ML20117M763
| ML20117M763 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/14/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20117M768 | List: |
| References | |
| 50-285-85-07, 50-285-85-7, NUDOCS 8505170196 | |
| Download: ML20117M763 (37) | |
See also: IR 05000285/1985007
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SALP BOARD REPORT
.U.S.. NUCLEAR REGULATORY COMMISSION
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REGION IV
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SYSTEMATIC APPRAISAL OF LICENSEE PERFORMANCE-
50-285/85-07
Omaha Public Power District
Fort Calhoun Station
September 1, 1983 --February 28, 1985
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INTRODUCTION
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The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
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a periodic basis and to evaluate licensee performance based upon this
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information. SALP is supplemental to normal regulatory processes used to
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ensure compliance to NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
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resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant operation.
An NRC SALP Board, composed of the staff members listed below, met on
April 16, 1985, to review the collection of performance observations and
data to assess the licensee performance-in accordance with the guidance in
NRC~ Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in
Section II of this report,
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This report is the SALP Board's assessment of the licensee's safety
performance at Fort Calhoun Station for the period September 1, 1983,
through February 28, 1985.
SALP Board for Fort Calhoun Station:
R. P. Denise, Director, Division of Reactor Safety and Projects
(Chairman)
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R. L. Bangart, Director, Division of Radiation Safety and Safeguards
L. E. Martin, Section Chief, Project Section A, Reactor Project
Branch 2
L. A. Yandell, Senior Resident Inspector
J. R. Miller, Chief, Operating Reactors Branch 3
E. G. Tourigny, Project Manager
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Attendees at all or part of the SALP Board Meeting were:
R. E. Hall, Chief, Emergency Preparedness and Radiological
Protection Branch
W. C. Seidle, Technical Assistant
J. B. Baird, Chief, Emergency Preparedness Section
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R. J. Everett, Chief, Nuclear Materials Safety Section
R. E. Baer, Regional Inspector
II. CRITERIA
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Licensee performance was assessed in 11 selected functional areas.
Each
functional area normally represents areas significant to nuclear safety
and the environment, and are normal programmatic areas.
One or more of the following evaluation criteria were used to assess each
functional area.
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1.
Management involvement and control in assuring quality.
2.
_ Approach to resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Reporting and analysis of reportable events.
6.
Staffing (including management).
7.
Training effectiveness and qualification.
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However,. the SALP Board is not limited to these criteria and others may
have'been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is
classi'ied into one of three performance categories. The definition of
-these performance categories is:
Categoryj.
Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational-safety is being
achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
reasonably effective so that satisfactory performance with respect to
operational safety is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used so that minimally satisfactory
performance with. respect to operational safety is being achieved.
The SALP Board has also categorized the performance trend over the course
of the SALP assessment period. The trend is meant to describe the general
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or prevailing tendency (the performance gradient) during the SALP period.
This categorization is not a comparison between the current and previous
SALP ratings; rather the categorization process involves a review of
performance during the current SALP period and categorization of the trend
of performance during that period only.
The performance trends are
defined as follows:
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' Improved: Licensee performance has generally improved over the course of
- the SALP assessment. period.
.Same:
Licensee performance has remained essentially constant over the
" course of. the SALP assessment period.
Declined: Licensee performance has generally declined over the course of
the.SALP assessment period.
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IIIT SUMMARY OF RESULTS
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In summary,. the ' licensee has exhibited significant-strength in the areas
of' plant operations, radiological controls, maintenance, fire protection,.
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surveillance, refueling, and licensing activities. Weak areas identified
included security and safeguards, and. training. The licensee's
performance and trend are summarized in the table below along with the
performance category-from the previous SALP evaluation period:
Previous
Present
Trend During
Performance
Performance
Latest
Category
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Category
-Functional Area-
(9/1/82 to 8/31/83) (9/1/83 to 2/28/85).
Period
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A.
~ Plant Operations
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1
Declined
B..
Radiological Controis-
1
Improved
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1.. Radiation Protection
2
N/A
2.
Chemistry / Radiochemistry
and Confirmatory
Measurements
3
N/A
3.
Radwaste Management,
Effluent Releases, and
Effluent Monitoring
2
N/A
4..
Transportation / Solid
Radwaste
3
N/A
5.
Environmental Monitoring
2
N/A
C.
Maintenance
2
1
Improved
D.
Surveillance
1
1
Same
. ' Fire Protection
2
1
Same
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2
2
Improved
' G.
~ Security and Safeguards
2
3
Improved
~H.
' Refuel.ing
1
1
Same
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Quality Programs and
Administrative Controls
Affecting Quality *-
3
2
Improved
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Licensing Activities
2
1
Improved
K.
Training-
3
3
Improved
- This category-was divided into two individual categories in the
previous SALP report.
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The total NRC inspection effort during this'SALP evaluation period
consisted of.44 inspections including resident inspector. inspections'and-
emergency exercises for a total of 3,241 direct inspection man-hours.
LIV. PERFORMANCE ANALYSIS'
A.
Plant Operations
1.
Analysis-
This area was inspected on a continuing basis.by the NRC
resident inspector. .Four violations and no deviations were
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identified in this functional area during the appraisal period:
. Failure-to properly terminate a containment pressure
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.. reduction.when the limiting X/Q was exceeded.
(Severity
Level IV, 8407-01)
Failure to provide an adequate procedure requiring
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independent verification of tag-outs to_ ensure that
equipment was properly isolated.
8412-01)
Failure of shift supervisor to document review of
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maintenance orders.
(Severity Level IV, 8412-02)
Failure to install the locking device.on a closed valve as
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required by the procedure lineup.
8429-02)
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~ The four Licensee Event Reports (LERs) listed below involved
activities in the area af plant operations:
Inadvertent opening of breaker supplying power to a control
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room DC panel. (LER 84-003)
Unplanned actuation of VIAS while shifting to the high
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alert / alarm setpoints.
(LERs84-014, 84-019, and 84-024)
Fort Calhoun Station maintains an experienced group of senior
operators and reactor operators.
The plant manager, three of
the five technical area supervisors, three training supervisors,
and the plant engineer all hold and maintain senior reactor
operator licenses and provide support and technical expertise to
the operations department. Operating personnel exhibit a strong
commitment to procedural compliance and a good understanding of
technical issues associated with plant operations. These
strengths have been observed by NRC inspectors during emergency
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preparedness drills, routine operations, and abnormal plant
situations. The Fort Calhoun Station completed 302 days of
continuous operation (the longest in the plant's history) during
this evaluation period which is indicative of the high caliber
of onshift personnel. The plant experienced only one reactor
trip this SALP period, the first since December 1982.
The operations department has experienced a net loss of licensed
personnel during this appraisal period. Attrition due to
resignations, retirement, and one transfer to another department
prevents the licensee from manning a full six-shift rotation as
they did on January 1, 1984, when the new manning regulations
went into effect. Additional burden was placed on the licensed
operators due to long term disabilities, hospitalizations, and
the removal of one senior operator from the shift rotation for
training following his failure of the annual requalification
examination. A review of licensee statistics for the last
quarter of this appraisal period indicated that overtime work
hours are increasing.
