ML20133A813
| ML20133A813 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/29/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133A777 | List: |
| References | |
| 50-285-96-17, NUDOCS 9701020119 | |
| Download: ML20133A813 (14) | |
See also: IR 05000285/1996017
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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Docket No.:
50-285
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License No.:
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Report No.:
50-285/96-17
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Licensee:
Omaha Public Power District
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Facility:
Fort Calhoun Station
Location:
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 393, Hv/y. 75 - North of Fort Calhoun
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Fort Calhoun, Nebraska
Dates:
November 22 through December 6,1996, and December 16 through
December 20,1996
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Inspectors:
W. Walker, Senior Resident inspector
V. Gaddy, Resident inspector
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Approved By:
W. D. Johnson, Chief, Project Branch B
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ATTACHMENTS-
1. SupplementalInformation
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2. PASS Containment Atmosphere Grab Sample White Paper dated
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December 13,1996
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9701020119 961229
ADOCK 05000285
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EXECUTIVE SUMMARY
Fort Calhoun Station
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NRC Inspection Report 50-285/EG-17
This specialinspection included aspects of the implementation and maintenance of your
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Technical Specification program. Specifically, the insper. tion focused on the events
associated with the inoperability of the postaccident sarapling system.
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Plant Sucoort
Although, in August 1995, the licensee knew that a sample of the containment
atmosphere could not be obtained using the in-line isotopN sequence of the
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postaccident sampling system, the licensee did not revise or cancel the preventive
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maintenance order which directed drawing containment atmosphere samples
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utilizir,g the isotopic sequence of the postaccident sampling system. This is an
apparent violation of Technical Specification 5.15 (Section R8.1).
Engineering management gave verbal authorization to perform a modification to the
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postaccident sampling system prior to the completion of the engineering change
notice that would have authorized the configuration change. Performing the
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modification prior to completion of the engineering change notice is an apparent
violation of 10 CFR 50, Appendix B, Criterion V (Saction R8.2).
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The licensee assigned the incorrect work priority to a maintenance work document
to repair the inoperable containment atmosphere sequence of the postaccident
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sampling system. This incorrect work priority potentially contributed to delays in
returning the system to an operable status. This is an apparent violation of
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Technical Specification 5.15.4 (Section R8.3).
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For over 4 months, the licensee failed to maintain the containment atmosphere
sequence of the postaccident sampling system as required by Technical
Specifications and could not have obtained a sample of the containment atmosphere
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because this sequence of the postaccident sampling system was inoperable. This is
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an apparent violation of Technical Specification 5.15 (Section R8.3).
The inspectors identified that a preventive maintenance order for a quarterly sample
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of the containment atmosphere was administratively closed without the approval of
the plant manager as required by the preventive maintenance program. This is an
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apparent violation of Technical Specification 5.15 (Section R8.5).
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Report Details
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Backaround
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On August 21,1996, the inspectors observed a chemistry technician attempt to obtain a
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sample of the containment atmosphere using the postaccident sampling system. The
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preventive maintenance order and the procedure being used directed the sample be drawn
using the isotopic analysis capabilities of the postaccident sampling system. The
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inspectors noted that the sample could not be drawn because the isotopic analysis portion
of the containment atmosphere sequence of the postaccident sampling system had been
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removed from service several months earlier. This issue was identified as an unresolved
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item in NRC Inspection Report 50-285/96-08.
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l. Enaineerina
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Engineering Support of Facilities and Equipment
E2.1
Review of Uodated Safety Analysis Reoort Commitments
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A recent discovery of a licensee operating their facility in a manner contrary to the
Updated Safety Analysis Report (USAR) description highlighted the need for a
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special focused review that compares plant practices, procedures and/or parameters
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to the USAR description. While performing the inspections discussed in this report,
the inspectors reviewed the applicable portions of the USAR that related to the -
areas inspected. The following inconsistency was noted between the wording of
the USAR and the plant practices. procedures and/or parameters observed by the
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inspectors.
