxiliary feedwater pump test procedure to permit a
full-flow test of the turbine-driven pump and included credit for operator actions to
manipulate valves and change lineups to maintain the operability of the motor-driven
pump.
The team reviewed the 10 CFR 50.59 screening associated with Procedure Change
Request 42290. Question 9.4 of the screening, asking whether the change involved a
change to the technical specifications, was answered no, stating that Technical Specification 2.5 had been reviewed and needed no changes. The team noted that the
screening failed to demonstrate that operator actions prescribed by the procedure
change would be sufficient to ensure that the motor-driven pump could still meet its
design function, in terms of both reliability and timing and, thus, maintain compliance with
Technical Specification 2.5 (1). Also, the screening failed to identify that Technical Specification 2.5 (3) was affected by the unlocking and movement of locked valves that
would need to be manually re-positioned.
10 CFR 50.59(a)(1)(iii) [as the regulation existed at the time of this violation] allowed a
licensee to conduct tests or experiments not described in the Final Safety Analysis
Report without prior Commission unless the proposed test or experiment involved a
change in the technical specifications or an unreviewed safety question. The team
concluded that the licensees' failure to recognize that Technical Specifications 2.5(1) and
2.5(3) were not being met by relying on operator action, and that therefore prior
Commission approval was needed, was a violation of 10 CFR 50.59(a)(1)(iii).
This finding was determined to have a credible impact on safety, in that, it involved a
flawed analysis that ultimately led to operation of the plant in a manner not anticipated in
the original license.
Using Phase 1 of the Significance Determination Process, the team determined that only
the mitigation systems cornerstone was affected and that the reliability of the operator
actions needed to restore system operability was very high. Also the plant was in this
configuration for only approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per month. Therefore, this finding was
determined to have a very low safety significance (Green).
Because of the low safety significance, and because the licensee included the item in
their corrective action program as Condition Report 200200632, this violation is being
treated as a noncited violation (50-285/0203-04) (EA 02-059) in accordance with Section
VI.A.1 of the Enforcement Manual.
-13-
4
OTHER ACTIVITIES (ZA)
4OA6 Management Meetings
Exit Meeting Summary
The team leader presented the inspection results to Mr. D. Bannister, Plant Manager,
and other members of licensee management at the conclusion of the onsite inspection
on March 1, 2002.
At the conclusion of this meeting, the team leader asked the licensees management
whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified.
A supplemental exit meeting was conducted by telephone on March 11, 2002, with
Mr. R. Ridenoure, Division Manager, Nuclear Operations, and other members of licensee
management.
ATTACHMENT
Licensee Contacts :
D. Bannister, Plant Manager
G. Cavanaugh, Supervisor, Station Licensing
M. Frans, Manager, Nuclear Licensing
S. Gebers, Corporate Health Physicist
R. Haug, Manager, Chemistry
R. Lentz, Licensing Engineer
E. Matzke, Station Licensing Engineer
J. McManis, Manager, Design Engineering
G. Miller, Inservice Testing Coordinator
M. Puckett, Manager, Radiation Protection
