ML20151R647

Insp Rept 50-285/88-10 on 880314-18.No Violations Noted. Major Areas Inspected:Surveillance Testing,Calibr Control Program,Surveillance Procedures & Records

ML20151R647
Person / Time
Site:	Fort Calhoun
Issue date:	04/13/1988
From:	Bundy H, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151R615	List: ML20151R610 ML20151R624 ML20151R634 ML20151R647
References
50-285-88-10, NUDOCS 8804280054
Download: ML20151R647 (10)

See also: IR 05000285/1988010

Text

. _ _ _ __ . __ .. _ . . _ _ _ ,

_,

'

1

, .,

.

_ APPENDIX C

4

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

l NRC Inspection Report: 50-285/88-10 Operating License: DPR-40

, Docket: 50-285

Licensee: Omaha Public Power District (OPPD)

1623 Harney Street

. Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station (FCS)

Inspection At: FCS, Blair, Nebraska

.

Inspection Conducted: March 14-18, 1988

l

-

'

Inspector: M/L3/91V

H. F. Bundy, Reactor Inspector, Test Frograms Date

Section, Division of Reactor Safety

!

4

,

Accompanied

By: W. C. Seidle, Chief, Test Programs Section

4 Division of Reactor Safety on March 17-18,

Approved: -

Y//3/ Pf

W. C. Seidl(,) Chief, Test Programs Section Date

i Division of Reactor Safety

Inspection Summary

4

Inspection Conducted March 14-18, 1988 (Report 50-285/88-10)

'

Areas Inspected: Routine, unannounced inspection of the licensee's

surveillance testing and calibration control program and surveillance

procedures and records.

>

, Results: The basic program for completion of Technical Specifications (TS)

l required surveillances and ASME Section XI required inspection of components

and testing of pumps and valves appeared to satisfy all requirements. The

licensee was using computer generated schedules advantageously. However,

followup by licensee management on delinquent completion of test reviews and

j filing appeared inadequate and an apparent deviation from a licensee commitment

j

$

8804280054

PDR 880419

O ADOCK 05000285

4 DCD

. .

2

was identified (paragraph 2). Scheduling of calibration of safety-related

components not identified in the TS appeared acceptable but cumbersome. In

recognition of this, the licensee was in the process of implementing a

computerized scheduling system for calibration.

Implementing procedures and the associated test records generated pursuant to I

the above programs generally satisfied all requirements. However, two apparent

violations involving failure to promptly resolve deficiencies identified during

a surveillance test and failure of the licensee to verify the correct

qualification for an examiner completing a reactor coolant leak test were

identified (paragraph 3).

i

l

-

1

'

'

, ..

.

3

DETAILS

1. Persons Contacted

OPPD

G. Gates, Manager, FCS

• L. Xusek, Manager (Acting), FCS

• M. Core, Supervisor, Maintenance

• T. Patterson, Supervisor, Technical

• J. O'Connor, Plant Engineer (Acting)

• L. Gundrum, Senior Nuclear Production Engineer

• J. Ressler, Test Engineer

E. Zbylut, Foreman (Acting), Instrumentation and

Control (I&C) Department

NRC

• P. Harrell, Senior Resident Inspector

• W. Seidle, Chief Test Programs Section, Division of Reactor Safety

The NRC inspector also interviewed other licensee personnel during the

inspection.

• Denotes those attendir.g the exit interview on March 18, 1988.

2. Surveillance Testing and Calibration Control Program (61725)

The purpose of this part of the inspection was to ascertain whether the

licensee had developed programs for control and evaluation of the

following:

• Surveillance testing, calibration, and inspection required by l

Section 3 of the FCS TS.  !

J

'

Inservice inspection of components and testing of pumps and valves as j

required by 10 CFR 50.553(g).

Calibration of safety-related instrumentation not specifically

controlled by TS. )

a. Surveillance Testing

The NRC inspector reviewed the licensee's Standing Order (S0) G-23, i

Revision 22 dated February 25, 1987, "Surveillance Test Program."

This 50 established a program for satisfaction of all surveillance

requirements specified in the TS. Among other requirements it

provided for the following:

Perfonnance of surveillance tests (ST) and inspections in

accordance with approved procedures

,

'

. .

'

,

4

Timely scheduling of all ST and inspections

4

• Proper review and approval of ST results

Followup on late or missed ST and on reported ST anomalies or

deficiencies

The NRC inspector learned, during an interview with the test engineer

responsible for master ST scheduling and generation of ST deficiency

reports, that a short-term delinquent report is generated daily for

tests not completed on schedule. It appeared that licensee

management had been taking appropriate followup action on the daily

report. The test engineer also discussed another report which shows

two categories of delinquencies. The first category is failure to

receive a certification of test completion from the person

responsible for test performance. The second delinquent category is

failure to receive the test for filing on time. This delinquency

indicates the ST results may not have been properly reviewed and

approved. This report is generated approximately every 2 to 3 weeks.

