ML20150E350

Insp Rept 50-285/88-07 on 880201-29.Violations Noted.Major Areas Inspected:Followup on Previously Identified Items,Ler Followup,Operational Safety Verification,Plant tours,safety- Related Sys Walkdown & Security Observations

ML20150E350
Person / Time
Site:	Fort Calhoun
Issue date:	03/25/1988
From:	Harrell P, Mullikin R, Reis T, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20150E345	List: IR 05000285/1988007 ML20150E344 ML20150E347 ML20150E350
References
50-285-88-07, 50-285-88-7, NUDOCS 8803310101
Download: ML20150E350 (17)

See also: IR 05000285/1988007

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/88-07 License: DPR-40

Docket: 50-285

Licensee: Omaha Public Power District

1623 Harney Street

Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station

Inspection At: Fort Calhoun Station, Blair, Nebraska

Inspection Conducted: February 1-29, 1988

Inspector: ~

/[ [ / NU

Dath /

E H. tiajreW,~ Senio'r Resident Reactor

Inspe'ctor

%-- &

T. Reis, Residentr' Reactor Inspector

3-7-88

Date

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R. Mullikin, Project Engineer

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Date

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Approved: l

T' F.

/[bd

luil

rlesterman, Chief, Projects

2/25/ 2

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8803310101 880325

PDR ADOCK 05000285

O DCD

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Inspection Summary

Inspection Conducted February 1-29, 1988 (Report 50-285/88-07)

Areas Inspected: Routine, unannounced inspection including followup on

previously identified items, licensee event report fellowup, operational safety

verification, plant tours, safety-related system walkdown, monthly maintenance

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observations, monthly surveillance observations, security observations,

i radiological protection observations, and in-office review of periodic and

special reports.

Results: Within the 10 areas inspected, 2 violations (failure to meet the fire

brigade manning requirements, paragraph 4; and failure to follow procedures,

paragraph 8) were identified.

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DETAILS

1. Persons Contacted

• R. Andrews, Division Manager, Nuclear Production

• W. Gates, Plant Manager

• W. Bateman, Supervisor, Procurement Quality Assurance

C. Brunnert, Supervisor, Operations Quality Assurance

• M. Core, Supervisor, Maintenance

T. Dexter, Supervisor, Security

• J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs.

J. Foley, Supervisor, I&C and Electrical Field Maintenance

• L. Gundrum, Plant Licensing Engineer

• B. Hansher, Plant Licensing Engineer

• H. Hendrickson, Manager, Civil Engineering, Generating Station Engineering

• R. Jaworski, Section Manager, Technical Services

J. Kecy, Reactor Engineer

L. Kusek, Supervisor, Operations

• J. Lechner, Acting Plant Engineer

T. McIvor, Supervisor, Technical

• K Morris, Division Manager, Quality Assurance and Regulatory Affairs

• T. Patterson, Supervisor, Technical

• G. Roach, Supervisor, Chemical and Radiation Protection

• J. Spilker, Senior Nuclear Production Engineer

• S. Willrett, Supervisor, Administrative Services and Security

• Denotes attendance at the monthly exit interview.

The NRC inspectors also contacted other plant personnel, including

operators, technicians, and administrative personnel,

2. Followup on Previously Identified Items

a. (0 pen) Unresolved Item 4.5-3 of NRC Inspection Report 50-285/85-22:

Fuse block enclosure not addressed by the fire hazards analysis.

This item identified a wooden fuse block enclosure installed in each

battery room that was not addressed by the fire hazards analysis. No

determination could be made as to the significance of the enclosure

on the overall combustible loading for each battery rocm as the

enclosures had not been included in the fire hazards analysis.

The licensee painted the untreated wooden enclosures with a

fire-retardant paint to minimize the affect of the combustible

enclosure on the overall combustible loading in the battery rooms.

The NRC inspectors toured the battery rooms and verified the

enclosures were painted. Based on this action, it appeared that the

enclosures did not significantly increase the combustible loading for

these rooms.

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In October 1987, the licensee issued an updated fire hazards analysis

, to reflect changes in the plant since the last fire hazards analysis

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was issued. However, the updated analysis did not include the

i enclosures as combustible materials in the battery room fire areas.

This item remains open pending a revision to the fire hazards

analysis to evaluate the significance of the enclosures as

combustibles in the battery room fire areas,

b. (Closed) Severity Level IV violation II.F.2.1 (Deficiency 5.2-1) of

NRC Inspection Report 50-285/85-22: Failure to check and verify a

computer calculation.

