ML20207H731
| ML20207H731 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/19/1988 |
| From: | Harrell P, Reis T, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207H720 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.D.1, TASK-2.E.1.1, TASK-TM 50-285-88-23, IEB-88-004, IEB-88-005, IEB-88-4, IEB-88-5, IEIN-88-046, IEIN-88-46, NUDOCS 8808300008 | |
| Download: ML20207H731 (38) | |
See also: IR 05000285/1988023
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APPENDIX B
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report: 50-285/88-23
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Docketi 50-285
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Licensee: Omaha Public Power District
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1623 Harney Street
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Omaha, Nebraska 68102
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Facility Name:
Fort Calhoun Station
Inspection At:
Fort Calhoun Station, Blair, Nebraska
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Inspection Conducted: July 1-31, 1988
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Inspector:
6-4- 6D
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% H.\\Harrell, Senior Resident Reactor
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infector
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T. Reis, Resideht Reactor Inspector
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Approved:
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T. F. Wes'te . n. Chief Project
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Section E(, D' vision of Reactor Projects
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Inspection Summary
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Inspection Conducted July 1-31, 1988 (Report 50-285/88-23)
Areas Inspected:
Routine, unannounced inspection including review of
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previously identified items, operational safety verification, plant tours,
safety-related system walkdown, monthly maintenance observations, monthly
surveillance observations, security observations, radiological protection
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observations, in-office review of periodic and special reports, review of
licensee activities on NRC Bulletin 88-05, review of licensee activities
related to the instrument air water intrusion event, followup on NRC
Information Notice 88-46, followup on NUREG-0737 (TMI), Item II.E.1.1.1, and
nonlicensed training.
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Results: Within the 14 areas inspected, 2 violations (failure to properly
store unused ion exchange resins, paragraph 5; and failure to provide adequate
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procedures for startup of the instrument air system, paragrapn 13) were
identifted,
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DETAILS
1.
Persons Contacted
- K. Morris, Division Manager, Nuclear Operations
- W. Gates, Plant Manager
C. Brunnert, Supervisor, Operations Quality Assurance
T. Dexter, Supervisor, Security
- J. Drahota, Supervisor, Maintenance Support
J. Fisicaro, Supervisor, Nuclear Licensing and Industry Affairs
J. Foley, Supervisor, Instrumentation and Control
K. Miller, Supervisor, Maintenance
- C. Simmons, Onsite Licensing Engineer
- R. Jaworski, Manager, Station Engineering
J. Kecy, Reactor Engineer
- D. Matthews, Supervisor, Nuclear Licensing
- S. Trausch, Supervisor, Operations
- T. Patterson, Assistant Plant Manager
- G. Roach, Supervisor, Radiation Protection
R. Scofield, Supervisor, Outage Projects
- F. Smith, Plant Chemist
- L, Wigdahl, Supervisor, Technical Training
- S. Willrett, Manager, Administrative Services
- Denotes attendance at the monthly exit interview.
The NRC inspectors also contacted other plant personnel, including
operators, technicians, and administrative personnel.
2.
Plant Status
During the period of July 1-31, 1988, the plant operated continuously at
90 percent power.
No plant trips, safety system challenges, or other
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abnormal plant operations were experienced.
The plant was operated at 90
percent power due to the inability to maintain condenser vacuum at higher
power levels.
The inability to maintain vacuum was attributed to
abnormally high river (condenser cooling water) temperatures and
biofouling in the main condenser.
See paragraph 4.b for a discussion of
p"oblems with the main condenser.
On July 5, 1988, the FCS set a record for Combustion Engineering (CE)
designed plants by operating continuously for 394 days.
The previous
record for CE plants was held by Maine Yankee at 393 days.
At the end of
this inspection period, the FCS had generated power for 420 continuous
days.
3.
Review of Previously Identified Items (92701)
a.
(Closed) Severity Level IV Violation 285/8634-03:
Failure to operate
the waste gas panel (AI-110) in accordance with approved procedures.
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This violation involved the failure of the licensee to properly
perform a valve alignment when placing AI-110 in the standby mode.
This violation was previously reviewed and thc review was documented
in NRC Inspection Report 50-285/87-33.
As noted in the report, the
licensee had not provided training to the chemistry technicians for
operatien of AI-110.
To address the training of chemistry technicians on AI-110, the
licensee issued a performance evaluation checklist (PEC) as Lesson
Plan 19-67-05.
This PEC provides the requirements for the
performance of practical factors by each chemistry technician for
operation of AI-110.
Successful completion of the PEC provides each
chemistry technician with the training necessary to ensure
satisfactory operation of AI-110.
The NRC inspector reviewed Lesson Plan 19-67-05, Revision 0, to
verify that the plan contained the appropriate elements for training
on the operation of AI-110.
No problems were noted.
The NRC
inspector also reviewed training records to verify that all chemistry
technicians had received the training.
No problems were noted.
b.
(Closed) Unresolved Item 285/8710-05:
Review of the amount of
triso1ium phosphate dodecahydrate (TSP) stored in containment.
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This item was related to an apparent discrepancy between the
Technical Specifications (TS) and the Updated Safety Analysis Report
(USAR) as to how much TSP should be stored in containment.
The TS
states that 40 cubic feet is required; whereas, the USAR states that
3000 pounds of TSP is required.
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Previous reviews of this item were performed to verify that a
sufficient amount of TSP was stored in containment to meet the
requirements of TS 3.6(2)d.
Previous reviews performed on this item
are provided in NRC Inspection Reports 50-285/87-13, 50-285/87-24,
and 50-285/88-03.
The purpose of this review was to verify that the
licensee had updated the USAR to provide a specific narrative on the
requirements for the amount of TSP to be stored in containment.
On July 22, 1988, the licensee issued a revision to Section 4.4 of
the USAR.
The revised narrative clearly describes the relationship
between the USAR requirement of 3000 pounds of TSP and the TS
requirement of 40 cubic feet of TSP.
The NRC inspector reviewed the USAR revision to verify that the USAR
and TS relationship was clearly defined.
No problems were noted,
c.
(Closed) Severity Level IV Violation 285/8710-07:
Inadequate
procedure for performance of containment local leak detection tests.
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This violation was related to the failure of the licensee to issue a
procedure that provided adequate instructions for performance of
containment local leak rate tests.
The procedure was inadequate in
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that the instructions provided to the technician did not reflect the
actual as-built conditions of the plant.
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in response to this violation, the licensee performed a walk down to
correct the deficiencies in Procedure ST-CONT-3, "Containment
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Isolation Valves Leakage Rate Test - Type C."
In addition, the
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licensee also issued a lesson planito be used to instruct technicians
in the proper methods of performing' leak rate testing.
An
instructional class was presented to the technicians to ensure that
the' technicians had received the training prior to the upcoming
refueling outage.
The NRC inspector reviewed selected portions of Procedure ST-CONT-3
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to verify that the instructions provided in the procedure accurately'
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reflected the plant as-built conditions.
No problems were noted
during review of the procedure.
The NRC inspector also reviewed
training records to verify that plant technicians had attended the
training class on leakage testing.
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Based on the review performed by the NRC inspector, it appeared that
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the licensee had taken appropriate actions to address this violation,
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d.
(Closed) Unresolved Item 285/8724-02:
Review of the licensee's
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program for submission of reports in accordance with
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This item involved an occurrence where the licensee did not report
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problems identified with the emergency feedwater storage tank
(EFWST).
The problems identified in the EFWST were related to
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deficient welds in the tank.
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Violation 285/8727-08 was issued in NRC Inspection Report 50-285/87-27
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to address the issue of the licensee's program for submission of
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reports required by 10 CFR Part 50.73.
A review of this issue will
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be performed during closecut of the violation.
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(Closed) Open Item 285/8730-01:
Failure to consider all information
in the issuance of a justification for continued operation.
This item was related to a special inspection performed by an NRC
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Region IV team in November 1987 to follow up on the water intrusion
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event that occurred in July 1987.
During the inspection, the team
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noted that the licensee had failed to consider all available
information during preparation of a justification of operation (JCO)
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for addressing continued plant operation.
The licensee issued a revision to the JC0 on April 7, 1988, to
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address the concerns identified by the team.
The licensee continued
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to revise the JC0 based on new inf)rmation obtained as testing of
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accumulator assemblies was completed.
On April 27, 1988, the
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licensee issued the final JC0 to address operability of the plant.
The JC0 was transmitted to the NRC's Office of Nuclear Reactor
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Regulation (NRR) for review.
Open Item 285/8815-12 was issued in NRC
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Inspection Report 50-285/88-15 to formally track the completion of
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the review of the JC0 by NRR.
This item will be reviewed during the
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performance of the follow up on the open item.
f.
(Closed) Severity Level IV Violation 8730-02:
No procedures existed
to preclude the mispositioning'of valves, breakers, or switches by
noncperatinns personnel.
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This item was related to the failure of the licensee to issue a
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procedure that addressed operation'of plant equipment by personnel
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not on the operations staff.
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This violation was formally issued as Violation 285/8727-06 in NRC
Inspection Report 50-285/87-27.
The probical identified by this
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violation will be addressed when the licensee's action in response to
Violation 285/8727-06 is reviewed.
g.
(Closed) Open Item 285/8733-02:
Shift chemistry technicians not
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answering pages by the control room.