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Section 9.13.1 of the USAR requires that a postaccident sampling system be
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provided to promptly obtain containment atmosphere samples. The sampling and
analysis mus2 be able to be performed under accident conditions. As discussed in
Section R8 of this inspection report, there was a period of over 4 months during
which the licensee could not obtain and analyze a containment atmosphere sample
under postaccident conditions utilizing the postaccident sampling system.
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11. Plant Suaport
R8
Miscellaneous RP&C issues
R8.1
(Closed) Unresolved item 50-285/96008-02: inadequate PASS procedures. In
response to the inspectors' concerns, the licensee provided additional information to
the inspectors.
On August 21,1996, the inspectors observed a chemistry technician attempt to
obtain a grab sample of the containment atmosphere. The sample was authorized
by Preventive Maintenance Order (PMO) 9605793. The sample was to be obtained
using Procedure CH-SMP-PA-0001," Post Accident Sampling System Normal
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Operation," Revision 11. As documented in NRC Inspection Report 50-285/96008,
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the sample could not be obtained because the PMO directed that Step 6.7 of the
procedure be completed to obtain an isotopic analysis of the containment
atmosphere using Intrinsic Germanium Detector SL-36. The sample could not be
obtained because this sequence of the PASS had been removed from service.
The chemistry technician informed the chemistry supervisor that performance of the
PMO or procedure as written was impossible. The chemistry supervisor indicate '
that the PMO should have directed that Step 6.8 of the procedure be used to
perform the sample. The inspectors learned that chemistry personnel knew that
although the PMO directed that Step 6.7 of the procedure be completed, this step
could not be done because the equinment called out in the step had been removed
from service. The inspectors reviewed a memorandum issued by the chemistry
department, dated May 1994, that stated that the in-line gamma isotopic analysis
detector (SL-36) was to be removed from service. In August 1995, the power
fuses to SL-36 were pulled which rendered it inoperable.
Although chemistry personnel knew that the equipment could not be used to
perform the specified function, they did not initiate the required procedure change
to ensure the accuracy of the procedure, nor did they initiate a change to the PMO
to ensure its accuracy. Failing to revise or cancel the preventive maintenance order
that directed analyzing the conta:nment atmosphere using the isotopic analyzer is an
apparent violation of Technical Specification 5.15.4, which required a program
which will ensure the capability to obtain and analyze a containment atmosphere
sample under accident conditions (50-285/96017-01).
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Subsequent investigations by the inspectors and the licensee revealed additional
deficiencies with the PASS and PMO program. These deficiencies are discussed
below:
R8.2 Unauthorized Modification of the PASS
a.
Inspection Scoce (92904)
The inspectors revie ned the activities surrounding an unauthorized modification
made
the PASS.
b.
Observations and Findinos
in Letter LIC-82-389, the licensee committed to Criterion 8 of NUREG-0737, item
II.B.3. In this commitment the licensee stated that the PASS was capable of
providing at least one sample per day for seven days following onset of an accident,
and at least one sample per week until the accident condition no longer existed.
Section 9.13.1 of the Updated Safety Analysis Report, states that sampling and
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analysis must be able to be performed under design accident conditions with a
dagraded core. Samples must be able to be taken of reactor coolant and the
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containment atmosphere over the entire range of possible conditions that could
exist both at the sample point and analysis station. The samples must be able to be
analyzed to quantify radioisotopes which are indicators of the degree of core
damage. Section 9.13.2.3 also states that the postaccident sampling system was a
remote system designed with some in-line analysis capabilities for obtaining data on
a real time basis. Flasks were provided for the containment atmosphere isotopic
analysis samples and as backup to the in-line equipment.
In a letter to the Office of Nuclear Reactor Regulation, dated September 23,1993,
the licensee submitted a request to revise the design basis for the postaccident
sampling system. The licensee proposed to replace the in-line isotopic analysis of
containment atmosphere with grab sampling.
On February 17,1994, the Office of Nuclear Reactor Regulation approved the
licensee's request to replace the in-line capability because of the poor reliability of
the in-line instrumentation. Since use of the grab sampling technique was
recommended as one of the options for isotopic analysis in Section ll.B.3 of
NUREG-0737, the request was approved.
In June 1994, Engineering Change Notice (ECN)94-107 was written to abandon
and/or remove the unreliable in-line isotopic analysis portion of the PASS. The ECN
was scheduled to be completed in October 1996.