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The licensee continued their program of upgrading the Fort
Calhoun Station annunciator system to eliminate nuisance alarms
and to h?vo no annunciators lit during power operation.
Significant progress was made during the last refueling outage
wfth work continuing in this area as part of the overall control
room design review being done in accordance with Supplement I to
NUREG-0737 (Generic Letter 82-33), Item 1.D.1.
Portions of the
safety parameter display system were energized this report
period and are available for use by the operators.
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2.
Conclusions
The overall performance level of the operations department has
'been excellent during this appraisal period. The net loss of
licensed personnel and the lack of qualified replacements are a
concern to the NRC.
The licensee is considered to be in Performance-Category 1 in
this area.
Trend: Declined
3.
' Board Recommendations
a.
Recommended NRC' Actions
The NRC inspection effort in this functional area could be
reduced.
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Recommended Licensee Actions
Licensee' management should give priority to reversing the
declining trend related to staffing and staff-qualifica-
tions to ensure that the licensee meets Fort Calhoun
Station staffing objectives.
Efforts to improve the
control room annunciator system and to implement the
recommendations of the control room design review should be
continued.
B.
Radiological Controls
1.
Analysis
Eight inspections were conducted during the assessment period by
region-based inspectors concerning radiological controls. These
eight inspections covered the following areas:
radiation-
protection-normal operations; radiation protection-refueling
outage; radwaste management, effluent releases, and effluent
monitoring; chemistry / radiochemistry and confirmatory
measurements; and transportation / solid radwaste. One violation
and no deviations were identified:
Failure to Follow Procedures.
(Severity Level V, 83-31)
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Radiation Protection
This area was inspected twice during normal plant
operations and once during a refueling outage.
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The-person-rem for 1983 was 433 as compared to the PWR
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national _ average of 592.
In 1984, 544 person-rem was
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expended. .The 1984 national averages have not been
tabulated,Ebut the 1984 values are expected to be near the
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1983clevels. The licensee's person-rem average between
_1978 and 1983 was 385 which is below the PWR national
average of 556 for the same time-period.
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-The-radiation protection staff was stable during the _
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assessment period. .All. members of the radiation protection
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staff _ met the ' ANSI N18.1-1971 qua11fication requirements as
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. senior radiation protection technicians: The radiation-
. protection staff consisted of.12' technicians, 2-
supervisors, and 2 ALARA coordinators. The licensee had
' decreased reliance on contractor. technicians; only one
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contractor technician was included in the radiation
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protection staff.
The lack of a. full-time ALARA coordinator was noted as a
concern in the previous assessment.
In this assessment
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. period,_the Itcensee established and filled an'ALARA-
coordinator and an assistant ALARA coordinator position.
.The implementation _of an extensive decontamination program
.in the auxiliary building corridors, that allowed access-
.into these areas without the need~for protective clothing,
was noted as;a program improvement in the previous
assessment. .The licensee had continued to expand this
decontamination effort to include additional areas and
rooms in the auxiliary building. The lack of timely action
to resolve open items was identified as a major concern in
the previous assessment.
In this assessment period, good
progress had been made toward the resolution of outstanding
open items.
A comprehensive training program has not been implemented-
for the radiation protection staff.
b.
Chemistry / Radiochemistry and Confirmatory Measurements
This area was inspected once during the assessment period
which included onsite. confirmatory measurements with the
Region M mobile laboratory. The following LERs concerning
this area were submitted:
Boron concentrations in the Safety Injection and
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Refueling Water Tank below Technical Specification
limits. (LERs84-012'and 84-021)
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An overall improvement was noted in the percent agreement
between the NRC's and the licensee's measurements in this
assessment period.
Considerable improvement was made in
the percent agreement concerning the comparative analyses
of gaseous samples. The percent agreement for gaseous
samples.in this assessmrat was about 70 percent as compared
to less than'50 percent in the previous-assessment period.
The licensee had implemented a quality control cross-check
program with an offsite: independent laboratory.
An approximate _60 percent turnover rate was noted among the
chemistry / radiochemistry staff in the assessment period.
A comprehensive training program had not been implemented
for radiochemistry personnel,
c.
Radwaste Management, Effluent Releases, and Effluent
Monitoring
This area was inspected once in the assessment period. The
following LERs concerning this area were submitted:
Exceeded Technical Specification Limits for I-131 Dose
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Equivalent in Reactor Coolant.
(LER 84-004)
Unplanned actuation of Ventilation Isolation Actuation
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Signal (VIAS) due to instrument error.
(LERs84-005,
006, 007, 010, 017, 018, and 023)
Disconnection of sample line from auxiliary building
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ventilation duct to gaseous effluent monitor.
(LER
84-011).
Gaseous leak in the waste gas vent header caused stack
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iodine monitor to initiate VIAS.
(LER 84-025)
The licensee had a well established program for sampling
and analyses of liquid and gaseous samples to assure
compliance with Technical Specification requirements.
Improvements noted in this area included:
installation of
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low-background steam generator blowdown radiation monitors;
in place calibration of liquid and gaseous effluent
monitors with liquid and gas standards; and an in place
testing program for the auxiliary building HEPA filters.
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Approximately 20 unplanned actuations of the VIAS related
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to instrument. error were reported in LERs during the
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assessment period.
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d.
Tr&nsportation/ Solid Radwaste
This area was inspected twice during the assessment period.
The licensee had updated their program to include the
revisions to Department of Transportation regulations
effective July 1, 1983, and revisions to 10 CFR Part 20.311,
10 CFR Part 61.55, and 10 CFR Part 61.56 effective
December 27, 1983.
Improvements noted in this area
included: assignment of a full-time radwaste coordinator;
development of detailed shipping procedures and records;
impler...tation of a QA/QC program concerning the packaging
.of radioactive materials; and establishing a procedure to
evaluate the amount of radwaste generated.
A comprehensive training program had not been established
for personnel involved with transportation / solid radwaste
activities.
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e.
Enviror, mental Monitoring
The radiological environmental monitoring program was
inspected once during the assessment period. No
significant problems were identified. There had been no
turnover in the onsite staff responsible for the program
during the past several years. Improvements noted in this
area included the use of persons with expertise in
environmental monitoring on the team responsible for
auditing the radiological environmentai monitoring program
and implementation of comprehensive procedures for
identification, collection, and shipping of environmental
samples.
A formal training program had not been established for
persons involved with.the radiological environmental
monitoring program.
2.
Conclusions
Improvements were noted in the area of radiological controls in
this assessment period as compared to the previous assessment
and these improvements reflect strong management attention to
weaknesses previously identified. The licensee had made good
progress toward resolution of outstanding open items.
During
the assessment ~ period, 31 open items were resolved and only one
new open item was identified. A high turnover rate was noted
among the chemistry / radiochemistry staff. -Comprehensive
training programs had not been established that included
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schedules, goals and objectives, full-time instructors, lesson
plans, and. training aids.