This item involved the failure of the shift chemistry technician to
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answer eight pages made by the control room during the lunch period.
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This item also involved the failure of the shift health physics (HP)
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technicians to answer control room pages,
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To ensure that pages are promptly answered, the chemistry and HP
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technicians were instructed by their manager that attention to the
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paging system was mandatory and that prompt answering of pages was
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required.
In addition, the licensee revised Form FC-15, "Operators
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Work Schedule," to include the names of the individuals acting in the
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capacity of shift chemistry and HP technicians.
By providing the
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names of the individuals to the control room staff, the technicians
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can be paged by name rather than by position.
The licensee also
established a policy whereby the shift chemistry and HP technicians
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report to the shift supervisor at the beginning of.each shift.
Prior
to this observation being made by the NRC inspector, the chemistry
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and HP technicians rarely visited the control room.
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The NRC inspector has verified during routine tours of the plant that
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the technicians are routinely responding to their pages.
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Verification of answsring the pages was made by ensuring the
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individual listed on Form FC-15 as the shift technician was not being
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paged more than once or twice before answering.
The NRC inspector
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has also noted during tours of the control room that the technicians
are visiting the control room in accordance with the newly
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established policy.
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h.
(Closed) Open Item 285/8807-01:
Revision to Procedure E0P-20 to
provide instructions to operations personnel.
This item involved the need to issue a revision to Procedure E0P-20,
"Functional Recovery Procedure," to provide instructions.to
operations personnel to manually shut Valves HCV-385 and HCV-386,if
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the plant goes into the containment recirculation mode.
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procedure revision was necessary because the installed air
accumulator assemblies canr.ot meet the design criteria of holding the-
valves shut for 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />.
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The NRC inspector revieweo Procedure'E0P-20, Revision 2, dated
March 14, 1988, and noted that the licensee had included instructions
for the operations staff.
The instructions state that the operator
shall manually shut Valves HCV-385 and HCV-386 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the
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loss of instrument air system if the plant is operating in the.
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containment recirculation mude.
The NRC inspector noted that the
4-hour time limit is appropriate since the licensee has functicnally
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tested the valve accumulator assemblies and verified the assemblies
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will hold the valves shut for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
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(Closed) Open Item 285/8815-01:
Submission of the licensee'r,
schedule for completion of testing of the safety-related air
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accumulator assemblies.
This item involved a commitment made by the licensee to submit a
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schedule to the NRC for the completion of testing of the air
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accumulator assemblies.
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In discussions between'the NRC inspector and licensee management on
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instrument air matters, as discussed in paragraph 13 of this report,
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licensee management verbally committed that the testing of the air
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accumulator assemblies would be completed prior to the end of the
upcoming refueling outage.
This item is discussed in this inspection
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report to formally document the verbal commitment made by licensee
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management.
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Operational Safety Verification (71707)
The NRC inspectors conducted reviews and observations of selected
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activities to verify that facility operations were performed in
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con'ormance with the requirements established under 10 CFR, the licensee's
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administrative procedures, and the TS.
The NRC inspectors made several
control room observations to verify the following:
Proper shift staffing
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Operator adherence to approved procedures and TS requirements
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Operability of reactor protective system and angineered safeguards
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equipment
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Logs, records, recorder traces, annunciators, panel indications,-and
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switch positions complied with the appropriate requirements
Proper return to service of components
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Maintenance orders (MO) initiated for equipment in need of
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maintenance
Appropriate conduct of control room and other licensed operators
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Management personnel toured the control room on a regular basis
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A discussion of the events that occurred during this inspection period is
provided below:
a.
At approximately 7:30 p.m. on July 19, 1988, the licensee experienced
a fire in a flammable liquid storage cabinet located in the water
plant.
During a routine tour of the water plant, an operator noted
smoke coming out of the cabinet.
The operator immediately notified
the control room and the fire alarm was sounded.
The fire brigade
arrived on the scene at approximately 7:35 p.m. and extiriguished the
fire at approximately 7:43 p.m.
The Blair, Nebraska, Fire Department
was alerted and was on standby to assist if required.
No assistance
was needed.
Once the fire was extinguished, all containers inside
the locker were moved outside of the water pl6nt building.
The water
plant building is not located near any safety-related equipment or
security vital areas; therefore, the fire posed no threat to the
safety or security of the plant.
Based on the investigation performed by the licensee, the fire was
attributed to the careless handling of epoxy paint by maintenance
personnel.
Personnel were painting the floor of the new maintenance
shop with epoxy paint.
The paint is a mixture of two parts that is
applied to the floor and allowed to dry by means of an exothermic
chemical reaction.
At the end of the work day, maintenance personnel
had some of the mixture left over and stored it in the locker for use
the next day.
Once the paint was stored in the cabinet, the
exothermic reaction continued and generated sufficient heat to cause
the other chemicals stored in the cabinet to ignite.
In response to this event, the licensee took corrective actions for
all flammable storage cabinets in the plant.
The actions taken by
the licensee are listed below.
The supervisor of maintenance met with all maintenance personnel
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to disuss the preper storage of chemicals in the storage
lockers, the types of chemicals that cannot be stored in
lockers, and the proper technique for disposal of 2 part epoxy
paint.
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A check of all storage cabinets in the plant was made and
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unnecessary chemicals were removed.
No toxic chemicals were
found in any of the cabinets.
Removed and/or relocated cabinets that were not in the immediate
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area of the fire detection system.
The cabinet in the water
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plant was not in the area of fire detection equipment.
Initiated a preventive maintenance requirement for a monthly
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inspection of all cabinets.
The first inspection will be
performed in August 1988.
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A review was performed by a representative from the authorized
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nuclear insurer.
The representative stated that the licensee
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has established good control of the flammables used at the
plant.
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The NRC inspector reviewed the actions taken by the licensee.
Based
on the review, it appeared that appropriate corrective actions were
implemented by the licensee.
The licensee reported this event to the NRC Headquarters duty officer
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via the emergency notification system on July 19, 1988.
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to the event, the licensee performed a review for reportability under
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the requirements of 10 CFR Part 50.73.
Based on the review, the
licensee determined that the issuance of a licensee event report
(LER) was not required; therefore, the licensee will not be issuing
an LER.
The NRC inspector reviewed the requirements for
reportability stated in Part 50.73 and concurred with the licensee's
determination that the submission of an LER was not required.
b.
The plant recently experienced a reduction in the efficiency of the
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main condenser that has required the plant to operate at 90 percent
power instead of 100 percent.
The licensee hired a consultant to
initiate a study of the reasons for the loss of efficiency.
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consultant determined that the lost efficiency was partly due to the
abnormally high temperature of the river (condenser cooling water)
and partly due to biofouling of the condenser tubes.
The licensee
has not previously experienced any biofouling problems; however,
because the river temperature has been abnormally high for a long
period of time, an environment for growing microorganisms has been
available.
In response to this problem, the licensee initiated the injection of
chlorine into the circulating water system.
The chlorine is being
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injected to kill the microorganisms.
The licensee has established plans to inspect the interior of the
main condenser during the upcoming refueling outage.
The licensee
also plans on inspecting the component cooling water heat exchangers
during the outage.
Based on the results of these inspections, the
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licensee will decide what actions, if any are required, will be taken
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to prevent biofouling of the heat exchangers,
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c.
The licensee recently added.the check valves (RW-115, RW-117, RW-121,
and RW-125) for the four raw water (RW) pumps to the inservice
inspection program._ The check valves were added to the program in
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order that the valve back leakage could be quantified.
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was.to be determined _so that the-licensee would not have to upgrade
the air accumulator assemblies of the four RW pump discharge valves
(HCV-2850, HCV-2851, HCV-2852, and HCV-285t) to a CQE (safety-related)
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status.
The testing of check valve leakage was first performed
during this inspection period and the leakage was found to be excessive.
The discharge flow from~t_he RW pumps supply a common header,
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pump discharge valves are normally open when the pump is running and
normally shut when the pumps are secured.
The valves are
air-operated and fail open on the loss of instrument air pressure.
Because the pump check valves, leaked excessively and because the pump
discharge valves fail open on a loss of instrument air, the licensee
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could not be certain that sufficient RW flow could be provided to the
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component cooling water (CCW) heat exchangers for plant shutdown in
all possible scenarios.
_ ith the pump discharge valve failing open
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and the pump check valve leaking excessively, some of the flow needed
by the CCW heat exchangers would be lost through an idle pump.
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To address this problem, the licensee upgraded the air accumulator
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assemblies for the RW pump discharge valves to a CQE status.
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licensee did this by installing tested check valves in the air supply
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line and performed calculations to verify that the accumulator
assemblies were seismically installed.
This item remains open
pending a review of the actions taken by the licensee to upgrade the
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air accumulator assemblies on the RW pump discharge valves by the NRC
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inspector.
(285/8823-01)
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During review of this item, the licensee identified an apparent
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discrepancy between the TS and the USAR.
Section 9.8 of the USAR
states that two RW pumps are required to supply sufficient flow to
the CCW heat exchangers to shut down the plant.
TS 2.4 allows the
licensee to take one RW pump out of service indefinitely without
entering a limiting condition for operation (LCO).
