ML20135D951

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Insp Rept 50-285/96-12 on 961015-1101.Violation Noted.Major Areas Inspected:Inservice Insp Program,Maint Program & Followup Insp Effort in Operations & Engineering Areas
ML20135D951
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 12/04/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135D942 List:
References
50-285-96-12, NUDOCS 9612100280
Download: ML20135D951 (16)


See also: IR 05000285/1996012

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.. 50-285

License No.: DPR-40

Report No.: 50-285/96-12

Licensee: Omaha Public Power District

Facility: Fort Calhoun Station

Location: Fort Calhoun Station FC-2-4 Adm.

, P.O. Box 399, Hwy. 75 - North of Fort Calhoun

l Fort Calhoun, Nebraska

Dates: October 15 through November 1,1996

Inspectors: L. E. Ellershaw, Reactor inspector

l P. C. Gage, Reactor inspector

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Approved By: Dr. Dale A. Powers, Chief, Maintenance Branch

Division of Reactor Safety

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Attachment 1: Supplemental Information

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9612100200 961204 T

PDR ADOCK 05000285

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EXECUTIVE SUMMARY

Fort Calhoun Station

NRC Inspection Report 50-285/96-12

This inspection was performed using the guidance of NRC Inspection Procedures 73753,

" Inservice inspection," dated May 4,1995, and 62700, " Maintenance implementation,"

dated April 30,1993; to determine whether the inservice inspection program, including

repair and replacement of Class 1,2, and 3 pressure retaining components, and the

maintenance program were being performed in accordance with Technical Specifications,

the applicable ASME Code, correspondence between NRC and the licensee concerning

relief requests, and ipquirements imposed by NRC/ industry initiatives. The inspection also

included followup inspection effort in operations and engineering areas, using NRC

Inspection Procedures 92901, " Followup - Operations," and 92903, " Followup -

Engineering."

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Operations

I * The licensee's fuel handling practices were nonconservative and not indicative of

the requisite concern that should be given to irradiated fuel. Water clarity was very

poor in the reactor cavity refueling pool, thus refueling crews in containment could

not visually verify fuel assembly identification, structural condition, and core

location. All observed fuel handling activities in containment were performed only

by reference to refueling bridge location and mast elevation. Refueling crews did

not utilize mast lighting and closed circuit television camera aids in handling fuel

assemblies. The governing procedure per.nitted this lack of assurance for fuel

placement and integrity. Also, the reactor core refueling procedure lacked detail

with respect to what constituted a safe condition for a fuel assembly if refueling

operations had to be suspended while a fuel assembly was in the upender or in

transit between the upender and the reactor core (Section 01).

  • Good communications were observed between the refueling crews and the control

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room staff (Section 01).

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Maintenance

i e The inspectors concluded that the observed inservice inspection activities were

. performed well and in accordance with ASME Code requirements and applicable

procedures (Section M1).

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and appropriately included required performance and examination criteria

(Section M3).

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The observed nondestructive examination personnel we i properly certified in

accordance with ASME Code requirements (Section M5).

Enaineerina

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i A violation of Technical Specification 2.8(4) limiting condition for refueling  ;

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operations was identified when the inspectors determined that the operable wide l

l range logarithmic power channels did not provide adequate continuous neutron flux ,

l monitoring capability while core geometry was being changed (Section E8.2). l

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Report Details

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Summarv of Plant Status

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Fort Calhoun Station was in a refueling shutdown condition.

1. Operations

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l 01 Conduct of Operations

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i a. Insoection Scope (92901)

j The inspectors conducted observations of refueling activities and the conditions

] under which these activities were performed. Of particular interest were the

controls established by the licensee with respect to foreign material exclusion and

! the use of visual aids to support the refueling crew activities.

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I b. Observations and Findinas

i While touring the reactor cavity and spent fuel pool areas, the inspectors observed

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minor lapses in foreign material exclusion control. The inspectors observed a piece

of wadded up duct tape, three loose Chicago fitting locking pins, and a small piece

of cardboard in the reactor cavity area. The concern with the locking pins was that,

while they were logged in, they were not secured to preclude them from being

inadvertently knocked into the reactor cavity pool. Licensee personnel took

immediate steps to remove the items from the area upon hearing the inspectors'

observations.

