IR 05000285/1988027
| ML20154S574 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/21/1988 |
| From: | Harrell P, Reis T, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154S564 | List: |
| References | |
| 50-285-88-27, NUDOCS 8810050101 | |
| Download: ML20154S574 (34) | |
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f APPENDIX, U. S. NbCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-285/88-27 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: August 1-31, 1988 Inspector: (
P. H. H.3rrell,~ Senior Resident Reactor
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'N Date Inspe: tor m 9~ /d-S T. Reis, Resfdent Reactor Inspector Date b , j N, * *
T .\F W L .n e f , P rbj Jc t ' Date Section B, Division of Rea to Projects
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t 2-Inspection Summary Inspection Conducted August 1-31, 1988 (Report 50-285/88-27)
Areas Inspected: Routine, unannounced inspection including followup on previously identified items, licensee event report followup, operational safety verification, plant tours, safety-related system walkdown, monthly maintenance observations, monthly surveillance observations, security observations, radiological protection observations, in-office review of periodic and special reports, and review of licensee activities related to the instrument air water intrusion even Results: Within the 11 areas inspected, no violations or deviations were identified.
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DETAIM Persons Contacted
- Gates, Plant Manager J. Adams, Reactor Engineer
- J. Dobba, Supervisor, Radiation Protection C. Brunnert, Supervisor, Operations Quality Assurance T. Dexter, Supervisor, Security
- J. Fisicaro, Supervisor, Nuclear Licensing and Industry Affairs
- J. Gasper, Manager, Training l
- S. Gebers, Supervisor, Radiological Services
- Jaworski, Manager, Station Engineering J. Kecy, Supervisor, System Engineering
, *R. Kellogg, Supervisor, Special Services
, *D. Matthews, Supervisor, Nuclear Licensing
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- J. O'Connor, Plant Engineer
- A. Richard, Manager, Quality Assurance and Quality Control
, C. Simmons, Plant Licensing Engineer
- J. Smith, Manager, Security Services '
- S. Trausch, Supervisor, Operations S. Willrett, Supervisor, Administrative Services
- Denotes attendance at the monthly exit intervie The NRC inspectors also contacted other plant personnel, including operators, technicians, and administrative personnel.
- Plant Status During the period of August 1-16, 1988, the plant operated continuously at approximately 90 percent power. On August 16, 1988, power was reduced due ,
to abnormally high river (condenser cooling wator) temperatures and inefficiencies existing in the main condenser. The latter half of August, ,
the plant operated continuously at approximately 80 percent power. The '
power level reduction to 80 percent was more than substantial to overcome the condenser inefficiencies. This power reduction was also initiated to ,
extend the current refueling outage start date from September 3-23, 1988, due to high system power demand. No plant trips, safety system challenges, or other abnormal plant operations were experienced. On August 20, 1988, the FCS set a world record for pressurized light-water reactor plants by operating continuously at power for 440 days At the end of this inspection period, the plant had operated continuously for 451 day . Followup on Previously Identified Items (92701) (Closed) Severity Level IV Violation 285/8724-04: Control of Compressed Gas Cylinders in the Auxiliary Building - This violation
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-4-involved the licensee's failure to properly store compressed gas cylinders in the auxiliary building in accordance with established requirement To provide clear and concise instructions to plant personnel, the licensee issued a revision to Procedure 50-G-6, "Housekeeping." The '
revision provided instructions on the acceptable and approved methods to be used to store cylinders. The licensee provided training to the appropriate personnel on proper storage technique >
The NRC inspector reviewed the revision to Procedure 50-G-6 issued by the licensee. The NRC inspector also verified that the appropriate personnel had been trained on the proper storage techniques. No problems were noted during the reviews.
During tours of the auxiliary building, the NRC inspectors routinely
- verify that gas cylinders were properly stored. No storage problems l have been noted during these tours, (Closed) Severity Level IV /iolation 285/8724-05
- Control of the Erection of Scaffolding - This violation involved the licensee's 4 failure to properly control the erection of scaffolding adjacent to
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safety-related equipmen The primary concern was that the i scaffolding should be seismically installed so that the scaffolding would not collapse and damage safety-related equipment during a i seismic even To provide instructions for the control of scaffolding, the licensee ,
issued a revision to Procedure 50-0-25, "Temporary Modification '
Control." The procedure requires that a seismic analysis of the scaffolding be performed prior to the shift supervisor authorizing installation.
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The NRC inspector reviewed Procedure 50-0-25 to verify that the proper controls for scaffolding seismic analysis and approval for ,
- installation had been provided. Based on the review, it appeared that the licensee had implemented proper control l I i j Since the issuance of the procedure revision, the licensee has ;
i installed temporary scaffolding on one occasion. The NRC inspector F
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reviewed the activities associated with the installation and noted no i
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problem The review performed by the NRC inspector is d cumented in !
j paragraph 7.a of NRC Inspection Report 50-285/88-2 l
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- (Closed) Severity Level III Violation 285/8727-04 (Violation B.2.a):
l Inadequate Instructions Provided in Procedure ST-FP-5 - This violation i
was related to inadequate instructions provided in Procedure ST-FP- The inadequate instructions involved the failure to provide clear and t concise directions to operations personnel for resetting the deluge '
valve on the emergency diesel generator (EDG) room dry pipe syste .
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-5-The NRC inspector reviewed the procedures listed below to verify adequate instructions had been provide Number Revision Title MP-FP-7 3 Resetting of Diesel Generator Dry Pipe Deluge Valve After Trip or Tripping ST-/P-5 5 Fire Protection-Auxiliary Building Sprinkler System Testing eT-rP-11 3 * e Protection-Functicnal ,
Test of Dierel Generator Rooms Dry Pipe Deluge Valve
, Based on the review performed by the NRC inspector of selected
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portions of the procedures listed above, it appeared that the licensee had provided adequate instructions to operations personnel.
- The NRC inspector also verified that the appropriate operations
, personnel had received training in the procedure changes issued by the licensee. No problems were noted during the reviews.
- Ouring routine observation of surveillance activities in June 1988,
, the testing of the deluge valves in accordance with Procedure ST-FP-11 was observe No problems were noted during
, performance of the testing.
! During followup on this violation, a number of other related aspects were considered to ensure comprehensive corrective actions had been
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take To ensure that personnel understand testing activities, the i licensee established a program for prejob briefings for any
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surveillance tests performed at a frequency less than or equal to i quarterly. This aspect was reviewed and is discussed in
! paragraph 13 I of this report. Another aspect of this violation was
) the need for the licensee to ensure that all personnel followed
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procedures as written. In NRC Inspection Report 50-285/88-07, the l NRC inspector issued Violation 285/8807-03. This violation cited the licensee for personnel not following procedures. The licensee has I
completed corrective actions to address the violation. The review of
the violation is documented in paragraph 3.h of this report.
i d. (Closed) Severity Level III Violation 285/8727-05 (Violation B.2.b):
1 Inadequate Instructions Provided in Procedure AOP-17 - This violation
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involved the failure of the licensee to provide aifeguate ir.structions
) in Procedure AOP-17, "Loss of Instrument Air," for operations personnel. The instructions did not adequately address the effect of
- the loss of instrument air for all safety related systems and
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components.
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f Since the issuance of this violation, the licensee has issued six ,
revisions to Procedure A0P-17. Although Revision 3 was issued to address the concerns identified by the NRC, the licensee has continued to upgrade Procedure AOP-17. The NRC inspector reviewed Revision 8 to the procedure and found that the procedure provided adequate instructions to operationc personnel for the actions to be taken in the event that instrutrent air pressure is lost. The NRC ,
inspector also verified that oparations personnel had reviewed i Revision 8 prior to its issu !
