ML20214M816

Insp Rept 50-285/87-10 on 870401-30.Violations & Deviations Noted:Failure to Establish Containment Integrity During Refueling Operations & Failure to Establish Fire Watch,Per Tech Spec Requirement

ML20214M816
Person / Time
Site:	Fort Calhoun
Issue date:	05/15/1987
From:	Harrell P, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214M745	List: ML20214M743 ML20214M791 ML20214M799 ML20214M816
References
50-285-87-10, IEB-86-002, IEB-86-003, IEB-86-2, IEB-86-3, NUDOCS 8706010438
Download: ML20214M816 (20)

See also: IR 05000285/1987010

Text

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APPENDIX C

U.S. NUCLEAR REGULATORY-COMMISSION

REGION IV

NRC Inspection Report: 50-285/87-10 License: OPR-40

Docket: 50-285

Licensee: Omaha Public Power District (OPPD)

1623 Harney Street

Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station (FCS)

Inspection At: Fort Calhoun Station, Blair, Nebraska

Inspection Conducted: April 1-30, 1987

Inspector:)

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N [(7

P.~ H. Harrell, Senior Resident Reactor

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Date

[ Inspector

Approved: _Cht

D. R. Hunter, Chief, Reactor Project

I f!87

Date

Section B, Reactor Projects Branch

Inspection Summary

Inspection Conducted April 1-30, 1987 (Report 50-285/87-10)

Areas Inspected: Routine, unannounced inspection including operational safety

verification, maintenance, surveillance, plant tours, safety-related system

walkdown, security observations, radiological protection observations,

in-office review of periodic and special reports, followup on previously

identified items, followup on IE Bulletins 86-02 and 86-03, refueling

activities, containment local leak rate testing, licensed operator initial

training, and licensed operator requalification program.

Results: Within the 14 areas inspected, 3 violations (failure to establish

containment integrity during refueling operations, paragraph 12; failure to

establish a fire watch in accordance with TS. requirements, paragraph 4; and

failure to establish and implement _ the procedure for leak rate testing of

containment isolation valves, paragraph 13) and 1 deviation (failure _to log a

missed surveillance test in-the shift turnover log, paragraph 7) were

identified.

8706010438 870528 "

PDR ADOCK 05000285

G PDR.

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DETAILS

1. Persons Contacted

• W. Gates,, Plant Manager

• B. Bateman, Quality Assurance Inspector

• C. Brunnert, Supervisor, Operations Quality Assurance

M. Core, Supervisor, Maintenance

T. Dexter, Supervisor, Security

• J. Drahota, Maintenance Engineer

• J. Fisicaro, Supervisor, Nuclear Regulatory.and Industry Affairs

J. Fleuhr, Supervisor, Station Training

• J. Gasper, Manager, Administrative and Training Services

• L. Kusek, Supervisor, Operations

• K. Miller, Supervisor, Mechanical Maintenance

• D. Munderloh, . Plant Licensing Engineer

T. McIvor, Supervisor, Technical

R. Mueller, Plant Engineer

G. Roach, Supervisor, Chemical and Radiation Protection

S. Willrett, Supervisor, Administrative Services and Security

• Denotes attendance at the monthly exit interview.

The inspector also contacted other plant personnel, including operators,

technicians, and administrative personnel.

2. Followup on Previously Identified Items

a. (0 pen) Unresolved Item 285/8624-01: Failure to maintain training

records in accordance with regulatory requirements.

This unresolved item involved the licensee's failure to maintain a

training records system. Since the issuance of this unresolved item,

the licensee has taken steps to establish a records program, but has

yet to complete the actions.

The NRC inspector discussed the current status of the records system

with the Supervisor Station Training. The supervisor stated that a

contractor with extensive. experience in establishing an auditable

records system was hired in February 1987. This-individual initiated

the development of a new records system. The new records system will.

be a. computerized system with software specifically developed for

this application. The new system will be fully functional by the end

of 1987.

This item remains open pending the establishment of a' functional

training records system.

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b. (0 pen) Unresolved Item 285/8624-02: Failure to provide on-the-job

training.

This unresolved item was related to the licensee's failure to provide

licensed operators with the on-the-job training specified in the

licensee's approved training program.

The licensee revised the worksheet used during simulator training.

The worksheet previously used by the licensee was the generic

worksheet issued by Combustion Engineering. The newly revised

worksheet was specifically developed to include all control

manipulations and plant evolutions required by the licensee's

NRC-approved training program. Each manipulation and evolution was

provided with an individual sign off to ensure all activities were

completed.

The NRC inspector reviewed the simulator worksheets for selected

reactor operators and senior reactor operators to verify that all

required evolutions and manipulations were performed. No problems

were noted during the review.