The NRC reviewed a delinquent report dated March 2, 1988. It

reported 11 STs dating from August 22, 1986, through the end of the

spring 1987 refueling outage, as delinquent for filing.

The NRC inspector questioned plant management on how they determine

associated component or system operability for STs which have not

been formally reviewed and filed. Licensee management responded that

any ST deficiencies or anomalies are discussed with the test engineer

and an informal disposition on operability is made. However, one of

the STs (NZ-1-F.1) on the report contained unresolved deficiencies

and anomalies and is further discussed in Section 3 below. The NRC

inspector did not identify any direct safety concerns resulting from <

the delinquent STs.

In pursuing the above problem, the NRC inspector discovered NRC

Violation 285/8511-01 had been issued on June 26, 1985. It involved

failure to account for six STs, performed during the refueling outage

ending in July 1984, in the files. In responding to this violation,

the licensee :tated, in part, "Each month the surveillance test clerk

will issue a list of ST's that are due but not filed and those due

but not completed. Each supervisor will be required to respond to '

this list by indicating the status of each test. This status list

will then be compiled and presented to the Plant Review

Comittee (PRC) by the Supervisor-Technical indicating those tests

not completed /not filed and the action taken to assure

completion / filing and the action taken to assure completion / filing by

the end of the next monthly review period."

l

This response clearly states that a delinquency will not be allowed [

to continue more than 1 month from the time it is identified. The i

existence of the 11 long-term ST delinquencies discussed above [

r

1

, .,

,

5

i

, represents an apparent deviation from the licensee's comitment to l

correct an identical problem in the response to '

Violation 285/8511-01.(285/8810-03).

! The scheduling of STs is performed utilizing a computer data base and ,

appears efficient. The licensee has identified isolated failures in  !

I

the scheduling which usually involves STs scheduled in a week which

i overlaps 2 months. The licensee is pursuing a resolution of this  ;

] problem.

j The NRC inspector observed that 50 0-30. Revision 4, dated August 27, l

!

1987 "Testing of Safety Related Equipment," provides adequate ,

requirements to ensure TS satisfaction and that safety is not l'

j related components. Also, SO G-23

'

compromised

requires whenreview

a biennial testingof;afetyll

a ST procedures which is implemented  ;

in accordance with 50 G-36,~ Revision 15. dated April 9, 1986, i

'

"Operating Manuals Review Documentation". Standing Order G-36  !

provides adequate guidelines to assure incorporation of any required  !

changes in the ST procedures.

t

'

The NRC inspector reviewed FCS License Amendments 109, 110, and 111  :

4 to ascertain that TS ST changes were properly incorporated in the  !

'

j procedures and found no discrepancies. However, the following  ;

1 documents were identified indicating problems with timely i

l incorporation of test changes in procedures had occurred.

i

"

NRC Violation 285/8729-04 identified that procedures for certain ,

surveillance tests identified in Amendment 110 had not been i

timely established and implemented. ,

I FCS Licensee Event Report (LER)87-037 stated that changes in i

l the EDG surveillance test required by Amendment 111 had not been *

!

l incorporated in the procedure and implemented as required. t

l In each instance above, the licensee committed to resolve generic  !

4 problems of correspondence control and distribution by April 15 j

j 1988.

! b. Inservice Inspection (ISI) of Components and Inservice Testing (IST)

,

of Pumps and Valves ,

l The NRC inspector reviewed the FCS "Inservice Inspection Program Plan  !

for the 1983-1993 Interval" (Plan), which was transmitted to the NRC l

by Letter LIC-83-226 dated September 26, 1983, and updated by ,

Letter LIC-84-009 dated January 10, 1984. The NRC inspector noted  !

that there are outstanding Nuclear Reactor Regulation issues on this  !

4

document which shoulo be resolved. The licensee comitted to the i

1980 Edition, Winter 1980 Addenda of the ASME Section XI Code. The

NRC inspector noted that review of this document had recently been  ;

) documented in NRC Inspection Report 50-285/88-06. Also, review of  ;

'

I

l

'

. .

.

6

selected records of component inspections had also been documated in

this inspection report. Therefore, the NRC inspector concentrated

his review on the program for testing pumps and valves and associated

procedures and records as discussed in paragraph 3 below.