In addition to Procedure A0P-17, the licensee also reviewed Procedures 01-CA-1, 01-CA-2, and 01-CA-3 for adequac These three procedures provide instructions for routine system operation. A review vi tue licende=1 arecctiva acti:ns uith r:cpact to these ,
procedures was performed by the NRC inspector. The review is !
documented in paragraph 13.c of NRC Inspection Report 50-285/88-2 !
As noted in paragraph 3.c of this inspection report and in this paragraph, the licensee has experienced problems with the adequacy of procedures. To address this problem on a generic basis, the licensee has established a group, Project 1991, to address procedure adequac The Project 1991 group is currently in the process of reviewing all procedures for potential upgrade. The activities of Project 1991 are ;
being tracked under another comitment made by the licensee, (Closed) Severity Level III Violation 285/8727-06 (Violation B.4):
Failure to Issue a Policy on Operation of Plant Equi went by n Nonoperations Personnel - This item was related to tie absence of a *
licensee policy to address operation of plant equipment by personnel not in the operations department. The absence of a policy was one factor that contributed to the introduction of water into the instrument air system on August 25, 1987. This event occurred in the water plant and did not atfect any safety-related equipment. See NRC Inspection Report 50-285/87-30 for a discussion of this even i The licensee issued an internal menorandum (FC-2034-87) to all plant personnel on December 31, 198 The merrorandum stated that only operations personnel could operate plant equipment, except for the following activitie * Chemists repositioning valves for primary and secondary samplin * !&C technicians operating root isolation valves for loop checks, calibrations, or other specified maintenanc ;
The licensee forn lized the policy by revising Procedure 50-0-29, !
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"Conduct of Operations." The revision included the exceptions described above, and also included the following exceptions where personnel not in the operations department are allowed to operate plant equipmen . . _ .
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I&C technicians may reposition nitrogen valves when filling electrical penetrations or performing local leak rate test Personnel may reposition valves within the boundaries of an equipment tagou *
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Personnel may reposition valves on hose bibs for potable water, demineralized water, and service ai ;
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The NRC inspector reviewed the policy implemented in Procedure 50-0-29 and it appeared that the licensee had taken appropriate exceptions to operation of plant equipment by personnel not in the operations -
department. The NRC inspectors routinely review plant activities to verify that nonoprations personnel are operating plant equipment within the established ga Helines. No problems have been note ' (Closed) Unresolved Item 285/8733-06: Lack of a Program for Periodic
Testing of the Antifreeze Solution in the Security and Technical !
Support Center (TSC) Diesel Generators - During an inspection of licensee cold weather preparations, the NRC inspector noted that the
- licensee had not determined the freezing point of the cooling water
- system for the security and TSC diesels. A subsequent review by tha (
j licensee revealed that procedures had not been issued to require '
- testing of the cooling system freezing point.
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The licensee issued Maintenance Orders (MO) 875927 and 875928 to
check the specific gravity and freeze points of the respective l coolants. Each was verified as satisfactory on January 7 and 8, l 198 To establish a program to check these parameters annually, the t
- licensee has entered winterizing procedures into the preventive r
- maintenance (PM) program. The coolant checks are now scheduled to be i
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j performed annually on October 30t '
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Based on the review of the procedures and the automated PM schedule, '
! it appeared that the licensee has taken adequate actions to include f j the verification of cooling water in the security and TSC diesel -
! generators in its cold weather preparations.
I (Closed) Unresolved Item 285/8803-01: Operability of Containment t j Penetration Assembly F-11 This unresolved item involved a concern as
- to the operability of Assembly F-11. The concern was identified !
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assembly was approximately 2 psig. The normal internal pressure of !
l penetration assemblies is approximately 20 psig.
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l In response to this concern, the licensee contacted the assembly
manufacturer, Conax Corporation, to determine if the low internal j pressure affected the electrical equipment qualification of the !
i assembly. Conax stated that an internal pressure was not required to ;
l br: maintained in the assertly to caintain the qualification of the !
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assembly.
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On March 9, 1988, the licensee issued an evaluation that discussed the
- operability of the penetration. The evaluation included a review of the past local leakrate tests performed on Assembly F-11. For the tesis reviewed, it was determined that no leakage was identified. The evc: nation also noted that Asfembly F-11 is a double-barrier cannister penetration assembly. This type of construction provides a
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double-leakage barrier which would require a failure in two distinct barriers before containment integrity would be lost. Based on the reasons discussed above, the licensee concluded that Assembly F-11 was operable.
- The NRC inspector .eviewed the evaluation and other documentation i related to the basis of the conclusions stated in the evaluatio !
During this review, no problems were noted, i On January 20, 1988, the licensee issued MO 880366 to r- surize l Assembly F-11 to 20 psig and to verify the pressure mer
. assemblies was at least 20 psig. As a result, the , " ,ure in .
- Assemblies D-1 and D-7 was also increased to 20 psig. To ensure that
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the pressure in all assemblies is maintained at 20 psig, the licensee
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stated that a PM procedure would be issued to check the pressure in
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each assembly quarterly, i
i On June 20, 1988, the licensee formally issued Procedure PM-EE-PENT
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! gage readings into its automated, scheduling system. The automated
) program calls for the task to be performed every 30 days.
i Based on the incorporation of Procedure PM-EE-PENT into the PM
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scheduling system and a review of the engineering analysis of containment integrity, this unresolved item is considered closed, (Closed) Severity Level IV Violation 285/8807-03: Failure to follow
- Procedures as Written - This violation concerned three examples of j Ticensee personnel failing to adhere to procedures exactly as written j as observed by the NRC inspector during an inspection performed in
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February 198 Specifically, during observation of Procedure ST-DC-2, the NRC i inspector noted that an electrician performed a portion of
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Step 1.b.(5) prior to performing Step 1.b.(4). This action was not allowed by procedur During observation of Procedure ST-ESF-6, the
- NRC inspector noted that during the portion of the test where the
- operator was required to unload the diesel generator, the operator i temporarily set aside the procedure while concentrating on the control
! board. By doing this, he inadvertently skipped Step 17 which
performed a checkout of the fuel oil transfer putos. On another I occasion, the NRC inspector observed a water pla.' operator timing the l stroke cycle of raw water Valve HCV-2853 per Procedure ST-ISI-RW-1.
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, Procedurally, the operator was required to use a stopwatch. Instead, the operator used his personal wristwatch which did not have a stop
, functio In NRC Inspection Report 50-285/88-07, the NRC inspector documented
, that the three examples of procedural noncompliance did not affect
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the safe operation of the plant. However, it was felt they were
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illustrative of what was perceived as inattention to detail and -
failure to follow procedures.
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At the time of the violation, Procedure 50-G-7 controlled the use of f
, procedure Procedure 50-G-7 stated, in part, that it is the
respomibility of every individual performing activities to follow proce n ces exactly as written and strict adherence to all procedures
- is abnlutely required. Based on interviews with licensee personnel, [
- it was evident that general awareness of the stringent requirements t of Procedure 50-G-7 did not exist.
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- To reemphasize the requirement for strict procedural compliance and
- to correct the deficiency of general unawareness with i.he [
i requirement, the plant manager issued a memorandum, dated !
I February 16, 1988, to all department heads to stress that strict i compliance with all procedures is mandatory. To disseminate this 1 information to all station personnel, a videotape concerning the q necessity to strict adherence to procedures has been incorporated :
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into the general employee training (GET) program. All personnel with 1 J
unescorted access to the plant are required to attend this training
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1 To improve procedures such that procedural compliance is achievable ;
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without seriously impairing the productive effort, the licensee has !