No problems were noted concerning enforcement history,
resolution of technical issues, management involvement, and
responsiveness to NRC initiatives.
The licensee is considered to be in Performance Category 1 in
this area.
Trend:
Improved
3.
Board Recommendations
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a.
Recommended NRC Actions
The NRC. inspection effort in this functional area could be
reduced.
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b.
Recommended Licensee Actions
Management attention is needed to ensure that comprehensive
training programs are established. Management should
investigate the cause of the high turnover rate in the
chemistry / radiochemistry staff and establish any
appropriate remedial actions.
C.
Maintenance
1.
Analysis
This area was inspected by region-based NRC inspectors and on a
continuing basis by the NRC resident inspector.
Four violations
and no deviations were identified in this functional area during
the appraisal period:
Failure to have proper receipt inspection of material
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performed prior ~to installation by maintenance personnel.
(Severity Level V, 8415-01)
Failure by maintenance craftsman to properly verify and use
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the correct revision of a surveillance test.
(Severity
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Level IV, 8418-02)
Failure to provide adequate procedures:
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to identify and resolve nonconformances associated
with plant process instrumentation, survei.llance test
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instrumentation, and pressure gauges when found to be
out-of-tolerance at calibration; and
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to implement the cleaning requirements for fluid
systems and associated components in accordance with
(Severity Level V, 8421-01)
Failure to follow procedures:
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a.
by failing to perform investigation to determine the
effect of secondary standards being out-of-tolerance;
and
b.
by failing to provide minimum calibration schedules
for oscilloscopes and electrical current measuring
standards.
(Severity Level IV, 8421-02)
The twelve LERs listed below involved activities in the area of
maintenance:
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Diesel generator field failed to flash during surveillance
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test.
(LERs83-008 and 83-011)
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Reactor Coolant Loop RC-2A flow indicator loop failed high.
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-(LER 83-009)
Low pressure safety injection pump sequencer timer failed
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during monthly ESF surveillance test.
(LER 83-010)
Failed power supply fuse in RPS channels. (LER 83-012)
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Containment pressure switches were found
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out-of-tolerance during surveillance test.
(LER 83-013)
Main steam safety valves failed to lift within setpoint
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values during surveillance test.
(LER 84-002)
Steam Generator RC-28 tube failure.
(LER 84-008)
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Electrical penetration assemblies failed under
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environmental qualification testing being conducted by the
test laboratory to fulfill the requirements of
(LER 84-009)
Noise spikes caused tripping of the "A" and "C" Thermal
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Margin Low Pressure reactor protective system trip circuits
which resulted in a reactor trip.
(LER 84-013)
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High alarm setpoint for stack noble gas monitor was found
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out-of-tolerance during surveillance test.
(LER 84-016)
Hydrogen analyzers failed to indicate proper concentration
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during calibration.
(LER 84-020)
The major maintenance efforts accomplished this appraisal period
occurred during the refueling outage March 5 to July 8,1984.
Maintenance activities accomplished included eddy current
testing of both steam generators, sludge lancing of the
secondary side of both steam generators, repair of the reactor
coolant pump gaskets, work on the Quality Safety Parameters
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Display System (QSPDS), and replacement of the high pressure
turbine rotor.
Extensive management involvement at the planning
level and expanded use.of the computerized tracking system
enabled these activities to be accomplished essentially on
schedule.
Three additional, events caused an extension to the originally
planned outage.
The first was the removal of the drilled tube
support plate rim in both steam generators to reduce the
potential for tube " denting" caused by stresses in the support
plate. This " rim cut" was accomplished by contract boilermakers
under the direct supervision of OPPD personnel and completed
within two weeks. The licensee utilized mockup training for all
craftsmen, and this contributed to the timely completion of the
job and to the less than anticipated overall man-rem exposure.
The second event was-the steam generator tube failure in RC-28
that occurred on May 16, 1984, during the reactor coolant system
leak test. The licensee had identified a small tube leak prior
to shutdown, and had expended considerable effort to identify
the cause prior to startup. This effort included an extensive
eddy current test program, helium leak checks before and after
sludge lancing, and dye leak tests, but no positive indication
of a leak was identified prior to the reactor coolant system
leak test.
Following the tube failure, the licensee removed the
failed tube from RC-28, performed eddy current testing on all
accessible tubes on both steam generators, performed a lab
analyses on the failed tube, initiated more restrictive limits
on the primary to secondary leak rate, and instituted vendor
recommended chemistry control procedures. The third event was
precipitated when a testing laboratory informed OPPD that
containment penetration lead wire insulation could fail under
the harsh environment of a Large Break Loss of Coolant Accident
(LBLOCA) . To correct this problem, the licensee developed a
cable splice using qualified sleeves that shielded the lead wire
insulation from the harsh environment. A total of 638 splices
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. involving 48 cables were reworked during this 2-week extension
'of the outage. With' regard to all three of these events, the
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licensee management responded quickly to address these matters
and to provide the necessary resources and support to these
activities.
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Another major maintenance effort undertaken by' Fort Calhoun
during1this_ appraisal period.was the installation of new spent
fuel. storage racks by an outside. contractor. Whi.le removing the
old racks,_there were instances where plant QC personnel stopped
. work because of the improper way the ~ job was being performed and
controlled. During the removal of one spent fuel rack, the wire
rope sling broke.and the rack became wedged.in the pool. OPPD-
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failed initially to exercise appropriate management control by
providing adequately trained people to direct this work.and
sufficient QC coverage to monitor contractor activities.
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The licensee's system-for tracing measuring and test equipment
(M&TE) usage was found to be weak and lacked adequate procedures.
to identify all items inspected,-. tested,' or measured to specific
M&TE. Adequate procedures were not established to make
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disposition of possible nonconformances of those items when M&TE
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was found to be out-of-tolerance. The licensee revised plant
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procedures and expanded the M&TE program during this SALP period
to address those concerns identified in NRC Inspection
Reports 50-285/84-12 and_50-285/84-21.
The previous SALP identified that.several long term electrical
' jumpers. dating back to 1973 were still outstanding. The
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licensee made significant progress during this SALP period at
closing out these items and incorporating them'as permanent
design changes in accordance with the plant standing order.
The tracking of maintenance. orders (MOs) was another item of -
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concern discussed in the previous SALP. A computerized M0
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system is now in effect that works in conjunction with a
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computerized tracking. system to provide current. status
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information.
The tracking and closeout of design changes was a-third item of-
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concern discussed in the. previous SALP report. The efforts of
the update team were completed this SALP period, and all
modifications through December 31, 1980, have been reviewed. A
computerized listing of all outstanding Design Change Requests
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and Engineering Evaluation and Assistance Requests was
established and Itcensee management now has the capability of
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assessing the status of the design change program.