This item involved the failure of the licensee to verify a computer

calculation generated by a contractor fcr the derating of electrical

cables that were enclosed in a fire protection wrapping system. The

cables were wrapped to meet the separation criteria specified in

Appendix R to 10 CFR Part 50.

The NRC inspectors reviewed Calculation MR-FC-85-25, "Cable Ampacity

Derating." This calculation was prepared by the licensee to verify

that the wrapped cables were capable of performing their intended

safety function. The calculation indicated that the cables were

satisfactory for continued plant operation.

In discussions with licensee personnel, it was determined that the

calculation provided by the contractor was intended for preliminary

analysis only and was not intended to be a part of the design basis.

, The contractor's calculation was only to be used as an independent

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verification of the licensee's calculation.

The NRC inspectors reviewed Calculation MR FC-85-25 and noted no

problems. Based on the review, it appeared that the licensee had

adequately established that the cables would adequately perform their

intended function.

! c. (Closed) Severity Level IV violation 285/8702-03: Failure to

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maintain the procedure for alignment of the breakers on the 480-volt

! motor control centers (MCC) in an up-to-date condition.

This violation was related to the licensee's failure to maintain the

procedure used for alignment of the breakers on the 480-volt MCCs in

an up-to-date condition. In response to this violation, the licensee

revised and reissued Checklist E of Procedure 01-EE-2, "480-Volt

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System (Normal Operation)," in May 1987 to correct the discrepancies

I noted during the walkdown performed by the NRC inspectors in

l January 1987.

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l During the July through August 1987 inspection period, the NRC

l inspectors performed a walkdown of the 480-volt electrical system

l using the revised chec 4 st. As documented in NRC Inspection

Report 50-285/87-20, this violation remained open pending the

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issuance of another revision to Checklist E. The revision issued in

May 1987 still contained deficiencies identified in January 1987 that

had not been corrected.

The licensee issued another revision to Procedure OI-EE-2 in

November 1987. This revision incorporated Checklists B, C, D, and E

of Procedure 01-CE-2 Into a single comprehensive checklist, ,

designated as Checklist B. In December 1987, the NRC inspectors

reviewed the revised Checklist B in conjunction with Figure 8.1-1 of <

the Updated Safety Analysis Report (USAR) and performed walkdowns of

various MCCs. The NRC inspectors found that the revised checklist l

still did not provide adequate instructions for all the electrical l

The NRC inspectors noted that some

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breakers on the MCCs.

safety-related loads were not included on the checklist and there was

no overall defined scope as to what should be included on the

checklist for normal operation of the 480-volt system.

The licensee performed a walkdown to determine the loads served by

each MCC. Based on this walkdown, Checklist B of Procedure OI-EE-2

was re-revised and issued on January 29, 1988. The NRC inspectors

reviewed the revision to Procedure 01-EE-2 and noted the

safety-related loads that were omitted during the December 1987

review were included. The NRC inspectors also verified, by a review

of selected loads, that the licensee had also included other loads in

Procedure OI-EE-2, as appropriate. Based on the review of the

revised procedure, it appears that the licensee has adequately ,

addressed the concerns noted by the NRC inspectors during the

previous procedure reviews and system walkdowns.

d. (Closed) Severity Level IV violation 285/8710-06: Failure to

maintain containment integrity. l

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This item involved the failure of the licensee to maintain

containment integrity during refueling activities. Containment

integrity was not reestablished after performing Procedure ST-DC-3,

"0C Transfer Switches," in that containment isolation valves were

automatically opened during transfer of the dc power supply and were

not subsequently manually reclosed by the control room operators.

To prevent recurrence of this problem, the licer,see issued a revision

to Procedure ST-DC-3. Tne revision required that the test not be

performed when containment integrity is required.

The NRC inspectors reviewed the procedure change made by the licensee

to verify that the change adequately implemented appropriate i

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corrective actions. By establishing a requirement that

Procedure ST-DC-3 can not be performed when containment isolation is

required, it appears that the licensee had taken appropriate actions

to prevent recurrence of this problem related to loss of containment

integrity.

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e. (0 pen) Open Item 285/8733-06: Freezing point of the antifreeze

solution in the cooling water system for the security and technical

suppart center (TSC) diesels was unknown.