) instituted a procedures upgrade project which includes the ,
development of a procedure writer s guide to provide guidance from a l
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- hun.an factors perspective. The procedures upgrade program is a part
of the licensee's long-term Project 1991. In the interim, personnel :
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have been instructed, in cases where procedures cannot be followed exactly as written, to suspend work and institute on-the-spot j procedure changes. The NRC inspectors note increased utilization of ;
this technique in the field since this violation was issue l
j Based on the action of the plant manager reiterating the necessity ;
- for procedural compliance with their personnel, documented attendance !
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of personnel at these meetings, incorporating these requirements into *
i the GET program, and the increased evidence af the use of on-the-spot !
l procedure changes, it appears the licensee has adequately addressed [
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l the concern of procedural noncompliance and reversed the trend to i what was perceived as inattention to detail and failure to follow
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! (Closed) Open Item 285/8813-01: Lack of a Policy Concerning and the j Training of General Maintenance Personnel Regarding Painting in
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10-Enclosed Areas - This concern was identified when the NRC inspector encountered general maintenance personnel painting in the raw water pump bays using combustible paint in a warm, nonventilated environmen t The raw water pump bays are normally open to the intake structure atmosphere; however, at the time the concern was identified, the '
overhead vents were sealed off to accommodate maintenance on the circulating water traveling screen; in the overhead. The situation created an environment in the pump bays that was considered questionable from habitanility, fire protection, and equipment
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protection standpoint, Tne licensee agreed to formulate a policy and train the general '
maintenance personnel on the necessary precautions to be taken when painting in enclosed area !
On August 15, 1988, the NRC inspector reviewed Procedure HP-C0ATINGS-1,
"Application of Protective Coatings Outside Containment," for the application of coatings outside of containment. The procedure defines
, and specifies confined or limited ventilation space and clearly provides instructions for the temporary ventilation of these spaces.
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Additionally, the NRC inspector reviewed verification sheets that the
- new procedure had been revlewed by general maintenance personne No i problems were noted during the review i i
{ j . (Closed) Open Item 285/8815-03: Review of the Seismic Calculations i for the $3fety-Related Air Accumulator Asse:nblies - This item involved '
j the submission of the seismic calculations for die accumulator assemblies to the NRC's Of fice of Nuclear Reactor Regulation (NRR) for c j review. The ulculations were submitted by the licensee in a letter c
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dated November 20., 1987.
J NRR reviewed the submission made by the licensee. Based on the ;
j submission and subsequent discussions with licensee personnel, NRR l
- arrived at the conclusions listed below. The conclusions were -
1 documented in a 'etter dated July 28, 198 ,.
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At the time of the plant design, all safety-related valves were !
! required to be seismically qualified, j r
Although Appendix B to 10 CFR Part 50 was in effect at the time
of plant construction, specific guidelines on the maintenance of *
equipment seismic qualification did not exis The licensee is presently undertaking an extensive program to
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reconstitute the design basis and will continue to attempt to locate any information to substantiate the statements made in j the Updated Safety Analysis Repor t
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Most of the equipment installed in the plant is in service in other nuclear, as well as fossil, units which either have adequate documentation or have survived ground shaking of actual strong earthquakes in the pas *
The site is located in a relatively low seismicity zone as "
compared to some other nuclear facilitie Based on these conclusions, NRR approved a licensee proposal to delay the resolution of the seismic qualification of equipment until Unresolved Safety Issue (USI) A-46 has been resolve The proposal was approved based on the conditions stated below:
Should an earthquake of design acceleration level or higher occur, all safety-related equipment in the plant shall undergo r an intensive inspection and evaluation for structural integrit :
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For active components, the licensee shall ensure the functional !
operability of the components prior to restart of the plan l
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Once the generic resolution of USI A-46 is complete, the licensee will pursue an aggressive schedule for implementation ,
of the resolution commitment .
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Based on the review and conclusions presented by NRR, this item is !
considered closed. ihesubjectofseismicqualificationofthe accumulator assemblies will be reviewed during the resolution of ,
USI A-4 '
- (Closed) Unresolved Item 285/8815-04: Preparation of a Calculation !
to Verify Accumulator Size - This item was related to a licensee e commitment to generate a calculation to verify that the size of the i
- air accumulators for the safety-injection and refueling water L tank (SIRWT) level controllers (bubblers) was adequate, j The licensee generated a calculation (ES-87-40) to verify the size of l the accumulators. The calculation was generated by licensee personnel and independently reviewed by a licensee contracto The i results indicated that the accumulators are sized to provide air flow j i to the SIRWT bubblers for greater than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. An operational ,
i requirement of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the accumulators was previously i established by the licensee to ensure that the bubblers are l functional in response to the design basis scciden ;
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The NRC inspector reviewed Calculation ES-87-40 to verify that the !
licensee had adequately established that the accumulators were l properly sized. No problems were noted during review of the !
calculation, j j j (Closed) Open Item 285/8815-08: Licensee to Submit a Revision to the !
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Inservice Testing (IST) Program - This item was related to an error l !
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-12-made by the licensee when a revision to the IST program was submitted on December 16, 198 The error involved the licensee stating that the check valves for the air accumulators for Valves HCV-238 and HCV-239 would be tested quarterly. The check valves are located inside the biological shield and the licensee did not intend that the plant would be shut down to test the check valve On July 29, 1988, the licensee submitted a revision to the IST program. This revision changed the program to require the check valves be tested during each cold shutdow The NRC inspector reviewed the revised IST program and verified that the frequency of testing the check valves had been changed to cold shutdow m. (Closed) Open Item 285/8815-12: Review of the Safety Analysis for Operability (SAO) Generated by the Licensee - This open item involved an 5A0 generated by the licensee to evaluate the operability of specific valves in the instrument air iystem. The operability of the specific valves was required to be reviewed by the licensee since the licensee had not performed testing of the valvos to verify that the valves could meet their established design requirement To address operability of tne valves, the licensee issued an SA0 (0SAR 87-10) to justify continued plant operation. The SA0 reviewed the status of each valve and provided justification as to why plant operation should continu OSAR 87-10 was forwarded by Region IV to NRR for an evaluation to verify that NRR concurred with the conclusions presented by the licensee. NRR reviewed OSAR 87-10 and concluded that the licensee was in compliance with the applicable rules and regulations, and continuedsafeoperationoftheplantwasjustified. During reviaw of OSAR 87-10 NRR noted that the information provided was generally underdeveloped and required numerous telephone calls to the licensee to determine the specific details of how the licensee reached the conclusions stated in OSAR 87-1 The licensee made a comnitment (Item No. I.B.2.b, Project No I.C.10 and I.C.11) in response to the instrument air water intrusion event to upgrade the process used to develop SA0 A review of the SAO process will be performed during followup on the commitment made by the license The NRC inspector previously reviewed the SA0 issued by the license The results of the review are documented in NRC Inspection Report 50-285/88-1 (Closed) Open Item 285/8819-01: Relabeling of Instrument Air Components - This item involved the failure of the licensee to relabel components in the instrument air system after a system change was
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-13-mad The system change involved changing the air supply for the EDG rooms deluge valve from the instrument air system to the plant air syste The licensee relabeled the affected components to indicate the components are installed in the plant air system. The NRC inspector reviewed the new labels added by the licensee and verified the tagging had been adequately performe No problems were noted, o. (Closed) Unresolved Item 285/8819-02: Apparent Failure of a Licensed 0)erator to Receive Training on System Design Change Information -
111s unresolved item concerned the apparent failure of a licensed operator to receive training in system design change information. On June 27, 1988, the NRC inspector attended the pretest briefing for the annual functional test of the dry pipe deluge valve for the EDG rooms as required by Procedure 57-FP-11. During performance of this test in July 1987, water from the fire water system entered the instrument air system and ultimately caused EDG 2 to shut dow Since the 1987 event, instrument air no longer services this system, as it has been replaced by service air. During the pretest briefing, the NRC inspector noted that an onshift licensed operator was not aware that instrument air no longer serviced the deluge valve. This indicated an apparent weakness in the licensed operator training progra On August 4,1988, a staff member of the training department presented the NRC inspector with a lesson plan and lesson notes pertinent to the design change, as well as verification that the licensed operator attended a lecture on the material. From the material and verification presented to the MRC inspector, it is apparent that the licensed individual did receive training on the system design change but was not able to recall the training. It shculd be noted that the NRC inspector questioned three other onshift licensed operators as to their knowledge of the system. All three were aware of the design change which had been implemente Based on the information presented, this unresolved item is considered close The NRC inspector performed a review to verify that the licensee had establish a program to ensure training is provided to licensed operators for all temporary modifications. The NRC inspector reviewed the Training Program Master Plan for licensed operator requalification and found that formal training is required for all permanent plant modifications but not necessarily required for temporary modifications. The manner in which information is disseminated to licensed operators on temporary modifications is through the shif t turnover sheet, Form FC-95, which requires operators to review the current temporary modifications log to be aware of all current modifications. Additionally, the NRC inspector reviewed Procedure 50-0-25, "Temporary Modification Control," which requires the cognizant engineer, for temporary modifications of
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-14-14 days duration or longer, to mark up a copy of the applicable i drawing or wiring diagram to reflect the current arrangement and enter these corrected drawings into official distributio l Based on the review, it appeared that the licensee had established an !