J. Ressler, Mechanical Design Engineer
R. Ridenoure, Division Manager, Nuclear Operations
NRC:
W. Walker, Senior Resident Inspector
L. Willoughby, Resident Inspector
ITEMS OPENED AND CLOSED
Opened and Closed
50-285/0203-01
Inadequate Corrective Action for Defective Emergency Diesel
Generator Air Starting System Air Relay Valves (Section 1R21.3.b)
50-285/0203-02
Inadequate Design Control of Emergency Diesel Generator Fuel
Oil Inventory (Section 1R21.5.b)
50-285/0203-03
Inadequate Procedure for Testing Auxiliary Feedwater Pumps
(Section 1R21.6.b )
50-285/0203-04
Inadequate 10 CFR 50.59 Safety Evaluation Associated with
Change to Auxiliary Feedwater Pump Test Procedure
(Section 1R21.6.b)
-2-
Documents Reviewed
Condition Reports:
199601064
199700434
199700523
199701063
199701248
199800133
199800495
199801246
199801563
199801642
199900170
199900611
199901062
199901558
199901600
199901608
200000708
200000723
200000866
200000870
200000931
200001124
200001194
200001758
200100008
200100399
200100407
200100407
200100407
200100623
200101064
200101108
200101108
200101265
200101265
200101398
200101472
200101515
200101515
200101854
200101906
200101907
200101907
200102254
200102254
200102256
200102256
200102383
200102407
200102419
200102419
200102437
200102437
200102573
200103112
200103112
200103141
200103319
200103419
200103557
200103692
200103716
200103736
200103772
200103837
200200126
200200126
200200160
200200184
200200275
200200283
200200286
200200304
200200322
200200464
200200475
200200476
200200496
200200498
200200632
Calculations:
FC03382, Diesel Generator LOCA Loads ETS-2.08N-L1, Revision 15
FC03519, Analysis Summary for Loss of all Auxiliary Feedwater Equipment due to FW-10
Steam Line Break, Revision 0
FC05007, Usable Capacity of Emergency Feedwater Storage Tank FW-19, Revision 0
FC05040, Calculation of the Flowrate for the Auxiliary Feedwater Pump (FW-6), During Last
Startup, Revision 0
FC05045, FW-10 Steam Line HELB, Revision 01
FC05072, Auxiliary Feedwater Maximum Operating Temperature and Pressure Calculation,
Revision 0
FC05073, Auxiliary Feedwater Pumps Design Calculation, Revision 0
FC05361, Auxiliary Feedwater System Calculation (Pump Design and Turbine Drive
Controller), Revision 5
FC05365, Auxiliary Feedwater Flow and Head Requirements, Revision 0
FC05467, Fuel Oil Transfer Pump FO-4A-1 and 2 and FO-4B-1 and 2 Discharge Pressure and
Motor Horsepower, Revision 0
FC05492, Diesel and Operating Conditions for the Diesel Generator Fuel Oil System,
Revision 1
-3-
FC05587, Emergency Diesel Generator Instrument/Relief Valve Setpoint Calculation,
Revision 1
FC05829, MOV Degraded Voltage Calculation, Revision 8
FC05916, Operating Temperature Limits for DG-1 and DG-2, Revision 3
FC06148, Auxiliary Feedwater Storage Requirements, Revision 3
FC06181, Auxiliary Feedwater System Flow Rates with SE-ST-AFW-3005 Recirculation Path to
EFWST in Service, Revision 0
FC06289, Diesel Generator Fuel Oil Storage Tanks Level TLU Calculation, Revision 0
FC06638, Capacity of Fuel Oil Tank FO-38, Revision 0
Engineering Analyses:
EA-FC-029, "IST Review of Surveillance Test Pump Procedures," Revision 0
EA-FC-90-028, "Effect of Single Failure of FW-10 Overspeed Limiting Governor," Revision 2
EA-FC-91-010, No Title, Revision 0
EA-FC-91-084, Breaker/Fuse Coordination Study, Revision 4
EA-FC-92-047, Diesel Generator Fuel Oil Requirements, Revision 0
EA-FC-92-072, Diesel Generator Loading Transient Analysis ETS-2.08N-MS1, Revision 2
EA-FC-92-080, Resolution of MOV Operating Conditions Design Basis Discrepancies, Revision 5