This item was identified during the performance of a review to verify

cold weather preparations had been established. During the review,

the NKC inspectors noted that the licensee had not determined the

freezing point of antifreeze solution in the TSC and security

diesels.

In response to this concern, the licensee issued Maintenance

Orders (MO) 875927 and 875928 to check the freezing point in the

security and TSC diesels, respectively. In addition, the licensee

issued M0s 875835 and 875836 to check the freezing points in '

Emergency Diesel Generator (EOG) 1 and 2, respectively. The results I

of the determination of the freezing point indicated the following:

TSC diesel, -39 F; security diesel, -60 F; EDG 1 -28 F; and EDG 2,

-33*F. The licensee's engineering staff reviewed the data and i

determined that the results obtained indicated the operability of the

four diesels was satisfactory.

The licensee had established requirements for routinely sampling and

testing the antifreeze solution in EDG 1 and 2; however, no

requirements exist for routine testing of the antifreeze solution in

the security and TSC diesels. This item remains open pending the

establishment of a routine testing program for the security and TSC r

diesels.

3. Licensee Event Report (LER) Followup

Through direct observation, discussions with licensee personnel, and '

review of records, the following event reports were reviewed to determine ,

that reportebility requirements were fulfilled, immediate corrective

action was accomplithed, and corrective action to prevent recurrence had '

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been accomplished in accordance with Technical Specifications (TS).

The LERs listed below are closed:

87-001 Surveillance test performance error

87-018 Inadequate sizing of the air accumulators for Valves

HCV-385 and HCV-386  !

A discussion of the review performed by the NRC inspectors for ea&. LER is ,

provided below.

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a. LER 87-001 reported an event where two raw water pumps were out of

service at the same time due to the performance of a surveillance

test. The surveillance test removed one raw water pump from service l

when another pump was already out of service due to maintenance. ,

This event caused entry into a TS limiting condition for operation.

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As documented in NRC Inspection Report 50-285/87-15, the NRC  :

inspectors performed a review of this event to address the specific  !

concerns related to this event. During tbc review, the NRC l

inspectors noted that the licensee had not properly addressed the ,

generic aspects of this event. The generic aspects were related to

the need to review other surveillance tests to verify thLt the tests

were adequate to prevent a recurrence of the event.

The licensee revien d other surveillance procedures to cetermine

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whether or not changes should be made. Based on the review, the '

i licensee issued a revision to Procedures ST-ESF-6, "Diesel Start and

Diesel Fuel Oil Transfer Pump," ST-ESF-12, "SIRVT Temperature

Indication and Alarm," and 01-51-1, "Safety Injection-Normal '

Operation."

The NRC inspectors reviewed seleded surveillance procedures to

, determine if a change was required and reviewed the procedure  ;

revisions issued by the licensee. Based on this review, it appeared

that the licensee had taken appropriate actions to address the '

generic aspects of this event.

b. LER 87-018 reported an event where it wu discovered, during followup

of a violation issued in NRC Inspection v.eport 50-285/85-22, that

. Valves HCV-385 and HCV-386 did not meet the defined operating ,

criteria. The operating criteria was not met in that a single air

accumulator supplied both valves causing the valves to be susceptible

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to a single failure, and the air accumulator may not have shut the  ;

j valves within the 45-second time criteria specifited in the accident

. analysis. The licensee performed testing to determine the stroke

i time of the valves. The test data indicated that the valve closing

l time was at or near 45 seconds.

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t The function of Valves HCV-385 and HCV-386 is to shut when the

safety-injection system is automatically aligned to operate in the

containment recirculation mode. The valves shut to prevent the

I radioactive water in containment from entering ti.e safety injection

l and refueling water tank (SIRWT). If the valves failed to shut, the

I water entering the SIRWT would be contained within the auyiliary

building. The auxiliary building ventilation radiation detectors

! would alarm to alert the operator to the presence of airborne

contamination in the auxiliary building. The auxiliary bui' ding can

be secured to prevent the discharge of the contamination to the

environment.

I To correct this apparent design deficiency, the licensee installed a

separate air accumulator for each v 've. The additional air

accumulator was installed for Valve h;V-386 in accurdance with Safety

! Related Design Change Order (SRDCO) 87-35, "Instellation Procedure

J for ar, Air Accumulator for HCV-386." The e:cumulator size was

i verified to be adequate by performance of Calcelation FC-00507

j "Accumulator Sizing and Seismic Support for Subsystem IA-4407 and

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IA-4408." The licensee tested the accumulator installation and

verified that the closing times for both valves were approximately

35 seconds.