adequate program for ensuring that information on temporary modifications was disseminated to the licensed operator (0 pen) Open Item 285/8823-06: Upgrade of the PM Program for the l Instrument Air System - This open item involved implementation of an '
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upgrade of the PM program for the instrument air system based on ;
recommendations made by the licensee's consultant. The 1 recommendations included routine blowdown of system accumulators and l
- low points, and routine rebuilding of system regulator l Subsequent to the issuance of this open item, the licensee contacted i the consultant to discuss the recommendations. The consultant stated t that as long as the system dew point was maintained within the stated !
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design basis, periodic blowdowns would not be required. However, !
i should another water intrusion event occur, the consultant stated ,
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that blowdowns should be immediately initiated.
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With respect to the air regulators, the licensee issued an internal memorandum (FC-1589-88) that stated the regulators would be rebuilt .
or replaced on a regular basis. The memorandum also stated that the j 4,
rebuild or replace program would be established prior to the end of ;
. the 1958 refueling outage and the rebuild or replace programs would i
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begin in 198 l I The NRC inspector reviewed the evaluation performed by the licensee.
4 It appears, based on the licensee's demon:,trated capability to maintain the system within design limits, that periodic blow down of the system is not require ;
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- This item remains open pending the inclusion of the air regulators in j
- the PM program and the rebuilding or replacement of the regulators, t I Licensee Event Report (LER) Followup (92700) l
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Through direct observation, discussions with licensee personnel, and l I
review of records, the following event reports were reviewed to determine
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that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had i been accomplished in accordance with the Technical Specifications (TS).
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The LERs listed below are closed: l l I
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- 87-025 Shutdown of EDG 2 Due to High Coolant Temperatures :
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87-033 Water Intrusion into the Instrument Air System l
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-15-A discus, ion of the review performed by the NRC inspector for each LER is provided below:
LER 87-025 reported an event where EOG 2 tripped off due to high temperatures in the cooling water system. The high temperatures were caused by the failure of the radiator exhaust damper to open. The radiator exhaust damper failed to open due to the presence of water in the air accumulator. LER 88-033 reported an event where water was inadvertently introduced into the instrument air system from the fire water sytte Both of the events described above were reported to describe an event where fire water was inadvertently introduced into the instrument air system. The corrective actions described by the licensee in the LERs have previously been reviewed during followup on the water intrusion event. The followup performed by NRC inspectors is discussed in NRC Inspection Reports 50-285/87-27, 50-285/87-30, and 50-285/88-1 Because the elements provided in the LERs have been reviewed and enforcement action taken as appropriate, these two LERs are considered close No violations or deviations were identifie . Operational Safety Verification (71707)
The NRC inspectors conducted reviews and observations of selected activities to verify that facility operations were performed in conformance with the requirements established under 10 CFR, the licensee's 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
H0s initiated for equipment in need of maintenance
Appropriate conduct of control room and other licensed operators
Management personnel toured the control room on a regular basis The following items were reviewed during this inspection period:
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-16-a. On August 16, 1988, a licensee contractor notified the licensee that the control system for the EDG 2 fresh-air dampers may not meet the requirements of Appendix R to 10 CFR Part 50 for alternate safe shutdown capability. The discrepancy was noted by the contractor during a review of the draft design basis documen During the review, the contractor identified a design error in an electrical conductor, used to control the position of the EDG 2 fresh-air dampers, that is installed in the control room and is used to provide the control room operators with a method of operating the dampers. If control room evacuation is required due to a fire, the EDGs are started and loaded locally in the EDG rooms. If the fire in the control room was a "smart" fire, the conductor could become shorted and could cause the fresh air dampers to go shut. The existence of this installation does not comply with the requirements of Appendix R in that the capability to perform a remote shutdown of the plant can be affected by a fire in the control roo The licensee, in response to this identified problem, opened and tagged the power supply breaker for the dampers. This action caused the dampers to open and stay open. With the breaker open, a fire in the control room will not affect operation of the breaker As a permanent correction for this problem, the licensee made a change to Procedure A0P-6, "Evacuation of the Control Room." The change required that an operator open the electrical supply breaker for the EDG 2 dampers if the control room had to be evacuate The NRC inspector reviewed the actions taken by the licensee to address this concern. It appeared that the licensee had taken timely proactive measures to ensure that a fire in the control room would not adversely affect operation of EDG 2. No problems were noted during the revie b, During an inspection performed from August 8 through August 12, 1988, by NRC Region IV inspectors, an inspector requested calculations to verify that the safety-injection pumps could pump water at a temperature of 40 F. TS 2.3 states that the minimum allowable temperature for the SIRWT is 40'F. The SIRWT would normally supply water to the safety-injection pumps during a design basis acciden For this reason, the NRC inspector was concerned that the SIRWT would be at a temperature of 40 F, as allowed by TS 2.3, and that the safety-injection pumps would not be capable of pumping water at this temperatur The licensee performed a document review and was able to verify that the safety-injection pumps had been successfully tested using water at 54 F, but could not confirm that the pumps had been tested using water at 40*F. During a review of the documentation, the licensee confirmed that the pumps failed a test when water at 46 F was use _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . ____________ _________ -________ _ _ _ ________ __-__
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-17-To address this concern, the licensee reviewe,* control room logs to determine the lowest temperature that had been recorded for the SIRWT temperature. The licensee confirmed that the lowest temperature recorded was 64*F. Based on the information discussed above, the licensee initiated a self-imposed higher limit for the SIRWT temperatu re. The licensee issued an operations memorandum to raise the lower temperature limit for the SIRWT from 40'F to 60*F. By imposing this administrative limit, the licensee will ensure that the temperature of the SIRWT will be maintained above the temperature at which the pumps had been successfully teste The NRC inspector reviewed the actions taken by the licensee. It appeared that the actions were conservative and adequately addressed the NRC inspector's concerns. No problems were noted during the revie The licensee is currently reviewing TS 2.3 to determine whether or not to submi+ an amendment request to change the lower limit of the SIRWT to 60* No violations or deviations were identifie . Plant Tours (71707)
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 equiprent, were satisfactor *
Equipment was being maintained in proper condition, without fluid leaks and excessive vibratio *
Plant housekeeping and cleanliness practices were observrd, including no fire hazards and the control of ccmbustible nateria * Performance of work activities was in accordance with approved procedure *
Portable gas cylinders were properly stored to prevent possible missile hazard *
Tag out of equiprent was perfonned properl '
Management personnel toured the operating spaces on a regular basi During a tour of the plant, the NRC inspector noted that the operations department had posted a sign throughout the plant. The sign was posted to thank all personnel for their efforts in providing support to the operations department that resulted in the longest continuous operation at