The Plan appeared to satisfy the requirements of 10 CFR 50.55a(g) and

ASME Section XI for IST of pumps and valves. The licensee utilizes

the same computer based system discussed in 2.a. above for scheduling

ISI and IST and tracking deficiencies. The NRC inspector selected

several pump and valve tests and verified that they were scheduled

and performed as required by the Plan.

c. Calibration of Safety-Related Components not Specifically Controlled

by 15

The NRC inspector reviewed S0 M-26, Revision 9, dated July 16, 1986,

"Calibration Procedures." It required PRC-approved procedures for

all critical system instruments. However, the Acting Foreman, I&C,

stated that PRC approved procedures are used for all regular calibrations

and that special calibrations would have equivalent controls.

Procedure 50-26 also required shift supervisor approval to perfonn

calibrations and the review and approval of the results by the shift

supervisor.

The calibration schedule was being prepared manually. However, a

computer data base was being loaded in preparation for switching to

computer generated schedules. The manual scheduling and tracking of

calibrations appeared cumbersome but effective. The Foreman, I&C,

was receiving all feedback on calibration completions. He stated

that he would personally follow up on any delinquencies or

deficiencies.

Because of. prior problems involving inadequate acceptance criteria

for some safety-related instruments, plant engineering was reviewing

the monthly schedule on an interim basis to determine if acceptance

criteria were appropriate for all safety-related-instruments. The

current calibration program appeared acceptable.

No violations were identified. One apparent deviation is discussed in 2.a

above.

3. Surveillance Procedures and Records (61700)

The purpose of this part of the inspection was to ascertain whether the

surveillance of safety-related systems and compcnents was being conducted

in accordance with approved procedures as required by the TS and IST Plan.

Pursuant to this objective, the NRC inspector selected certain TS

surveillance requirements and components listed in the IST Plan, and he

reviewed the associated licensee test procedures and an appropriate number

. . .

.

7

of test results records for each procedure. The TS surveillance

requirements or IST component together with the associated test procedures

reviewed by the NRC inspector are tabulated in the Attachment.

The NRC inspector determined that the required tests were being scheduled

and performed as required in accordance with approved procedures.

Acceptance criteria were specified in the procedures and, with the

exceptions discussed below, the records stated satisfaction of acceptance

criteria. Appropriate instructions for returning equipment to service

following testing were given. Some problems involving failure-to complete

timely reviews of completed test records are discussed in Section 2.a.

above and an example is given below.

The NRC inspector discovered that completed Procedure ST-NZ-1,

Section F.1, for flow testing containment spray nozzles noted anomalies

and deficiencies which had not been formally reviewed and dispositioned.

Specifically, it was noted that ten nozzles were not tested because of

inaccessibility and that one nozzle was not working properly. The test had

been completed on May 8, 1987, and was listed as delinquent for filing in

the list updated on March 2, 1988. The failure to evaluate the anomolies

or deficiencies with these nozzles is an apparent violation of 10 CFR

Part 50, Appendix B, Criterion XI, and the approved quality assurance

program. (285/8810-01)

The NRC inspector discussed the deficiencies noted in the test record for

ST-NZ-1 with plant management on March 15, 1988. The NRC inspector

expressed concern that the plant had been restarted with a question about

the operability of the containment spray system. The Supervisor-Maintenance

initiated an Incident Report on March 16, 1988, to address the test

problems noted. It contained the results of a preliminary safety analysis

which indicated that over 100 spray nozzles must be plugged before the

design flow rate of 5100 gpm would be decreased. The NRC inspector had no

further safety concerns on this test or the operability of the system.

During the inspection, the NRC inspector requested records verifying the

appropriate qualification level of examiners who completed reactor coolant

system leak testing on May 29, 1987, and on June 1, 1987, in accordance

with Procedure ST-RLT-1, Section F.1. Because these records were not made

available prior to the exit, it was discussed as an unresolved item.

Copies of qualification records were subsequently forwarded by the

licensee to the NRC Region IV office on March 22, 1988. The qualification

record for the examiner completing the test on May 29, 1987, indicated he

had only an ANSI N45.2.6, Level I qualification for hydrostatic testing.

Paragraph F.1.b.(2)(a) of ST-RLT-1 states that examiners must be qualified

in accordance with ASME Section XI, Article IWA-2000. Paragraph IWA-2212

of Article IWA-2000 requires the use of VT-2 visual examination for leak

testing. Subarticle IWA-2300 requires qualification of personnel

__ _ _

'

..

.

8  !