The plant is
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designed such that RW Pumps A and B are supplied alectrically by
Emergency Diesel Generator (EDG) I and the RW Pumps C and D are
supplied by EDG 2.
In the event that RW Pump A was out of service
for maintenance and EDG 2 failed to supply power to the vital bus
during a loss of offsite power, then only RW Pump B would be
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available to supply water to the CCW heat exchangers.
To correct
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this apparent problem, the licensee voluntarily increased the
requirements of TS 2.4.
Whenever one of the RW pumps is removed from
service, the licensee voluntarily enters a 7-day LCO.
If the pump is
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not repaired within 7 days, then the plant shall be placed in hot
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shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Previously these actions were
required when two pumps were removed from service.
Correspondingly,
the LCO action statements for two and three pumps have also been
upgraded by the licensee.
The licensee stated that the apparent discrepancy between the USAR
and the TS will be resolved with NRR during the upcoming refueling
outage.
This item remains open pending the resolution of the
apparent discrepancy.
(285/8823-02)
The NRC inspector reviewed the actions taken by the licensee as
described above.
The NRC inspector noted on three occasions during
this inspection period, where the licensee voluntarily entered the TS
LCO when one RW pump was removed from service.
In each case, the
lice'nsee repaired and returned the pump to service prior to the end
of the 7-day LC0 time limit.
The NRC inspector also contacted NRR to
verify that the action taken by the licensee with respect to
upgrading of the LCO was adequate.
NRR stated that the upgrade was
consistent with the TS requirements established for other plants.
Based on the review performed, it appeared that the licensee had
taken appropriate actions to correct a problem identified by them,
d.
During a routine tour of the auxiliary building, an operator noticed
that the outboard bearing on CCW Pump AC-3C was hot.
The operator
noted the bearing was hot as operations personnel routinely feel pump
bearings during routine tours of operating spaces.
The licensee replaced the bearing and performed tests on Pump AC-3C
to verify proper operability.
The pump failed to operate properly
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and was declared inoperable until the wear rings could be replaced.
At the time Pump AC-3C was experiencing problems, an NRC inspector
from Region IV was on site performing a review of the inservice
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testing program.
This inspector monitored the actions taken by
the licensee and will provide the results in NRC Inspection
Report 50-285/88-26.
e.
On July 6, 1988, the NRC resident inspector observed the licensee
perform an evacuation drill per the emergency plan.
The NRC resident
inspector observed a site area alert at 8:41 a.m and witnessed the
licensee attain full personnel evacuation accountability at 9:06 a.m.
This observation was performed at the licensee's request as the
licensee wanted to demonstrate the ability to attain full personnel
accountability within 30 minutes.
The licensee had failed to attain
full accountability during the annual emergency preparedness exercise
held on June 29, 1988.
No violations or deviations were identified.
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Plant Tours (71707)
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The NRC inspectors conducted plant tours at various times to assess plant
and equipment conditions.
The following items were observed during the
tours:
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General plant conditions, including operability of-standby equipment,
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were satisfactory.
Equipment was being maintained in proper condition, without fluid
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leaks and excessive vibration.
Plant housekeeping and cleanliness practices were observed, including
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no fire hazards and the control of combustible material.
Performance of work activities was in accordance with approved
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procedures.
Portable gas cylinders were properly stored to prevent possible
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missile hazards.
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Tag-out of equipment was performed _ properly.
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Management personnel toured the operating spaces on a regular basis.
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During tours of the plant, the NRC inspectors noted the items. listed
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a.
The inspection certificate for the passenger elevator in the
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administration building was out of date.
The certificate expired in
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March 1988.
The licensee stated that the elevator had been inspected
but the certificate had not been. received from the State of Nebraska.
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b.
During a plant tour, the NRC inspector noted that the licensee had
stored eight barrels of unused ~ ion _ exchange resins in Room 69.
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Room 69 has an automatic fire detection system, but does not have a
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sprinkler system installed.
Section II.A of Appendix R to 10 CFR Part 50 states, in part, that a
fire protection program shall be established at each nuclear power
plant and the program shall establish procedures required to
implement the program,
Section 3.3 of the Updated Fire Hazards Analysis (UFHA) and
1
Section 3.3.1 of Procedure 50-G-6, "Housekeeping," state, in part,
that unused ion exchange resins should be stored in an area protected
by an automatic detection / sprinkler installation.
Contrary to the above, the licensee stored eight barrels of unused
ion exchange resins in Room 69 which does not have a sprinkler system
installed.
This is an apparent violation.
(285/8823-03)
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In response to this problem, the licensee removed four barrels of
resins and left four barrels in Room 69.
In discussions with the
licensee as to why four barrels were lef t,-the ' licensee stated that
the fire loading analysis for Fire Area 20 (which includes Room 69)
indicated that up to 1000 pounds of resins could be stored in the
area. The NRC inspector reviewed the analysis the licensee had
performed for Fire- Area 20 and confirmed the licensee's statement.
It appears that the analysis done for Area 20 and the requirement
'
stated in Section 3.3 of.the UFHA and in Procedure 50-G-6 are in
conflict.
The analysis allows 1000 pounds to be stored in the area
whereas the other requirements. state that no resins can be stored in
Room 69; Nevertheless, the NRC inspector calculated the amount of
resin stored in Room 69 to be.1736 pounds-(8 barrels at 217_ pounds
each).
Therefore,'the licensee was in violation of the requirements
established by the UFHA, whichever one is appropriate.
The licensee stated that the apparent-inconsistency would be
corrected.
The NRC inspector will' verify that the inconsistency is
!
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corrected during subsequent followup on this violation.
6.
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 positions.
The
i
system was walked down using the drawings and procedures noted.
'
Containment spray system (Procedure 01-05-1, Revision 16, and
.
Orawing E-23866-210-130, Revision 44)
,
During the walkdown, the NRC inspector noted no discrepancies between the
drawings, procedures, and plant as-built conditions for the selected areas
checked.
No violations or deviations were identified.
f
7.
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 observations:
l
The TS limiting conditions for operation were met while systems or
.
,
components were removed from service.
Approvals were obtained prior to initiating the work.
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Activities were accomplished using approved M0s or preventive
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maintenance (PM) procedures and were inspected, as applicable.
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Functional testing and/or calibrations were performed prior to
.
returning components or systems to service.
Quality control records were maintained.
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Activities were accomplished by qualified personnel.
.
Parts and materials used were p.roperly certified.
.
Radiological and fire prevention controls were. implemented.
.i
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The NRC inspector reviewed and/or observed the following maintenance
activities:
i
Construction of scaffolding for removal of asbestos insulation on the-
.
EDG 1 exhaust line (MO 882620)
.
"
Check of the flow transmitters for the two RW system heaners
.
(M0 883012)
[
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Resetting of a regulator for the instrument air supply to the safety
.
injection and refueling water tank level detectors (M0 882499)
!
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Installation of a check valve in the instrument air accumulator
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assembly for RW Pump AC-10B (M0 882926)
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Installation of Gamma-4 setpoint changes on thermal margin / low power
.
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Channels A/8/C/D (M0 882819)
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A discussion of each item is provided below:
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a
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a.
On July 7, 1988, the licensee began erecting scaffolding over EDG 1
,
1
to allow the crafts to remove the insulation from the EDG exhaust
line.
A scaffolding platform is required for the insulation removal
i
because special techniques are needed for handling of the insulation
j
as it contains asbestos.
3
,
!
During a review of the M0 issued for the work, the NRC inspector
,
i
noted that the MO had not been signed by the shift supervisor.
In
'
followup on the reason that the MO was not signed by the shift
j
supervisor, the NRC inspector noted that the MO had been assigned a
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plant status code of "O."
This code is used whenever an M0 does not
require the crafts to obtain the signature of the shift supervisor.
4
The M0 plant code is assigned by the supervisor of operations or his
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designated alternates.
The code is assigned based on the nature of
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the work being performed.
The "0" code is usually reserved for work
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that has no af feet on plant operations such as painting in the
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administrative building and other such sctivities.
Based on the
review performed for M0 882620, it appeared that the supervisor of
i
operation's designated alternate inadvertently assigned an "0"
designation when another designation was appropriate.
The licensee
stated that the misassignment of the plant status code was caused by
]
the reviewer not fully understanding the work that was to be done by
the M0 due to the brief and nondescriptive information supplied on
-l;
the M0.
In response to this problem, the licensee immediately
discussed with the individuals responsible for assignment of plant
codes, the need to ascertain exactly what activities will be
performed by the M0.
The NRC inspector discussed the erection of the scaffolding with four
of the shift supervisors.
In all four cases, the shift supervisor
!
was aware that scaffolding was being erected over EDG 1.
The NRC
inspector reviewed a sampling of 32 M0s to determine whether or not
~
the correct plant status code had been provided.
No problems were
-
noted during this review.
g
Based on the reviews performed by the NRC inspector, it appeared that
}
this instance of assignment of the wrong code was an isolated case.
The NRC inspector's review did not indicate that s programmatic
,
problem existed.
The NRC inspectors will mcnitor the assignment of
plant codes while performing routine maintenance inspection
-
activities in the future,
m
The instructions for erecting the scaffolding were attached to
M0 882620.
The NRC inspector reviewed the instructions and it
appeared that adequate instructions were given for installation and
-
removal of the scaffolding.
b.