The NRC inspectors reviewed selected portions of SRDC0 87-35 and

Calculation FC-00507. During review of this documentation, the NRC

noted that the air accumulator had been seismically mounted, the

tubing used to connect the valve and the accumulator was seismically

supported, the size of the air accumulator was adequate, system

components were purchased in accordance with the appropriate quality

assurance requirements, and testing was performed to verify proper

performance of the accumulator installation.

The NRC inspectors also noted that the licensee's assumption for

proper operation of Valves HCV-385 and HCV-386 within the stated

accident analysis required operator action. Operator action is

required to manually shut Valves HCV-385 and HCV-386 to ensure that

the valves stay shut for 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> af ter initiation of the

containment recirculation. The licensee was in the process of

issuing a revision to Procedure E0P-20 "Functional Recovery

Procedure" to provide instructions for operations personnel at the

end of this inspection period. Because the licensee had not

completed the revision to Procedure E0P-20, this item remains open

pending approval and issuance of the procedure change. (285/8807-01)

To ensure that the air accumulators and associated valves continue to

perform their intended function, the licensee issued a revision to

Procedure ST-ISI-SI-1, "Safety Injection Valve Inservice Testing."

This procedure requires a regularly scheduled surveillance test be

performed to verify the adequacy of the installation by confirming

that valve stroke time is less than 35 seconds. The NRC inspectors

reviewed Procedure ST-ISI-SI-1 and determined that the procedure was

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! Based on the reviews performed by the NRC inspectors, as discussed

l above, it appeared that the licensee had taken appropriate action to

I correct the design deficiency for the air accumulators for

l Valves HCV-385 and HCV-386.

The licensee is continuing to review the adequacy of air accumulators

for other safety-related valves. The results of the reviews

performed by the licensee will be evaluated during close out cf

Deficiency 2.1-1 in NRC Inspection Report 50-285/85-22. ,

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No violations or deviations were identified. N

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4. Operational Safety Verification

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l The NRC inspectors conducted reviews and observations of selected

l activities to verify that facility operations were performed in

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conformance with the requirements established under 10 CFR, administrative

procedures, and the TS. The NRC inspectors made several. control room

observations to verify the following:

Proper shift staffing

Operator adherence to approved procedures and TS requirements

Operability of reactor protective system and engineered safeguards

equipment

Logs, records, recorder traces, annunciators, panel indications, and

switch positions complied with the appropriate requirements

Proper return to service of components

Maintenance orders (M0) initiated for equipment in need of

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Appropriate conduct of control room and other licensed operators

Management personnel toured the control room on a regular basis

During a review of the level of the licensee's staffing to meet the

requirements for manning the fire brigade, the NRC inspectors noted that

the onsite staff was not adequate. TS 5.2.2.e states that a fire brigade

consisting of five members shall be maintained on site at all times.

Amendment 40 to the TS issued the fire protection safety evaluation report

as part of the licensee's operating license. Section 6.1 of Amendment 40

states, in part, that a 5-man brigade be available onsite during all

shifts and independent of demands placed on operating personnel and the

security force in a fire situation.

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The licensee's staffing included eight security guards and seven operators

per shift that were qualified fire brigade members. The adequacy of

staffing was reviewed by the NRC inspectors based on the assumption that a

fire occurred in the control room. The duties of each onshift individual

, were: three operators to shut down the plant from remote locations, one

j operator to man the emergency notification system telephone as the

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declaration of an alert is required when evacuating the control room, five

j guards as an armed emergency response force, one guard to assist in plant

l shutdown, and one guard stationed on a compensatory measures post. With

these individuals assigned duties other than the fire brigade, the

remaining individuals, three operators and one security guard, were

available for fire brigade duties.

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By having only four individuals available for fire brigade duties, as

discussed above, the licensee failed to meet the TS requirement for

staffing of the fire brigade. This is an apparent violation.

(285/8807-02)

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During review of this item, the NRC inspectors and licensee personnel

determined that the establishment of a compensatory measures post for a

security guard' caused the fire brigade to be one member short of its

required complement.- When the compensatory post was established in

approximately June 1987, licensee personnel did not realize ~that the

action affected fire brigade staffing and did not add an additional fire

brigade member to each shift.