This unresolved item also identified a problem with the licensee not

providing classroom lectures for the evolutions not capable of being

performed at the simulator. The NRC inspector reviewed records to

verify that classroom training was given for-the loss of instrument

air and the loss of shutdown cooling. Based on the results of the

review, the licensee did not provide classroom lectures for the loss

of instrument air or shutdown cooling during 1985 and 1986.

This item remains open pending the completion of the appropriate

classroom lectures and the establishment of a program by the licensee

to ensure that a lecture in the loss of instrument air and the loss

of shutdown cooling is provided in each 2 year requalification

training cycle.

c. (Closed) Open Item 285/8624-06: Implementation of commitments made

by the licensee to upgrade the licensed-operator requalification

program.

This open item is related to commitments made by the licensee in a

letter dated December 23, 1985, for upgrading the requalification

program. The commitments were made in response to the failure of the

NRC-administered requalification examination by six of eight licensed

operators. Each of the specific areas addressed by the licensee for

program upgrade are discussed below.

. Improved attendance at scheduled requalification training

sessions was encouraged by issuance of a management policy in

October 1986. Licensee personnel stated that the new policy

increased lecture attendance by licensed operators, but

attendance by licensed staff personnel had not changed

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significantly. Licensee personnel also stated that the new rule

change to 10 CFR Part 55 made by the NRC will solve the problem

of attendance as attendance will be mandatory. The rule change

becomes effective in May 1987.

. Lesson plans have been upgraded to reflect the new

performance-based training program. The upgraded lesson plans

were being used by classroom instructors and had been provided

to NRC operator licensing personnel.

. The licensee issued new qualification manuals to each senior

reactor operator. The new manual provided requirements for

completion of specific items during the requalification cycle.

Completion of the items will ensure that each senior operator

reviews the appropriate areas.

3. Operational Safety Verification

The NRC inspector conducted reviews and observations of selected

activities to verify that facility operations were performed in

conformance with the requirements established under 10 CFR, administrative

procedures, and the TS. The NRC inspector made several control room

observations to verify the following.

. Proper shift staffing and turnover

Operator adherence to approved procedures and TS requirements

. Operability of reactor protective system and engineered safeguards

equipment

Logs, records, recorder traces, annunciators, panel indications, and

switch positions complied with the appropriate requirements

. Proper return to service of components

. Maintenance orders (MO) initiated for equipment in need of

maintenance

Appropriate conduct of control room and other licensed operators

. Management personnel toured the control room on a regular basis

No violations or deviations were identified.

4. Plant Tours

The NRC inspector 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,

were satisfactory.

. Equipment was being maintained in proper conditions, without fluid

leaks and excessive vibration.

. Plant housekeeping and cleanliness practices were observed, including

no fire hazards and the control of combustible material.

. Performance of work activities was in accordance with approved

procedures.

. Portable gas cylinders were properly stored to prevent possible

missile hazards.

. Tag out of equipment was performed properly. ,

. Management personnel toured the operating spaces on a regular basis.

During a plant tour on April 1,1987, the NRC inspector noted that a hose

had been run through the doors to both emergency: diesel generator (EDG)

rooms. The hose held both doors open. causing.the fire' barriers associated

with the doors to be nonfunctional. The NRC inspector also noted that a

hose had been run through an opening with a fire guillotine _ curtain that

separated the EDG rooms. With the hose in place, the curtain could not

perform its intended function, causing the fire barrier to be

i nonfunctional. In discussions with security personnel, the NRC inspector

determined that the hoses had been run through the EDG doors and the

opening for approximately 2 days. At the time of discovery by the NRC

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inspector, personnel were working in the area. However,- the areas were

not continuously manned during the 2-day period.

TS 2.19(7) states, in part, that all penetration fire barriers protecting

safety-related areas shall be functional. With a penetration fire barrier

nonfunctional, within I hour, either establish a continuous fire watch on

j at least one side of the affected penetration, or verify the- operability

of fire detectors on at least one side of the penetration and establish an

hourly fire watch patrol.

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The licensee implemented the requirements of TS 2.19(7) by issuance of

Procedure S0-0-38, " Fire Watch Duties and Turnover Procedures." This

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procedure required that, if an hourly watch patrol is allowed per TS 2.19,

an FC-1006 form shall be filled out for the duration of the patrol watch

period.