On July 11, 1988, MO 883012 was performed to check the accuracy of
-
the RW header flow transmitters.
The accuracy of the transmitters
I
was checked using an ultrasonic flow testing device.
The testing was
-
performed to verify the data obtained during leak testing of the RW
-
pump check valves.
See paragraph 4.c of this inspection report for a
discussion of the test performed on the RW pump check valves.
The NRC inspector noted that the personnel performing the test was
--
qualified and the equipment used for the test was in current
-
calibration.
No problems were identified during observation of this
'
maintenance activity.
'-
c.
On July 22, 1988, the NRC inspector observed two technicians reset
2
the air regulator for the safety injection and refueling water tank
_
level detector (A/FIC-383) in accordance with the instructions
_=
provided on MO 882499.
The regulator was reset to 25 psig to ensure
-
that a sufficient air supply would be available to A/FIC-383 in the
event instrument air pressure was lost.
The NRC inspector noted that
-
=
the technicians performed the task in accordance with the procedure
steps and that all equipment being used was in current calibration.
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MO 882499 had been signed by the shift supervisor to authorize the
work.
The NRC inspector also verified that the level setpoint for
A/FIC-383 was checked prior to returning the level detector to
service.
No problems were noted with the performance of the
technicians,
d.
On July 14, 1988, the NRC inspector witnessed I&C technicians
replacing the check valve for the instrument air assembly for the RW
Pump AC-10B discharge valve.
The check valve was replaced and the
air assembly was tested for 30 minutes to verify proper operation.
The NRC inspector noted that the work was properly authorized and
postmaintenance test instructions were included.
e.
On June 29, 1988. the thermal margin / low pressure (TM/LP) trip
function of the reactor protection system was found to be inoperable
in that the licensee had discovered that each channel had been
improperly set.
The NRC inspector observed I&C technicians resetting
the TM/LP setpoints in accordance with Procedures CP-TM/LP-A, B, C,
and D.
The NRC inspector observed that the reactor engineer
monitored the progress of the technicians and provided technical
,
guidance,
j
All four channels of TM/LP were recalibrated and declared operable,
after the performance of the appropriate surveillance test, within 8
hours of being declared inoperable.
For further information
1
regarding this event, refer to NRC Inspection Report 50-285/88-22.
During this inspection period, the licensee completed construction of the
new maintenance shop.
The new maintenance shop is approximately three
times larger than the old one and provides more than adequate space for
each craft.
The crafts commenced moving their tools and equipment into
the new shop to prepare for the upcoming refueling outage.
On July 18, 1988, the licensee notified the NRC inspector that they had
experienced problems with one of the four banks of the plant cathodic
protection system.
To repair the system, the licensee obtained the
services of a consultant.
The consultant and an engineer from the
downtown OPPD offices went on site, adjusted the system rectifier, and
then departed the site.
Approximately 30 minutes later, the rectifier
burned out.
In followup on this item, the NRC inspector determined that the OPPD
engineer did not process an M0 to authorize the work to be completed nor
'j
did the engineer notify the shift supervisor that the work was going to be
performed.
The rectifier has not yet been repaired as the licensee is awaiting parts.
l
The licensee stated that the loss of one bank of cathodic system shouldn't
be a problem for the protection of the piping for approximately 2 months,
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In response to this problem, the licensee took immediate corrective
i
action.
The security badge for the engineer was pulled by the plant
manager so that he no longer has site access.
The engineer will not be
'
allowed to have site access until his division manager confirms, in
writing, to the plant manager that the individual has been fully retrained
in all aspects of the administrative controls applicable to site activities. '
At the end of this inspection period, the engineer had not regained site
,
access.
.
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The NRC inspector reviewed the actions taken by the licensee.
It appeared
that the actions were prudent and conservative in this instance.
The
licensee has not experienr.ed an incident similar to this one in the past.
No violations or deviations were identified.
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8.
Monthly Surveillance Observations (61726)
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The kRC inspectors observed selected portions of the performance of and/or
j
reviewed completed documentation ior 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
-
.
procedures.
Test Instrumentation was calibrated.
.
The TS limiting conditions for operation were met.
.
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Removal and restoration of the affected system and/or component were
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accomplished.
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Test results conformed with TS and procedure requirements.
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Test results were reviewed by personnel other than the individual
)
directing the test.
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Deficiencies identified during the testing were properly reviewed and
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resolved by appropriate management personnel.
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The NRC inspector observed and/or reviewed the documentation for the
following surveillance test activities.
The procedures used for the test
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activities are noted in parenthesis.
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Ofesel fire pump full-flow test (ST-FP-4)
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Monthly test of EDG 2 (ST-EST-6)
)
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Monthly check of the subcooled margin monitor (ST-SM-1)
.
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A discussion of each surveillance observed is provided below:
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a.
On July 21. 1988, the NRC inspector observed the full-flow test of
the diesel fire pump.
The inspector noted that the test was
performed in accordance with the procedure, as written, and the
i
results obtained were within the specified acceptance criteria.
+
.
During the testing, the NRC inspector noted that a-first-line
,
!
maintenance supervisor was actively involved in performing an
i
2
overview of the testing.
The NRC inspector notes that the presence
1
of the first-line supervisor in the. field is a positive aspect that
was not previously provided by the= licensee,
b.
On fuly 13, 1988- the NRC inspector observed the monthly test of
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EDG 2.
The ii.spector observed the portion of the test that was
!
9
performed in the control room by a licensed operator. The NRC
,
inspector noted that the oprator performed the test by using the
,
proct., dure, as written.
No problems were noted during the test.
4
.
c.
On July 13, 1988, the NRC inspector observed portions of the test
1
'
performed to verify thdt the subcooled margin monitor operated
[
correctly.
The test was performed using the procedure, as written,
i
During observation of this test, the NRC inspector again noted that
1
the first-line maintena..ce supervisor was in the field observing the
performance of the testSng.
No violations or deviatitps were iduntified.
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9.
Security Observations (71881)
I
The NRC inspectors verified the physical security plan was being
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ieplemented by selected observation of the following items:
I
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)
The security crganization was properly manned,
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Personnel within the protected area (PA) displayed their
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identificatien badges.
Vehicles were properly authorized, searched, and escorted or
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controlled within the PA.
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Persons and packages were prcperly cleared and checked before entry
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into the PA was permit.ted.
The effectiveness of the security program w3s maintained when
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sect.rity equipment failure or impairment raquired compensatory
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measures to be employed.
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The PA barrier was maintained and the isolati0n zone kept free of
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'vansient material.
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The vital area barriers were maintained and not compromised by
.
breaches or weaknesses.
Illumination in the PA was adequate to observe the appropriate areas
.
at night.
Security monitors at the secondary and' central alarm stations were
.
functioning properly for assessment of possible intrusions.
On July 27, 1988,.the NRC inspector assisted in monitoring three security
drills initiated by security specialists from the Region IV Office.
The'
fit st drill involved neutralization of an armed intruder into the
protected area, the second drill involved response to a vital area in
alarm when the first responder became incapacitated, and the third drill
demonstrated the deployment and function of compensatory measurcs when the
alarm and detection systems' failed.
The details of the results of.the
drills are provided in NRC Inspection Report 50-285/88-24.
No violations or deviations we e identified.
10.
Radiological Protection Observations (71709)
The NRC inspectors verified that selected activities of.the' licensee's
radiological protection program were implemented in conformance vith the
facility policies and procedures and in compliance with regulatory
requirements.
The activities listed below were observed and/or reviewed:
-
Health physics (HP) supervisory personnel conducted plant tours to
.
check on activities in progress.
Radiation work permits ccntained the appropriate information to
.
ensure work was performed in a safe and controlled manner.
Personnel in radiation controlled areas (RCA) were wearing the
.
required personnel monitoring equipment and protective clothing.
Radiation and/or contaminated areas were properly posted and
.
controlled based on the activity levels within the area.
Personnel were properly frisked prior to exiting an RCA.
.
No violations or deviations were identified.
11.
In-Office Review of Periodic and Special Reports (90713)
In-office review of periodic and special reports was performed by the_NRC
resident inspectors and/or the NRr. Fort Calhoun project engineer to verify
the following, as app opriate:
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.
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resolution of identified problems.
Determination.'as to whether any information contained in the
.
correspondence report should be classified as an abnormal occurrence.
Correspondence did not contain' incorrect, inadequate, or incomplete-
.
information.
'
The NRC inspectors'. reviewed the'following correspondence:
June Monthly Operating Report, dated July 14, 1988
.
Cycle 11 Setpoint Errors, dated July 1 and July 25, 1988
.
Responses to-Request for Additional Information Concerning
.
NUREG-0737, Item II.D.1, Performance Testing of Rel_ief and Safety
Valves, dated June 28 and June 30, 1908
OPPD Nuclear Reorga'1ization, dated July 1, 1988
.
Core Reloa Methodology Changes for Cycle 12, dated July 8, 1988
.
Resp)nse to NRC Bulletin 88-04, dated July 8, 1988
.
Status of the Detailed Control Room Design Review and Safety
.
Parameter Display System Audit Findings, dated July 6, 1988
Licensee Critique of 1988 Annual Emargency Exercise, dated July 19,
.
1988
Correction,to Special Report on Inoperability of Postaccident
.