EA-FC-92-082, Provide Test Conditions for MOVs Covered by GL 89-10, Revision 4
EA-FC-93-010, "Steam Leak Through FW-1314 in Room 19," Revision 0
EA-FC-95-022, NFPA 13 Code Compliance Verification Checklist - Diesel Generator Rooms Dry-
Pipe System, Revision 2
EA-FC-95-048, Evaluation of Susceptibility of Safety Related Power Operated Gate Valves to
Pressure Locking or Thermal Binding, Revision 2
EA-FC-96-12, Safety Significance of the MFIVs and Their Ability to Open,
Revision 0EA-FC-96-134, Evaluation of Hydraulic Snubber Inspection Results, Revision 0
EA-FC-97-012, "Evaluation of Reduced Auxiliary Feedwater Flow," Revision 0
-4-
IC-PM-FW-0900, "Operational Verification of FW-54 Fuel Oil Day Tank FO-38 Level Controls,"
Revision 1
OP-ST-AFW-0004, Auxiliary Feedwater Pump FW-10 Operability Test, Revision 21
Design Basis Document
SDBD-DG-112, Emergency Diesel Generators, Revision18
Drawings:
B120D06002, Sheet 1, Auxiliary Fuel Oil Day Tank, Revision 5
B120F14501, Sheet 2, Schematic Engine Control, Revision 15
D-4665, DG-1 Diesel Generator One Line Diagram, Revision 5
D-4666, DG-2 Diesel Generator One Line Diagram, Revision 5
11405-E-1, Main One Line Diagram, Revision 36
11405-E-3, 4.16 KV. Auxiliary Power One Line Diagram, Revision 19
11405-E-7, Sheet 2, 480 Volt Primary Plant Motor Control Center One Line Diagram, Revision 17
11405-M-282, Sheet 1, Fuel Oil Flow Diagram, Revision 54
13229, Fuel Oil Tank FO-1, Revision 5
17016, DG-1 and DG-2 Diesel Generator Assembly, Revision 5
17396, Sheet 16, Schematic Engine Control, Revision 6
17398, Sheet 18, Schematic, Engine Control, Revision 8
Fig. 8.1-1, Simplified One Line Diagram Plant Electrical System, Revision 117
11405-M-252, Cover Sheet, Composite Flow Diagram Main Steam P & ID, Revision 24
11405-M-252, Sheet 1, Flow Diagram Steam P & ID, Revision 92
11405-M-253, Cover Sheet, Composite Flow Diagram Steam Generator Feedwater and
Blowdown P & ID, Revision 26
11405-M-253, Sheet 4, Flow Diagram Steam Generator Feedwater and Blowdown P & ID,
Revision 29
11405-M-254, Cover Sheet, Composite Flow Diagram Condensate P & ID, Revision 31
-5-
11405-M-262, Sheet 1, Fuel Oil Flow Diagram P & ID, Revision 54
Miscellaneous:
OPPD Letter Dated September 17, 1993
NRC Safety Evaluation Date March 29, 1994
System Training Manual, Volume 16, Emergency Diesel Generators, Revision 19
Nuclear Procurement Manual NPM-260, Revision 1
Material Discrepancy Report [PO. S042950], December 2, 1999
EPRI Report NP-6608, Shelf Life of Elastomeric Components, May 1994
Self Assessment LIM-01-0024, an assessment of the 10 CFR 50.59 process, report dated
December 28, 2001
Report LIC-01-0076, 10 CFR 50.59 Twenty Four Month Report to NRC, October 5, 2001
Safety Audit Review Committee Report (Meeting Minutes) 02-QUA-011, January 23, 2002
Procedure PED-QP-3, Calculation Preparation, Review, and Approval, Revision 7 dated June 14,
2001
10 CFR 50.59 Continuing Training Plan
SDBD-FW-AFW-117, "Design basis document auxiliary feedwater," Revision 23
TM C438.0010, Technical Manual for Coffin Turbo Pump Auxiliary Feed Pump, Revision 10
Procedures:
AOP-06, "Fire Emergency," Revision 9AOP-07, "Evacuation of Control Room," Revision 7
AOP-17, "Loss of Instrument Air," Revision 4
AOP-23, "Reset of Engineered Safeguards," Revision 6
AOP-31, "161 KV Grid Malfunctions," Revision 5
AOP-32, "Loss of 4160 Volt or 480 Volt Bus Power," Revision 6
EM-ST-DG-0001, "Diesel Generator and Emergency 4.16 kV Bus Protective Relays," Revision 7
-6-
EM-ST-ESF-0001, "Quarterly Engineered Safety Features Offsite Power Low Signal (OPLS)