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The licensee implemented a Qualified Life Program (QLP) during
this appraisal period to " establish and maintain the qualified
life of safety-related equipment installed in a harsh
environment." Although the QLP was established in April 1984,
the licensee was slow in fully implementing the program and
delegating appropriate. responsibility to the various crafts. A
full-time coordinator was assigned to this effort in order to:
(1) review Electrical Equipment Qualification (EEQ)
documentation since the QLP started, (2) review QLP entries for
accuracy in the computer data base used in the maintenance
. program, and (3) provide comprehensive training of the QLP/EEQ
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program.
2.
. Conclusions
The licensee has initiated additional management control
programs to strengthen the maintenance area, and has established
a better working interface between the plant and design groups
at the Jones Street office. The resolution of items mentioned
in previous SALP reports indicates OPPD's commitment in
maintenance, but poor control of the new spent fuel rack
installation and delays in full implementation of the EEQ
program suggest areas that require additional management
attention.
The plant has a stable, well qualified maintenance staff that
has seen little turnover the past three SALP periods.
The licensee is considered to be in Performance Category 1 in
this area.
Trend:
Improved
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection. effort in this functional area could be
reduced.
b.
Recommended Licensee Actions
The licensee should continue the increased management
attention being given to the EEQ program in preparation-for
a site verification inspection by the NRC in 1985.
D.
Surveillance
1.
Analysis
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This area was inspected on a continuing basis by the NRC
resident inspector. No violations or deviations were identified
in this area.
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Fort Calhoun maintains a well-developed and effectively managed
surveillance test program. A monthly surveillance testing
- schedule is published to ensure that all required tests are
. assigned as to due date and responsible department. The program
is set.up to verify that the current revision to the test is
being used, that QC verification is obtained where required, and
that calibrated test equipment is used and identified on the
procedure. .During the last refueling outage, the master
schedule was updated and the applicable surveillance tests were
written or modified to reflect new Technical Specification
requirements.
2.
Conclusions
The licensee maintains a well-developed and effectively managed
surveillance test program.
The licensee is considered to be in Performance Category 1 in
this area.
Trend: Same
3.
Board Recommendations
a.
Recommended NRC Actions
.The NRC inspection effort in this functional area should
remain at the reduced level.
b.
Recommended Licensee Actions
The Board recommends that the licensee continue to exercise
strong management control of the surveillance program.
E.
' Fire Protecti'on
1.
Analysis
This area was inspected on a continuing basis by the NRC
resident inspector. No violations or deviations were identified
in this area.
The one LER listed below involved activities in
the functional area of fire protection:
. Temporary fire barrier failed to meet design criteria.
.
(LER 84-022)
A major activity in this area by OPPD during this appraisal
period was the resolution of items identified by the NRC special
inspection team and documented in NRC Inspection
Report 50-285/83-12 dated July 1, 1983.
.
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'Another major effort by the licensee this report period was the
upgrading of_ temporary fire barriers into permanent barriers and
to grout conduit penetrations. This 3-month effort utilized a
qualified outside contractor and resulted in approximately 350
fire barriers being upgraded. The licensee is presently
developing a program to enable OPPD personnel to install new
fire barrier penetrations and perform maintenance on permanent
2.
- Conclusions
The licensee has made significant progress at resolving the
items identified in the fire protection audit report and is
working toward compliance with the requirements of
10 CFR Part 50, Appendix R, Sections III.G and III.L.
The licensee is considered to be in Performance Category 1 in
this area.
.
-Trend: Same
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should
remain at the present level.The NRC should complete the-
review and processing of OPPD's exemption requests,
b.
Recommended Licensee Actions
The licensee management should continue their efforts to
resolve all identified items pertaining to compliance with
Appendix R.
F.
1.
Analysis
During the assessment period, five routine emergency
preparedness inspections were conducted. Three of the
inspections were routine reviews of the implementation status
for various elements of the emergency preparedness program.
Two emergency _ exercise inspections were also conducted during
the assessment period in conjunction with the licensee's annual
emergency exercises held December 6-7, 1983, and October 24,
1984. No violations or deviations were observed by the NRC
inspectors.
~
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-17-
Most of the open items identified during inspections in the
previous assessment periods were closed during this assessment
period based on timely licensee actions.
For concerns
identified during the reporting period, corrective action was
noted for most items during the next review of that item.
During the October 24, 1984, emergency exercise, the Federal
Emergency Management Agency (FEMA) evaluated offsite emergency
preparedness of states and local agencies. As a result of this
evaluation, FEMA identified a Category A deficiency in regard to
agreements for ambulance services in two counties of the state
of Iowa side of the 10 mile emergency planning zone. Plans for
resolution of this deficiency included agreements between Iowa
and the ambulance services, training for ambulance personnel,
and a drill to demonstrate this capability. The licensee has
been active in this matter and is cooperating with state and
local authorities to achieve resolution of this offsite
preparedness concern.
.
Management involvement and control of the emergency preparedness
program during the period appeared to be adequate for
implementation of an effective program.
Staffing of the emergency preparedness program was also
considered to be adequate during this reporting period. No
reportable events in the. emergency preparedness area were
received during this reporting period.
2.
Conclusions
The licensee has maintained an acceptable level of emergency
preparedness during the period and demonstrated adequate
capability to protect the health and safety of the public by
conducting two successful emergency exercises. Management
-involvement and control has been adequate for implementation of
an effective program.
Responses to NRC concerns have been
timely, thorough, and acceptable in most cases. Overall, the
licensee's program appeared to have increased in effectiveness
since the previous assessment period.
The licensee is considered to be in Performance Category 2 in
this area.
Trend:
Improved
3.
Board Recommendations
a.
Recommended NRC Action
The NRC inspection effort in this functional area should
continue at a normal level.
_
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$
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b.
Recommended Licensee Action'
A more aggressive level .of management attention to
implementation of-the emergency preparedness program should
be pursued. Additional management attention should be
given to resolution of.each of the NRC identified concerns
in a timely manner.
G .~
Security and Safeguards
1.
Analysis
The physical security staff performed five inspections during
this SALP period.
Twelve violations were identified in this functional area
during the appraisal _ period.
Failure to demonstrate that the microwave system _is tested
.
quarterly against the manufacturer's design specifications.
(Severity Level IV, 8417-02)
Failure to take proper compensatory action when the
.
perimeter intrusion detection system coverage was
discovered to be ineffective.
(Severity Level iV, 8417-03)
. Failure to provide authorized escort.
(Severity
.
Level IV, 8418-01)
' Failure to report facility modification.
(Severity
.
Level *, 8420-01)
Inadequate key control.
(Severity Level *, 8420-02)
.
Failure to provide an adequate barrier for part of one
.
vital area.
(Severity Level IV, 8420-03).
Inadequate compensatory measures.
(Severity Level *,
.
8420-04)
Inadequate surveillance television coverage.
(Severity-
.
Level *, 8420-05)
Failure to provide adequate access control for a vital
.
-
area. _(Severity Level IV, 8420-06)
Insufficient search at access control point.
(Severity
.