I

performing VT-2 examinations in accordance,with the comparable levels of

competency ~as defined in ANSI N45.2.6-1973. It also requires annual

visual examinations to verify satisfaction of stated criteria. Records of

the visual examinations were not made available by the licensee. The

licensee's 50 G-26, "Maintenance Quality Control Program," implements

.

qualification of personnel to ANSI N45.2.6-1973 requirements. Table 1 of

50 G-26 requires a minimum Level II capability for personnel who evaluate

and report test results. Compliance with procedures is required by

TS 5.8.1 as discussed above. Evaluation and reporting of test results for

ST RLT-1, Section F.1, on May 29, 1987, by an examiner having an ANSI

N45.2.6 Level I qualification (lower than the required Level II)-is'an

apparent violation of TS 5.8.1. -(285/8810-02). Because the examiner who

performed the retest on June 1, 1987, appeared to be qualified to ANSI

N45.2.6 Level II capability, the NRC inspecto- had no direct safety

concern resulting from the qualification problem.

The NRC inspector noted that neither the qualification records nor 50 G-26

specifically mention qualification to ASME Section XI VT-2 requirements.

One qualification record referenced hydrostatic testing and the other

record referenced leak inspection. To avoid confusion, the ASME,

SNT-TC-1A, or other code terminology should be utilized in preparing the

qualification record.

Two apparent violations are discussed above. No deviations were

identified in this area.

4. Exit Interview

The NRC i pector met with licensee representatives denoted in Section 1

on Marci s, 1988, and summarized the scope and findings of the

insr " a. After receipt of additional information regarding

qua' 'at',ns of the examiners performing Leak Test'ST-RLT-1 (discussed

.

in h . on 3 above), the NRC inspector contacted the licensee's

Ms. l .andrum and informed her that there appeared to be a violation

involving an inadequate qualification level. The licensee did not

identify as proprietary any of the materials provided to or reviewed by

the inspecto. during the inspection.

l

i

l

l

i

,

l

l

1

_

'

,~

-

, ,

Attachment

PROCEDURES AND RECORDS REVIEWED

Requirement /

Component Description' . Test Procedure

TS 3.1, Table 3-1, RCS Flow Rx Trip ST-RPS-3-F.2,

Item 3.C R37/06-05-87

TS 3.1, Table 3-2, Containment Spray 5f-ESF-4-F.3,

Item 5.b Logic' Test R13/04-24-86

TS3.3(2)a Valve Seat Leakage ST-CV-1,

Test (Record for SI-204) RS/02-15-83

TS3.4(1) Leak Test of RCS ST-RLT-1,

R7/12-06-84

TS3.5(7)a Inspection of Containment ST-CONT-4,

Dome Tendons R7/10-10-85

TS3.6(1) SI System Test ST-ESF-2-F.3 & F.4,

R38/03-20-87

ST-ESF-2-F.1 & F.2,

R43/11-25-87

TS3.6(2)b Verify Containment ST-NZ-1-F.1,

Spray Nozzles Open R6/03-25-83

TS3.7(1)b Test Auto-Start ST-ESF-6-F.2

Initiating Circuit for EDG R74/01-21-88'

TS3.9(6)a Auto Actuation of AFW ST-FW-3-F.4

Valves on SI Signal R12/07-26-84 j

TS3.10(1)a.1 Verify CEA Group Withdrawal ST-CEA-1-F.2,

is above Transient Insertion R60/06-18-87

Limits

TS3.10(5)b Determine F[t andFkY ST-ICI-1-F.1,. l

R4/10-16-86

TS3.15(2)d Functional Test of ST-FP-4, j

Fire Pumps R5/3-19-85 l

01-FP-6-1,

R51/04-23-87 ,

1

i

i

i

. . . - . _ _ .. _ . _ _ . _

.

<,,e,. <

I

.

2 l

1

TS3.15(3)b~ - ' Spray / Sprinkler Nozzle ~

ST-FP-5,

Air Flow Test in EDG Room R3/02-12-86

- IST/FW-10 AFW Pump Test ST-FW-1, .

l

R34/09-15-87- i

!

. IST/HCV-383-3 Test of SI Suction to .ST-SI/CS-1-F.1,.

Containment Sump. Valve R43/08-06-87 q

ST-CONT-3,  :

l

R25/07-09-87-'

Calibration RCS Flow Rate! CP-A/114 W.

R10/04-17-87 ,

Calibration Boric Acid Storage Tank CP-255,

Temperature R3/12-17-86 i

l

'i

l-,

'

a

!

,

l

l

i

) .

'

,

., .. y-._., . y _.g _. . ..y# . . , ., . ., . . - , , , . ,-