Sensor Check," Revision 7
EOP-00, "Standard Post Trip Actions," Revision 15
EOP-01, "Reactor Trip Recovery," Revision 8
EOP-02, "Loss of Offsite Power, Loss of Forced Circulation," Revision 10
EOP-03, "Loss of Coolant Accident," Revision 18
EOP-07, "Station Blackout," Revision 8
EPIP-RR-17A, TSC Administrative Logistics Coordinator Actions, Revision 19
FCSG-23, 10 CFR 50.59 Resource Manual, Revision 1
NOD-QP-3, 10 CFR 50.59 Reviews, Revision 23
OI-AFW-4, Auxiliary Feedwater Startup and System Operation, Revision 42
OI-AWF-1-CL-A, "Operating Instruction Auxiliary Feedwater," Revision 49
OI-DG-1, Diesel Generator No. 1, Revision 31
OI-DG-2, Diesel Generator No. 2, Revision 36
OP-FT-DG-0002, "Function Test: Emergency Diesel Generator Endurance Functional Test,"
Revision 9
OP-PM-AFW-0004, "Third Auxiliary Feedwater Pump Operability Verification," Revision 23
OP-ST-AFW-0001, "Auxiliary Feedwater System Valve Alignment Check," Revision12
OP-ST-AFW-0004, Auxiliary Feedwater Pump FW-10 Operability Test, Revision 21
OP-ST-DG-0001, "Surveillance Test: Diesel Generator 1 Check," Revision 35
OP-ST-DG-0002, "Surveillance Test: Diesel Generator 2 Check," Revision 36
OP-ST-ESF-0001, "Surveillance Test: Diesel Auto Start Initiating Circuit Test," Revision 18
OP-ST-ESF-0002, "Surveillance Test: Diesel Generator No. 1 and No. 2 Auto Operation,"
Revision 24
OP-ST-ESF-0006, "Engineered Safety Features Off-site Power Low Signal (OPLS) Functional
Test," Revision 17
-7-
OP-ST-ESF-0022, "S1-2 Automatic Load Sequencer Test," Revision 18
OP-ST-ESF-0023, "S2-2 Automatic Load Sequencer Test," Revision 19
PED-SEI-12, "Guidelines for FCS lube oil test results and action parameters," Revision 7
SO-M-11, Maintenance Work Control, Revision 54
SO-R-01, Reportability Determination, Revision 08
SO-R-02, Condition Reporting and Corrective Action, Revision 19
SS-PFT-TX- 1002, "Performance functional test valve monitoring program," Revision 2
Modifications Packages
DCN 2796 (MR-FC-96-013), Snubber Upgrades
EC 11239 (MR-FC-95-003), Replace Bad Actor Relays for DG-1& DG-2"
EC 11260 (MR-FC-95-024), Steam Trap on FW-10 Steam Chest
EC 11296 (MR-FC-97-021), Diesel Generator Tach. Loop Isolation
EC 13583 (ECN-96-048), Diesel Generator Lube Oil Low Temperature Alarm
EC 13584 (ECN-96-049), Diesel Generator Starting Air Relief Valves
EC 13915 (ECN-97-135), Remove Expanded Metal Cage Around FW-10"
EC 13953 (ECN-97-196), Revise Engine Mounting on Diesel Engine FW-56"
EC 14002 (ECN-97-321), Replacement of FW-56 Fuel Shutoff Solenoid
EC 14994, (DCN 10282), FW-10 Reliability Enhancements
EC 14992, FW-10 Reliability Enhancements, Revision 10
ECN 93214, SGBP System Isolation Mechanical, Revision 0
EC 14994, FW-10 Reliability Enhancements, Revision 0
Temporary Modification Package
EC 15045 (DCP 10375/ DCN 10333), Place FW-10 throttle valve positioner YC-1039-2 in bypass
so it can be removed and rebuilt without taking FW-10 out of service, Approved June, 12, 2000
Surveillance Tests:
IC-ST-DG-0017, Calibration of Emergency Diesel No. 1 Auxiliary Fuel Oil Day Tank Level Control
and Alarm, dated December 27, 2001
IC-ST-DG-0057, Calibration of Emergency Diesel No. 2 Auxiliary Fuel Oil Day Tank Level Control
and Alarm, dated February 6, 2002
OP-PM-AFW-0004,Third Auxiliary Feedwater Pump Operability Verification, Revision 12,
Performed January 21, 1998
-8-
OP-ST-ESF-0002, Diesel Generator No. 1 and No. 2 Auto Operation, dated April 16, 2001,
October 27, 1999, and May 3, 1998
OP-ST-ESF-0006, Engineered Safety Features Off-Site Power Low Signal (OPLS) Function Test,