Level *, 8420-07)
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Failure to maintain operable assessment aids.
(Severity
.
Level *, 8420-08)
Inadequate compensatory measures following failure of-
.
search equipment.
(Severity Level *, 8420-09)
- Violations 8420-01, 02, 04, 05, 07, 08, and 09 were
categorized individually at Severity Level IV or V, but were
considered in the aggregate as a Severity Level III
Violation.
Three deviations were identified in this functional area during
the appraisal period.
Failure to revise security' plan according to commitment
.
made to NRC.
(8326-04)
Failure to provide continuous monitoring.
(8420-10)
.
Failure to perform effectiveness test.
(8420-11)
.
Forty-nine licensee event reports (LER) of physical security
events were submitted in accordance with 10 CFR Part 73.71:
Loss of primary (CPU 1) and secondary (CPU 2) security
.
computers.
(LER's Nos. 83-07 through 12, 84-02 through 27,
84-29 through 34, and 85-01 through 09)
Loss of_ AC power and failure of uninterruptible power
.
source to operate the security computers.
(LER No. 84-01)
Reduction in offsite communications to local law
.
enforcement agencies.
(LER No. 84-28)
The licensee lost use of his primary (CPUI) and secondary (CPL'2)
security computers 47 times during this SALP period. On one
occasion, the licensee lost AC power and his backup source of
uninterruptible power failed to operate automatically.
In
LER 84-28, the licensee lost " normal" offsite communications to
the local area due to an accidental slicing of the underground
cable by an offsite nonutility construction crew.
The licensee was issued a Confirmatory Action Letter (CAL) on
'
August 16, 1984. The CAL was. issued as a result of a Region IV
inspection in July 1984. An enforcement conference was held
October 11, 1984, and documented in NRC Inspection Report
50-285/84-27. The enforcement conference was called to discuss
I
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the apparent violations from the special security inspection
(NRC Inspection Report 50-285/84-20) conducted during the period
August 20-24, 1984. The importance of. management involvement in
establishing an effective security program was emphasized by the
NRC participants. The need to develop and implement an effective
testing and maintenance program for security-related equipment
was discussed. As a consequence of the August special security
inspection, a Notice of Violation and Proposed Imposition of
Civil Penalty (CP) dated February 14, 1985, was issued to the-
licensee. The CP was reduced by 50 percent to $25,000 because
of prior good performance in the area of concern; specifically,
no. previous escalated enforcement actions and repeated ratings
of Category 2 in their (SALP) evaluations.
Subsequent to'the August 20-24,-1984, inspection, OPPD initiated
an extensive security improvement program. OPPD management
approved a Fort Calhoun Station security organizational change
providing for a dedicated security supervisor reporting to the
Supervisor-Administrative Services and Security at Fort Calhoun
Station, a review of: the maintenance and testing program
relating to security equipment, and a review of the entire
physical security plan by a qualified security consultant.
In
addition, Fort Calhoun Station made a commitment to submit a
revised physical security pian to the NRC by May 1, 1985.
2.
Conclusions
The licensee had not placed emphasis and dedication on
maintaining an. effective security program and management
involvement with security matters has been marginal. The result
of management's lack of commitment to security was evidenced by
insufficient training and maintenance, and by improper
compensatory actions resulting in violations.
The licensee is considered to be in Performance Category 3 in
this area.
Trend:
Improved
3.
Board Recommendations
a.
Recommended NRC Actions
Tne NRC inspection effort in this functional area should be
increased. An' evaluation of the licensee's corrective actions
and their impact on the security program should be performed by
August 31,~1985.
b.
Recommended Licensee Action
The level of licensee management attention evidenced during the
last_ quarter of this SALP period should be continued.
t
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The licensee should increase audit. activity of security
training, maintenance, and requirements of the security plan.
Licensee management should ensure that security resources and
organization are adequate to implement the security plan.
H.
Refueling
1.
Analysis
This area was inspected on a continuing basis by the NRC
resident inspector during the period of refueling April 1-8,
1984.
Fort Calhoun Station was in a refueling outage from
March 5 to July 8, 1984, for Cycle 9 refueling. A total of
40 new bundles were inserted into the core.
No violations or deviations were identified during this
evaluation period.
The licensee continued to utilize a fuel load / shuffle scheme
designed to reduce neutron flux to the reactor vessel as part of
OPPD's efforts to address the pressurized _ thermal shock issue.
The fuel movement was completed without incident and the NRC
inspector verified that Technical Specification requirements
were satisfied.
2.
Conclusions
The licensee management demonstr'ated excellent prior planning
and effective control of refueling activities. The licensee is
considered to be in Performance Category 1 in this area.
Trend: Same
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should
remain at reduced levels.
b.
Recommended Licensee Actions
Licensee management should continue its involvement in the
planning of refueling outages, the observation of refueling
activities, and adherence to procedures.
I.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
This functional area was inspected on a continuing basis by the
NRC resident inspector and by region-based NRC inspectors. Six
.
.
..
-22-
violations and no deviations were identified in this area during
the appraisal period:
Failure to audit security procedures every 12 months.
.
(Severity Level IV, 8326-01)
Failure to adequately perform the review and approval steps
.
of a CQE piping isometric as part of the post-installation
modification review process.
(Severity Level IV, 8335-01)
Failure to provide procedures to assure that appropriate
.
Fort Calhoun Station personnel were provided with current
lists of CQE equipment.
(Severity Level V, 8410-03)
Failure to properly review OPPD's response to IE
.
Bulletin 82-02 resulting in a material false statement
being made that was contrary to actual practice at the Fort
Calhoun Station.
(Severity Level III, 8412-03)
Failure to take prompt corrective action on the resolution
.
of QA deficiency / quality reports within the required
response period.
(Severity Level IV, 8429-01)
Failure to properly establish, monitor, and closeout
.
temporary CQE storage areas.
(Severity Level IV, 8501-01)
The two LERs listed below involved activities in the area of
administrative controls:
Auxiliary building crane interlocks were left in the bypass
.
position without the crane supervisor being present.
(84-001)
A load of approximately 250 pounds was carried by the~ polar
.
crane over the reactor coolant system when the fluid in the
pressurizer was greater than 225 degrees F.
(84-015)
The licensee submitted the revised OPPD QA Plan to the NRC for
review on August 31, 1984. The program is fully implemented and
the complete set of QA department procedures has been issued.
These items were addressed in the last SALP period and the delay
in implementing the new program was considered a weakness in the
OPPD program.
It was determined during routine inspections by regional
inspectors in the radiological controls area that there were no
QA auditors on the licensee's onsite staff that had any training
or background experience in radiation protection except for
instrument calibration. The NRC determined during another
.-.
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_.
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inspection that the licensee did not have a program established
to audit vendors that are contracted to perform radiochemical
analyses on samples of Fort Calhoun Station radwaste for the
requirements of 10 CFR Part 61.55.
In the area of security and
safeguards the NRC determined that the licensee had failed to
perform an audit of security procedures and practices every 12
months as required by the Fort Calhoun Station Physical Security
. Plan.