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The NRC inspector determined that an FC-1006 form (hourly fire watch

patrol log) had not been completed for the nonfunctional barriers in the

EDG rooms. Without completion of the form, no objective evidence existed

to indicate that an hourly fire watch had been established or that the-

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fire detectors.on one side of the fire barrier had been checked for

operability. The failure to provide an hourly fire watch in accordance

with TS 2.19(7) is an apparent violation'. (285/8710-01)

Upon notification by the NRC inspector, the fire barriers were restored to

a functional. status. In followup on this apparent problem, the NRC

inspector noted that the fire-door lights for the.EDG room doors on the

central alarm station (CAS) were not operating. The. security guard

stationed on the CAS uses the lights as an indication that the doors are

open. Prior to an hour elapsing with the lights lit, the security guard

notifies the shift supervisor that an hourly fire watch patrol is.

required. The shift supervisor will then verify operability of the fire

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detectors on one side of the barrier and establish a roving fire watch by

completion of the FC-1006 form.

4 During plant tours, the following items were.also identified.

. The state of Nebraska certification of the annual inspection for the

personnel elevator-in the administrative building expired on April 1,

1987. Upon notification by the NRC inspector, the licensee had the

elevator recertified.

. One end of the handrail in the stairwell adjacent to the auxiliary

building elevator had come loose due to the fastener falling out of

the wall. The loose handrail posed a personnel safety hazard for

anyone using the stairwell. The licensee was notified of this item

on April 20, 1987; however, the handrail had not been repaired prior

to the end of this inspection period.

. Fire Door 989-11 was found not to function properly. On two

occasions during the month, the door was found unlatched. Upon

notification by the NRC inspector, the door was repaired. The-

licensee continued to experience difficulty in maintaining fire doors

as evidenced by the repeated identification of nonworking fire doors

during previous monthly inspections.

5. Safety-Related System Walkdown

The NRC -inspector walked down accessible portions of 'the following

safety-related system to verify system operability. Operability was

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determined by verification of selected valve and switch positions. The

system was walked down using the drawing and procedure noted.

. Fire protection system (Procedure OI-FP-6, Revision 50, and

Drawing M-266, Revision 35)

During the walkdown, no problems were noted between the drawing,

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procedure, and plant as-built conditions for the selected areas checked. i

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No violations or deviations were identified. l

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6. Monthly Maintenance Observations

The NRC inspector 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.

. The TS limiting conditions for operation were met while systems or

components were removed from service.

. Approvals were obtained prior to. initiating the work.

. Activities were accomplished using approved M0s and were inspected,

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as applicable.

. . Functional testing and/or calibrations were performed prior to

returning components or systems to service.

. Quality control records were maintained.

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. Parts and materials used were properly certified.

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. Radiological and fire prevention controls were implemented.

The NRC inspector reviewed and/or observed the following' maintenance

activities:

. Painting of emergency feedwater storage tank (M0 862360)

. Repacking of Valve FW-339 (M0 851969)

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j. . Sealing of ducts for control room heating, ventilating, and air

conditioning system (M0 870012)

i . Repacking of a main feedwater isolation valve (M0 871778)

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. Inspection of pipe wall thickness on balance-of plant piping

(MO 840127)

No violations or deviations were identified.

j 7. Monthly Surveillance Observations

The NRC inspector observed selected portions of the performance of and/or

reviewed completed documentation for the TS required surveillance testing

i on safety-related systems and components. The NRC inspector verified the

following items during the testing.

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. Testing was performed by qualified personnel using approved

procedures.

. Test instrumentation was calibrated.

. The TS limiting conditions for operation were met.

. Removal and restoration of the affected system and/or component were

accomplished.

. Test results conformed with TS and procedure requirements.

. Test results were reviewed by personnel other than the individual

directing the test.

. Deficiencies identified during the testing were properly reviewed and

resolved by appropriate management personnel.

The NRC inspector observed and/or reviewed the documentation for the

following surveillance test activities. The procedures used for the test

activities are noted in parenthesis.

. Mechanical penetration seals leak rate testing (ST-CONT-2-F.6)

. Monthly check of station batteries (ST-DC-1-F.1)

. Remotely operated ventilation damper check (ST-VA-1-F.3)

. Inservice inspection of raw water valves (ST-ISI-RW-F.1)

Fire protection system test and inspection (ST-FP-1-F.1)

. Control room ventilation filter circuit operation (ST-CRV-1-F.1)

. Phosphate basket chemical sampling (ST-CHEM-1-F.3)

Containment isolation valves leak rate testing (ST-CONT-3-F.1).

During review of the completed copy of Surveillance Test ST-CRV-1,

" Control Room Ventilation Filter Circuit Operation," the NRC inspector

noted that the test had not been completed when scheduled on April 2,

1987. The test is required to be performed by TS 3.2, Table 3-5,

Item 10.a.3.9, to verify the operation of ventilation dampers for the

design basis accident mode. A note made by the control room operator on

the completed test copy stated that the testing was_not performed because

the plant was in a limiting condition for operation (LCO) due to one

channel of the toxic gas monitors being out of service for calibration.

