ML20034C592
| ML20034C592 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/16/1990 |
| From: | Galiardo J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034C590 | List: |
| References | |
| 50-285-90-14, NUDOCS 9005040184 | |
| Download: ML20034C592 (9) | |
See also: IR 05000285/1990014
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APPENDIX-B
U.S. NUCLEAR REGULATORY COMMIS$10N-
P.EGION IV
NRC Inspection Report: 50-285/90-14
Operating License: DPR-40
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Docket: 50-285
Licensee: OmahaPublicPowerDistrict(OPPD)
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444 South 16th Street Hall
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Omaha, Nebraska- 68102-2247
Facility Name: FortCalhounStation(FCS)
Inspection =At:
FCS, Blair, NE
Inspection Conducted
March 12-16, 1990
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Inspector:
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'nter, Senior Reactor Inspector,
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nal Program Section
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Approved:
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J.\\E. Gyliardo, Chief, Operational Program
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Section, Division of Reactor Safety
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Inspection Summary
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Inspection Conducted March 12-16, 1990 (Report 50-285/90-14)
Areas Inspected: Routine, unannounced inspection of abnormal and alarm
response procedures and the followup of previously identified inspection
findings.
Results: Within the two areas inspected, one violation was identified
(inadequate abnormal operating procedures, paragraphs 2.2 and 2.3).
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The overall upgrade of the abnormal operating procedures was completed by the
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licensee in December 1989; however, deficiencies were identified during.this
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inspection regarding the scope / coverage of two of the three abnormal procedures
selected for review. The deficiencies were associated with malfunctions-which
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would likely result in a plant transient. The licensee had not fully assessed
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the need for detailed written off-normal procedures and had continued to depend
heavily on-the overall experience and expertise of the operating crews to
respond properly to the events.
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The licensee had recently determined that the station electrical and certain
other procedures were within-the scope of the initial safety-related procedure
upgrade program.
The licensee was in the' process of developing and fornelizing
procedure classification _ criteria and reassessing all the plant procedures to
ensure proper classification. Additionally, the licensee had recently-
commenced the upgrade of the 1408 annunciator response procedures'with plans
for completion in early 1991. Selected-groups of the annunciator procedures
had been.given priority in order to have the procedures available for initial ~
sinolator activities commencing in mid-1990.
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DETAILS
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PERSONS CONTACTED
OPPD'
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- W. G. Gates. Division Manager, Nuclear Operations
- R. L. Andrews, Division Manager; Quality & Environmental Affairs
- S.-K. Gambhir, Division Manager, Production Engineering;
- G. R. Peterson, Manager
- J.- K. Gasper, Manager, Training-
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- R. L. Jowarski, Manager, Station Engineering
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- L. T. Kusek, Manager, Nuclear Safety Review -
- T. J. McIvor, Manager, Nuclear: Projects
' *R. Phelps, Manager, Design Engineering (.QA)/ Quality Control (QC) -
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- W. W. Orr, Manager, Quality Assurance
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- P. Swartz, Manager, Electrical
Instrumentation and Control-(I&C)
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- J. W. Tills, Assistant Manager
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- R. Mueller . Supervisor, Nuclear Projects
- D. J. Mathews, Supervisor, Station Licensing
- T. G. Therkildsen, Supervisor,-Nuclear Licensing
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- D. W. Dale, Supervisor, QC-
-D. Trausch, Supervisor, Operations
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J. Fluehr, Supervisor, Technical Training-
- C. Huang, Supervisor, HPES/RCA
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F. Simons, Station Licensing Engineer
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- T. C. Mathews, Station Licensing Engineer
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Stice, Licensing Engineer
D. Stading, Procedures Review Project
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M. Lazar, Supervisor,. Technical Training
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- S. Swearingen, Nuclear Safety Review Specialist
- R. Short, Supervisor, Special Services Engineering
- C.- Boyd, Special Services Engineer
- R. Lippy, Special Services Engineer
- P. Hamer, Special Services Engineer
NRC
- J. Gagliardo, Chief Operational Programs Section
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- P. Harrell, Senior Resident Inspector,.FCS
Other members of the technical and administrative staff were also contacted,
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- Denotes those attending the management exit on March 16, 1990.
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2.
FOLLOWUP ON PREVIOUSLY IDENTIFIED INSPECTION FINDINGS (92701)
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(0 pen)InspectorFollowupItem(285/8936-01): Development o'f Acceptance'
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Criteria Regarding the Classification of Safety-Related Procedures.
The lack of definitive acceptance criteria associated with the classification
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of the safety-related procedures to be included in the procedures upgrade
program was identified'during the previous inspection conducted in September-
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1989.