Monitoring Instrumentation, dated July 19, 1988
Special Report on Inoperability of Fire Barrier, dated July 25, 1988
.
Application for Amendment of Ope"eting Licensee,' dated July IS,1988
l
.
During rev' v of reports, NRC personnel identified a 10 CFR Part 21 report
submitte-
a supplier that appeared to be applicable to the licensee's
facili ty
i NRC resident inspector provided a copy of the report to the
plant lic.
~ineer for review of applicability by the licensee.
The.
"
issu.ed by Gamma-Metrics on May 10, 1988, and pertained
report pn.
c.
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to possible solder connection problems in cable assemblies.
No viciations or deviations were identified.
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12.
Review of Licensee Activities on NRC Bulletin 88-05 (92703)
On May 6, 1988, th'e NRC issued NRC Bulletin 88-05, "Nonconforming
Materials Supplied by Piping Supplies, Inc. at Folsom, New Jersey, and.
West Jersey Manufacturing Company at Williamstown, New Jersey," to alert
licensees that fraudulent material may have been supplied by Piping
Supplies, Incorporated and West Jersey Manufacturing (WJM) Company.
On
June 15, 1988, the_NRC issued Supplement l'to NRC Bulletin 88-05.
Then
bulletin and supplement required that licensees search their procurement
records to determine if they had purchased any material from them.
companies and to notify the NRC if any materials were identified during
~
the search.
'
On July 21, 1988, the licensee notified NRC Headquarters and Region IV
personnel that ten flanges supplied by .the WJM Company had been found
installed in the plant.
Six of the flanges are installed in the waste
disposal system, two of the flanges are installed on containment
electrical Penetration E-11, and two flanges are installed on the
containment penetration used to pressurize the containment for the
integrated leak rcte test.
The licensee has taken samples of the flange material for analysis o.n
eight of the ten flanges.
Two of the flanges are currently inaccessible
because they are inside containment and the plant is at 90 percent power.
The licensee is also performing hardness tests on the flanges.
At the end
of this inspection period, the licensee had not completed the analysis of
the flange testing.
The licensae was in the process of developing and issuing a justification
of continued operation (JCO) for the flanges at the end of this inspection
pericd.
The licensee stated that the JC0 would be issued within the
30-day period allowed by the bulletin.
The licensee performed a
preliminary evaluation and determined that the flanges could perform their
intended safety function as the flanges are rated for 150 pounds, but the
flanges installed on containment penetrations would be exposed to a
maximum of 60 pounds pres * Jre and the flanges installed in the waste
.
,
disposal system are exposd to about 50 pounds.
At the time the ten flanges were identified, the licensee had completed
approximately 10 percent of the review to be dele of the procurement
records.
The licensee stated that they will notify the NRC as other
components are identified.
The NRC will review the results of the testing
and the JC0 during a future inspection.
No violations or deviations were identified.
13.
Review of Licensee Activities Related to the Instrument Air Water
.
,
Intrusion Event (9273)
On July 6, 1987, the licensee experienced an eve" where water from the
fire water system entered the instrument air system.
On November 13, 1987,
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an enforcement conference was held at NRC Headquarters to discuss the
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 confiriation of the
corrective actions-that they would implement.
On February 22, 1988,-the NRC'tssued a Notice of Violation _and Proposed
Imposition of Civil Penalty based on the 'results of followup NRC
inspections on the instrument air event.
The resdits of the_ inspections
perfortned by the NRC are documented in NRC Inspection Reports 50-285/87-27
and 50-285/87-30. On April 27, 1988, the licensee responded to the Notice
of Violation.
In this response, in additicn to addressing the specific
violations contained in the Notice, the licensee provided a status of
actions related to commitments made during the enforcement conference on
November 13, 1987. ~The purpose of this_ portion of this inspection.was to
verify that the licensee had adequately implemented those commitments.
A
discussion of each commitment reviewed is provided below;
a.
Assignment of a System Engineer (Item No. I.A.I.a. IA Project
No I.C.13)
This item was related to a commitment to assign an individual as a
full-time system engineer for the instrument air (IA) system.
On November 18, 1987, a memo was issued by the licensee to assign an
individual as the system engineer for the IA system.
The memo noted
that the assignment became. effective on December 1, 1987.
Since the
engineer was
- signed, he has actively participated in identifying
and resolvi;
, sues related to the IA system.
,
.
In discussions with licensee personnel, the NRC inspector noted that
the individual presently assigned as system engineer will be
transferred in the near future. .In discussions with the manager of
system engineering, it was established that the present system
engineer would not be reassigned until a fully qualified and
knowledgeable individual is available to' replace the present system
engineer.
This item is considered closed,
b.
Change to Procedure MP-FP-7 to Ensure Deluge Valve Operability
(Submittal Item No. I.A.2.a, IA Project No. I.B.1)
This item involved a change to Procedure HP-FP-7 to provide complete
instructions to the operator on the proper method of resetting the
deluge valve after trip testing has been completed.
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This. Rem was formally issued as a'part_of Violation 285/8727-04
(Violation B.2.a) in NRC Inspection Report'50-285/87-27.
The
iaentified concerns will be_. reviewed when. followup on the violation
is performed.
This item is considered closed.
c.
Review of IA Operating Procedures (Submittal Item'No. I.A.2.b, IA
Project No. I.A.16)
>
This item' involved a commitment.by the licensee to review and.
upgrade, as necessary, the IA system. operating procedures to ensure-
that plant operators are provided.with clear, concise procedures'.
The NRC inspector. reviewed selected portions of the procedures listed
below.
The review was performed to verify that the procedures were
clear and concise.
Number
Revision
- Title
01-CA-1
20
Compressed Air System-
Normal Operations
01-CA-2
6
Compressed Air System Test
,
01-CA-3
5
Auxiliary Building and
Containment Instrument Air
Outage
01-CA-4
2
Containment. Instrument Air
Outage
01-CA-5
0
Backup Cooling Supply.
to Air Compressors
01-ES-1
19
Engineered Safeguards
i
Controls-Normal Operation
j
GP-1
32
Master Checklist for Startup
or Trip Recovery
The NRC inspector also reviewed Piping and Instrument Diagram
(P&ID) 11405-M-264, Sheet 1, Revision 20; Sheet 2, Revision 8;
Sheet 3, Revision 14; Sheet 4, Revision 14; and Sheet 5, Revision 14.
In conjunction with the review performed on the procedures listed
above, the NRC inspector also reviewed operating procedures for other
safety-related systems.
The purpose of the review was to verify that
the valve checklists-contained a verification of the position of the
air supply valves for the accumulator assemblies servicing
safety related valves and components.
A review of the checklists was
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performed because it was noted that' the air supply valves were not
listed in the valve checklist contained in Procedure 01-CA-1.
The checklist. review revealed 'that many of the air supply valves were
listed; however, not all air supply valves were included on'the
checklists. -For example, the NRC inspector noted that no air supply
valves were on the checklists' for the c_ontainment spray and safety
injection systems.
In addition, many of the air-operated valves in
the plant contain a handwheel that manually overrides the air.
operator of.the valve.
By positioning the handwheel in the shut
position, the valve will stay shut regardless of any signal the valve
may receive to open using the air operator. .During review of the
licensee's procedures, the NRC inspector noted that no verification
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of the position of the manual handwheel was provided fur the valves
that are normally shut during plant operation.
TS 5.8.1_ states, in part, that written procedures shall be
established that meet the minimum requirements of Regulatory
Guide 1.33.
Section 3 of Regulatory Guide 1.33 states, in part, that instructions
for startup should be prepared, as appropriate, for the instrument-
air system.
Contrary to the above, the licensee did not_ provide appropriate
instructions for startup of the instrument air system in that a
position verification for all instrument air supply valves to
safety-related components and equipment was not included in the
operating instructions for plant systems.
For example, instructions
were not provided for verification of the air supply valves in the
containment spray and safety injection systems.
In addition,
procedural verification of the manual override handwheels was'not
provided in plant procedures.
This-is an apparent violation.
(285/8823-04)
In response to the apparent violation discussed above, management
stated that a revision to the appropriate checklists would be made
prior to startup from the next refueling outage.
In addition to the problems noted with the checklists not listing the
air supply valves, the NRC inspector also noted that the supply
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valves for all the safety-related ac;.umulator assemblies were not
shown on P&IC M-264.
During the performance of a safety system outage modification
inspection (S50MI) in December 1985, the SSOMI team noted that
P&ID M-264 did not show the air supply valves to the accumulator
assemblies for the auxiliary feedwater turbine-driven pump steam
supply valves (HCV-1045A and HCV-10458).
The SS0MI team provided
details of this deficiency as Deficiency 2.2-5 in NRC Inspection
Report 50-285/85-22.
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In response to Deficien:y 2.2-5, licen'see stated that it was not
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their policy to add small valves in nonsafety-related systems to
P& ids.
This deficiency remains open pending discussion between the
SS0MI team and the licensee.
In discussions between the licensee and the NRC inspector, licensee.
management stated that P&ID M-264 would be updated prior to the end
of the upcoming. refueling outage to include the accumulator air
supply. valves for all safety-related, air-operated valves.
Licensee
management stated that the other IA system valves would be added.to
the.P&ID in the future.