When in the LCO, operation of the ventilation system in the filtered

makeup mode is prohibited. A review of the station log indicated that the

LCO was exited at 10:15 a.m. on April 2, 1987. It appeared that the test-

was signed off prematurely as the test could have been performed later in

the day.

During a subsequent review of completed surveillance tests by the

Supervisor Operations, it was noted by the supervisor _that the test had

not been performed. The supervisor rescheduled the test and the test was

completed on April 17, 1987. By performing the test in April, the

TS required frequency of the surveillance test was not exceeded.

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On January 13, 1987, the licensee issued Licensee Event Report (LER) 86-05

that described an event where the surveillance test frequency for

exercising the control element assemblies every.2 weeks was exceeded. The

frequency was exceeded due to plant conditions prohibiting performance of

the test. . The licensee stated in the LER that anytime a surveillance test

can not be performed when scheduled, an entry would be made on the shift

turnover log. This commitment was made to ensure the oncoming shifts were

. aware of the need to perform any surveillance that was not performed due

to plant conditions.

Under the licensee's system of administrative controls, a shift turnover

log was not required to be kept whenever the reactor coolant system

temperature was less.than 300 degrees. The plant was in the cold shutdown

mode on April 2,1987. For this reason, when ST-CRV-1 was not performed

as scheduled, no entry was made on the shift turnover log. The failure to

list surveillance test not performed when scheduled on the shift turnover

log is an apparent deviation from a commitment made to the NRC in

LER 86-05. (285/8710-02)

On April 29, 1978 the licensee changed the administrative controls that

defined the use of the shift turnover log. The new controls stated that

, the. log shall be used at all times. The NRC inspector verified that

operations personnel had commenced using the shift turnover log and were

entering surveillance tests'on the log when not performed as scheduled.

i- During review of the completed copy of surveillance test

procedure ST-CHEM-2-F.3, " Phosphate Basket Chemical Sampling Inspection,"

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the NRC inspector noted that the test had not been performed in accordance

with the requirements of TS 3.6(2) d.(ii). Testing of the trisodium.

phosphate dodecahydrate (TSP) is performed during the refueling outage to

verify that the TSP stored in the containment is chemically capable of

raising the pH of the boric acid solution used in the containment' spray

system to a minimum of 7.0. The boric acid solution is stored in the

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safety injection and refueling water tank and is maintained at the

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refueling boron concentration. The pH of the slightly acidic boric acid

I solution is raised to a pH of 7.0 to minimize the effects of chloride

stress corrosion on exposed materials in containment when the solution is

reused during recirculation operations.

ST-CHEM-2-F.3 was performed to verify that the TSP stored in containment

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was chemically capable of performing its intended safety function by

requiring that a specified amount of TSP be dissolved in a given volume of.

boric acid solution at the refueling boron concentration. The

surveillance test required that the resultant pH of the TSP / boric acid

mixture be a minimum of 7.0. The test procedure did not specify the value

of the refueling boron concentration.

On March 9,1987, the NRC issued TS Amendment 103 Sdlich' raised the

required refueling boron concentration from 1700 parts per million (ppm)

to 1800 ppm. The effective date of the TS amendment was March 9, 1987.

The licensee completed the surveillance test on March 19,11987. During

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performance of the test, the chemistry technician used a refueling boron '

concentration of 1755 ppm and obtained a ^ resultant-pH of :7.08. At the j

time the test was performed,_.the technician did not realize that the value

, of the refueling boron concentration had been changed by a TS amendment.

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The NRC inspector reviewed the circumstances related to the-error made

during performance of the test to determine whether the. information . .

provided by the TS amendment was not available to the technician or the

technician failed to consult the appropriate documentation.during

performance of the test. The inspector had not completed this review by

the end of this inspection period. This. item remains unresolved pending

completion of the review by the NRC inspector. (285/8710-03)

Upon notification by the NRC inspector, the . licensee stated that another

test would be performed to verify that the TSP was capable of. performing .

its safety function. The licensee stated that the test would be-performed t

' at a refueling boric acid concentration of at least_1800 ppm. The-

licensee had not completed the retest at the end of this inspection

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period. This item remains unresolved pending completion of the' test and a 9

review of the test results by the NRC inspector.- (285/8710-04)

During review of the TS and the updated safety analysis report (USAR), the  ;

NRC inspector noted an apparent discrepancy between the amount of TSP-

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required to be stored in containment by the TS and the amount required by

the USAR. The TS states that the amount of TSP required is 40 cubic feet

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(approximately 1500 pounds); however, the USAR states that 3000 pounds qf

TSP is required. The licensee could not explain the. apparent discrepancy

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, between the values stated in the two documents. .This_ discrepancy remaias

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an unresolved item pending determination by the licensee of the correct

amount of TSP that should be stored in the containment. -(285/8710-05)

j 8. Security Observations ,

i The NRC inspector verified the physical security plan'was being

implemented by selected observation of the following items.