Document reviews and interviews revealed that seven electrical procedures had
been added to the. list of safety-related procedures. The' initial review of the
list of operations procedures by the licensee revealed that 43 other procedures-
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were.apparently safety-related and another 31 procedures were potentially-
safety-related. The system for the classification of procedures _was. presently
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being developed. The project completion,- including the reassessment of all-
procedures, was scheduled for April 1990. This issue will remain open as an-
. inspector followup item pending the: completion of the project by the licensee.
2.2 '(0 pen) Inssector Followup Item (285/8936-03): AbnormalOperating(A0P)
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and Alarm Response (ARP) Procedures. The AOPs and ARPs required further
review following the completion of the procedure apgrade project by the
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licensee.
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The inspector reviewed selected A0Ps for scope'and content to ensure that;the
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procedures addressed the requirements of Technical Specification 5.8,
Procedures; ANSI N18.7-1972, Sections 5.3, " Operating and Maintenance'
Procedures"; Sections E and F (5 and 6) of Appendix A to RG 1.33; FCS.QA
Program, Appendix A to USAR, Section A.6, " Instructions, Procedures, and
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drawings"; FCS QA Plan, Section 2.1, " Procedures and Instructions"; and USAR,
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Section 12.3, " Conduct of Operations."
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Document reviews and interviews revealed that the licensee completed the A0P'
upgrade / rewrite program on December 7, 1989, and the revised procedures became
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effective on January 4,1990. The A0P upgrade project included procedure
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restructure and reformating, some regrouping, and a comparison of the FCS plant
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procedures to certain other plants. However,.a specific project directive or
charter was not provided. The writer's guide, utilized for the upgrade
project, was subsequently issued as a Station Procedure 50-G-74, " Fort'Calhoun
E0P/A0P Writer's Guide," Revision 0 (December 12,1989). The results of the
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review of specific procedures is discussed in the following sections.
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2.2.1 A0P-02, "CEA and Control System Malfunction," Revision 0 (January 4,
1990)
The AOP addressed the following situations:
Section I, Inoperable, Stuck, or Untrippable Control Element Assembly
(CEA);
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Section II, Hisaligned CEA;
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Section III, Unplanned / Uncontrolled CEA Withdrawal; and-
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Section IV, Loss of Position Indication or Function.
The inspector reviewed the procedure.and associated ARPs to determine if.the .
.AOPincluded-selectedforeseeablereactor/planttransients(excursionsand/or
perturbations) resulting from a control system malfunction. An unplanned /uncon-
trolled CEA insertion (negative reactivity insertion-and reactor power reduction)
producing reactor-turbine power mismatch was.not sufficiently addressed in
'the procedure. This scenario would result in ~a reactor trip from system low . ,
pressure (transient / excursion / perturbation)intheabsenceofpositivecorrective:
actions by the operators to return the plant to stable conditions. The procedure-
did not specify the prompt operator actions to: terminate the transient, and-
prevent the challenge.to the reactor protection system by the elimination
of the reactor-turbine power mismatch.
Interviews with the licensee revealed that the rod control selector switch was
generally maintained in the "0FF" position when not in use; therefore, the.
chances for CEA withdrawal or insertion events were minimized.
In addition-to-
.the AOP, the inspector reviewed the anunciator. response procedures (ARP)
associated with the reactor controls (Panel CB-4, Annunciators'A7 and A8). The
ARPs provided minimal guidance regarding1the automatic actions, immediate-
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operators actions, and long-range operator actions to. address'the response and
recovery actions associated with this foreseeable event.
The review of A0P-02 by the inspector also revealed an apparent inconsistency
regarding the use of applicable Technical-Specifications (TS) references. The
applicable TS was not generally referenced; however,-(in one instance).
TS2.10.2(1),regardingshutdownmarginrequirements,wasspecifically
referenced in Section I of the procedure. The methodology for including the TS
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requirement within the procedure and/or referencing the TS requirement was not
addressed by the A0P/E0P Writer's Guide (50 G.74). This item was discussed
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with the licensee.
A specific cross reference to the documents providing the basis for A0P-02 was
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notprovided(e.g...specificUSAR,TS,orcommitment). Discussions with the
licensee revealed that a " Design Basis Document" was being.develo
A0P which would provide.the specific bases and cross references. ped for each
The licensee
indicated that these docun'ents were scheduled to.be: issued sometime in the
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April 1990,
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2.2.2 A0P-16, " Loss of Instrument Bus Power," Revision 0 (January 4,1990)
-The A0P addressed the four safety-related 120V AC inverter buses (AI 40A, 40B,
40C,and40D). Document review and interviews revealed that vital equipment-
receiving electrical power from the inverter buses, including inputs to the CEA
clutch power panels, the radiation monitoring panels, the reactor regulating
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systems, and the feedwater regulation systems. The procedure did not address
the impact of the foreseeable loss, partial loss, and/or degradation of these
vital power sources on the reactor plant and other vital equipment. Positive
operator corrective actions were not adequately addressed.