No specific date was given by the licensee
for completing the update of the P&ID.
The P&ID will be updated
based on~a walkdown to be performed by the system engineer during the
refueling outage.
This item remains open pending issuance of the
updated P&ID and a review of the P&ID by the NRC inspector.
(285/8823-05)
During review of this item, the NRC inspector noted that the licensee
had filed Procedure 01-CC-4, Revision 8, in the wrong place in the
official copy of the operating procedures manual.
The official copy
of the manual is used by plant personnel to verify that they are
using the latest revision of a procedure when performing an activity.
When the NRC inspector looked at the place in the official manual
where the procedure should have been filed, it was noted that
Revision 7 was in the proper location.
The NRC inspector was
concerned that since the latest revision of Procedure 01-CC-4 was
misfiled, someone may have checked the officia'. manual and
inadvertently used the wrong revision of Procedu.o 01-CC-4.
Licensee
personnel concurred with this assessment.
Upon notification by the NRC resident inspector, the licensee
immediately initiated corrective actions.
Procedure 01-CC-4,
Revision 8, was filed in the correct position in the manual and
Revisix / was removed.
Other' volumes of the manuals were checked to
verify the appropriate filing of other procedures.
The licensee
stated that no other problems were noted.
The licensee also verified
that the procedures in the other official copies of the manuals were
properly filed.
The licensee found the same problem with
Procedure OI-CC-4 being misfiled, but not with other procedures.
The NRC inspector reviewed selected portions of the official manual
copies located in the administration building and the control room to
verify that procedures were not misfiled.
No problems were noted.
It appeared that the licensee had immediately taken appropriate
corrective actions to resolve the apparent problem with filing of
procedures in manuals.
This item is considered closed.
d.
Upgrade the Incident Reporting Process (Submittal Item No. I.A.2.c,
IA Project No. I.C.3)
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This item involved a review of the operating incident reporting
system to provide prompt determination of the safety significance of
an incident.
To upgrade the incident' reporting process, the licensee revisedi
Procedure 50-R-4 to provide clear instructions for evaluation of an
incident. .The-revision designated the shift technical advisor (STA),
in conjunction with the shift supervisor, as the individual
responsible.for evaluation of off-normal events.
Procedure 50-R-4
previously did not designate a. specific individual responsible for.
event evaluation.
The NRC inspector reviewed the procedures listed below:
Number
Revision
Title
S0-R-4
16
Station Incident Reports
50-R-11
11
Notification of Significant
Events
S0-R-12
3
Reporting of Physical
Security Events
Based on a review of these procedures, it appeared that the licensee
had established an adequate incident reporting program.
Although it
appeared that an adequate program has been established, the licensee
has experienced some difficulty in reporting off-normal events as
evidenced by issuance of Violation 285/8811-03 in NRC Inspection
Report 50-285/88-11.
The specific problems of the incident
evaluation process will be reviewed when followup on the violation
is performed.
The NRC inspector reviewed training records to verify that the STAS
had received training on the new incident reporting process.
It
appeared that the STAS have been trained in use of the new reporting
program.
This item is considered closed.
e.
Development of Operating Instructions for High Dew Point (Submittal
Item No. I.A.2.d, IA Project No. II.A.10)
The item was related to the development of instructions for
operations personnel on what actions to take in the event the dew
point indicator or routine testing indicate the dew point exceeds the
system design limit of -20 degrees Fanrenheit.
The NRC inspector reviewed Procedure 01-CA-1 and noted that the
licensee had provided adequate instructions to operations personnel.
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On July 6, 1988, the licensee experienced a problem where the. shift
chemist monitored the dew point and found that.the system dew point
exceeded the system limit. 'The operations staff took immediate1
action and restored the system dew point by_ switching from the
on-line to the standby air dryer.
Subsequent tests indicated that
the dew point.had returned to -34 degrees Fahrenheit.
It appeared,
based on the actions taken by the operations staff, that the.
instructions provided in Procedure 01-CA-1 were adequate.
The NRC inspector reviewed training records to verify that the
appropriate personnel had received training in the actions required
in the event of a high dew point event.
Based on the training
records reviewed, it appeared that the appropriate personnel had
received training.
This item is considered closed,
f.
Review IA System Lineup and Tag-Out Status for Adequacy (Submittal
item No. I.A.2.e, IA Project No. I.A.19)
This item was related to a licensee commitment to review
administrative procedures for lineup and verify that IA system
compo ents were appropriately tagged to prevent inadvertent
operation.
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The licensee performed a walk down of the IA system to verify that
the system was properly tagged with danger or caution tags to prevent
inadvertent operation of system components. _The licensee also
reviewed ,ccedure 50-0-20, "Equipment Tagging Procedure," to
determint G ether or not changes to the procedure were necessary.
Pased on the two actions described above, the licensee determined
that the IA system tagging and Procedure S-0-20 were adequate;
therefore, no changes were made.
In followup on this item, the NRC inspector performed a walkdown of
selected areas of the IA system.
During the walkdown, the NRC
inspector noted no problems with the danger or caution tags installed
on the system.
In addition, no instances were noted where tags were
not installed and should have been.
The NRC inspector reviewed Procedure S0-0-20, Revision 19, to verify
that the procedure provided clear instructions for tagging of
equipment.
Based on the review performed, it appeared that
Procedure 50-0-20 provided adequate instructions.
This item is considerad closed.
g.
Upgrade of the Preventive Maintenance Program (Submittal Item
No. I.A.3.a, IA Project No. I.A.4)
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This item was related to a licensee commitment to conduct a review of
ie preventive maintenance (PM) program for the IA system.
The
review was performed by industry consultants to determine what
' additional PMs, if any, were required to be initiated for the system.
Based on t he review performed by the licensee's consultants, existing
PMs were tevised to increase the frequency of performance.
Review of
the PMs is discussed in paragraph 13.1 of this report.
During a review of this item, the-NRC inspector noted that the
industry consultants recommended PMs be established that had not b'en
previously performed by the licensee. ~The. recommended PMs included
periodically abuilding the system air regulators and periodically
checking for moisture by ' blowing down accumulators and system lo,e
points.
The licensee has not yet instituted these PMs.
In discussions with the licensee, the NRC inspector determined that
the licensee would not be implementing the recommendation made by the
consultant with respect to blow down of the accumulators and system
low points.
The licensee stated that, since dew point monitoring has
shown that a high quality of air is~being supplied to the IA system,
no periodic blow-downs are required.
In addition, the licensee also
stated that, since' the water intrusion event, no water or
particulates have been found in any components disassembled for
repair where water was not expected to be found.
With respect to the
performance of PM activities on the regulators, the licensee stated
that they had no plans to include the regulators in the PM prngram at
this time.
The' licensee stated that a decision would be made within
6 months as to what actions will be taken on inclusion of the
regulators in the PM program.
This item remains open pending the
licensee's decision on including the regulators in the program and a
review of the licensee's decision by an NRC inspector.
(285/8823-06)
This item is considered closed,
b.
Air Dryer Desiccant Replacement (Submittal Item No. I.A.3.b, IA
Project No. - None)
This item was related to a licensee commitment to replace the
desiccant in the air dryers to ensure maximum moisture removal.
The NRC inspector reviewed M0 874814 to verify that the desiccant had
been replaced.
The NRC inspector also observed, at the tice of
replacement in December 1987, the craftsmen replacing the desiccant.
It appeared that the desiccant was appropriately replaced.
This item is considered closed.
i.
Revision to the Air Dryer Preventive Maintenance Schedule (Submittal
Item No. I.A.3.c, IA Project No. - None)
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This item involved the licensee ' revising.the PM schedule for the air
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. dryers. The revision of the PM program for the air dryers was based
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on the input received by the licensee from an IA consultant.
To upgrade the PM program for-the~ air dryers, the licensee revised
two PMs to re' quire'the maintenance be performed at a greater
frequency.
Procedure PM-UXHV was revised to require inspection and
lubrication of the dryer components biweekly.
This activity was
previously performed on a quarterly basis.
Procedure PM-TXCB was
revised to require replacement of the' dryer desiccant every refueling
outage. . Procedure PM-TXDB previously required an inspection of the
desiccant each refueling outage.
The NRC inspector reviewed Procedures PM-UXHV and PM-TXDB to verify
that the procedures provided adequate instructions and that the
inspection frequency was correctly specified.
No problems were
noted.
The NRC inspector also reviewed a sample of completed Procedure PM-UXHV
to verify that the activity was completed.
Based on the review, it
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appeared that the licensee inspected and lubricated dryer cor.ponents
biweekly.
PM-TXDB has not been performed yet.
The licensee replaced
the dryer desiccant in accordance with the instructions provided by
an M0.
See paragraph 13.h (above) of this section of this report.
This item is considered closed.
j.
Initiate Preventive Maintenance or Surveillance Testing for the
Air-Operated Dampers Associated with the Emergency Diesel Generators
(Submittal Ite,a No. I. A.4.a
IA Project No. I. A.11 and I. A.23)
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This item involved the inclusion of the air dampers associated with
the EDGs into a routine testing program.
This item also involved the
initiation of a program to routinely blow down the accumulators for
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the exhaust dampers on the EDGs.
To routinely verify satisfactory operation of the air dampers, the
licensee issued Procedure SP-STROKE-1.