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. The security organization was properly manned.

. Personnel within the protected area (PA) displayed their

, identification badges.

. Vehicles were properly authorized, searched, and escorted or

controlled within the PA.

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). . Persons and packages were properly cleared and checked before entry

j into the PA was permitted.

. The effectiveness of the security program was maintained when

security equipment failure or impairment required compensatory: ,

measures to be employed.

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. The PA barrier was maintained and the isolation zone kept free of

transient material.

. 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.

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No violations or deviations were identified.

9. Radiological Protection Observations

The NRC inspector verified that selected activities of the licensee's

radiological protection program were implemented in conformance with 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 contained 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 properly frisked prior to exiting an RCA.

. Personnel were aware of and actively participated in the as low as

reasonable achievable (ALARA) program.

. The licensee was meeting the ALARA goals for personnel exposure.

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The plant has been in a refueling shutdown for approximately two months.

For this reason, the licensee has expended approximately 250 man-rem of

tne 345 man-rem goal established for 1987. The refueling outage will last

approximately one additional month. Licensee management stated that

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meeting the man-rem goal for 1987 was still achievable, as the exposure

,. levels will decrease significantly when the plant returns to operation.

The licensee instituted an ALARA concerns program where any person working

onsite can submit concerns to the ALARA committee. Each concern is

reviewed by the committee and an answer provided to the individual

submitting the concern. If the concern will improve the ALARA program,

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the concern is adapted by the committee and implemented. The licensee

publishes a monthly ALARA newsletter that provides the man-rem exposure >

' _for the year-to-date. The newsletter also publishes concerns _ submitted by-

individuals and provides the committee's resolution of each concern for

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o the information of all site personnel.

No violations or deviations were identified.

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10. In-Office Review of Periodic and Special Reports

In-office review of periodic and special reports was performed by the. NRC

resident inspector and/or the Fort Calhoun project inspector to verify the

following, as appropriate.

. Reports included the information required by appropriate NRC

requirements.

. Test results and supporting information were consistent . th design

predictions and specifications.

. Determination that planned corrective actions were adequate for

resolution of identified problems.

. Determination as to whether any information contained in the report

should be classified as an abnormal cccurrence.

The following reports were reviewed.

. Report on inope'rability of fire barriers, dated April.2, 1987

March monthly operations report, dated April 15, 1987

. Request for a TS change for postaccident monitoring instrumentation,

dated April 15, 1987

. Special report on inoperability of fire pump, dated' April 22, 1987

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During review of reports, NRC personnel identified 10 CFP Part 21 reports

submitted by suppliers or vendors that appeared to' applicable to the

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licensee's facility. The NRC resident inspector provided copies of these

reports to the _ plant licensing engineer for review of applicability by the

licensee. The reports provided are listed-below.

. A letter dated November 10, 1986,_ from the Vermont Yankee Nuclear

Power Corporation related-to unsatisfactory operation'of Limitorque

valves lubricated with new, less viscous NEBULA-EP-0 grease.

. A letter dated January 26, 1987,.from the Niagara Mohawk Power.

Corporation related to improper socket seating of Agastat GP Series

relays.

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. A . letter dated. February 3, 1987,.from Toledo Edison related to

inadaquate instructions supplied by-Limitorque for maintaining the.

value-of the torque switch settings on their motor-operated valves.

. JA letter dated February 2,1987, from 'the Niagara Mohawk Power

. Corporation related to an improper electrical manhole duct. seal.

design.

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. A -letter-dated December 19,1986, from the Automatic Valve

Corporation related to the use of Houghto 620 lubricant adversely

affecting aluminum in their valves.

. A letter dated December 1,1986,. from the Automatic Sprinkler

Corporation related to problems identified in their 6-inch, Model C

valves and their mercury check devices.

. A letter dated September 18, 1986, from the Indiana and Michigan

Electric Company related to problems with defective parts in the

auxiliary feedwater pump turbine.

No violations or deviat'on, were identified.

11. Followup on IE Bulletins 86-02 and 86-03

IE Bulletin 86-02, " Static 0-Ring Differential-Pressure Switches," dated

July 18, 1986, was itsued to' alert licensees of problems experienced with

Series 102 and 103 differential pressure switches supplied by SOR,

Incorporated. The specific concern identified in the bulletin was the

installation of the switches in systems subject to the requirements of the

TS.

On July 29, 1986, the licensee provided a response to IE Bulletin 86-02.

The response stated that the' licensee had conducted an investigation and

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' determined that no SOR Model.102 or 103 differential pressure switches-

were installed or planned to be installed in any systems subject to the

requirements of-the TS.