Interviews revealed
that the licensee had not provided a detailed evaluation of the loss of the
120V AC inverter buses and the impact on the plant.and other vital equipment.-
The specific operator actions required to cope with these foreseeable conditions,
are'needed'to assure safe; operation of the plant.
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The failure to address adequately the loss or degradation of the vital bus
power- sources (120V AC . inverter buses 40A.- 40B, 40C, and 40D) including the
impact on the plant and'the required-operator actions is an apparent
violation (285/9014-01) of Technical Specifications 5.8.1, which requires'that
written procedures shall be established to provide guidelines to the operators
for off-normal conditions that could-' degenerate into true emergencies.
The inspector also questioned the fact that the A0Ps did not address the loss of
twoadditional120VACinverterbuses(Al42A/IB1AandA142B/IB1B),which
provided power to the steam plant and turbine control board,
2.2.3 AOP-07, " Evacuation.of-'the Control Room," Revision 0 (January 4; 1990)
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The inspector. reviewed the procedure for overall content and checked the'
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procedure specifics to ensure that adequate directions were provided to
operators regarding the-performance of the procedure-steps (e.g.. valve
numbers, panel numbers, specific locations)
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No deficiencies were identified in this procedure.
2.2.2 AnnunciatorResponseProcedures(ARP)-
The inspector reviewed the status of the ARP-rewrite program. Document reviews
and interviews revealed that the ARP rewrite program was in progress. The
detailed project plan and a writer's guide for ARPs-(S0 G-75) had been drafted.
Theilicensee had identified 1408 annunciator windows associated with 55 alarm
panels. The licensee was in the process of placing.a priority for upgrading
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the ARPs based on a judgement regarding the importance of the panels and to '
assure they would be availab!c for initial simulator activities.
The project had been estimated to require over 2 man-years of effort and
additional manpower was assigned to the project. The projected completion date
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was early 1991.
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This matter will remain open pendire the completion of the ARP rewrite program.
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2.3 (Closed)Inge,;torFollowupItem(285/8936-04): Loss or Degradation of
Power to Vital AC Buses (4160V AC and 480 V AC) and Associated Load
Distribution Centers
The need for these procedures was . identified to the licensee during.the
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previousinspection-(50-285/89-36) in September 1989. During the review of;
E0P-2, " Loss of Off-Site Power / Loss of Forced Circulation " the inspector-
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noted that-the licensee-apparently had no procedures which addressed the
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actions to be taken for a loss or degradation of_ electrical' power to the; vital-
AC buses. During the exit interview, the-licensee acknowledged the concern
and stated that they would evaluate the issue and take appropriate action'to;
correct the concern.
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Although the licensee had revised Item 48 of the Safety Enhancement Program-(SEP)
to incorporate the revision to the ARPs as discussed in paragraph 2.2.2 above,.
-_they had not revised Item 49, " Revise and Conduct Training on Emergency and-
Abrormal 0perating' Procedures." When questioned about this, a licensee represen-
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. tative stated that this. issue had not been included in a revision =to Item 49
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'because of an oversight. He stated that Item 49 had already been closed.and-
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.they had no' desire to reopen it.- The licensee's representative agreed that
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there was'a need to evaluate the loss.or degradation'of the electrical power
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" supplies, including the 4160V AC, 480V AC, 480V AC motor control centers? l20V
AC and 125V DC. The licensee: representative stated that on or about yay 1,;
1990, they would begin.to evaluate-the-total plant-electrical' power systems for
impact and to determine the need for providing appropriate procedures to.
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respond to the identified conditions. Their plans were to complete this effort
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by early 1991.
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The failure to provide procedures addre'ssing the loss or degradation of
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electrical power sources (e.g., 4160V AC, 480V AC, 125V DC) including'the
impact on the plant and the required operator actions is another example of'the-
violation (285/9014-01) of TS <5.8.1 cited in paragraph'2.2.1.
2.3.1 E0P-07,"StationBlackout," Revision 1(January 25,1990)
The. inspector reviewed the emergency operating procedure for recovery a station
blackout (lossofboth4160VACvitalbuses).