This procedure requires that
the exhaust dampers (YCV-871E and YCV-871F) be cycled monthly and the
time for the dampers to cycle open recorded.
The recorded data was
plotted and a trend established.
Procedure SP-STR0KE-1 also requires
that the operation of the EDG fresh air inlet dampers-(YCV-871A,
YCV-871B, YCV-871C, YCV-8710, YCV-871G, and YCV-871H) be verified.
Cycle timing for these dampers are not recorded.
'io verify operability of the dampers, the licensee revised
Procedure ST-ESF-6.
This procedure is used to verify operability of
the EDGs in accordance with TS requirements.
The revision added a
requirement that the operability of all EDG dampers be performed on a
monthly basis.
Procedure ST-ESF-6 also required that the stroke time
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for YCV-871E and YCV-871F be recorded each quarter.
The licensee
provided' instructions for monitoring of stroke times in
Procedures SP-STR0KE-1.and ST-ESF-6 because this will ensure
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that the stroke times will be recorded in the future.
During the
upcoming outage, the licensee will.' review the results obtained by
Procedure SP-STROKE-1 since November.1987 to determine whether or not
it is necessary to continue the performance of Procedure SP-STR0KE-1.
-The licensee issued Procedures PM-DAMP-1 and PM-DAMP-2 to provide for
blowdown of the accumulators for the EDG exhaust dampers on a
quarterly basis.
The NRC inspector reviewed the following procedures during followup
on this item:
Number
Revision
Title
SP-STR0KE-1
4
Inservice Testing of
Air-0perated CQE Valves
PM-DAMP-1
1
Blowdown of Accumulator
for YCV-871E
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PM-0 AMP-2
1
Blowdown of Accumulator
for YCV-871F
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Diesel Start and Diesel
Fuel Oil Transfer Pump
The NRC inspector also reviewed the trending documentation for
Dampers YCV-871E and YCV-871F.
Based on the review of the documentation listed above, it appeared
that the licensee has established an adequate program for testing the
The NRC inspector reviewed the documentation
for the testing that had been completed.
The review indicated that,
based on the documentation, the dampers are properly operating.
A
review of the completed documentation for blow down of the exhaust
dampers indicated that no moisture or foreign material has been
found.
This item is considered closed.
k.
Performance of a Particulate Monitoring Program (Submittal Item
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No. I.A.4.b, IA Project No. I.A.7 and I.A.8)
This item involved the commitment by the licensee to establish a
particulatt monitoring program.
The program was to be established to
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verify that 'here wasn't sufficient particulate matter to affect the
operation of IA components and equipment.
The licensee's program was
performed by the onsite chemistry group.
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A limit of 0.005 milligrams per liter (mg/1) was established based on
the accepted limit for air used to supply breathing apparatus for
plant personnel.
The results of the tests performed in October, November, and December
1987 indicate that the particulate level in the IA system is less
than 0.0033 mg/1.
This value represents the lowest level of
detection of the instrument used.
In February 1988 the licensee
sampled the IA system for particulate and found that the particulate
level remained at less than 0.0033 mg/1.
Because the particulate
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level has not increased, the licensee has not performed a particulate
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sample since February 1988.
The NRC inspector reviewed the documented results of the sampling
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performed by the licensee and verified that the results indicated
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that particulate matter was found to be less than 0.0033 mg/1.
Based on the continuous low r = ding., of particulates in the IA
system, the licensee stated that'a routine sampling program will not
be continued.
The licensee stated that, in the event of an
occurrence that warrants reinitiation of testing, the testing will be
resumed.
This item is considered closed.
1.
Establishment of a Dew Poir.t Sampling Program (Submittal Item
No. I.A.4.c, IA Project No. I.A.5 and I.A.6)
This item was related to the establirhment of a dew point sampling
program to verify the dew point is maintained within the established
design criteria of -20 degrees Fahrenheit.
The licensee has established a program for weekly sampling of the IA
system dew point.
The sampling program has been instituted by the
licensee's chemistry department.
The licensee also installed a
temporary gross dew point indicator in the system.
This on-line
indicator is monitored each shift by operations personnel and is used
to indicate a malfunctioning air dryer.
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The NRC inspector reviewed Procedure CMP-3.74, "Dew Point By Alnor
Dewpointer," to verify that proper instructions had been provided for
operation of the dewpointer.
No problems were noted.
The NRC
inspector also reviewed the results of the dew point measurements
that had been taken by the licensee.
The data that established the
measured baseline for the dew point readings were obtained in
accordance with the instructions provided in M0s 875429, 875400, and
875547.
The NRC inspector noted that the results of the baseline
measurements indicated that the dew point was continually below
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-20 F. ' Based on the review performed in review'of this item, it
appeared'that the licensee has established an adequate dew point
monitoring program.
This item is considered closed.
m.
hrformance of a System Functional Inspection (Submittal Item
Ne. I.A.5.a, IA Project No. I.A.15)
This item involved the licensee contracting with an outside
con;ultant to perform a functional inspection of the IA system.
The licensee contracted with Stone and Webster (S&W) to perform an
inspection of the IA system.
The inspection report, "Instrument Air
System Evaluation," was issued on ' January 15, 1988.
The results of
the evaluation performed by S&W identified 63 concerns related to the.
installation, operation, maintenance, and design of the system.
The licensee reviewed the concerns identified by S&W and determined
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that only one of the concerns was safety significant.
The concern
was related to the operability of Valve PCV-1849, the IA containment
isolation valve.
The licensee notified the NRC of the concern and a
review of the problem was performed by the NRC.
The details of the
review are provided in NRC Inspection Report 50-285/88-11.
The
remaining 62 items are in the process of being dispositioned by the
licensee.
The NRC inspector will review the disposition of the items
when the licensee completes a commitment (Submittal Item No. II.A.5.C,
IA Project No. I.A.28) made in response to the IA event.
A review of
the items will be made by the NRC during a future inspection.
The NRC inspector reviewed the report generated as a result of the
S&W evaluation of the IA system.
It appeared that the evaluation was
indepth, performed by qualified individuals, and the identified
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concerns were based on sound judgement.
This item is considered closed.
n.
Evaluation of Interface Valves and Bubblers (Submittal Item
No. I.A.S.b, IA Project No. None)
This item involved a licensee commitment to evaluate valves
constructed with internal diaphragms and tank level instruments to
determine the potential for allowing water to enter the IA system.
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The licensee performed a walk down of the IA system in December 1987
and identified valves constructed with an internal diaphragm.
The
diaphragms in the valves presented a potential path for water to
enter the IA system in the event the diaphragm failed.
The licensee
evaluated the diaphragm failure and established that water entry into
the IA system was not possible.
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The NRC inspector reviewed th( actions taken by the licensee to
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evaluate the diaphragms.
The results of the review are provided in
NRC Inspection Reports 50-285/87-33 and'50-285/88-03.
The' review.
performed by-the NRC inspector' determined that the probability of
water leaking'past the diaphragm'into the IA system _was extremely
remote.
As a followup to the' identification of diaphragm valves being
supplied by the IA system, the lic.nsee stated that an additional
walk down of the IA system would be performed during the next
scheduled refueling outage.
The-NRC inspector had. issued Open
Item 285/8733-05 to track the licensee's actions.to complete another
walkdown.
This item will be reviewed during closeout of the open
item.
The licensee performed an evaluation of the tank level instrumen'ts
(bubblers) to verify that the liquid in the tanks could not enter.the
IA system if system pressure was lost.
The results of the evaluation
indicated that water cannot enter the IA system through the bubblers.
The NRC inspector discussed the evaluation with the licensee and
noted no problems.
This item is considered closed.
o.
Include Consideration of Check Valve Failures in the Safety Analysis
for Operability (Submittal Item No. I.A.S.c, IA Project No. I.A.26)
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This item was related to the need for the licensee to revise the
safety analysis for operability (SAO) to include all IA check valves
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installed on accumulators for safety-related valves. At the time the
licensee made this commitment, all check valves had not been included
in the SA0.
The SA0 was generated to verify that the plant could
continue to operate safely.
On April 27, 1988, the licensee issued an SA0 for~ evaluation of
continued plant operation.
The SA0 included an evaluation of all the
accumulator assembly check valves that had not been tested and
verified to operate satisfactorily.
The conclusions of the
evaluations performed by the licensee indicated that the plant was
safe to continue to operate.
The SA0 generated by the licensee was forwarded to NRR for review.
Open Item 285/8815-02 was issued in NRC Inspection Report 50-285/88-15
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to formally document the cesults of the review to be performed by
NRR.
This item will be reviewed during followup on the open item.
This item is considered closed.
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Consideration of Common-Mode Failure During Modification Process
(Submittal Item No. I.A 6.a, IA Project No. I.C;5)
This item was related to a commitment made~by the 1icensee to revise
and. upgrade engineering procedures to ensure that modifications
formally address potential common-mode failures.
' This. item was formally. issued as Violation 285/8727-01'(Violation B.3)
in NRC Inspection Report 50-285/87-27.
This item will be reviewed
during followup on the violation.
This item is considered closed.
q.
Establishment of An Event Investigative Team (Submittal Item
No. I.B.1.b, IA Project No. I.C.4)
This item involved a' licensee commitment to establish a management
investigative safety team (MIST) to be responsible for collecting and
preserving data, analyzing event significance, and identifying root
causes.