In general, the reactor cavity and spent fuel pool areas were clean. The inspectors

observed snat each area had a single entry point where material accountability logs

were being maintained. With the exception of the piece of tape and the small piece

of cardboard, all observed items, including the Chicago fitting locking pins, had

.been entered into the log.

During core reload, the inspectors observed the clarity of spent fuel pool water to

be very good. However, the clarity of reactor cavity pool water was very poor,

oven though lighting fixtures had been suspended in the pool. The mast mounted

TV camera was not being used by the refueling crew to observe fuel assembly serial

numbers or to observe damaged or impending handling damage to fuel assemblies.

Because of the poor water clarity, the inspectors could not observe beyond

approximately 2 ft below the vessel flange, nor could the inspectors observe the

opender or fuel assemblies during transit. Licensing personnelinformed the

inspectors that efforts to improve water clarity were ongoing; however, assurance

that placement of fuel assemblies in their designated core locations was controlled

by computer zone coordinates and an above water alpha-numeric index marking

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system. The inspectors observed that Operating Procedure OP-11, " Reactor Core

Refueling," Revision 23, allowed fuelloading verification and the core alignment )

check to be performed following reload activities, i

The inspectors observed good communications between the refueling crews (spent

fuel pool, reactor cavity, and the control room).

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Early on October 30,1996, the licensee suspended refueling operations while Fuel  !

Assembly T004, a once-burned assembly, was in transit between the upender and

the reactor core. Rather than leaving the fuel assembly suspended for an indefinite

period of time, refueling personnel determined the best course of action was to

return the fuel assembly to the opender and place the upender in a horizontal

position. Licensee personnel were asked if thermal consequences had been

considered for leaving the fuel assembly in a horizontal position in the upender,

which restricted natural circulation. Licensee personnel then determined that the  !

upender should be placed in a vertical position. Upon review of Operating )

Procedure OP-11, the inspectors noted that precautionary statements existed which

would not allow operators to leave the area with a fuel assembly in a suspended

position, or, under certain conditions, provided guidance to return the fuel assembly

to the upender area, or to place the fuel assembly in a safe condition. The

inspectors discussed with licensee personnel the apparent lack of detail with regard

to wnat constitutes a safe condition, or what to do with the fuel assembly once it

had been placed in the upender,

c. Conclusions

Foreign material exclusion controls had been established and were, in general, being

implemented. Water clarity was very good in the spent fuel pool, but very poor in

the reactor cavity refueling pool. Refueling crews in containment could not visually

verify fuel assembly identification, condition, and core location; and the governing

procedure permitted this lack of assurance for fuel placement and integrity. Also,

the reactor core refueling procedure lacked specificity with respect to what

constituted a safe condition for a fuel assembly if refueling operations had to be

suspended while it was in the upender, or in transit between the opender and the

reactor core. Good communications existed between the refueling crew personnel.

ii. Maintenance  ;

M1 Conduct of Maintenance

a. inspection Scope (62700,73753)

The inspectors observed all or portions of the following work activities which were

performed by contractor personnel (Raytheon Engineers & Coristructors, and The

Atlantic Group), using the applicable procedures identified in the attachment.

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  • FC-96-VT-027 Visual examination of Auxiliary Cooling Water System

Support 12-AC-3C/PS-ACH-367/ACS-184.

  • FC-96-VT-028 Visual examination of Auxiliary Cooling Water System

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Support 16-AC-5/PS-ACH-371/ACS-188.

System Pipe Weld 12-CSS-2004/07.

System Pipe Weld 12-CSS-2004/07D.

Pipe Weld 12-CSS-2004/07.

Pipe Weld 12-CSS-2004/07D.

of Field Weld FW-19, root pass and final pass,

respectively, on ASME Code replacement

Valve FW-663.

b. Observations and Findinas

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The inspectors found the work performed under these activities to be professional i

and thorough. All work observed was performed with the work package

documentation and nondestructive examination procedures present and in use. The

inspectors determined through discussions and observations, that the observed ,

technicians were experienced and knowledgeable of their assigned tasks.  !

The inspectors also observed the Authorized Nuclear Inservice inspector witnessing

these activities. During discussion with the Authorized Nuclear Inservice inspector,

the inspectors learned that he planned on witnessing a minimum of 30 percent of

the inservice inspections scheduled to be performed during this refueling outage. In

addition, the inspectors observed that the Authorized Nuclear Inservice inspector

had reviewed and accepted all of the contractor's nondestructive examination I

procedures being used for inservice inspection.