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The.. inspector noted:that the entry point of the procedure (E0P-07) ~was from the
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reactortripprocedure(EOP-00)-hotshutdownfollowinga_reactortrip/ turbine
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trip. The procedure addressed the use of the turbine driven auxiliar
feedwater pump (FW-10) in accordance with the operating instruction (y01-FW-4)
or E0P-20, " Functional Recovery Procedure." The . inspector identified to the
. licensee that a' station blackout.might occur at conditions when E0P-00 could
not be easily applied to the situation. The-inspector's review of-S0-G-74,
'"EOP/A0PWriter'sGuide," Revision 0(December 12,1989), Section 2.1
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-(Procedure' Network) revealed that.the procedure specified that for events more
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serious than normal transients, but not severe enough to require a reactor trip
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or for which the reactor' is already shutdown, shall be included in an A0P.
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was not apparent to the inspector which procedure or procedures would be
utilized by the operators to address a station blackout at other than normal'
Mode 1 or 2 conditions.
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This situation was discussed with the licensee for consideration' and followup
to ensure the. operators have clear' guidance _regarding this type of situation.
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It was noted'that this question may have generic-implications. .The inspector-
had no further questions regarding this issue.
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The inspector reviewed'the procedure E0P,-" Functional Recovery (Procedure," safety
Revision 7 (January 25,1990) for the recovery of.125Y DC bus
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bus _and the success paths (Resource Tree B) to recover one 125V DC bus.
The inspector noted that- EOP-20 addressed the recovery of the 125V DC
battery / bus; however, the procedure did not address the. foreseeable' impact on
the plant, systems, or components resulting from the initial loss or
degradation of the 125V DC battery / bus.
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This situation was discussed with the licensee for consideration and to ensure
that the loss or degradation of the.'125V DC was to be considered'during the
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upcoming evaluation of the electrical buses.
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PROCEDURES - GENERAL (42700)
The inspector reviewed selected procedures regarding the implementation of the
off-normal: procedures,
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Standing Order SO 0-1, " Conduct of Operations," Revision 0 (February 26
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Section 10. " Plant Operating Procedures,"' addressed procedure compliance
requirements for operating-procedures only;-however, the1 standing order
did not adequately address the procedure compliance for other types _of
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procedures and no other guidance documents addressed the ~other types of
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_ procedures. The inspector discussed this-item with the licensee.
Standing' Order S0-16, " Operating Procedures," Revision 7 (July 25,1990).
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Section 7.2, regarding performance requirements, addressed OP-10 (annunciator
response-procedures-ARPs),Lnoting that the ARPs-provided corrective
actions-for alarms caused by specific conditions; however, the interface
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between ARPs, A0Ps, and'EOPs was not addressed. The inspector discussed
this matter with the licensee.
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Standing-Order S0-18, " Emergency Operating Procedures," Revision 5
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Wuly 25,1988) .
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No performance requirements such as the purpose of the E0Ps and the
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interfaces _between-the EOPs, A0Ps, and ARPs were specified in the
procedure. The inspector discussed this matter with the licensee.
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Standing Order 50-18A, " Abnormal Operating Procedures," Revision 1
(April 11, 1987)
No performance requirements such as the purpose of the A0Ps and the
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interfaces between the A0Ps, E0Ps, and ARPs were specified in the
procedure. The inspector discussed this item with the licensee._
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No Yiolations or deviations were identified in the review of this program
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@ALITYASSURANCEAUDITS
The inspector reviewed the status of the planned.QA audit regarding procedures.
(QAAudit67).
Document review and-interviews revealed that the QA audit regarding the E0Ps
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and A0Ps was presently scheduled to be performed in May through June _1990.
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This time period was chosen to; assure the use of_the plant simulator;during the
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audit.
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The.. inspector discussed the overall involvement of the: QA staff in these and
other special safety-related activities, considering early and frequent-
involvement in ongoing projects.
Regarding the off-normal procedures'(E0Ps, A0Ps,cand:ARPs),QA'noted'that'asa-
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- result of the accomplishment of the root cause analyses associated with recent-
loss of electrical power events, several program / procedure-inadequacies:would:
likely be identified. These deficiencies may have generic as well as-specific-
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implications and QA would be following the matters.-
The specific involvement. of:the QA group in the procedure upgrade program _
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associated with the off-normal procedures upgrade projects is considered to be
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an inspector followup-item and will be reviewed further during a subsequent
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inspection. -(285/9014-02)-
No violations or deviations were identified in the review of this program-area.
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EXIT INTERVIEW
The inspector summarized the inspection scope and findings with the individuals
tuentified in paragraph 1.
Ine licensee-indicated that a previous commitment had been made to complete the
rewrite of the ARPs by January 15, 1991. No information reviewed by the-
inspector was identified by the licensee as proprietary.
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