ML20154K117

Forwards Reinsp Rept 50-285/88-200 on 880218,0321-25 & 0404- 08 Re Safety Sys Outage Mod.Corrective Action Review Found 39 of Original 47 Findings Closed.One New Issue Identified. Enhancements to Design Process Noted

ML20154K117
Person / Time
Site:	Fort Calhoun
Issue date:	09/16/1988
From:	Holahan G Office of Nuclear Reactor Regulation
To:	Petersen F OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20154K120	List: ML20154K117 ML20154K131
References
IEB-79-14, NUDOCS 8809230224
Download: ML20154K117 (5)

See also: IR 05000285/1988200

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September 16, 1988

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Docket No. 50-285

M'r. Fred M. Petersen, President

anc Chief Executive Officer

Omaha Public Power District

IC3 Harney Street

Omaha, Nebraska S8102

Dear Mr. Petersen:

SUBJECT:

REINSPECTIOh 0F SAFtT) 3YSTFMS OUTAGE MODIFICATION 'NSPECTION

DESIGN FINDINGS, 50-/M/83-200

This letter conveys the results and nntiusions of the reinspection of the

findings originally documented in Safety Systems Outage Modification inspection

(550MI) Report 50-285/85-22 dated January 25, 1986.

The inspection team

consisted of personnel from NRC's Office of Nuclear Reactor Regulation (NRR),

Region IV, and consultants.

The inspection took place at your offices in

Omahe, Nebraska, on February 10 and the weeks of March 21 and April 4,1988.

The exit meeting was conducted on April 8, 1968.

The primary purpose of the inspection was to review the corrective actions

and implementation of corrective ae.tions for ali the findings documented in

the original SSCMI design inspection report.

The secondary purpose of the

inspe: tion was to perform a programatic review of Fort Calhoun's design basis

reconstitution program whitn was developed as a result of the original SSOMI

design inspection.

With regard to the corrective action review of the original SSON! findings.

39 of the original 47 findings identified in Inspection Report 50-285/85-22

were c?o;ed. One new issue was identified in the mechanical components

discipline ard was closed for the purpose cf the inspection report.

There-

fore, 40 of the 48 findings identified by NRC are closed. However, four of the

closed findings are licensing issues that Omaha Public Power District (OPFD)

needs to 'esolve.

The licensino issues include adequacy of the piping analyses

performed in response to NRC Bulletin 79-14 and compliance with Updated Safety

Anslysis Report (USAR) seismic design requirements for valves, electric motor

operators, junction boxes, and pressure switches. See findings 03.1-4, D3.2-4,

03.2-6, and 03.2-8 in the mechanical components area for a more cceprehtnsive

discussion of these licensing issues.

In review 49 the corrective actions assretated with the SSOMI findings, the

inspection teani identified the following significant itens for which

increased OPPD management involvement appears to be warranted to bring the

issues identified to effective resolution.

First, the functioral testing

associatec with the accurulators for air-operated valves wat inacaquate.

Previously tested air-operated valves need to be retested or the test data

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Mr. Fred M. Petersen

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September 16, I U

should be reevaluated to ensure that adequate function:1 tests were performed.

' All air-operated valves with accumulators need to be functionally tested before

the end of the next refueling outage using techniques that include consideration

of worst-case operating conditions. Also, development of criteria for functional

testing and surveillance testing of air-operated valves is recomended to

ensure consistent postmodification testing and assurance of design adequacy

over the life of the plant. Second, many of the corrective actions for the

previously identified findings were not complete at the beginning of the

inspection. Since the findings were identified by the NRC more than two years

ago, the fact that many corrective actions were incomplete is indicative of a

lack of attentio:' to NRC identifieo issues.

Further, closure of the findings

required direct NRC involvement to define actions nececsary for resolution.

Once the inspection team identified the required actio , OPPD was able to close

many of the findings.

However, OPPD must be more self-sufficient and should

have closed many of these findings without relying on interaction with the

inspection team.

It was the feeling of the inspection team that, were it not

for the NRC presence, many of these corrective actions would have languished

for a considerable time before being completed

Third, the inspection team

identified areas where the USAR is not being ktpt current. An updated and

ac urate USAR is essential for Fort Calhoun because it remains the major source

of design-basis information until the design-basis reconstitution program is

completed.

Finally, the team identified areas where USAR comitments were not

being implemented.

For example, containment isolation valve position indica-

tion as not maintained for all operating modes (Deficiency 04.3-1) and valve

actuator seismic acceleration design requirements were not censistently utilized

(Deficiency D3.2-7).

As a result of this recent inspection, the team became aware of the many

enhancements made by 0 PPD to its design process.

OPPD's comitment to the

design reconstitution program is a necessary and major undertaking. The

programatic changes were apparent to the inspection team and if properly

implemented should result in an acceptable documented design tasis when the work

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is com,'leted in 1991, as scheduled. The team was generally impressed by the

overall structure and content of the auxiliary feedwater system design basis

document as well As the number of desig* attributes addressed in-depth in

that document.

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You are rcquested to respond in writing to the eight open items listed on

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pages A-1 through A-3 of the enclosed report within 60 days after receipt of

this letter.

You should address the specific action required for each item

and the schedule for completion of that action.

In accordance with 10 CFR 2.790(a), a copy of this letter and enclosures will

be placed in the hRC Public Document Room.

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Mr. Fred M. Petersen

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September 16, 1988

Should you have any questions concerning this inspection, please contact Mr.

Ronald Parkhill (301-492-0963) of this office.

Sincerely,

@W

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Gary M. Hola

n. Acting Director

Division of Reactor Projects. III, IV, V

and Special Projects

Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 50-265/88-200

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Mr. Fred M. Petersen

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September 16, 1988

cc w/ enclosure:

Mr. Harry H. Voigt. Esq.

LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, NW

Washington, D.C.

20036

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Mr. Jack Jensen, Chairman

Washington County Board

of Supervisor

Blair, Nebraska 68008

Mr. Phillip Harrell, Hesident Inspector

U.S. Nuclear Regulatory Commission

P.O. Box 309

Fort Calhoun, Nebraska 68023

Mr. Charles B. Brinkman, Manager

Washington Nuclear Operations

C-E Power Systems

7910 Woodmont Avenue

Bethesda, Maryland 20814

Regional Administrator, Region IV

U.S. Nuclear Regulatory Comission

Office of Executive Director

for Operations

611 Ryan * .aza Drive, Suite IF

Arlington, Texas 76011

Mr. Harolo Borchert, Dire t',r

Division of Radiological halth

Department of Health

301 Centennial Mall, South

P.O. Box 95007

Lincoln, Nebraska. 68509

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Mr. W. G. Gates, Manager

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Fort Calhoun Station

P.O. Box 399

Fort Calhoun, Nebraska 68023

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INPO

1100 Circle 75 Parkway

Atlanta, Georgia 30339

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Mr. Fred M. Pet rsen

5-

September 16, 1988

Distribution:

Docket File 50-285

RSIB R/F

DRIS R/F

RWParl' hill, NRR

EVImbro, NRR

CHaughney, NRR

JEKonklin, NRR

BKGrimes, hRR

LBMarsh, NRR

PTKuo, NRR

Alee, NRR

ABeach, RIV

JMilhoan, PlV

TWestermun, RIV

JJaudon, RIV

ABournia, NRR

JCalvo, NRR

VNoonan, NRR

PHHarrell, SRI

MMurphy, Rly

Regional Administrators

Regional Division Directors

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08/2/88

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