On December 21,1995, the system engineer for the PASS initiated Condition
Report 199500428, documenting that portions of the PASS system had been
removed and taken to the warehouse for disposal. Specifically, computer
equipment that controlled the isotopic analysis was removed. This equipment was
most likely removed after August 1995 and discovered missing in December 1995.
The inspectors were informed that the power fuses for the in-line isotopic analysis
portion of the PASS were pulled in August 1995 thus rendering this portion of the
PASS inoperable. Although pulling fuses was allowed by the licensee's program,
removing the computer equipment prior to the issuance of the ECN violated the
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licensee's configuration control program. The ECN would have ensured that all the
required engineering analyses were performed prior to removing the equipment.
Removing portions of the PASS prior to completion and issuance of the ECN is an
apparent violation of Step 4.1.5(2) of Procedure PED-QP-2, " Configuration Change
Control," Revision 18, which requires, in part, that all configuration changes within
the configuration control boundary shall be authorized by an
ECN (50-285/96017-02).
Condition Report 199500428 indicated that the manager of design engineering
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nuclear and the acting manager of design engineering mechanical had given verbal
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authorization to remove the equipment prior to issuance of the ECN.
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Following discussions with the inspectors, on October 4,1996, the licensee
installed a temporary modification on the PASS until the issuance of the ECN and
counseled the managers that gave the verbal authorization to perform the
modification.
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Conclusions
A lack of adherence to the configuration controi proce is resulted in an unauthorized
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modification of the PASS.
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R8.3 Inocerability of the Grab Samole Capabilities of the PASS
a.
Inspection Scoce (92904)
The inspectors followed up on issues that resulted in one sample sequence of the
PASS being inoperable.
b.
Observations and Findinas
in February 1996, chemistry technicians initiated a maintenance work request to
repair a leaky fitting on the containment atmosphere grab sample sequence of the
PASS. The system engineer indicated that this leaky fitting prevented grab samples
of the containment atmosphere from being obtained and rendered this sequence
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inoperable. However, repairs to the PASS to allow grab samples to be obtained and
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analyzed were not performed. On June 14,1996, the system engineer initiated
Condition Report 19960781 documenting that the repairs had not been performed
and that this PASS sequence had been out of service since February 1996.
The inspectors reviewed Standing Order SO-G-98, " Administrative Controls for
Operation, Maintenance and Testing of the Post Accident Sampling System,"
Revision 2, to ensure that the licensee had assigned the correct priority to the
maintenance work request initiated in February 1996. The standing order required
that deficiencies that caused the PASS to be inoperable be assigned a Priority 3,
targeting work completion in 21 days. A review of Condition Report 199600781
concluded that the emergent work group had assigned the inoperable PASS a Work
Priority 4 in February 1996. Assigning the incorrect priority to an inoperable PASS
sequence is an apparent violation of Technical Specification 5.15
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(50-285/96017-03).
This was significant because with both the in-line isotopic analysis sequence of the
PASS and the grab sample analysis sequence of the PASS inoperable, the licensee
could not have obtained samples of the containment atmosphere as committed to in
Letter LIC-82 389. The in-line isotopic analysis sequence of the PASS had been
inoperable since August 1995. The grab sample sequence of the PASS had been
inoperable since February 1996, and was returned to service in July 1996. From
February 1996 to July 1996, the licensee could not have obtained a sample of the
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containment atmosphere. Technical Specification 5.15.4 states that the PASS
program shall be implemented and maintained to ensure the capability to accurately
monitor and/or sample and analyze radiological effluents and concentration in a
postaccident condition. This program will ensure the capability to obtain and
analyze a containment atmosphere sample under accident conditions. Failing to
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ensure that the PASS was operable from February to July 1996 is an apparent
violation of Technical Specification 5.15.4(50-285/96017-04).
The licensee performed an investigation into the delays surrounding repairing the
PASS. The investigation did not determine what happened to the original
maintenance work request initiated in February 1996. This maintenance work
request was rolled to another maintenance document about May 5,1996. This
new work document was assigned a Priority 3. The process of ordering parts to
repair the PASS was begun on May 6. Delays were encountered during the process
of ordering parts. On May 9, a request for quote was sent to the vendor. The
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vendor responded that a two week turnaround was needed to delivery the parts.