The inspectors observed the technicians calibrate the ultrasonic equipment before

and after performance of the ultrasonic examinations. The calibration blocks were

identified and traceable to their certifications. The inspectors also verified that the

liquid penetract materials were certified as meeting ASME Code requirements.

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c. Conclusions

The inspectors concluded that the observed inservice inspection activities had been

performed well and in accordance with ASME Code requirements and applicable

procedures.

M3 Maintenance Procedures and Documentation

a. Inspection Scope (73753)

The inspectors reviewed the welding proceOtre specification, quality control

procedure, and work order documents listed in the attachment for the replacement

and examination of one component. The inspectors reviewed these documents to

determine if they had been developed in accordance with regulatory requirements

and the applicable ASME Code requirements.

b. Observations and Findinas

The inspectors observed that the welding procedure specification and the

nondestructive examination procedures had been developed in accordance with

licensee procedures, regulatory requirements, and applicable ASME Code

requirements. Accordirigly, applicable essential and nonessential variables and

acceptance criteria had been identified and documented in the procedures. The

inspectors also reviewed Maintenance Work Order MWO 961055, dated October

17,1996, which was developed for the replacement of Valve FW-663 (a Class 3

emergency feedwater bypass valve). The inspectors noted that the work order

specified the use of NRC authorized (via request for relief) ASME Code

Case N-416-1. The use of this Code Case allowed system pressure test alternatives

provided that additional surface examinations were performed on the root pass layer

of butt and socket welds on the pressure retaining boundary during repair and

replacement of Class 3 components.

c. Conclusions

The inspectors concluded that the work order package and procedures were well

developed for the identified tasks, and appropriately included required performance

and examination criteria.

M5 Maintenance Staff Training and Qualification

a. Inspection Scope (73753)

This area of the inspection was conducted to verify that nondestructive examination

personnel were properly certified in accordance with ASME Code requirements.

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b. Observations and Findinas

Based on. review of the qualification records for five contractor nondestructive

examination personnel who had been observed performing the e>.iminations

' identified in paragraph M1 above, the inspectors noted that all had recently been

requalified (based on examination) as Level 11 Examiners for the appropriate

exarnination method.

The inspectors verified that each examiner's qualification records contained a

current annual near-distance visual acuity and color vision examination certification.

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c. Conclusions

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The inspectors concluded that the observed examiners were properly certified in

accordance with ASME Code requirements.

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111. Enaineerina

E2 Engineering Support of Facilities and Equipment -l

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A recent discovery of a licensee operating their facility in a manner contrary to the

Updated Final Safety Analysis Report description highlighted the need for a special

focused review that compares plant practices, and/or parameters to the Updated

Final Safety Analysis Report description. While performing the inspections

discussed in this report, the inspectors reviewed the applicable portions of the

Updated Safety Analysis Report that related to the areas inspected. The inspectors

verified that the Updated Safety Analysis Report wording was consistent with the

observed plant practices, procedures and/or parameters.

E8 Miscellaneous Engineering issues (92903)

E8.1 (Closed) Licensee Event Report 50-285/95002: During a refueling outage the

containment polar crane (HE-1) was used to move the reactor vessel internals lift rig

over the reactor vessel while the reactor vessel head was not installed and

irradiated fuel was in the reactor vessel. Subsequently, the licensee also used the

crane and lift rig to install the reactor vessel internals hold down ring. The licensee

identified that appropriate containment conditions had not been fully established

prior to movement of these heavy loads. The licensee's Technical Specifications did

not specifically require containment closurc or isolation during movement of heavy

loads over the reactor vessel. The licensee performed a timely and detailed safety

evaluation and root cause determination.

The inspectors reviewed the licensee's root cause determination and corrective

actions, and determined them to be thorough. The inspectors also reviewed the

changes submitted for implementation in the Updated Final Safety Analysis Report

and the operationalinstructions and maintenance procedures regarding containment ,

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closure requirements during heavy load movements. The inspectors concluded that

the licensee was in compliance with the limiting conditions for operation dunng  ;

j- 'these events, and that the implemented corrective actions should prevent '

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. In conjunction with the review of Licensee Event Report 95-002, the inspectors i

l evaluated the licensee's actions in response to Bulletin 96-002, which requested  !

licensees to review plans and capabilities concerning heavy load movements during I

q plant operations.' The licensee, upon review of Technical Specifications, determined  !