During this appraisal period, major management changes were
implemented at the OPPD corporate. level and at the Fort Calhoun
Station. A Nuclear Production Division was formed and a
separate division manager for nuclear matters was established
directly under the assistant general manager. The
reorganization provided increased management attention to the
operation of the-Fort Calhoun Station. The NRC resident
inspector observed that the manager of the Nuclear Production
Division initiated weekly staff meetings at the site, made
routine tours of the plant, and attended all NRC exit interviews
at the site.
The licensee reorganized the site management structure to have
the Quality Control (QC) section report to the Supervisor-
Technical, instead of the Supervisor-Maintenance. Observations
by the resident inspector indicated that this move provided a
greater degree of independence for the QC section from the
Maintenance Department and enhanced their effectiveness onsite.
A Supervisor-Station Training position reporting directly to the
plant manager was established this appraisal period and filled
in February 1985.
This reflects the licensee's commitment to
provide increased management attention to plant training
activities.
An area of continued long standing concern'to the NRC is the
matter of the Fort Calhoun Station construction QA records. An
enforcement conference between OPPD and NRC personnel was held
in the Region IV offices on September 9,1983, to address this
matter and identify the licensee's corrective actions. OPPD
agreed to review "all commitments to the NRC for retention of
design, procurement, manufacturing, installation and
construction records, and all applicable involved codes,
standards, and specifications." The licensee has examined the
available records and identified those which were missing, along
with an evaluation of their significance. A recent inspection
by the NRC indicates that this review and evaluation was not
done to the depth and detail necessary to resolve this matter.
.l
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.
-24-
In addition to those specific items discussed in the various
functional areas, other items that indicated a lack of
sufficient administrative controls and management attention
during this assessment period include:
The. inadequate review of OPPD's response to IE
.
Bulletin 82-02 and the subsequent escalated enforcement, as
. discussed in Section IV.C of.this report, indicated a-
weakness in the licensee's technical evaluation and review
process. Although the specific incident occurred before
this SALP evaluation period, the investigation during this
SALP period revealed that weaknesses still existed. The
licensee exerted significant effort during the past nine
months to correct these problems.
-The failure to followup on identified deficiencies in a QA
.
audit of the plant security program, and the lengthy times
-involved in ' closing out other deficiency reports / quality
reports indicated that management failed to achieve
appropriate and timely corrective actions.
2.
Conclusions
The licensee has demonstrated improvement in the QA area with
regard to program implementation.
OPPD's administrative
controls and management attention had weaknesses in the specific
areas outlined above and in the other analyses sections. The
= establishment of a separate Nuclear Production Division is a
positive step towards bringing management controls to bear on
those areas that need attention.
The licensee is considered to be in Performance Category 2 in
this area.
Trend:
Improved
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should be
maintained at normal levels.
-b.
Recommended' Licensee Actions
The licensee management needs to work toward a timely
resolution of the NRC concerns regarding construction
records and to address the other weaknesses identified.
- _.
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.-
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.
.
,
J.
Licensing Activities ~
~1;
Analysis-
\\
-The NRC Office of Nuclear Reactor Regulation has ' performed an
assessment of licensee performance in the functional area of
-
licensing activities.
Refer to Attachment 1 for details.of this-
'
assessment.
-2.
. Conclusions-
As discussed in. Attachment 1, the licensee is considered to be
-in Performance Category 1 in this area.
Trend:
Improved
3.
. Board Recommendations
.
a.
Recommended NRC Actions
Continue to perform 111 censing activities as required.
-
- b' .-
Recommended Licensee Actions
The licensee should continue its high level of management
.
involvement in-this area.
-
K.
- Training
1.
. Analysis
This functional area was inspected by region-based NRC
inspectors and on a periodic basis by the NRC resident
,.
inspector. Three violations and no deviations were identified
in this functional area during the appraisal period:
Failure to follow approved training and qualification plan-
.
as it pertains to firearms qualification program.
(Severity Level IV, 8326-02)
,
! Failure to complete security training program in accordance
.
with commitment made to NRC.
(Severity Level IV, 8326-03)
4
Failure to' provide training as required by the Fort Calhoun
..
Station Security Plan.
(Severity Level IV, 8417-01)
.
The licensee has devoted much attention to this functional area
-since receiving a Category 3 rating in the previous SALP report.
An outside consultant was brought in for evaluation and
o
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-26-
consultation during the winter of 1983/84, and in May 1984, a
working group was in place preparing training materials. This
group started with about five persons and has grown to 15 during
the past nine months.
Following the failure of all three
license candidates in June 1984, OPPD initiated an evaluation to
identify and correct the specific causes of these failures.
Part of this evaluation included an independent task force
assessment of the existing operator training program. The-
results of this assessment formed the bases for short term and
long term corrective actions to be implemented to ensure that
future license candidates are prepared to pass the NRC
examination and safely operate the plant. OPPD and NRC
personnel met in September 1984, to discuss the licensee's
-
operator licensing program and.the results of this independent
task force assessment. OPPD established the position of
Supervisor-Training Services in July 1984, to head the newly
established offsite Training Services Department. .The NRC
resident inspector reviewed the independent assessment report
and concluded that the observations made represented an accurate
picture of the training program at that time, and that the-
three groups of recommendations set forth would correct the
problems if implemented.
Some results from the efforts
described above that occurred during this evaluation-period
included:
(1) improved and expanded lesson plans and training
packages, (2) the successful licensing of two reactor operator
license candidates, (3) the additio'n of instructors from an
inter plant transfer and outside contractors, and (4) the
appointment of the new Supervisor-Station Training.
The NRC
resident inspector reviewed portions of the revised student
handout material and instructor lesson plans and found them to
be comprehensive, well organized, and clearly written.
Three operator licensing examinations were administered during
this evaluation period as tabulated below:
SR0 Candidates
R0 Candidates
Total Pass Fail
Total Pass Fail
November 29-December 1, 1983
6
3
3
1
1
0
June 5-7, 1984
0
-
-
3
0
3
November 7-8, 1984
0
-
-
2
2
0
One requalification examination was administered as tabulated
below:
-
1
- .;
a
-27--
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1
SR0 Candidates
R0 Candidates-
Total Pass Fail
Total Pass Fail
~
November 7, 1984-
5_
2
3
2
2
0
'The first two examination results. continued a downtrend that was
.. identified in the previous.SALP period. _These results were
below the industry norm and reflected a weakness .in the
licensee's training department to adequately screen and' prepare
candidates- for licenses. The intensive training effort. focused
'
on the November 1984, candidates and the successful licensing of
-
.both examinees indicated that this trend may-have been reversed.
License requalification training continued to be a problem area
during-this, evaluation period.
Interviews.by the NRC_ resident
. inspector and a region based NRC inspector with licensed'. .
" operators indicated that actual in-class lecture time was.b'eing
cut short and that the~ quality.of training was suffering because
-
of the limited availability _of experienced licensed instructors.