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-18-power for any pressurized light-water reactor (LWR). On August 20, 1988, the FCS broke the existing world record for LWRs by operating continuously for 440 days. The posting of the sign by the operations department is an indication that the licensee was taking actions to promote the cooperation between the various licensee organizations. The lack of intraorganizational support was a concern identified in the latest systematic assessment of licensee performance (SALP) repor No violations or deviations were identifie . Safety-Related System Walkdown (71710)
The NRC inspector walked down accessible portions of the following safety-related system to verify system operability. Operability was determined by verification of selected valve and switch position The system was walked down using the drawings and procedure note *
Emergency Diesel Generator 2 Support Systems (Procedure 01-DG-2, Revision 28; and Drawings B120F07001, Revision 6; B120F03001, Revision 7; and B120F04002, Revision 3)
During the walkdown, the NRC inspector noted no discrepancies between the drawings, procedure, and plant as-built conditions for the selected areas I checke No violations or deviations were identifie . Monthly Maintenance Observations (62703)
The NRC inspectors reviewed and/or observed selected 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 observation *
The TS limiting conditions for operation were met while systems or components were removed from servic * Approvals were obtained prior to initiating the wor *
Activities were accomplished using approved H0s and were inspected, as applicabl *
Functional testing and/or calibrations were performed prior to returning components or systems to servic *
Quality control records were maintaine *
Activities were accomplished by qualified personne Parts and materials used were properly certifie _a
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Radiological and fire prevention controls were implemente The NRC inspector reviewed and/or observed the following maintenance activities:
Repair bearings on Component Cooling Water (CCW) Pump AC-3A (M0 883287)
Mechanical installation and test procedure for an air compressor (MR-FC-87-32)
A discussion of each item is provided below:
a On August 3,1988, the NRC inspector observed the return-to-service of CCW Pump AC-3 CCW Pump AC-3A had been declared inoperable because its motor current was running high and upon investigation the licensee discovered that the pump shaft bearings were running ho Machinists repacked the bearings under authorization of MO 88328 The NRC inspector observed the preliminary run-in of the pump and monitoring of the temperature of the replaced bearing with the use of a contact pyrometer, On August 12, 1988, the NRC inspector reviewed plant modification Procedure MR-FC-87-32. The procedure provided instructions for installing, connecting, and testing of the air compressor used to operate the deluge valve for the EDG rcom The NRC inspector found the package to include a safety review, detailed work instructions, and postinstallation testing instructions. Based on the review, it appeared that Procedure MR-FC-87-32 provided adequate instructions for installation of the air compresso On August 15, 1988, the licensee completed construction of a new warehous The warehouse is now partially located within the protected area boundary and provides access without personrel having to leave the protected area. The old warehouse was located outside the protected are The new warehouse should promote efficiency of the licensee's maintenance staff as maintenance personnel will not have to exit the protected area to obtain spare parts. The efficiency of the maintenance staff was a concern addressed in the last issue of the SALP repor No violations or deviations were identifie . Monthly Surveillance Observations (61726)
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 during the testing:
- Testing was performed by qualified personnel using approved procedure _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _. ___ ______
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Test instrumentation was calibrate *
The TS limiting conditions for operation were me *
Removal and restoration of the affected system and/or component were accomplishe *
Test results conformed with TS and procedure requirement *
Test results were reviewed by personnel other than the individual directing the tes *
Deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The NRC inspectors observed and/or reviewed the documentation for the following surveillance test activitie The procedures used for the test activities are noted in parenthesi * Monthly test of the reactor coolant system low-flow trip (ST-RPS-3)
Quarterly test of the main steam valves (ST-ISI-MS-1)
Monthly testing of the primary power-operated relief and safety valve tailpipe temperature monitor (ST-TEMP-1)
A discussion of each surveillance observed is provided below: On August 9, 1988, the NRC inspector observed an I&C technician performing the monthly functional check of the reactor coolant low-flow trip of the reactor protection system. During performance of the procedure, the technician reached a sequence of steps which could not be performed exactly as written. The technician terminated the test, returned the system to operation, and initiated a procedure field change to accommodate current conditions. The procedure was changed and the test reinitiated and completed on August 10, 1988, in the absence of the NRC inspecto On August 16, 1988, the NRC inspector witnessed the inservice testing of the air-operated Valve YCV-1045A which serves as an isolation valve for steam from Steam Generator A to the steam-driven auxiliary e feedwater pump. The valve fails open on a loss of air pressure. An
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accumulator is installed to hold the valve shut in the event of a
! loss of instrument air pressure. The NRC inspector witnessed the l
testing of check Valve IV-1045A-C, associated with the accumulator, i It exhibited no leakage in a soap bubble test. The NRC inspector i also witnessed the stroke timing of Valve YCV-1045A in both the open
- and closed directions. In each direction, the stroke time was less j that 50 percent of the required maximum. The NRC inspector witnessed i
the system returned to normal operating condition and the normal l operating lineup verified by a quality control inspector.
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- On August 18, 1988, the NRC inspector independently verified, via the ;
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instructions in Procedure ST-TEMP-1, that the tailpipe temperatures :
i for the primary power-operated relief and safety valves were within acceptable ranges. This procedure involved only reading and
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recording the respective temperature ;
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In addition to the above surveillance testing reviews, the NRC inspector also reviewad the completed surveillance tests listed below. The tests .
were reviewed to verify that prejob briefings had been performed. This ;
review was performed as a followup to a commitment made by the licensee as
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, discussed in paragraph 13.1 of this inspection report. During the review, f i the inspector also verified the overall adequacy of the completed tests.
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No problems were note j f
Fire Detection Zones Calibration (ST-FD-1) !
Full-flow Test of the Motor-driven Fire Pump (ST-FP-4) :
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Containment Isolation Valve Leakrate Test (ST-CONT-3)
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Fire Earrier Penetration Inspection (ST-FP-9) !
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) Chemical and Volume Control Valves Inservice Testing (ST-ISI-CVCS-1) ;
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Component Cooling Valves Inservice Testing (ST-ISI-CC-1) l Component Cooling Water Pump Inservice Testing (ST-ISI-CC-3) :
- Waste Disposal Valves Inservice Testing (ST-ISI-WD-1) l i
- Refueling System Interlocks (ST-FH-1)
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Leakage Test cf the Waste Gas System (ST-WG-1) l
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Toxic Gas Monitors (ST-TGM-1) i
j No violations or deviations were identified.
l l l 10. Security Observations (71881) ;
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- The NRC inspectors verified the physical security plan wcs being i j implemented by selected observation of the following items: ;
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- The security organization was properly manned, f i
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- I l Personnel within the protected area (PA) displayed their t j identification badges, i
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i Vehicles were properly authorized, searched, and escorted or
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controlled within the P i
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i Persons and packages were properly cleared and checked before entry i
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I The effectiveness of the security program was maintained when [
! security equipment failure or impairment required compensatory L measures to be employed.