The licensee established the charter and niembership of the MIST by
issuance of Procedure NPD-QP-18, "Management Investigative Safety
Team (MIST)," on April 22, 1988.
Procedure NPD-QP-18 established
three permanent team members with the provision that specific
expertise could be added to the team, depending on the nature of the
event.
The three permanent team members are the manager of station
nuclear engineering, manager of training, and the division manager of
production engineering.
The NRC inspector reviewed Procedure NPD-QP-18 to verify that the
appropriate requirements had been provided.
No problems were noted.
This item is considered closed.
r.
Upgrade the Emergency Plan Implementing Procedures (Submittal Item
No. I.B.2.a, IA Project No. I.C.14)
This item involved a review by the licensee of the emergency plan
implementing procedures (EPIP).
The EPIPs were reviewed to verify
that the procedures properly addressed the consideration of common-mode
failures into the declaration of plant emergency classification;.
This item was formally issued as Violation 285/8727-07 (Violation B.5)
in NRC Inspection Report 50-285/87-27.
The review of this item
will be performed during followup of the violation.
This item is considered closed.
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Additional Walkdown of the IA System (Submittal Item No. II.A.1.a,
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IA Project No. II.A.13)
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This item was related'to a commitment made.by the licensee to perform-
a walk down of the IA system.
The: walk down was to be performed to
identify the existence of any IA/ water. interfaces.
This item was formally issued'as Open Item 285/8733-05 in NRC
Inspection Report 50-285/87-33.
This item.will be reviewed during'
the followup performed for the open item.
This item is. considered closed.
t.
Upgrade the Abnormal ~0perating Procedure'for Loss of Instrument Air
(Submittal Item No. II.A.2.a, IA Project No. I.A.12)
This item involved the revision ofgProcedure A0P-17, "Loss of
Instrument Air," to provide clear and concise instructions to the
operations staff in the event'the IA system ' pressure'is lost.
This item was formally issued as Violation 285/8727-05
(Violation 3.2.b) in NRC Inspection Report 50-285/87-27.
This item will be reviewed during the performance of followup on the
violation.
This item is considered' closed.
14.
Followup on NRC Information Notice 88-46 (92701)
On July 8, 1988, the NRC issued NRC Information Notice (IN) es-46,
"Licensee Report of Defective Refurbished Circuit Breakers," to alert
licensees of the discovery by the Pacific Gas and Electric Company of
defective refurbished electrical equipment, such as circuit breakers, that
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may have been supplied to nuclear power plants.
Subsequent to the
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issuance of IN 88-46, the NRC received information that OPPD may have
purchased two refurbished breakers (Model GE THEF136ml100) from the GE
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Supply Company (GESCO) in Omaha, Nebraska.
The infermation also stated
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that the breakers had been originally supplied by the General Magnetics
Company of Commerce, Californis.
On July 19, 1988, the NRC inspector
informed the licensee of the information on the breakers.
The licensee immediately commenced a search of their procurement records
to verify the breakers had been received and to identify if the breakers
had been ir. stalled in the plant. On July 21, 1988, the licensee informed
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the NRC inspector that they had identified where the breakers had been
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used in the plant.
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On February 14, 1985, one of the breakers was installed in the electrical
supply circuit for the nuclear detector well cooling fan (VA-12A) motor.
VA-12A is nonsafety-related equipment; however, the circuit breaker is
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classed as CQE (safety-related) because the breaker is installed in a
motor control center containing other safety-related breakers.
On
July 29, 1985, the bteaker failed.
The second breaker was removed from the
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warehouse and tested prior to installation.
The second breaker failed the
test and was never installed in the plant.
The licensee replaced the-
VA-12A breaker with another Model GE THEF136m1100 breaker.that had been
installed in the plant, but the equipment serviced by the' breaker was no
longer used.
The breaker used to replace the VA-12A breaker was purchased
from General Electric as original equipment.at the time the plant was
constructed.
The NRC inspector performed a review of the' activities related to the
purchase and installation of the two breakers purchased from GESCO.
The
results of the review are provided below.
At the time of the purchase of.'the breakers, no requirement existed
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for testing breakers purchased as commercial grade items.
The
licensee'.s procedures in effect'at the time allowed the replacement
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of electrical compomnts as long as the component was being replaced
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due to normal wear or damage, perforrance had been satisfactory, and
the component used for' replacement was a like-for-like replacement.
However, as a matter of routine, the licensee performed testing on
breakers to verify proper operation.
During an interview with the
individuals involved with replacement of the breaker, it was
determined that testing was performed on the breaker and that the
breaker passed the testing.
The testing included a visual
examination, manual operations check, and an overcurrent trip check.
The breaker was installed in accordance with M0 844225, but the M0
did not document that testing was performed or the results of the
testing.
When the first breaker failed, MO 852558 was issued to troubleshoot
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the cause of the breaker failure.
H0 852558 did not document the
cause of the failure of the breaker.
The individuals performing the
maintenance recalled that the breaker failed due to a poor connecticq
between the breaker and one of the incoming electrical feeder lines.
The poor connection caused localized overheating and damaged the
breaker.
The individuals recalled that there was no damage to the
breaker itself.
When the second breaker was removed from the warehouse, the breaker
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was tested prior to installation.
The individuals recalled that the
breaker failed the test because it could not be mechanically reset
following the overcurrent trip test.
For this reason, the breaker
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was never installed in the plant.
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Licensee personnel stated that both breakers were trashed as neither
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was fit for use.
The breakers were purchased by Purchase Order (PO) 98507-J1 that
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specified the receipt inspectior. requirements of checking for
cleanliness, physical damage, workmanship, electrical insulation
undamaged, protective covers and seals installed, markings in
accordance with the P0, and packaging met the requirements of
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Documentation provided by the licensee' indicated that'
both breakers: met the receipt inspection acceptance criteria.
Since the breakers are no longer in service 'at the plant, no immediate
safety concerns exist with respect to this specific purchase.
The
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licensee is continuing with.the search of procurement records to determhe
whether or not other defective equipme'nt-may have been furnished by GESCO
and/or the General Magnetics Company.
The licensee is currently in the process of upgrading their procedures for
dedication of material purchased as commercial grade items.
The new
program should be initiated in the near future.
The NRC inspector performed a review to determine whether or not a
10 CFR Part 21 report should have been made by the licensee at the time
the breaker was found to be defective. . Based on this review, it appears
that this event was not reportable in that a substantial safety hazard did
not exist because there was not a major reduction in the degree of
protection provided to public health and safety.
No safety hazard existed
since the defective breaker was never installed in the plant.
No violations or deviations were identified.
15.
Followup on NUREG-0737 (TMI) Item II.E.1.1.1
(25565)
Followup was performed to verify that the licensee had installed an
auxiliary feedwater (AFW) system that met the reliability criteria
established by TMI Item II.E.1.1.1.
Based on an onsite inspection performed by NRC Headquarters personnel and
the reliability analysis provided by the licensee, NRR has determined that
the AFW system met the established reliability criteria.
In a letter
dated May 9, 1988, NRR issued an evaluat#vn of the AFW system and noted
that the system is generally well designed, maintained, and operated.
The
NRR evaluation also noted that the licensee had made a commitment, in a
letter dated February 17, 1988, to the NRC to install a third AFW pump
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auring the 1990 refueling outage.
NRR noted that even though a third pump
will be installed, the current system meets the reliability criteria
stated in the standard review plan.
This item is considered closed.
16.
Nonlicensed Training
During this inspection period, the NRC inspector participated in the
licensee's annual vaqualification program for general employee training
(GET).
To evaluate the knowledge of each individual participating in the
class, the licensee adrainistered an examination that covered the material
provided in the GET program.
When the NRC inspector was presented his
examination booklet, he noted that the booklet contained six questions
with the correct answers circled.
Based on the fact that the NRC
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inspector had been presented an examination with corre'ct answers, the NRC
inspector questioned the licensee about the control .of. examination
booklets.
In response to this identified problem,;the licensee performed a review of
the 720 examination booklets for GET training.
Of the 720 booklets,13
were destroyed as unusable because answers were marked in the booklets.
The licensee stated that no more than six answers were marked in any one
booklet.
To correct this problem,'the 1icensee' took the actions discussed below:
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All examinations in use were destroyed and replaced with new
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examinations containing new questions.
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Each examination was serialized'so that traceability.could be
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established as to which examination was used by each individual at
the conclusion of GET.
All booklets will be checked by the GET instructor prior to being
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used to verify that no marks have been made in the booklets.
A
signoff sheet was initiated so that each instructor verifies, in
writing, that each booklet was checked.
The instruction sheet for the booklets was updated to stress-to each
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student that no marks shall be made in the booklets.
Key control for the cabinets containing the examination booklets was
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established.
The NRC inspector reviewed the actions taken by the licensee to address
this problem.
Based on the review, it appeared that the licensee had
established a program for controlling the examinations used for GET.
17.
Exit Interview
The NRC inspectors r.iet with Messrs. K. J. Morris (Division Manager,
Nuclear Operation) and W. G. Gates (Plant Manager) and other members of
the licensee staff at the end of this inspection.
At this meeting, the
NRC inspector summarized the scope of the inspection and the findings.
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