The parts were received on May 20,1996. Although the proper priority was
assigned to the second maintenance work document, the repairs were not
completed within the targeted due date (approximately May 27). These delays
extended the inoperability of the containment atmosphere sequence of the PASS.
The licensee determined that the original maintenance work request did not identify
that the leak caused the containment atmosphere grab sample sequence to be
inoperable. This resulted in the emergent work group assigning the maintenance
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work request the incorrect priority.
The inspectors performed additional reviews of Standing Order SO-G-98, and noted
that in Step 4.9.5 one of the responsibilities of the system engineer was to ensure
the PASS was maintained operable. The inspectors noted that with Intrinsic
Germanium Detector SL-36 inoperable, and with the repairs to Sample Fink SL-34
being assigned a Priority 4, the system engineer failed to ensure that the repairs
needed to return the containment atmosphere sequence of the PASS to an operable
status were completed in a timely manner,
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Conclusions
Although the grab sample sequence of the PASS was identified in February 1996 as
being inoperable, the repairs necessary to retuin the system to an operable status
were not performed until July 1996. This resulted in the licensee not maintaining
the Technical Specification required containment atmosphere sequence of the PASS
operable for over 4 months. Two successive maintenance work requests were
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generated to repair the PASS. In each case the licensee did not return the PASS to
an operable status by the target date. Failing to ensure the repairs were made
extended the inoperability of the containment atmosphere PASS sequence.
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Although the licensee recognized that the ability to obtain a grab sample was not
available in February of 1996, the licensee did not repair the inoperable portion of
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the PASS within a reasonable time. Based on the actions of the licensee, it
appeared thst there was inadequate sensitivity to maintaining the PASS operable.
R8.4 Repair of Inocerable Grab Samole Capabilities of the PASS
a.
Inspection Scope (92904)
The inspectors reviewed the circumstances surrounding the repair of the PASS.
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b.
Observations and Findinas
After the system engineer wrote the condition report in June 1996, documenting
that the grab sample portion of the PASS had been inoperable since February 1996,
the licensee initiated another maintenance work document. This maintenance work
document was completed on July 1,1996. The inspectors reviewed this work
document and determined that maintenance personnel replaced an autoclave valve
that was leaking near Pressure Transmitter 6703.
c.
Conclusions
if an accident had occurred while the system was inoperable, it was not apparent
that the licensee could have obtained and analyzed the samples of the containment
atmosphere as required by Technical Specifications.
R8. J vASS Administrative Controls
a.
Insoection Scope (92904)
The inspectors performed reviews to determine if the routine required samples of
the PASS were being performed as required by procedure and the licensee controls
over the preventive maintenance program.
b.
Observations and Findinas
The inspectors reviewed Standing Order SO-G-98, " Administrative Controls for
Operation, Maintenance and Testing of the Post Accident Sampling System
(PASS)," and noted that this procedure required that a containment atmosphere
grab sample in the normal mode be taken every 3 months. Grab samples were
obtained and analyzed on October 26,1995, and January 18,1996. The
inspectors were informed that the second quarter sample was not taken. This
sample was due on April 11,1996.
The inspectors learned that the licensee had administratively closed PMO 9603987.
This PMO required the April 1996 sample to be taken. The justification for
administrative closure recorded on General Form FC-1066 was that the equipment
was out of service and the task could not be performed. The inspectors reviewed
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Standing Order S0-M-2, " Preventive Maintenance Order," Revision 24, and
determined that this process provided for administratively closing PMOs.
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The inspectors reviewed the Form FC-1066 that administratively closed the
preventive maintenance task that was due on April 11,1996. The inspectors noted
that the authority to close the task was granted by the maintenance manager on
May 22,1996. However, Step 11.2.4 of Standing Order SO-M-2 states, in part,
that the maintenance supervisor and plant manager shall sign for approval of tasks
which are safety, security, and commitment related for administrative closure.