dated April 7, 2001, October 28, 1999, and May 4, 1998
OP-ST-ESF-0022, S1-2 Automatic Load Sequencer Test, dated December 27, 2001, October 4,
2001, July 12, 2001 and April 23, 2001
OP-ST-ESF-0023, S2-2 Automatic Load Sequencer Test, dated February 25, 2002, November 29,
2001, September 5, 2001, and June 13, 2001
OP-ST-SHIFT-0001, Operations Technical Specification Shift Surveillance, for December 2001,
January 2002, and February 2002
10 CFR 50.59 Evaluations Associated with the Following Documents
Design Change Notice DCN-10235, RC-3A L. O. Cooler CCW Supply Piping Replacement,
April 25, 2000
Design Change Notice DCN-10271, M22 Penetration Inside Containment Manual Valve, July 24,
2000
Design Change Notice DCN-10282, FW-10 Reliability Enhancements, July 27, 2000
Engineering Change EC-14643, CCWA Corrosion Monitor, February 18, 1998
Engineering Change EC-25423, Temporary Air Supply to FCV-1904 A/B/C, September 6, 2000
Engineering Change EC-25851, Pressurizer Temperature Nozzle Leak Repair, October 26, 2000
Engineering Change EC-25898, Pressurizer TE-107 Mechanical Nozzle Seal Assembly,
October 30, 2000
Engineering Change EC-26581, Component Cooling Water System Drain Down and Refill,
March 8, 2001
Engineering Change EC-27317, Install a Second Isolation Valve on the Sample Line of Each
Safety Injection Tank, April 26, 2001
Engineering Change EC-27083, UT Void Detection for LPSI Injection Lines, April 12, 2001
Engineering Change EC-28349, Install Restraint on IA Piping to HCV-1041A Actuator,
August 28, 2001
-9-
10 CFR 5.59 Screenings Associated with the Following Documents
Procedure OP-ST-FO-3001 (EC-28451), Diesel Generator 1 Fuel Oil System Pump Inservice
Test, September 20, 2001
Procedure OP-ST-AFW-0001 (EC-29137), Aux FW System Valve Alignment Check, January 17,
2002
Procedure OI-EE-3 (EC-28171), 125 VDC System Normal Operation, August 30, 2001
Procedure OI-AFW-4 (EC-28785), Aux FW Startup and System Operation, November 15, 2001
Procedure EOP-00 (EC-25657), Standard Post Trip Actions, September 20, 2001
Procedure PE-ST-VX-3001 (EC-27830), ASME Section XI Code Relief Valve Test for the CCW
System, June 26, 2001
Procedure OI-CH-3 (EC-28724), Chemical and Volume Control System Normal Operation of
VCT, November 15, 2001
Procedure OI-MS-1A (EC-27987), Main Steam System Operation, July 31, 2001
Procedure OI-RM-1 (EC-14940), Radiation Monitoring, December 7, 2001
Procedure IC-ST-RPS-0010 (EC-27565), Quarterly Function Test of Low Flow Reactor Coolant
Trip Units, June 7, 2001
Calculation FC 03382, Diesel Generator LOCA Loads ETS-2.08N-L1, January 16, 2002
Purchase Order
PO S042950: From Morrison Kundsen Co. Inc., 1989 (Air relay valves)
Work Orders
19232, completed May 21, 1999
70415, completed October 6, 2000
83895, competed May 30, 2001
103960, completed December 13, 2001
Work Request 39332, Troubleshoot D2 air relay valve, leaks during engine start, October 17, 2001
-10-
Licensee Event Reports
1997-004, Diesel Generator Outside of Design Basic Due to a Violation of Appendix R,
Revision 1
1998-005, Emergency Diesel Generator Start Due to Failure of one of the Off Site Power
Sources, Revision 0
1998-008, Over Pressurization of Auxiliary Feedwater Piping Due to Misadjustment of Governor,
Revision 0
1999-001,Shutdown Technical Specification Entry Due to Auxiliary Feedwater Inoperability,
Revision 0
Quality Surveillance Observations
070, 03/08/01
083, 03/15/01
184, 04/27/01
194, 04/29/01
254, 06/21/01
342, 09/13/01
414, 10/29/01
472, 11/29/01
475, 11/29/01
604, 12/27/01