The NRC inspector performed a random, independent check o'f selected

switches to verify that the switches were not 50R Model 102 or 103.

During this review, no problems were noted.

IE Bulletin 86-03, " Potential Failure of Multiple ECCS Pumps Due to' Single -

Failure of Air-Operated' Valve in Minimum Flow Recirculation Line," was '

issued to alert licensees of the possibility of a common-cause failure' of-

emergency core cooling system (ECCS) pumps due 'to failure of the

air-operated valve ~1n the. minimum recirculation flow line. Potential

problems had been noted at other plants due to the recirculation valv'e

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failing-closed on loss of air pressure to the valve, causing the ECCS

pumps to become inoperable.

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On November 13, 1986, the licensee provided a. response to IE

Bulletin 86-03 that stated the air-operated valves used in-the

-recirculation line for the ECCS pumps were not subject to single-failure.

problems. .The results of the licensee's investigation indicated that the

recirculation valves failed open on:a' loss of electrical power or air

pressure.

The NRC inspector reviewed the operat' ion of the-valves in the ECCS pumps

recirculation line to determine if any potential single failures would

affect operation of-all ECCS pumps. No instances were noted of

single-failure conditions affecting the pump ~ recirculation lines.

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No violations or deviations were identified.

12. Refueling Activities

The NRC inspector reviewed / observed various activities performed during

refueling to verify the activities were performed in accordance with the

TS and approved licensee procedures. The activities observed / reviewed

included the following.

. Proper shift staffing by qualified individuals was provided.

. Containment integrity was established and maintained. .

. Good housekeeping and loose object control on the refueling bridge

was maintained.

Fuel handling operations were performed in accordance with approved

licensee procedures.

. The proper refueling cavity water level was maintained.

. Chemistry sampling was performed at the frequency specified in the

TS.

During observation / review of the above activities, a problems was noted by.

the NRC inspector concerning containment integrity. 'During a tourfof the

control room on April 9, 1987, the NRC inspector noted that the-automatic

isolation valves'(HCV-438A and HCV-438C) inside containment for component

cooling water (CCW) supply and return for the' reactor coolant pumps were

inoperable. The valve control fuses-had been removed for maintenance.and

the valves were in the open position. The plant was in refueling

operations, but the automatic isolation valves (HCV-4388 and HCV-4380)

outside containment were not-closed.

TS 2.8 states, in part, that the following conditions shall be satisfied

during any refueling operations. TS 2.8(1) states, in part, that all

automatic containment isolation valves shall-be operable or at least one

valve in each line shall be' closed.

_ _ _ _

C

o.. .

15~

The licensee failed to meet the requirements of-TS 2.8(1) in that the CCW

automatic isolation Valves HCV-438A and HCV-438C were-inoperable, and

Valves HCV-438B and HCV-438D in each CCW line were not closed. This is an.

apparent violation. (285/8710-06)

.

Upon notification'of the apparent" problem by the NRC inspector, control'

room personnel shut Valves HCV-438B and HCV-4380. During followup by the

NRC inspector, it was determined that Valves HCV-4838 and HCV-438D had

been danger tagged in the closed position on March 13, 1987. However,

during performance of a surveillance test on April 8,~1987, power was-

, momentarily lost on each DC bus. This loss of DC power caused

^

Valves HCV-4388 and HCV-4380 to automatically open. When power was

restored to the DC bus,'the valves did not automatically reclose. The

actions of the valves on loss of DC power conformed to the engineering-

design of the valve circuitry. Subsequent to the performance of the

surveillance test on the DC bus, control room personnel failed to note

that Valves HCV-438B and HCV-438D remained open. The valves were

subsequently found open by the NRC inspector.

During the previous inspection period, the licensee performed an off load

of all fuel assemblies. The off load was performed to check for leaking

fuel assemblies. During this inspection period, the licensee completed

the testing of the fuel assemblies. The testing indicated that two of the

fuel assemblies were leaking. The licensee provided a like-for-like

replacement of the leaking assemblies. The assemblies were returned to

the vessel. The NRC inspector observed transfer of the assemblies and

noted no other problems associated with the movement or handling of the

fuel.

13. Containment Local Leak Rate Testing

The NRC inspector performed this inspection -to verify, through observation

and records review, that the local leak rate test program for testing of

the containment isolation valves was being performed'in accordance with TS

requirements. The NRC inspector observed / reviewed the following' items.

-

. All containment isolation valves listed in the TS were tested in

accordance with the licensee's approved procedure.

l . Procedure ST-CONT-3, " Containment Isolation Valves Leakage Rate Test

- Type C," provided the appropriate instructions for testing of

penetrations.

!' . The test equipment used was in current calibration.

i

'.