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i The vital area barriers were maintained and not compromised by
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breaches or weaknesse *
- Illumination in the PA was adequate to observe the appropriate areas
at nigh *
Security monitors at the secondary and central alarm stations were functioning properly for assessment of possible intrusions, j On August 19, 1988, the licensee issued a security bulletin to address the announcement of the arrival of NRC personnel on site. The bulletin stated i that security personnel shall not announce the arrival of NRC personne The bulletin also states that security personnel shall not announce the
! arrival on site of licensee management personnel. This bulletin was i issued in anticipation of a pending rule change to 10 CFR Part 50 becoming j effective which will prohibit the announcement of the arrival of an NRC
- inspector on site.
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No violations or deviations were identified.
- 11. Radiological Protection Observations (71709)
) The NRC inspectors verified that selected activities of the licensee's radiological protection program were implemented in conformance with the
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! facility policies and procedures and in compliance with regulatory
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requirement The activities listed below were observed and/or reviewed:
Health physics (HP) supervisory personnel conducted plant tours to check on activities in progres *
l Radiation work permits contained the appropriate information to
- ensure work was performed in a safe, controlled manner.
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Personnel in radiation controlled areas (RCA) were wearing the required personnel monitoring equipment and protective clothing,
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- Radiation and/or contaminated areas were properly posted and i'
controlled based on the activity levels within the are *
Personnel properly frisked prior to exiting an RCA.
l No violations or deviations were identified.
! 12. In-office Review of Periodic and Special Reports (90713)
! In-office review of periodic and special reports was performed by the NRC i residentinspectorsand/ortheNRCFortCalhounprojectengineertoverify j the following, as appropriate:
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Correspondence included the information required by appropriate NRC requirements.
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- Test results and supporting information were consistent with design
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predictions and specifications, !
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Determination that planned corrective actions were adequate for resolution of identified problem !
- Determination as to whether any information contained in the correspondence report should be classified as an abnormal occurrenc ;
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Correspondence did not contain incorrect, inadequate, or incomplete !
informatio l
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The NRC inspectors reviewed the following correspondence: l
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July Monthly Operating Report, dated August 12, 1988 !
- Monthly Operations Report for July 1988, undated l t
Revision of the Inservice Inspection Program Plan for the Fort j Calhoun Station, dated July 29, 1988 !
Relief Request from ASME Boiler and Pressure Vessel Code Section XI, :
dated July 29, 1988 !
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- Response to Generic Letter 88-13, dated August 31, 1988 i i s Improvements in the Licensed Operator Requalification Training l Program, dated August 30, 1988
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! Implementation of a Commitment Tracking System, dated August 30, 1988 l t i
- Additional Information for Response to NRC Generic Letter 88-05, i
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! dated August 31, 1988 :
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I Supplemental Reports Identified in LERs, dated August 30, 1988
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) No violations or deviations were identified,
! I l 13. Review of Licensee Activities Related to the Instrument Air Water .
l Intrusion Event (92701)
! i l On July 6,1987, the licensee experienced an event where water from the l l
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fire water system entered the instrument air system. On November 13, l l 1987, a conference was held at the NRC Headquarters Office to discuss the i NRC's concerns related to the event and the licensee's corrective actions '
! that would be taken in response to the concerns. The licensee, in a letter dated November 20, 1987, submitted written confirmation of the l corrective actions that they would implemen ,
On February 22, 1988, the NRC issued a Notice of Violation and Proposed Imposition of Civil Penalty based on the results of followup NRC i
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I inspections on the instrument air even The results of the inspections !
performed by the NRC are documented in NRC Inspection Reports 50-285/87-27 l
and 50-285/87-30. On April 27, 1988, the licensee responded to the Notice :
- of Violation. In this response, in addition to addressing the specific !
j violations contained in the Notice, the licensee provided a status of the i
' actions related to commitments made during the conference on November 13, '
l 198 The purpose of this portion of this inspection was to verify that the licensee had adequately implemented those commitment A discussion :
l of each commitment reviewed is provided below: ! Conduct Employee / Management Conferences (Item No. I.8.3.a. IA Project i l No. I.C.8) !
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l This item was related to the licensee's commitment to conduct small ,
i group meetings between employees and management personne The :
i meetings were held so management could communicate their expectations i i and so employees could discuss their safety and personal concerns [
j directly with managemen ,
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l The licensee conducted the first series of meetings with appropriate :
j OPPD personnel in January and February 1988. A follewup series of l
- meetings was conducted with personnel in April 198 !
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- The NRC inspector reviewed documentation to verify that all l j appropriate personnel had attended the small group meetings. During ;
j the review, the NRC inspector noted that all but nine people had I i attended the second session. The licensee stated that the nine ;
j individuals would be provided with a small group meeting in the near !
- future.
I The NRC inspector discussed the results of the small group meetings i with various OPPD personnel. Generally, the personnel felt that they i
- were able to express concerns at the meetings and get management
response to the concerns. Many individuals felt that the meetings l l improved communications betwe6n management and employee I This item is considered close j
{ Issuance of a Policy Statement Concerning Equioment Operation by l
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j Nonoperations Personnel (Item N I.B.4._a, IA Project No. I.C.6 and
- I.C.7)
- This item was related to a commitment made by the licensee to issue a i j policy statement on operation of plant equipment and components by !
j personnel not in the operations department, j
j This item was formally issued as Violation 285/8727-06 in NRC }
( Inspection Report 50-285/87-27. This violation was reviewed and is l
discussed in paragraph 3.e of this inspection repor j
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This item is considered close i
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! perform Cleaning and Flushing of the IA System (Item No. II.A.3.a, IA !
Project No, I.A.27) !
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This item involved a licensee commitment to evaluate the need to l clean and flush the IA system. Cleaning and flushing the system was i proposed by the licensee to ensure that particulates and moisture !
were remove The licensee performej an evaluation of all the data collected thus i f ar on the status of the testrument air system. The data included j measurement of the system dew point, sampling the system for l particulates, disassembly of valves to check for corrosion product .
and inspection of the filters contained in the air regulators ;
installed on the valves. Based on the results obtained from ;
examination of the IA system, the licensee concluded that a cleaning !
and flushing of the system was not required. The conclusion reached l by the licensee is documented in an internal licensee memorandum ;
(FC-1047-88) issued on May 24, 198 '
The NRC inspector has reviewed a wide variety of actions performed by the licensee in response to the instrument air event. The activities reviewed are documented in this section of this report and in NRC Inspection Report 50-285/88-23. Based on the review performed by the ,
NRC inspector and a review of the evaluation performed by the !
licensee, it appeared that the conclusion reached by the licensee l related to cleaning and flushing the system was appropriat During the upcoming refueling outage, the licensee plans on [
disassembling additional air-operated valves to check for i abnormalities. See paragraph 13.4 of this inspection repor The i NRC inspectors will review licensee activities in this are If appropriate, further discussions will be held with the licensee on ,
the need to clean and flush the system based on the results of the [
valve teardown inspection i
This item is considered close [
t Testing of Safety-Related Valves Not in the Inservice Inspection '
Program (Item No.~II.A. IA Project No None) {
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This item is related to a commitment made by the licensee to test air-operated, safety-related valves that were not in the inservice inspection program. The purpose of the tests was to determine, ,
through cycling of the valves, whether or not the valves had been degraded due to the intrusion of water into the IA syste [,
To test the 38 valves selected by the licensee as a representative sample, Procedure SP-STROKE-1, "Inservice Testing of Air-Operated, CQE Valves," was issued. The procedure established requirements for !
the valves to be cycled on a monthly basis and the cycle time !
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recorded. The data has been recorded for the valves each month since l
December 1987 and the data has been trended for review by the IA
- system enginee !