When the NRC inspectors notified the licensee of this problem, the

licensee took immediate actions to ensure that fire brigade was staffed to

meet TS requirements. This was done by reassigning the duties required of

the security guard in the event the control room is evacuated to another

individual. This allowed the security guard to participate in fire

brigade activities without having concurrent duties. The NRC inspectors

reviewed the actions taken by the licensee and it appeared that the fire

brigade was fully staffed.

5. Plant Tours

The NRC inspectors conducted plant tours at various times to assess plant

and equipment conditions. The following items were observed during the

tours:

General plant conditions', including operability of standby equipment,

were satisfactory.

Equipment was being maintained in proper condition, without fluid

leaks and excessive vibration.

Plant housekeeping and cleanliness practices were observed, including

no fire hazards and the control of combustible material.

Performance of work activities was in accordance with approved

procedures.

Portable gas cylinders were properly stored to prevent possible

missile hazards.

Tag out of equipment was performed properly.

Management personnel toured the operating spaces on a regular basis.

No violations or deviations were identified,

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6. Safety-Related System Walkdown

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The NRC inspectors walked down accessible portions of the following

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safety-related system to verify system cperability. Operability was

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determined by verification of selected valve and switch positions. The

system was walked down using the drawings and procedure noted.

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Auxiliary feedwater system (Procedure 01-FW-4, Checklist 'A,

Revision 31, and Drawings _ 11405-M-254, Revision 63, and 11405-M-253,

Revision 58)

During the walkdown, the NRC inspectors noted no discrepancies between the

drawings, procedure, and plant as-built conditions for the selected areas

checked.

No violations or deviations were identified.

7. Monthly Maintenance Observations

The NRC inspectors reviewed and/or observed seier,ted station maintenance

activities on safety-related systems and components to verify the

maintenance was conducted in accordance with approved procedures,

regulatory requirements, and the TS. The following items were considered

during the reviews and/or observations:

The TS limiting conditions for operation were met while systems or

components were removed from service.

Approvals were obtained prior to initiating the work.

Activities were accompli;hed using approved M0s and were inspected,

as applicable.

Functional testing and/or calibrations were performed prior to

returning components or systems to service.

Quality control records were maintained.

Activities were accomplished by qualified personnel.

l Parts and materials used were properly certified.

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Radiological and fire prevention controls were implemented.

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i The NRC inspectors reviewed and/or observed the following maintenance

activities:

M0 880525, "Charging Pump CH-1A Breaker Not Working Properly." This

! M0 was initiated because CH-1A had been tripping off line for no

l apparent reason. The problem was presumed to be associated with the

breaker itself. On February 10, 1988, the NRC inspectors observed

portions of the troubleshooting performed on the CH-1A breaker. The

NRC inspectors noted that the work was being performed in an approved

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critical quality equipment storage area. The personnel performing

the work were qualified electrical maintenance technicians and a

maintenance engineer was present to assist in the troubleshooting.

The NRC inspectors reviewed the M0 and verified proper authorization

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had been obtained to perform the work. The NRC inspectors also

verified that proper tags had been hung to identify that the

equipment was out of service.

Preventative Maintenance (PM) 880930, "Raw Water Pump Vibration

Testing." On February 8, 1988, the NRC inspectors observed an

electrician taking: vibration readings on raw water pump C. The

inspectors noted that the technician was using an approved procedure

and had a calibrated instrument to take readings.

M0 880340, "Repair Latches, Knobs, and Closures on Station Doors for

the Month of February." The NRC inspectors witnessed maintenance

personnel repairing a key card lock on the door that provided access

from the northeast turbine building to the switchgear room. The NRC

inspectors reviewed the M0 and noted it was properly filled out and

authorized. The NRC inspectors also noted that a security guard was

properly posted as a compensatory measure while the door was

undergoing repair.

M0 880579, "Remove and Repair VA-12A Fan / Motor Assembly." The

neutron detector well cooling fan, VA-12A, failed in early February.

The licensee decided to remove the fan from containment, and to

repair and reinstall it to minimize the risk of exceeding the

temperature limits specified in TS 2.13 for the concrete surrounding

the neutron detector cooling wells. Prior to performing the task,

the licensee surveyed the area for gamma and neutron dose rates to

develop man-rem estimates. The NRC inspectors reviewed the man-rem

estimates with appropriate licensee personnel. Based on the review,

it appeared the licensee employed appropriate measures to obtain

reliable dose rates.