Failing to ensure that approval for administratively closing the preventive
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maintenance task was granted by the plant manager is an apparent violation of
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Technical Specification 5.15(50-285/96017-05). The inspectors also noted a
similar requirement for deferring preventive maintenance tasks.
The inspectors also determined that Form FC-1066 only required the plant manager
to approve administrative closure of preventive maintenance tasks that were safety
and EEQ related. It did not require that the plant manager approve security or
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commitment related tasks. These functions were not specified as requirements in
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the responsibilities section of the procedure. The inspectors asked if other security
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or commitment related tasks had been administratively closed or deferred without
the approval of the plant manager. In response, the licensee initiated Condition
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Report 199601134to address the generic implications of administratively closing
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and deferring preventive maintenance tasks without the plant manager's approval.
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The licensee initiated a change to Form FC-1066 to require plant manager's
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approval for closing or deferring PM tasks that were security or commitment related.
c.
Conclusions
The inspectors identified that the licensee violated their Standing Order SO-M-2 by
administratively closing PMO 9603987 without plant manager approval. The
inspectors also determined that Form FC-1066 only required the plant manager to
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approve administrative closure of preventive maintenance tasks that were safety
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and EEQ related. It did not require that the plant manager approve security or
commitment related tasks as required by the Standing Order.
111. Manaaement Meetinas
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Exit Meeting Summary
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The inspectors presented the inspection results to members of licensee management at the
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conclusion of the inspection on December 6,1996. At the exit meeting, the plant manager
stated that the inoperability of the postaccident sampling system was self-identified as
documented in the June 1996 licensee condition report.
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The inspectors acknowledged the licensee's position concerning identification and stated
that the issue would be further discussed at the predecisional enforcement conference.
The licensee did not identify as proprietary an information provided to, or reviewed by, the
inspectors.
On December 9,1996, the licensee provided the inspectors some additional information.
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The licensee stated that even with the leaking fitting, the containment grab sample could
have been taken.
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On December 16,1996, the inspection was re-opened to consider this additional
information. On December 17,1996, the licensee provided the inspectors with a white
paper that summarized a test that had been performed to prove that the grab sample could
have been taken. The test, conducted on December 10,1996, concluded that in a
accident condition a grab sample of the containment atmosphere could have been obtained
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provided containment pressure remained greater than 1.2 psig. With containment pressure
less than 1.2 psig, in-leakage through the leaking fitting could compromise the sample and
result in an inaccurate representation of the containment atmosphere.
The licensee provided the inspectors with a figure from the 1988 containment pressure
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analysis to support the basis that containment pressure would have remained above 1.2
psig. The figure plotted the containment pressure response for the design basis loss of
coolant accident during the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the event. The figure showed that
containment pressure peaked to approximately 52 psig immediately following the design
basis loss of coolant accident but decreased to less than 5 psig 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into the design
basis loss of coolant accident. The inspectors asked what would containment pressure be
beyond the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into the accident. At the conclusion of the inspection, the licensee
did not have an analysis to show how containment pressure would respond beyond 24
hours into a design basis loss of coolant accident.
The inspectors concluded that based on the additionalinformation provided, the licensee's
capability as required by Technical Specification 5.15 to obtain and analyze a containment
sample under accident conditions was questionable. The licensee did not provided an
analysis which demonstrated how the commitment in Letter LIC-82-389, dated
December 3,1982, could be accomplished. This commitment to NUREG-0737, Item
II.B.3, Criterion 8, stated that PASS equipment would be available for providirig at least
one sample per day for seven days following onset of an accident, and at least one sample
per week until the accident condition on longer existed.
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The inspectors re-exited on December 20,1996, with this additional information and
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determined the original apparent violations as previously stated were still applicable.