] The IA system engineer has reviewed the data and determined that no
, degradation of valve operation has occurred since data trending was initiated. During cycling of the valves, minor problems were j encountered. The problems included items such as the valve packing i being too tight, air regulators leaking slightly, and valves j sticking. The licensee issued MOs and immediately repaired the minor i problem The licensee stated that the problems encountered would i' not have prevented the valve from performing its intended safety functio i
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The NRC inspector reviewed Procedure SP-STROKE-1, Revision 4, and the trending data recorded by the licensee. Based on this review, it
appeared that the licensee had established an appropriate program for
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testing the valves. In addition, a review of the trending data i appeared to indicate that none of the valves had degraded due to the l presene.e of water in the IA syste ! During the upcoming refueling outage, the licensee plans on reviewing j the recorded data to determine whether or not to continue cycling the i vs.lve s. The NRC inspector will review the evaluation when completed I t'y the licensee. This is considered an open item pending completion
! of the review. (285/8827-01)
i l' Increased Frequency of Cycling of Valves in the Inservice Inspection Program (Item No. II.A 4.b, IA Submittal No. I.A.9)
This item was related to a commitment made by the licensee to increase the frequency of cycling of valves in the inservice inspection program. Valves that were normally cycled on a quarterly
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basis were decreased to a cycling frequency of monthly. The increased frequency was perfortned to determine whether or not the valve was affected by the introduction of water into the instrument air syste The licensee changed the inservice inspection schedule to require
- that safety-related, air-operated valves were cycled each month I versus each quarte Each valve was cycled in accordance with the
} instructions provided in the previously existing test procedure that l was issued for each valve. Each time a valve was cycled, the tirae i
required for cycling was recorded and compared against the acceptance l criteria provided in the test procedure. The data obtained was j recorded for trending purposes by the licensee. Based on the data j recorded to date, no detrimental affects have been identified by the licensee.
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The NRC inspector reviewed a sampling of the valve cycling tests performed by the licensee. During the review, the NRC inspector
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- verified that the testing was performed on a monthly basis and that i i the timing recorded for valve cycling complied with the established ;
acceptance criteria. No problems were noted during the revie !
i During the upcom!ng refueling outage, the licensee plans on reviewing !
the recorded data to determine whether or not to continue cycling the r i valves at a monthly frequency. The NRC inspector will review the ;
j evaluation when cortpleted by the licensee. This is considered an ,
d open item pending copletion of the review. (285/8827-02) [
] This item is considered close L i
l Update the Inservice Inspaction Plan (Item No. II.A.4.d, IA Project !
No. None)
i This item is related to a licensee commitment to issue a revision to '
l the inservice inspection (ISI) plan for review and approval by the i 1 NR The update of the ISI plan was to be performed to include the f j accumulator assembly check valves.
! This item was formally issued as Open Item 285/8815-02 in NRC i
{ Inspection Report 50-285/88-15. This item will be reviewed during the followup inspection on the open ite l j t I This item is considered closed.
t ! Assessment of Instrument Air System Design to Current Industry f
, Standards (Item No. II.A.5.b, IA Project No I.A.14) !
1 I I This item was related to the licensee obtaining the services of a !
4 consulting firm to assess the design of the IA system against current !
l industry standard !
> 1 j Since the occurrence of the instrument air event, the IA system has '
j been reviewed by two engineering firms and a firm specializing in the [
{ sale of IA systems. These three firms performed four separate j
- reviews of the system. During the reviews, the consulting firms ;
- identified a number of recommendations for upgrading the syste t I I l The licensee evaluated the reviews performed by the consultants and !
! concluded that, with specific system modifications, the IA system l 1 complies with all industry standards. The evaluation performed by r j the licensee is documented in an internal memo (PED-FC-88-468). The {
modifications to be performed to the IA system are being tracked by [
other commitments made by the license j The NRC inspector reviewed the evaluation performed by the license I i
Based on the discussion provided by the licensee, it appeared that
! the consultants perfor adequate, indepth review of the IA 1 system. The system is dcd dtsign, maintenance, operation.
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and testing aspects. The NRC inspector will review implementation of l the recommended modifications during followup on the specific !
licensee commitments, i l'
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1 I l Formation of an Instrument Air Steering Committee (Item No. II.B.1.c, !
TA Project No. None)
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- This i+.e
- n involved a commitment to establish an IA steering l committe The committee was established to monitor and coordinate !
resources, activities, and information to provide timely response to l
, commitments made as a result of the instrument air water intrusion l j event,
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The committee established by the licensee included members from
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en ineering, licensing, training, and an upper-level management ;
in ividual as chairman. The committee met on a monthly basis and j discussed the status of each item related to commitments made as a
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] result of the IA event. The committee established a tracking system !
j to ensure each item was completed in a timely manne ;
! The NRC inspector reviewed a sampling of minutes from meeting held by [
l the committee. Based on this review, it appeared that the committee *
I functioned effectively in tracking each commitment and providing
! timely close out of each ite The licensee stated that this !
! committee would be disbanded when each item has been fully addresse !
. i j This item is considered closed, j
! Upgrade General Employee Training for Safety Awareness (Item I No. II.B.2.a. IA Project No. I.C.9)
[
i This item involved a comitment made by the licensee to upgrade [
general employee training (GET) to increase safety awareness. The !
j method of instruction to be employed was the preparation of a video l j tap i
) !
i The NRC inspector attended GET in July 198 During the class, the 1 instructor played a video tape that featured the plant manager. The {
l' tape effectively stressed the need for safety awareness. In l discussions with training personnel, it was established that the tape l
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is played for all general employee training classe !
- This item is considered close I i l i Provide Training in Field Observations (Item No. II.B.2.b, IA Project
! No. I.C.15)
i i This item is related to a licensee commitment to train personr.el in [
,
l the methodology for field observations. The intent of providing the !
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-29-training is to provide personnel with the capability to assess the effectiveness of general employee training (GET) and verify that GET results in improved safety consciousness and procedural compliance through observations in the fiel ,
To establish a training program for observation training, the licensee issued the following document Number Title NA Training Development Plan for the Observation Training Program 10-36-01 Instructor Handbook for Introduction to Observation Training 10-36-02 Instructor Handbook for Four Steps of an Observation 10-36-03 Ir.structor Handbook for Observation Training Videotape Exercise 10-36-01 Student Handbook for Introduction to Otservation Training The licensee has provided training for most of the appropriate division heads, supervisors, anct foremen. The licensee stated that training for the remaining management personnel would be performed in the near futur The NRC inspector reviewed the lesson plans and student handout listed above. Based on the review, it appeared that appropriate instructional material had been developed. The NRC inspector also reviewed the attendance lists and noted that most of the management personnel had attended the trainin This item is considered close Upgrade of Lesson plans (Item No. II.B.2.C, IA project No. I.C.12)
This item was related to a commitment to upgrade the lesson plans used in the licensed-operator training program. The lesson plans are to be upgraded on an ongoing basis and are to be upgraded to emphasize the unique features of systems which have the potential for detracting from the safety of the plan To ensure that lesson plans are upgraded during the next routine revision, the licensee revised the training administrative procedure The procedures were revised to errphasize that lesson plans include a discussion of the unique system features. The administrative procedures revised by the licensee are listed below:
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I Number Titie i r
TAP 2 Training Program Requirements:
Identification, Analysis, Approval, and Authorization l
iAP-3 Training Program Design f
TAP-4 Training Program Development l
TAP-7 Revision of Training Programs TAP-17 Review of Training Programs The NRC inspector reviewed the changes made to the training administrative procedures. Based on this review, it appeared that -
the licensee has established a program to ensure that lesson plans i are upgraded on an ongoing basi This item is considered closed, f Provide Prejob Briefings for Surveillance Tests (Item No. II.B.2.d, l IA Project No. None) !