. The pressure used for testing conformed to the pressure specified in

the TS.

l . Repairs were initiated for any penetrations discovered-to be leaking.

,

4

w '

. - , . ..

16-

. . Action was taken to verify that.the maximum allowable leakage rate

was not exceeded upon discovery of a leaking penetration.

,

.During. review of Procedure ST-CONT-3, the NRC inspector noted that the

, procedure failed to provide adequate instructions for the performance of.

'

leak rate testing of the containment isolation valves. The. instructions

were provided by using a one-line, test equipment connection diagram and

.providing a valve lineup on each diagram. The specific examples of the

inadequate instructions are provided below.

'

. The diagram for testing Valves HCV-500A and HCV-5008 (Penetration

M-20) indicated that the pressure source used for testing be

connected on the upstream side of Valve HCV-500B,-instead of

connecting the pressure source between the valves. By performing the

test as stated.in.the-instructions, the actual leak rate of the-

valves could not be. determined.

~

. The valve lineup shown on the diagram for testing Valves HCV-506A and

HCV-506B (Penetration M-8) was inadequate in that a vent path on each

side of the nonpressurized side of the valves was not established.

. Without a vent path, the actual leakage rate through the valves could

not be determined.

'

. Instructions =for testing of Valve HCV-2983 (Penetration M-22) did not

ensure that the piping on the side of the valve not pressurized by

the test wasn't pressurized during testing. If the pressure across

the. valve became equalized,'the test would not indicate the actual

valve leakige rate.

. The valve lineup on the diagram for 1esting Valves HCV-2604A and

<

HCV-2604B (Penetration M-43) stated Valve VD-374 should be opened for

the test; however, VD-374 did not exist.

i

'

. The valve lineup on the diagram for testing Valve HCV-746B was

incomplete as Valve VA-262 was not included. .

The instructions established by Procedure ST-CONT-3 were inadequate in

that the procedure did not provide instructions that would ensure that;the

i

actual leak rate of the valves was determined.

'

, During review by the NRC inspector,. it was established that the testing

for the valves listed above was not performed in accordance with the

instructions provided in the procedure. The technicians realized that the-

instructions were not accurate-and established an alternate method of

testing the valves in lieu of following the-instructions.

i

TS 5.8.1 states, in part, that written procedures shall be established,

implemented, and maintained that meet the minimum requirements of

j Regulatory' Guide 1.33.

!

h

1

~ . . . ~

. - , . _ - , _ - - . . ,..v ., . .-e .

... .

4

.'.. .

17-

Section 8.b of Regulatory Guide l.33 states, in part, that containment

local leak detection tests should be covered by written procedures.

Contrary to the above, the licensee failed to properly establish a

procedure for local leak detection tests in that-Procedure ST-CONT-3 did

not. provide adequate instructions for performance of-the local leak rate

testing. In addition, the licensee failed to properly implement the

instructions for local leak detection in that the . instructions provided in

Procedure ST-CONT-3 were.not followed by the technicians performing the.

work. This is an apparent violation. (285/8710-07)

In review of-the performance of leak rate tests, the NRC inspector

determined that the licensee performed the leak rate testing during the

1985 refueling outage using the same instructions-in Procedure ST-CONT-3.

No action had been taken by the licensee to correct the. inadequate

instructions at that time or during the current refueling outage. The

licensee has not established a policy or procedure that requires procedure

adherence. In response to this violation, the licensee should address-the

lack of having a procedure that addresses the need for verbatim compliance

when performing safety-related activities.

2'

Upon notification by the NRC inspector of the inadequate instructions in

Procedure ST-CONT-3, the licensee issued a procedure change. The basis of.

j the-changes made to the procedure was to reflect how the tests were

actually performed by the technicians.

The licensee had not cumpleted the Type B and C tests for all penetrations

at the end of this inspection period. For this reason, this portion of

! this inspection will be continued into the next inspection p'eriod.

14. Licensed Operator Initial Training

The NRC inspector reviewed the initial licensed operator training program

to verify that the program being implemented by the licensee complied with

~

the licensee's NRC-approved training-program and 10 CFR Part 55. During

performance of this review, the NRC inspector verified that the following-

program elements were properly implemented by the licensee.-

. Required lectures by the licensee's NRC-approved training program

were attended.

. Simulator training center certification of training was completed.

. Required time onshift was performed.

. Records were maintained by the training department to document

participation by each licensing candidate in the above activities.

No violations or deviations were identified. This portion of the

inspection has been completed.

1

--. . - - -- _ _ .. - . - . . . _ - . . , . . _ . . - - _ _ _.

. . . .

18

15. Licensed Operator Requalification Program

The NRC inspector reviewed the licensed operator requalification program

to verify that the program being. implemented by the licensee complied with

the licensee's NRC-approved training program and 10 CFR Part 55. During

performance of this review, the NRC inspector verified that the following

program elements were implemented by the licensee.