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that no changes were required for NRC review and approval regarfog this subject. l

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j The inspectors reviewed the Technical Specifications, procedures regarding heavy

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load movement during plant operations, and the licensee's responses to

j Bulletin 96-02. The inspectors concluded that the licensee's plans and capabilities

! to handle heavy loads during power operations were consistent with existing

i regulatory guidelines. The inspectors also concluded that corrective actions in

response to Licensee Event Report 95-02 adequately addressed movement of heavy

1 loads in containment or over safety-related equipment during shutdown refueling

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! E8.2 Wide Ranae Loaarithmic Power Channels

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a. Inspection Scoce (92902)

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Reactor surveillance test results and operations logs and records were reviewed,

and reactor operations were observed to detarmine compliance with requirements in

j Technical Specifications 2.8. The procedures listed in the attachment were

j reviewed to determine satisf actory completion of initial conditions of Procedure OP-

11, " Reactor Core Refueling", Revision 23.

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l b. Observations and Findinas

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i The inspectors observed the licensee's control room operations during loading of the

! initial fuel assemblies at the periphery of the east quadrant of the core. The

inspectors verified that this loading sequence was in accordance with the fuel

! handling checklist found in Appendix A of procedure OP-11, " Reactor Core

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Refueling," Revision 23. During observation of control room operations, no audible

! counts were heard during loading of the initial seven fuel assemblies in the core,

l including Fuel Assembly T028, which contained one of the installed neutron sources

i for the core. The inspectors verified that these first seven fuel assemblies loaded

were adjacent to Channel D of the wide range excore nuclear instrumentation

j system. Subsequently, the inspectors verified that wide range Channel D of the

i excore nuclear instrumentation system was inoperable pending completion of an

i approved modification for the instrumentation. The inspectors confirmed that the

i other three wide range channels were declared operable, and that the licensee was

j utilizing Channeis A and C for supplying the neutron flux information, visually and

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audibly, while loading fuel into the core. The inspectors observed the control room

operator utilizing the wide range nuclear instrumentation data to calculate the i

inverse count ratio to provide the necessary information needed to monitor the core

for unexpected changes in neutron flux while changing core geometry. l

j Control room operators stated that the first audible indications of neutron counts  ;

were noticed during the loading of the first fuel assembly (Fuel Assembly T037)in j

! the west quadrant of the core. The inspectors observed that Fuel Assembly T037 l

and the next six that were loaded were located near the core periphery in the '

vicinity of operable Channel A of the wide range excore nuclear instrumentation

system.

I In addition to the audible count rate, a review of the inverse count ratio data

showed that a substantialincrease (30 times previous readings for Channel A and 2

times previous readings for Channel C) in monitored neutron indications was

observed. Yet, when the analogous assemblies near the inoperable detector of

Channel D were loaded, including a source, there was no change in the dats

a provided by the operable Channels A and C. I

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The design core load for Cycle 17 had the periphery assemblies near the wide range

detectors as twice burned fuel, thus similar characteristics were expected. During

the review of inverse count ratio data for subsequent fuel assembly loading, the

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inspectors noticed a normal progression of neutron subcritical multiplication effects

for the corresponding core geometry changes.

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The inspectors reviewed Technical Specification 2.8 limiting conditions for operation

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during refueling operations. The inspectors noted that this specification states in

part, "Whenever core geometry is being changed, neutron flux shall be continuously

monitored by at least two source range neutron monitors, with each monitor

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providing continuous visual indication in the control room." As discussed in detail

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above, the indications observed by the operators during the loading of the initial

seven fuel assemblies revealed that no signs of neutron flux monitoring, visual or

? audible, were provided by Channels A, B, or C until core loading resumed in the

vicinity of the Channel A detector. The inspectors observed that conditions within

the reactor vessel were of several thousand gallons of a high concentration (greater

that 2100 ppm) of borated water in addition to the geometrical consideration that