Reactor power was reduced to 35 percent to remove the unit. The area

was shielded with water bottles to reduce the neutron flux at the

work site. The unit was removed, repaired per an approved procedure,

. reinstalled, and returned to service the following day.

MO 880467, "Leaking Air Regulator to HCV-2893." The NRC inspectors

witnessed an instrumentation and control technician remove a leaking

air regulator in the instrument air system for Valve HCV-2893, the

raw water backup inlet isolation valve. The NRC inspectors noted

that the technician had a properly authorized M0 and completed the

work in accordance with the instruction provided by the M0.

No violations or deviations were identified.

8. Monthly Surveillance Observations

The NRC inspectors observed selected portions of the performance of and/or

reviewed completed documentation for the TS-required surveillance testing

on safety-related systems and components. The NRC inspectors verified the

following items uuring the testing:

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Testing was performed by qualified personnel using approved

procedures.

Test instrumentation was calibrated.

The TS limiting conditions for operation were met.

Removal and restoration of the affected system and/or component were

accomplished.

Test results conformed with TS and procedure requirements.

Test results were reviewed by personnel other than the individual

directing the test.

Deficiencies identified during the testing were properly reviewed and

resolved by appropriate management personnel.

The NRC inspecto ; observed and/or reviewed the documentation for the

following surveillance test activities. The procedures used for the test

activities are noted in parenthesis.

Monthly testing of the pressurizer pressure channel check (ST-ESF-1)

Quarterly inservice testing of the raw water system valves

(ST-ISI-RW-1)

Biannual testing and loading of the emergency diesel generator

(ST-ESF-6)

Monthly test of the station battery chargers (ST-DC-2)

Quarterly inservice testing of the main steam isolation valves to the

turbine driven auxiliary feedwater pump (ST-ISI-MS-1)

Quarterly inservice testing of the chemical and volume control system

valves (ST-ISI-CVCS-1)

During observation of the above surveillance tests, the NRC inspectors

noted three examples where licensee personnel did not strictly adhere to

approved station procedures. The examples are discussed below.

The NRC inspectors observed a water plant operator timing the stroke cycle

of raw water Valve HCV-2853 per ST-ISI-RW-1. Procedurally, the operator

was required to use a stopwatch. Instead, the operator used his personal

wristwatch which did not have a stop function. The NRC inspectors noted

that, upon realizing the noncompliance, the operator stopped, obtained a

stopwatch, and reperformed the test on Valve HCV-2853 as well as other

valves he had timed prior to the arrival of the NRC inspectors.

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The NRC inspectors witnesse'd the performance of ST-ESF-6. During the

portion of the procedure where the operator was required to unload the

diesel generator, the operator temporarily set aside the procedure while

concentrating on the control board. By doing this, he inadvertently

skipped over Step 17 which performed a checkout of the fuel oil transfer

pumps. The NRC inspectors alerted the operator of the omitted step and

they were subsequently performed prior to shutting down the diesel. The

NRC inspectors noted that performing these steps just prior to shutting

down the diesel is allowed by procedure. However,- it is apparent from the

scenario that the steps were simply overlooked.

, During observation of ST-DC-2, the NRC inspectors noted that an

electrician performed a portion of Step 1.b.(5) prior to performing

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Step 1.b.(4). This action was not allowed by procedure. The NRC

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inspectors noted that the performance of these steps out-of-sequence posed

no safety significance.

Section 5.8.1 of the TS states, in part, that written procedures shall be

established, implemented, and maintained that meet or exceed the minimum

requirements of ANSI 18.7-1972. ,

Section 5.1.2 of ANSI 18.7-1972 states, in part, that procedures shall be

followed and the requirements for use of procedures shall be prescribed in

writing.

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, Section 2.4 of Procedure 50-G-7 states, in part, that it is the

i responsibility of every individual performing activities to follow

procedures exactly as written and strict adherence to all procedures is

j absolutely required.

i

Contrary to the above, as described in the three examples discussed above,

individuals failed to follow surveillance test procedures exactly as'

written. This is an apparent violation. (285/8807-03)

The preceding three examples of procedural noncompliance did not affect

the safe operation of the plant. However, they are illustrative of what

was perceived as frequent inattention to detail and failure to follow

procedures. Four operations personnel were questioned and it was noted

that they were unfamiliar with the stringent requirement of Section 2.4 of

Procedure 50-G-7, which states that strict adherence to all procedures is

absolutely required.