,
This item involved a commitment made by the licensee related to 1 providing prejob briefings prior to the performance of surveillance l tests. The briefings were to be provided for testing done at a i frequency less than quarterl [
To address this item, the licensee revised each appropriate I surveillance test to require that a prejob briefing be given. A I written verification of performance of the briefing was also provided !
in each appropriate tes i t
To ensure that any new surveillance test contains a requirement for a !
briefing, if appropriate, the licensee revised Procedure 50-G-23, I
"Surveillance Test Program." The revised procedure established a l requirement for the inclusion of a briefing in all surveillance tests !
that have a frequency less than or equal to quarterly. The NRC i inspector reviewed a sampling of completed surveillance tests j that were performed at a frequency less than quarterly. See {
paragraph 9 of this inspection report for a list of the surveillanco !
tests reviewed by the NRC inspecto The tests were reviewed to .
verify that a prejob briefing had been performed. The NRC inspector l also attended two prejob briefings to verify that the briefings were '
adequat The NRC inspector reviewed Procedure 50-G-23 to verify ;
that the licensee had provided proper instructions for the 5 preparation of surveillance tests. No problems were noted during any ;
of these reviews, This item is considered closed, f
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i Reem)hasizu Loemunications with the NRC (Item No. None, IA Project t
N ione)
, This item involved a commitment made by the licensee to reemphasize the requirement to notify the NRC of onsite events. The need to lI reemphasize communications was due to the failure of the licensee to
,
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I notify the NRC of the instrument air water intrusion event, i
!
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l To reemphasize communications with the NRC, the plant manager issued !
a memorandum (FC-1786 87) to the shift supervisors, licensed senior r
, operators, and shift technical advisor The memorandum stated the t j NRC should be notified promptly after any even The NRC inspector reviewed the memorandum and noted that it provided [
, the proper perspective for notification of the NRC. Since issuance l 1 of the memorandum, the licensee has experienced a number of events ;
i where the notification of the NRC was required. In each instance, j the licensee promptly notified the NR l i
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j This item is considered closed.
!
< Damaers for the EDGs to be Added to the ISI Program (Item No. None, .
i IA Project No. None) -
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! This item involved a commitment made by the licensee to add the '
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fresh-air dampers (YCV-871A, YCV-871B, YCV-871C, YCV-8710, YCV-871G, and YCV-871H) for the EDGs to the ISI program. The licensee made the j commitment to ensure that damper operation was verified on a regular .
basis to ensure proper operatio !
i
! The licensee, after a review performed subsequent to making the [
! commitment, has opted not to include the dampers in the ISI progra ;
1 Instead, the licensee has included the dampers in the PH progra l The NRC inspector previously reviewed the pro ram implemented by the
! licensee. Thedetailsofthereviewareprovdedinparagraph1 s i of NRC Inspection Report 50-285/88-2 t
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This item is considered close !
j Testing of the Accumulator Assembly Check Valves (Item No. None, IA l ;
j Proj(ct No. None) j
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l This item involved a commitment to test all check valves installed as k
part of the accumulator assembly on safety-related valves, f This item was formally issued as Violation 285/8727-03 (Violation B.1) {
in NRC Inspection Report 50-285/87-27. The commitment identified by j this item will be reviewed during followup on the violatio ;
This item is considered close l
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1 -32-i Provide Indepth Operator Training for the IA System (Item No. None,
! IA Project No. None)
! This item involved a commitment to provide indepth training to licensed operators on the function and operation of the IA system.
The licensee provided additional indepth training by classroom j discussions and/or individual review of the following items:
- LER 87-033, "Water Intrusion Into the Air System"
,
- Nuclear Network Entry OE-2262, "Failure of Safety Systems Oue to Unintentional Introduction of Water into the Instrument Air System at Fort Calhoun"
J Conference, November 13, 1987, Meeting Summary i
j Presentation given on air system problems at American Nuclear Society Meeting on November 19, 1987
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! NRC Inspection Reports 50 285/87-27 and 50-285/87-30
- LER 87-025. "Emergency Diesel Generator Shutdown on High Coolant
] Temperature" I The NRC inspector reviewed the material provided to the licensed
operators. Based on the review, it appeared that the licensee had provided training to the licensed operators that covered all aspects i of the water intrusion event. The NRC inspector also reviewed the
! documentaton of operator attendance in classroom presentations and in j individual review of the information provided. No problems were
!
noted during the review.
l l This item is considered close Outage and Postoutage Activities to be Performed on the IA System
)
, As a result of reviews performed by consultants and licensee i personnel, a number of activities were identified that can be
! completed only when the plant is shut down. The activities are l related to system modification and inspection. Each item is j discussed below:
! * A valve teardown program has been initiated and will continue l during the upcoming outage in accordance with a commitment
! (Item No. II.A.3.b, IA Project No. I.A.1, I.A.2, and I.A.3) made l
by the licensee. The valve teardown program was initiated to l
determine if damage occurred to valves that had been exposed to
, water.
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The licensee identified valves in the ISI program that need to j be cycled and timed to verify proper operation. Three valves were identified that could not be cycled until the plant was placed in cold shutdow The licensee made a commitment (Item i No. II.A.4.C, IA Project No. I.A.20) to cycle the valves during j the upcoming refueling outage.
.
Due to the problems operienced with the inoperability of the
. control mechanism for the EDG air dampers, the licensee made a
, commitment (Item No. II. A.5.a. IA Project No. I. A.24 and I. A.25)
to replace the damper control mechanis *
To protect individual components from potential damage due to particulates in the IA system, the licensee committed (Item No. II.A.5.e, IA Project No. I.A.17 I.A.18, and I.A.22)
, to install filters upstream of all air-operated valves that j currently do not have filter *
, To ensure that all air systems are not susceptible to water a intrusion, the licen ne made a commitment (Item No II.A.5.f.
j IA Project No. I.A 21) to disconnect the interface between the i
plant air system *,nd the fire water system. The plant air i system is currootly isolated from the IA system. Tho fire water i
deluge system will be supplied with air f rom its own air compressor system,
j To upgrade the IA system to a higher level of operating
) efficiency, the licensee committed, in response to a consultant recommendation, to install a smaller micron filter on the
! discharge of the air dryers. This modification is currently j planned to be performed as an on-line modification during 198 *
The licensee's consultant also reconmended that the licensee
- install a new dryer to enhance the Jerformance capabilities of
- the IA system. The installation of . new dryer will be
,
performed as an on-line modification during 198 )
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The seven items listed above represent commitments made by the licensee to modify or inspect the IA system and are not tracked by findings in an NRC inspection report, The items have been collected i in this report and are designated as an open item for tracking
purpose (285/8827-03)
- The items listed above are considered closed as followup will be
- performed under the identified open ite . Public SAtP Meeting (94703)
I
- On August 19, 1988, a public meeting was held at the licensee's emergency 1 operations facility in Omaha, Nebraska. The meeting was held to discuss j the Systematic Assessment of Licensee Performance (SALP) report issued on l
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July 29, 1988. The meeting was attended by the NRC Region IV regional administrator, upper-level management from the Region IV office, a representative from NRR, the president of OPPD, and upper-level management from OPPD. Also in attendance were the local news media and individuals from the publi Prior to the SALP meeting, the NRC personnel met with officials from the states of Nebraska and towa. The meeting was held to brief the state representatives on the mission of the NRC and how the NRC fulfills its mission. NRC personnel also discussed t.he SALP report with the state representative . Exit Interview (30703)
The NRC inspectors met with Mr. W. G. Gates (Plant Manager) and other members of the licensee staff at the end of this inspectio At this meeting, the NRC inspector summarized the scope of the inspection and the findings.
!