. Preplanned lectures required by the licensee's NRC-approved training

program were given to the operating staff in each 2 year

requalification program.

. Documentation was available to indicate that staff supervision

personnel (licensed individuals not assigned to an operations crew)

reviewed facility design changes, procedure changes, facility license

changes, and abnormal and emergency operating procedures.

All licensed individuals who failed the annual written examination

were placed in an accelerated requalification program.

All licensed individuals who scored low in any particular category

were required to attend appropriate lectures.

All licensed individuals received on-the-job training as specified by

the licensee's NRC-approved training program.

. Each licensed operator completed an annual requalification

examination prepared by the licensee.

Records were maintained by the training department to document

participation by each licensed operator in the above activities.

The NRC inspector also reviewed the training program presently used by the x

licensee against the training program originally appewed by the NRC.

This review was performed to verify that revisions made by the licensee to

the NRC-approved program had not lessened the requirements of the program.

No instances were noted where the program had been degraded.

During review of the results of the annual written examinations given in

1986, the NRC inspector noted that a senior reactor operator (SRO) had

failed to pass the examination given on December 11, 1986. The SR0's

overall score on the examination was 73.9 percent. Due to the low score,

the SRO should have been placed in accelerated requalification training,

but was not. At the time of the examination, the SR0 was in training for

preparation to take an NRC-administered written and walk-through

examinations. Licensee personnel stated that the training given in

preparation for the NRC-administered examination was equivalent to-the

training the SRO would have received in the accelerated training program.

In March 1987, the SRO was given a walk-through examination by an NRC

licensing examiner and successfully passed the examination. Shortly

e...

19

thereafter, the SR0 was returned to the operating shift in the capacity of

a licensed operator. The licensee had not given the SR0 another written

examination prior to returning the SRO to licensed-operator duties. The

SR0 was onshift for approximately 2 weeks before being removed and placed

back in a training status. The SR0 was returned to training to prepare

for the NRC written examination to be given in June 1987.

Section 4.a of Appendix A to 10 CFR Part 55 requires, in part, that the

requalification program include an annual written examination which

determine areas in which retraining is needed to upgrade licensed senior

operator knowledge.

'

Section 9.a. of the licensee's NRC-approved training program (Appendix B

of the licensee's Training Manual) requires, in part, that an annual

written examination be conducted and failure of this examination (overall

grade of less than 80 percent) requires the individual be placed in an

accelerated requalification program. The NRC-approved training program

also requires that an individual failing the annual written examination be

removed from licensed duties during the period of accelerated training.

The failure of the licensee to remove the SRO from licensed duties during

the period of training is a potential violation which will be considered

an unresolved item. (285/8710-08)

Licensee personnel stated in discussions regarding this unresolved item

that the SRO should not have been allowed to resume licensed duties until

the SRO had been reexamined to determine that the SR0 had an adequate

knowledge level. Licensee personnel also stated that the SR0 was allowed

to return to licensed duties due to an oversight on their part.

The NRC inspector reviewed the licensee's actions related to' corrective

measures taken on the unresolved items identified in the previous review

of the requalification program performed by the NRC in August 1986. The

results of the review is provided in paragraph 2 of this inspection

report.

The NRC inspector did not complete the inspection in this area during this

inspection period. This portion of this inspection will be continued into

the next inspection period.

No violations or deviations were identified.

16. Unresolved Items

An unresolved item is a matter about which more information is required in

order to determine whether it is acceptable, a violation, or a deviation.

Three unresolved items are discussed in paragraph 7 and one unresolved

item is discussed in paragraph 15.

_-. _

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20

Item Paragraph Subject

285/8710-03 7 Performance of a surveillance

test without up-to-date data

285/8710-04 7 Verification that TSP will

perform its intended safety

function

285/8710-05 7 Discrepancy between the TS and

USAR related to the quantity of

TSP required to be stored in

containment

285/8710-08 15 Operator performed licensed

duties while in an accelerated

requalification status

17. Meetings

During this inspection period, two meetings were held with licensee

personnel. On April 6, 1987, a meeting was held in the Region IV office

at the licensee's request to discuss plant design basis documentation.

Attendees included licensee representatives, Region IV management

personnel, the NRR project manager, the senior resident inspector, and a

representative of IE Headquarters.

The second meeting was held on April 15, 1987, at the licensee's emergency

offsite facility to discuss core damage estimates. Attendees at the

meeting included licensee representatives, Region IV management, the

Region IV emergency planning specialist, the senior resident inspector,

and representatives from the states of Iowa and Nebraska.

18. Exit Interview

The NRC inspector met with Mr. 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.