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ATTACHMENT 1
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SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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R. Andrews, Division Manager, Nuclear Services
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G. Bishop, Assistant Plant Manager
C. Brunnert, Manager, Quality Assurance and Quality Control
J. Chase, Manager, Fort Calhoun Station
R. Conner, Manager, Training
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.G. Cook, Supervisor, Station Licensing
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M. Core, Manager, System Engineering
H. Faulhaber, Manager, Maintenance
S. Gambhir, Division Manager, Production Engineering
W. Gates, Vice President, Nuclear
S. Gebers, Manager, Radiation Protection
T. Matthews, Supervisor, Nuclear Licensing
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R. Mueller, Acting Manager, Design Engineering, Nuclear
R. Phelps, Manager, Station Engineering
H. Sefick Manager, Security Services
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D. Spires, Manager, Chemistry
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M. Tesar, Manager, Corrective Action Group
J. Tills, Manager, Nuclear Licensing
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R. Wylie, Manager, Nuclear Construction
NRC
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V. Gaddy, Resident inspector
W. Walker, Senior Resident inspector
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INSPECTION PROCEDURES USED
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lP 92903:
Followup - Engineenng
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IP 5,'904:
Followup - Plant Support
IT_ EMS OPENED AND CLOSED
Opened
50-285/96017-01
eel
failure to revise or cancel preventive maintenance order
(Section R8.1)
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50-285/96017-02
eel
unauthorized modification of postaccident sampling system
(Section R8.2)
50-285/96017-03
eel
incorrect priority for postaccident samplir.g system repair
(Section R8.3)
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50-285/96017-04
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postaccident sampling system inoparable for over 4 months
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(Section R8.3)
50-285/96017-05
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failure to have plant manager approve administrative closure of
preventive maintenance work order on the postaccident
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sampling system (Section R8.5)
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Glosed
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50-285/96008-02
inoperable postaccident sampling system
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ATTACHMENT 2
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PASS Containment Atmosphere Grab Sample White Paper
In February 1996, during the perfonnance of CH-SMP-PA-0001 it was discovered a test connection "T"
Hattag upstream of PT-6703 was leaking. The test connection is located on the containment atmosphere gas
di6utson loop.
Pressure data was collected on 12/10/96 to determine the pressure at the test tee when a PASS containment
yob semiple is taken per CH.SMP-PA-0001, Section 6.6.
A -:- , :r-M test gauge was installed under MMO 964228 at the test tee (ref. Drw. file No. 24721). Section
6.4 o(CH-SMP-PA-0001 was then run and data recorded. The following data was obtained-
Containment pressure at the beginning and end of the data collection was 1.22 and 1.26 psig,
respectively. These readings were obtained from the Control Room narrow range pressure indicator
located on Al-66.
Pressure recorded at the test gauge with SL-30 running was 0.2 psig.
Pressure recorded at the test gauge after SL-30 was stopped and the suction line was subjected to a
static pressure from containment was 1.4 psig. The reason for the slight discrepance between the
control room narrow range prescure indicator and the test gauge reading is unknown. However, it is
assumed that the slight discrepance between the control room instrument reading and the test gauge
was due to instrument error.
Depending on which pressure indication is believed to be the most accurate, the data would indicate
est with SIf30 running a differential pressure from containment to the gas pump suction header
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(test tee)is approximatley 1.0 to 1.2 psi.
Additionally, when the Nitrogen purge sequence of the containment grab sample loop was initiated,
pressure at the test gauge was 17.2 psig with SI-30 running. Pressure after approximatley 10
seconds dropped to 16.8 psig during the purge sequence (SI-30 is running). Pressure increased to
18 psig when SL-30 was stopped.
At no time during the containment sample or nitrogen purge sequence did the gas pump, SL-30
drew a suction such that the pressure at the test tee was below atmospheric.
Casm&seiam
Freen he data collected, it can be reasonably concluded the PASS containment atmosphere sample loop
would have been operable during the period of time the test connection was leaking provided containment
pressure was greater that 1.2 psig. Containment atmosphere pressure above 1.2 psig would ensure the
enseien header was maintained at a positive pressure such that inleakage through the test connection would
not 'urvalidate the sample results. Since the PASS containment atmosphere sample is used to confirm core
desengs, post LOCA, there is a high probability sampling would occur within the period of time containment
pressure was greater than 1.2 psig (ref. attached LOCA pressure response curve).
Proyeeed By:
Date:
/3"/5 " 74-
Reviewed By: A
li
_Date: /2W W d
%
/
/
1
--
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m.
. . . ,
Fig. ~1 :
Pressure for 24 Hour LOCA Run
1984 FCS Centsinment Prweeurs Analyels
80
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