ML20151R647
| 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: |
| References | |
| 50-285-88-10, NUDOCS 8804280054 | |
| Download: ML20151R647 (10) | |
See also: IR 05000285/1988010
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_ APPENDIX C
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report:
50-285/88-10
Operating License: DPR-40
Docket:
50-285
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Licensee:
Omaha Public Power District (OPPD)
1623 Harney Street
Omaha, Nebraska 68102
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Facility Name:
Fort Calhoun Station (FCS)
Inspection At:
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Inspection Conducted:
March 14-18, 1988
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Inspector:
M/L3/91V
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H. F. Bundy, Reactor Inspector, Test Frograms
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Section, Division of Reactor Safety
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Accompanied
By:
W. C. Seidle, Chief, Test Programs Section
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Division of Reactor Safety on March 17-18,
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Approved:
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W. C. Seidl(,) Chief, Test Programs Section
Date
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Division of Reactor Safety
Inspection Summary
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Inspection Conducted March 14-18, 1988 (Report 50-285/88-10)
Areas Inspected:
Routine, unannounced inspection of the licensee's
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surveillance testing and calibration control program and surveillance
procedures and records.
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Results:
The basic program for completion of Technical Specifications (TS)
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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
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filing appeared inadequate and an apparent deviation from a licensee commitment
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8804280054 880419
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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
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).
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DETAILS
1.
Persons Contacted
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
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Section 3 of the FCS TS.
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Inservice inspection of components and testing of pumps and valves as
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required by 10 CFR 50.553(g).
Calibration of safety-related instrumentation not specifically
controlled by TS.
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a.
Surveillance Testing
The NRC inspector reviewed the licensee's Standing Order (S0) G-23,
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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
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Timely scheduling of all ST and inspections
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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
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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
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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."
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This response clearly states that a delinquency will not be allowed
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to continue more than 1 month from the time it is identified. The
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existence of the 11 long-term ST delinquencies discussed above
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represents an apparent deviation from the licensee's comitment to
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correct an identical problem in the response to
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Violation 285/8511-01.(285/8810-03).
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The scheduling of STs is performed utilizing a computer data base and
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appears efficient. The licensee has identified isolated failures in
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the scheduling which usually involves STs scheduled in a week which
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overlaps 2 months. The licensee is pursuing a resolution of this
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problem.
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The NRC inspector observed that 50 0-30. Revision 4, dated August 27,
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1987 "Testing of Safety Related Equipment," provides adequate
requirements to ensure TS satisfaction and that safety is not
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compromised when testing ;afetyll ST procedures which is implemented
related components. Also, SO G-23
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requires a biennial review of a
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in accordance with 50 G-36,~ Revision 15. dated April 9, 1986,
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"Operating Manuals Review Documentation".
Standing Order G-36
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provides adequate guidelines to assure incorporation of any required
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changes in the ST procedures.
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The NRC inspector reviewed FCS License Amendments 109, 110, and 111
to ascertain that TS ST changes were properly incorporated in the
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procedures and found no discrepancies.
However, the following
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documents were identified indicating problems with timely
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incorporation of test changes in procedures had occurred.
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NRC Violation 285/8729-04 identified that procedures for certain
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surveillance tests identified in Amendment 110 had not been
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timely established and implemented.
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FCS Licensee Event Report (LER)87-037 stated that changes in
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the EDG surveillance test required by Amendment 111 had not been
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incorporated in the procedure and implemented as required.
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In each instance above, the licensee committed to resolve generic
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problems of correspondence control and distribution by April 15
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1988.
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b.
Inservice Inspection (ISI) of Components and Inservice Testing (IST)
of Pumps and Valves
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The NRC inspector reviewed the FCS "Inservice Inspection Program Plan
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for the 1983-1993 Interval" (Plan), which was transmitted to the NRC
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by Letter LIC-83-226 dated September 26, 1983, and updated by
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Letter LIC-84-009 dated January 10, 1984. The NRC inspector noted
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that there are outstanding Nuclear Reactor Regulation issues on this
document which shoulo be resolved. The licensee comitted to the
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1980 Edition, Winter 1980 Addenda of the ASME Section XI Code.
The
NRC inspector noted that review of this document had recently been
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documented in NRC Inspection Report 50-285/88-06. Also, review of
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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
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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
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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
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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
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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
N45.2.6Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 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
N45.2.6Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 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
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'at',ns of the examiners performing Leak Test'ST-RLT-1 (discussed
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in h . on 3 above), the NRC inspector contacted the licensee's
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.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.
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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,
5f-ESF-4-F.3,
Item 5.b
Logic' Test
R13/04-24-86
TS3.3(2)a
Valve Seat Leakage
Test (Record for SI-204)
RS/02-15-83
TS3.4(1)
Leak Test of RCS
R7/12-06-84
TS3.5(7)a
Inspection of Containment
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
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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,.
R4/10-16-86
TS3.15(2)d
Functional Test of
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Fire Pumps
R5/3-19-85
01-FP-6-1,
R51/04-23-87
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TS3.15(3)b~
- ' Spray / Sprinkler Nozzle
Air Flow Test in EDG Room
R3/02-12-86
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- IST/FW-10
AFW Pump Test
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R34/09-15-87-
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. IST/HCV-383-3
Test of SI Suction to
.ST-SI/CS-1-F.1,.
Containment Sump. Valve
R43/08-06-87
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R25/07-09-87-'
Calibration
RCS Flow Rate!
CP-A/114 W.
R10/04-17-87
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Calibration
Boric Acid Storage Tank
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Temperature
R3/12-17-86
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