In addition, the high failure rate for new license ~ candidates
and NRC requalification candidates during this appraisal period
seemed to confirm that the overall. quality of training at the
.
licensed operator level remained marginal. _The NRC resident-
inspector attended selected training lectures during this
,
appraisal period and observed a wide variation in quality of
,
handout material and instructor capabilities.
-
As part of the overall restructuring of the training program, a
_
new " performance based" training. program for newly hired
.
auxiliary operator trainees has been developed and will be
+
implemented during the first quarter of 1985. This program has
clearly defined written goals, a' complete schedule for classroom
_'
and onshift _ time, and a structured. system of lesson plans,
- -..
_ qualification cards, and practical factors to be completed.
>
This' program is one of many being developed by the. licensee to
qualify for INPO certification in 1986.
I
The in-house. training program for five inexperienced
-
chemistry / health physics technicians was completed this
.
,
,
evaluation period and all five trainees became qualified to work
shift-technician duties.
It was noted in an NRC inspection
'
report.that the training department did not have an instructor
_ qualified or experienced in nuclear power plant chemistry and
that a comprehensive training' program for radwaste operators did
not exist. The chemistry / radiochemistry training program was
being conducted primarily by the chemistry section senior staff
>
personnel under the supervision of the plant chemist. A review-
-
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_ _ ,
. , . _ , , _ . . , , , , - , _ . , , _ , . , , _ , , _ _ , _ _ , , _ _ . _ _ . . _ , _ . . , . .
_
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_
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'
of qualification verification records for Chemistry and
-Radiation Protection supervisory personnel revealed that no
training had been completed in any of the study areas listed in
Section 6.1 of the Fort Calhoun Station Training Manual.
The NRC resident inspector noted that the training manual
prepared for Cycle 9 modifications was the'most complete and
informative of those issued to date. The~ licensee provided
acceptable training on short notice in response to the steam
generator tube failure incident and covered the applicable
emergency procedures, the lessons learned from the Ginna tube
rupture incident, and the revised Technical
' Specification / Surveillance Tests.
2.
Conclusions
The licensee has done an excellent job of identifying and
evaluating the problems in this functional area, and has
expressed a strong commitment to resolve these matters. The
initial results of their-efforts have been positive, but the
overall training program has not yet seen the benefits of OPPD's
commitments and plans.
During this evaluation period the
licensee's record in licensee examinations and requalification
examinations remained poor. Many of the personnel changes to
the training department and the appointment of the
Supervisor-Station Training occurred too late in this SALP
evaluation period to have had a significant impact on
performance.
The' licensee is considered to be in Performance Category 3 in
this' functional area.
Trend:
Improved
3.
Board Recommendations
a.
Recommended NRC Actions
=The NRC inspection effort'in this functional area should be
.
increased. An evaluation of the licensee's corrective
actions and their impact on the training program should be
performed by August 31, 1985.
b.
Recommended Licensee Actions
Licensee management should provide aggressive action to
ensure control of the training program in order to maintain
the positive trend that appears to have been established
toward the end of this evaluation period. The effort at
. _ _ -
. - -
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-29-
upgrading lesson plans and student material needssto be
carried through to completion. The need for an expanded
training staff remains and this shortcoming should be
resolved as soon as possible. The licensee should further
-consider the benefits of obtaining access to a
site-specific simulator for training of the Fort Calhoun
Station operators.
The quality of instructors should be evaluated and training
provided as required to increase the effectiveness of the
training staff. Training in the areas of security,
chemistry, and radiation protection needs to be better
coordinated and administered under the training department.
'V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee' Activities
1.
Major Outages
-The refueling outage occurred during the period March 5 to
July 8, 1984.
In addition to the insertion of 40 new fuel
bundles into the core, major planned maintenance activities
included eddy current testing of both steam generators, sludge
lancing of the secondary side of both steam generators, repair
of the reactor coolant pump gaskets, work on the QSPDS, and
replacement of the high pressure turbine rotor. Three
additional activities that occurred during this outage included
the " rim cut" on the steam generator's tube support. plate,
plugging of the failed tube in Steam Generator RC-2B, and rework
,'
of 638 containment penetration lead wires to protect them from
the harsh environment of a LBLOCA.
Fort Calhoun Station experienced a 2-week outage from
November 18 to December 3,1984, to repair a body-to-bonnet
flange leak on a pressurizer spray valve.
2.
Power Limitations
The reactor was not limited in power level below the licensed
limits during this appraisal period.
3.
License Amendments
Amendment No. 75
-Authorized Spent Fuel Pool Rerack,
September 9,-1983
Amendment No. 76
Administrative Changes, January 26, 1984
... ..
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' Amendment No. 77
Cycle 9 Restart, April 26, 1984
Amendment No. 78
Shift Manning and QC Personnel Changes,
May 16, 1984
Amendment No. 79
Snubber Changes, May 23, 1984
Amendment No. 80
Add Operability and Surveillance
Requirements for RCS Vents and
Administrative Requirements for Analysis of
Plant Effluents, July 9,1984
Amendment No. 81
Add Operability and Surveillance
Requirements for Containment Wide Range
Radiation Monitors, Wide Range Noble Gas
Monitors, and Main Steam Lines Radiation
Monitor, July 12, 1984
Amendment No. 82
Add Operability and Surveillance
Requirements for Containment Hydrogen,
Water, and Pressure Monitors, August 2, 1984
Amendment No. 83
Update Surveillance Capsules Removal
Schedule, September 7, 1984
Amendment No. 84
Plant Support and Plant Organization
Changes, September 7, 1984
Amendment No. 85-
Limit Overtime and Report PORV/SV
Failures and Challenges, October 11, 1984
4.
Significant Modifications
Major modifications completed during this appraisal period
included the installation of new spent fuel racks, removal of
steam generators drilled tube support plate rim, implementation
of new secondary chemistry control in response to the failed
tube in Steam Generator RC-2B, and the upgrading of
instrumentation, limit switches, containment penetrations, etc.
to meet EEQ requirements.
B.
Inspection Activities
1.
Violations
See Table 1.
2.
Major Inspections
During this appraisal period, one special inspection was
conducted in the area of security and safeguards. The
7-
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-31-
inspection was performed by a team of three inspectors and one
observer from outside Region IV and involved a total of 235
direct inspection man-hours.
(NRC Inspection
Report 50-285/84-20)
C.
Investigations and Allegations Review
One investigation was conducted during this appraisal period and it
addressed the material false statement made by the licensee in their
response to IE Bulletin 82-02, " Degradation of Threaded Fasteners in
Reactor Coolant Pressure Boundaries of PWR Plants." It was confirmed
by the investigation that the OPPD response to the NRC was false in
that " Super-Moly" (molybdenum disulfide) was used on the reactor
vessel and reactor coolant pump studs and that a mixture of 50
. percent oil and 50 percent graphite was designated for use on manway
studs. These failures by the licensee to perform an adequate review
of the related documentation, to coordinate the response with
knowledgeable personnel, and to identify the false statement during
.
the OPPD required procedural review, resulted in a Severity Level III
Violation. An enforcement conference was held on December 20, 1984,
between the NRC and the licensee to discuss this matter.