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the east core quadrant area was several feet away from the nearest operable

detector when Channel D was rendered inoperable. The inspectors considered that

4 given the core geometry, boron concentration, and inoperable detector location in

conjunction with core load sequence, that Technical Specification 2,8 was violated,

in that the operable detectors were incapable of providing changing neutron flux

indications in response to core geometry changes during the loading of the first

seven fuel assemblies (50-285/9612-01).
Condition Report 199601336was written on October 28,1996, by the licensee to

document the inspectors' observation of the prudence of loading fuel near an

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inoperable detector channel, and to track possible revisions to future reload

sequences to improve core monitoring. The inspectors noted that Condition Report

199601336 documented comments that the rep'acement schedule for the

modification cf the wide range excore nuclear instrumentation system would ensure

Channels A and D be operable for core reload operations because of the neutron

source locations. A review of the core load sequence reflected the licensee's

priority for installing the neutron sources early for assurance of indication provided

to the corresponding detectors.

After some delays were experienced with the implementation of the Channel D wide

range excore nuclear instrumentation modification, the licensee continued the fuel

load with the other three channels of instrumentation to support their original fuel

load sequence. When questioned by the inspectors, licensee personnel stated that

they considered their actions to be in compliance with Technical Specification 2.8,

in that two operable monitors were being utilized. Licensee personnel also stated

that the utilization of a temporary detector, or " dunking chamber" was not

l considered, nor was an alternate fuelioading sequence discussed in the event of an

inoperable wide range detector.

l Further actions by licensee management included a commitment to evaluate <

Operating Procedure OP-11, " Reactor Core Refueling," to determine the need for

establishing requirements that would cause an evaluation of fuel reload sequence to

l occur in the event of an inoperable wide range logarithmic power channel,

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The inspectors reviewed the current engineering analysis determining the minimum

refueling boron concentration. The inspectors noted that the analysis incorporated

conservative assumptions such as 5 percent shutdown margin maintained with all

control element assemblies fully withdrawn,68 F coolant temperature, xenon-free

l core condition, and a 0.4 percent reactivity uncertainty. Based on the review of the

reactor operations log, the inspectors verified that between October 28-30,1996,

i the licensee exceeded the minimum refueling boron concentration, as documented

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at eight hour intervals.

i c. Conclusions

A violation of Technical Specification 2.8(4) limiting condition for refueling ,

operations was identified when the inspectors determined that the operable wide

range excore neutron instrumentation channels did not provide continuous neutron

flux monitoring capability while core geometry was being changed during initial fuel

loadina. The inspectors concluded that inadequate procedural guidance existed to

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ensure that this Technical Specification requirement was complied with. 1

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The licensee's logs and records adequately documented reactor operations. All

reactor surveillance tests were completed at the reauired frequencies, and the

surveillance test results met Technical Specification requirements.

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Reactor maintenance activities were performed properly and in accordance with

approved procedures. The licensee's logs and records satisfactorily documented

reactor maintenance activities.

V. Mannaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on November 1,1996. While licensee management

acknowledged the findings presented, they also stated that they did not believe that a

potential violation of Technical Specification 2.8(4) existed, in that there were at least two

operable wide range logarithmic power channels as required by the Technical

Specifications while fuel was being reloaded. The licensee representative made a

commitment, which is described above in Section E8.2, related to the potential violation.

The inspectors asked the licensee whether any material examined during the course of the

inspection should be considered proprietary. No proprietary information was identified.

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ATTACHMENT

PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. Andrews, Division Manager, Nuclear Services

C. Boughter, Supervisor, Special Services Engineering l

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C. Brunnert, Manager, Quality Assurance /Ouality Control

J. Chase, Plant Manager

R. Connor, Manager, Training i

G. Cook, Supervisor, Station Licensing l

D. Dryden, Licensing Engineer

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M. Ellis, Supervisor, Maintenance Support )

S. Gambhir, Division Manager, Production Engineering

J. Gasper, Manager, Nuclear Projects

B Jaworski, Manager, Design Engineering

T. Patterson, Division Manager, Nuclear Operations

R. Phelps, Manager, Station Engineering

C. Stafford, Reactor Engineer

J. Tills, Manager, Nuclear Licensing

NRC l

F. Brush, Resident inspector, Callaway Plant

INSPECTION PROCEDURES USED

IP 73753 Inservice Inspection

IP 62700 Maintenance implementation

IP 92901 Followup - Operations

IP 92903 Followup - Engineering

ITEMS OPENED AND CLOSED

Ope ned

50-2535/9612-01 VIO Violation of Technical Specification 2.8(4) regarding the

f ailure to continuously monitor neutron flux during core

geometry changes.