Upon notification of the three problems by the NRC inspectors, the

licensee issued a memo, dated February 16, 1988, to all department heads

to stress that verbatim compliance with all procedures is mandatory. Each

department head then discussed the philosophy issued by the plant manager

with the individuals assigned to their departments.

'

[

1

. . - - . . . - . , .,__ - __ _ _ ,_r. . _ _ _ _ _____,_ ._ -,__.._.-..___ . _ , _ _ _ _ . , _ _ _ _ _ - , - --

. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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15

9. Security Observations

The NRC inspectors verified the physical security plan was being

implemented by selected observation of the following items:

The security organization was properly manned.

Personnel within the protected area (PA) displayed their

identification badges.

Vehicles were properly authorized, searched, and escorted or

controlled within the PA.

Persons and packages were properly cleared and checked before entry

into the PA was permitted.

The e'. '9ctiveness of the security program was maintained when

securi .y equipment failure or impairment required compensatory

measures to be employed.

The PA barrier was maintained and the isolation zone kept free of

transient material.

The vital area barriers were maintained and not compromised by

breaches or weaknesses.

Illumination in the PA was adequate to observe the appropriate areas

at night.

Security monitors at the secondary and central alarm stations were

functioning properly for assessment of possible intrusions.

On February 27, 1988, the licensee identified an event where a loss of

compensatory measures occurred due to a nuclear watch officer (NWO)

sleeping on watch. The NW0 was immediately relieved of his duties and

replaced with another qualified individual. The licensee took action to

prevent recurrence t'v reducing the frequency of watchstander radio checks

from 30 to 15 minutcs. In addition, the licensee also established a

program where the security officer-in-charge performs random tours of all

compensatory posts. The licensee reported the event to the NRC in

accordance with the requirements of the physical security plan. No prior

violations had been identified by the NRC that were similar to this event.

The NRC inspectors reviewed the actions taken by the licensee. Based on

this review, it appeared that the licensee had taken actions to correct

the event and had taken actions to prevent recurrence.

No violations or deviations were identified.

.

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16

10. Radiological Protection Observations

,

The NRC inspectors verified that selected activities of the licensee's

radiological protection program were implemented in conformance with the

facility policies and procedures and in compliance with regulatory

requirements. The activities listed below were observed and/or reviewed:

Health physics (HP) supervisory personnel conducted plant tours to

check on activities in prcgress.

Radiation work permits contained the appropriate information to

ensure work was performed in a safe and controlled manner.

Personnel in radiation controlled areas (RCA) were wearing the

required personnel monitoring equipment and protective clothing.

Radiation and/or contaminated areas were properly posted and

controlled based on the activity levels within the area.

Personnel properly frisked prior to exiting an RCA.

No violations or deviations were identified.

11. In-office Review of Periodic and Special Reports

In-office review of periodic and special reports was performed by the NRC

resident inspectors and/or the NRC Fort Calhoun project engineer to verify

the following, as appropriate:

Correspondence included the information required by appropriate NRC

requirements.

Test results and supporting information were consistent with design

predictions and specifications.

Determination that planned corrective actions were adequate for

resolution of identified problems.

Determination as to whether any information contained in the

correspondence should be classified as an abnormal occurrence.

Correspondence did not contain incorrect, inadequate, or incomplete

information.

The NRC inspectors reviewed the following:

Additional questions on OPPD response to Generic Letter 86-06, dated

February 4, 1988

Monthly operations report for January 1988, undated

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17

January monthly operating report, dated February 12, 1988

Threshold levels for the Fort Calhoun internals vibration monitoring

system dated February 25, 1988

During review of reports, NRC personnel identified a 10 CFR Part 21 report

submitted by a utility that appeared to be applicable to the licensee's

facility. The NRC resident inspectocs provided a copy of the report to

the plant licensing engineer for review of applicability by the licensee.

The report (Reference 87-74) was issued by the Northern States Power

Company and discussed problems with abrasive damage to the leads of

Limitorque valves.

No violations or deviations were identified.

12. Exit Interview

The NRC inspectors met with you and other members of your staff at the end

of this inspection. At this meeting, the NRC inspectors summarized the

scope of the inspection and the findings.