One allegation was received during this appraisal period that
identified certain incidents which had occurred over the past five
years and alleged poor management practices in the area of
supervision and discipline that could affect the safety and health of
the public. The review and followup of this allegation was still in
progress at the close of this appraisal period, and is expected to be
resolved during the first quarter of the next SALP period.
D.
Escalated Enforcement Actions
1.
Civil Penalties
Two notices of violation with proposed imposition of civil
penalties were issued to the licensee during this appraisal
period.
A Severity Level III Violation and a proposed civil penalty
.
of $40,000 were issued as a result of the material false
statement made by the licensee in their response to IE
Bulletin 82-02, " Degradation of Threaded Fasteners in
Reactor Coolant Pressure Boundaries of PWR Plants." In
consideration of OPPD's prior good performance in this
area, and their prompt and extensive corrective actions,
the Regional Administrator determined that the civil
penalty should be fully mitigated.
-
1
!
- -
.
!
-32-
A Severity Level III Violation was issued in the area of
.
security and safeguards that comprised a composite of seven
Severity Level IV and V Violations and reflected an overall
weakness in the Fort Calhoun Station security program. A
civil penalty of $50,000 was proposed, but this amount was
mitigated to $25,000 on the basis of the licensee's
previous good enforcement history in this. area.
E.
Management Conferences Held During Appraisal Period
1.
Conferences
The following conferences were held between Region IV and the
licensee during this appraisal period:
Enforcement conference of September 9, 1983, at the Region
.
IV office to discuss NRC concerns related to construction
QA records and the QA records file room.
The bases for
.
this meeting were the findings described in NRC Inspection
Report 50-285/83-17.
Management meeting of September 21, 1984, at the Region IV
.
office to discuss the licensee's operator licensing program
in response to Mr. J. T. Collins letter of August 13, 1984,
to Mr. W. E. Miller of OPPD.
Enforcement conference of October 11, 1984, at the Region
.
IV office to discuss the results of NRC Inspection
Report 50-285/84-20 which documented nine violations and
two deviations identified by the special inspection team.
Enforcement conference of December 20, 1984, at the Region.
.
IV office to discuss the licensee's response to IE
Bulletin 82-02 and the associated material false-statement
cited in NRC Inspection Report 50-285/84-12.
2.
Confirmation of Action Letters (CALs)
The following CALs were issued by Region IV during this
appraisal period:
J. T. Collins letter of June 5,1984, to W. C. Jones of
.
OPPD to confirm the actions and conditions required of OPPD
in relation to the failed tube in Steam Generator RC-2B.
J. T. ' Collins letter of August 16, 1984, to Mr. R. L.
.
p
Andrews of OPPD to confirm the actions required of OPPD in
- -
response to security matters identified in NRC Inspection
Report 50-285/84-17.
r
!
L-
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' ~
..
-33-
_
-
F.
' Review of Licensee Event Reports and 10 CFR Part 21 Reports
Submitted by the Licensee
1,
Licensee Event Reports (LERs)
The SALP Board reviewed the LERs for the period September 1,
1983, through February 28, 1985. This review included
LERs83-008 through 83-013, and 84-001 through 84-025. The SALP
Board reviewed the licensee's cause classification for these
LERs and did not identify any significant differences between
those made by the licensee and those made independently by the
board.
Due to the. revised LER rule that went into effect on January 1,
1984, the licensee was required to report a significant number
of unplanned VIAS actuations that were not performing a safety
function.
This resulted in an increase of LERs this appraisal
period even though the new rule was intended to eliminate
inconsequential reports.
The licensee is considering a
Technical Specification revision to modify this specific LER
requirement.
The NRC Office for Analysis'and Evaluation of Operational Data
performed a review of licensee LERs, focusing on the accuracy
P
and completeness of the reports. Refer to Attachment 2 for
details of this review.
7
b
2.
Part 21 Reports
None
G.
NRR Activities
1.
NRR License Meetings
December 20, 1983
March 23, 1984
Environmental Qualification
April 17, 1984, and
Radiological Effluent Technical
October 11 & 13, 1983
Specifications
~
May 29, 1984
Steam Generator 8 Major Leakage
Event
December 13, 1984
Plant Security
February 5-8, 1985
In-Progress Audit of Licensee's
Detailed Control Room Design Review
t
,
,
, .
,.
-34-
2.
NRR Site Visits
October 11 & 14, 1983
Discussed Licensing Actions with
Resident Inspector and Visited Local-
May 23-26, 1984
. Emergency Trip to Address Steam
Generator 8 Major Leakage Event
August 27-29, 1984
Toured Plant, Reviewed TMI Related
Modifications, and Discussed Licensing
Actions with Resident Inspector
February 6-7, 1985
Toured Control Room and Remote
Shutdown Panel and Discussed Licensing
Actions with Resident Inspector
3.
Commission Briefings
.
None-
- 4.
Schedular Extensions Granted
IST 2nd 10 year program, interim schedular relief for 1 year,
September 30, 1983
IST 2nd 10 year program, interim schedular relief for 1--year,
October 9, 1984
EQ Schedular-Extension, May 18, 1984
5.
Reliefs-Granted
ISI 1st 10 year program, 2 reliefs, November'14, 1984
ISI 2nd 10 year program, I relief, September 30, 1983
ISI 2nd 10 year program,'8 reliefs, April 6, 1984
6.
Exemptions Granted
None
7.
Emergency Technical Specifications Issued
None-
L.
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.
.
.
.
.._
. -
.
.
. . .-.
e.
.
I
pp .c
.~
-35-
- 8.
- Orders Issued
Order confirming licensee commitments on emergency response
capability.as. required by Supplement l'to NUREG-0737,
,
- February 22, 1984.
.
9.
NRR/ Licensee Management Conferences
None-
.
'
i
4
.
Y
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-36-~
'
TABLE 1
. INSPECTION ACTIVITY AND ENFORCEMENT
'
,
,j;j
FUNCTIONAL
NO OF VIOLATIONS IN EACH SEVERITY LEVEL-
- ~ -
AREA
V
IV.
III'
II
I
DEVIATIONS.
,
'
o
'A.' l Plant Operations
4
B.
Radiological Controls
1
.C.~
Maintenance'
2
2
-
,,
10.
Surveillance
E.
' Fire Protection
.
'F.
- Emergency Preparedness-
G.
Security and Safeguards
5
1*
3
-
H. : Refueling
.I.
Quality Programs and
1
4
1
.,
Administrative Controls.
'
,:Affecting Quality
.J.
Licensing Activities'
,
'
- K.
Training
3
. TO TA'L '
.4
18
2*
0
0
3
2
.
'
'*This. comprises seven Severity Level IV and V Violations identified in NRC
Inspection Report 285/84-20.
,
. - - -
.
-
-