C_Losed

50-285/95002 LER Movement of heavy loads over reactor vessel under

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inappropriate conditions.

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! LIST OF DOCUMENTS REVIEWED i

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PROCEDURES i

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Nondestructive Examination Procedure OPPD-UT-89-1," Ultrasonic Examination of Class 1 i

& 2 Similar and Dissimilar Metal Piping Welds," Revision O l

Nondestructive Examination Procedure OPPD-VT-89-3, " Visual Examination For Mechanical '

and Structural Condition of Components and Their Supports," Revision 0 ,

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! Nondestructive Examination Procedure OPPD-PT-89-1, " Liquid Penetrant Examination - I

! Solvent Removable, Visible Dye Technique," Revision 0 l

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Quality Control Procedure OCP-310, " Liquid Penetrant Examinations (Solvent Removable)," r

Revision 10 '

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Quality Control Procedure OCP-201, " Review of Vendor Procedures, Materials, Personnel l

and Equipment Certifications," Revision 0 ~

Welding Procedure Specification, WPS-101, Revision 7  !

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Station Engineering instruction PED-SEl-27, " Inservice inspection and Test Program," {

Revision 3 I

l Procedure SS ST MX-3001," Coordination of Safety Related System inservice Inspection," i

j Revision 9

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Maintenance Procedure MM-RI-FH-0708," Spent Fuel Machine PostoperationalInspection l

l and Maintenance," Revision 1

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! Operating Procedure OP-11, " Reactor Core Refueling," Revisions 22 and 23

Operating Instruction Ol-FH-1, " Fuel Handling Equipment Operation," Revision 32 l

Standing Order S0 M-10, " Foreign Material Exclusion," Revision 16

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Surveillance Test Procedure IC-ST-RM-5001," Functional Test of Process Radiation

Monitors," Revision 9  !

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Surveillance Test Procedure IC-ST-RM-0001," Functional Test of Area Radiation Monitors,"

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Revision 9

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Surveillance Test Procedure OP-ST-FH-0001," Refueling System Fuel Handling Machine

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, (FH-1) Interlocks Test," Revision 9

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Surveillance Test Procedure OP ST-FH-0002," Refueling System Fuel Transfer System

Interlocks Test," Revision 9

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Surveillance Test Procedure OP-ST-FH-0004," Refueling System New Fuel Elevator Test,"

Revision 9

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Surveillance Test Procedure OP-ST-FH-0005," Refueling System Spent Fuel Hardling

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Machine Refueling interlocks Test," Revision 9

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Surveillance Test Procedure OP-ST-FH-0006," Refueling System Spent Fuel Handling

Machine Interlocks Test For New Fuel Receipt," Revision 9

Calibration Procedure IC-CP-01-NT-001/2/3/4," Wide Range Log Channels integral Bias

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Curves and Calibration of Discriminator Voltage," Revision 2

I DRAWING

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Drawing FW-43971/1, dated October 30,1970

WORK ORDER AND ASSOCIATED DOCUMENTATION

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Maintenance Work Order MWO 961055 dated October 17,1996

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Weld Data Form, WDF-1, dated October 29,1996

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l ENGINEERING ANALYSIS

EA-FC-95-035," Critical Boron Concentrations and Refueling Boron Concentrations,"

Revision 0

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l REFUELING RECORDS

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, inverse Count Rate Ratio Data Records

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CONDITION REPORTS

199601217

199601336

, MODIFICATION

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MR-FC-94-004," Installation and Testing Requirements for Wide Range Neutron Monitoring

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Channels," Revision 0

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TECHNICAL SPECIFICATIONS 2.8, " Refueling Operations"

INSERVICE INSPECTION DESIGN DOCUMENTS

Safety Evaluation of the Third Ten-Year Interval inservice inspection Program Plan

Request for Relief From Pressure Test Requirements Following Repairs and Replacements

(ASME Code Case N-416-1)

UPDATED FINAL SAFETY ANALYSIS REPORT

Section 14.24," Heavy Load incident," Revision 2

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