ML20153D618

Insp Rept 50-285/86-02 on 860101-31.Violation Noted:Failure to Follow Procedure Requirements for Insp of U Hexafluoride Storage Cylinders

ML20153D618
Person / Time
Site:	Fort Calhoun
Issue date:	02/11/1986
From:	Harrell P, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153D584	List: ML20153D580 ML20153D592 ML20153D618
References
50-285-86-02, 50-285-86-2, IEB-79-01B, IEB-79-1B, NUDOCS 8602240201
Download: ML20153D618 (19)

See also: IR 05000285/1986002

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/86-02 License: DPR-40

Docket: '50-285 *

. Licensee: Omaha Public Power District

1623 Harney Street

Omaha, Nebraska 68102

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Facility Name: Fort Calhoun Station

Inspection At: Fort Calhoun Station, Blair, Nebraska

Inspection Conducted: January 1-31, 1986

Inspector:

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P. }, 'Sen'iTr Ifesident Reactor Date

Approved: h .2,////84

D. M. Hunnicutt, Chief, Project Section B, _ Date '

Reactor Project Branch-

Inspection Summary

Inspection Conducted January 1-31,1986~(Report 50-285/86-02)

Areas Inspected: Routine, unannounced inspection including operational safety

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

walkdowns, followup on IE Bulletin 79-01B, followup on a. regional request for

review of uranium hexafluoride cylinder storage,, followup on a 10 CFR Part 21

report on Limitorque valves, followup on previously, identified items, cold

weather preparatic is, and plant startup from refueling.

The inspection involved 96 inspector-hours-(including 15 backshift hours)

onsite by one NRC inspector.

P.esults: Within the 11 areas inspected, one violation (failure to follow

procedure requirements for inspection of uranium hexafluoride storage cylinders,

paragraph 5) was identified.

8602240201 86021B ~

PDR ADOCK 05000285

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DETAILS

1; Persons Contacted

1. • W. Gates, Plant Manager

~A.~ Cattano, Quality Assurance Inspector

M. Core, Maintenance Supervisor

D. Dale, Quality Control Inspector

1. J. Fisicaro, Nuclear Regulatory'and Industry. Affairs Supervisor

J. Foley, I&C and Electrical Field Maintenance Supervisor

R. Jaworski, Technical Services Section Manager

R. Johansen,' Test Engineer

M. Kallman, Security Supervisor

L. Kusek, Operations Supervisor

1. T. McIvor, Technical Supervisor

R..Mehaffey, I&C and Electrical Technical Services Supervisor

1. R. Mueller, Plant Engineer

C. Norris,' Radiological Services Supervisor

T. Patterson, Technical Support Manager

G. Roach, Chemical and Radiation Protection Supervisor

J. Tesarek, Reactor Engineer

S. Willrett, Administration Services and Security Supervisor

• Denotes attendance at the monthly exit interview.

1. Denotes attendance at the exit interview held on January 14, 1986, for

the electrical equipment qualification portion of this inspection.

. The inspector also contacted other plant personnel, including operators,

technicians, and administrative personnel.

2. Followup on Previously Ideni.ified Items

(Closed) Unresolved Item 285/8117-01: Review of repeat radiography for

auxiliary feedwater welds.

An NRC inspector reviewed the repeat radiographs for welds in

the auxiliary feedwater system. The review found that the-

radiographs were satisfactory. For details of the reinspection

of the radiographs, see NRC Inspection Report 50-285/81-31.

(Closed) Unresolved Item 285/8410-04: Lubrication periodicity

requirements for the hydrogen monitors.

The licensee has reviewed the manufacturer's recommendations {

regarding lubrication of the hydrogen monitors. Based on this -l

review, the licensee has changed Procedure MP-H2-1, " Post LOCA

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. Cont' a inment Hydrogen Monitoring l System Sample Pump Motor, Lubri-

, cation," to require a 3 year interval. instead of.a-5 year:

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interval. The. licensee lubricated the' sample pump motors;ini

January '1986. <

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'The NRC inspector reviewed this procedure'along'withiothern

procedure's for lubrication; requirements. The'detailslof.theT

. > review are provided in paragraph 4 of this~ report.- ,

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(Closed) Unresolved Item 285/8509-01:- . Equipment qualification? -

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maintenance program. 7

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l .The licensee has completed _the appropriate documentations . . s

, reviews and performed the required maintenance' activities'. ESee:

' paragraph 4 for a detailed discussion of;this item.- y

(Closed)~ Unresolved Item 285/8509-02: --Postaccident. monitoring instrument' '

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accuracy.

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The licensee has performed an-analysis' to . verify lthat the; . i

l postaccident monitoring' instrumentation-accuracy is adequate.

A detailed discussionTof this item is provided in. paragraph 4. .

(Closed)- Unresolved Item 285/8509-04i Replacement of' States 1 Company

terminal blocks.  :

The licensee has replaced the unqualified States Company terminal.. l

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blocks with nuclear qualified. Raychem splice-kits. ~ The details ~ l

of this item are provided in paragraph 4.

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! (Closed) ' Unresolved Item 285/8509-05: Aging analysis of Rockbestos'

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!~ Pyrotol III cable.  :

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l The licensee had completed the aging' analysis for.the cable. '

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This item is discussed in. detail in paragraph 4.

'(Closed) Severity Level-IV' Violation 285/8515-02: - Combustible material'  ;

stored inside the. uranium hexafluoride (UF6) storage area.  ;;

The NRC. inspector- toured' the UF6- storage area to verify that no .

t combustible materials were stored inside the area.and'no-

! flammable material was stored within 100 feet of the area.

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The"NRC inspector noted no flammable or combustible materialfin  ;

the area. The licensee has placed signs;on'all four. sides ofi

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the UF6 storage area to warn personnel that combustible materials

o are not to be stored within the area and- no flammable liquids- are: 't

. to be stored within 100 feet of the fenced area.

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< 3' . . Licensee Event Report (LER) Followup

Through direct observation, discussio'ns,with' licensee l personnel,'and; .. '

U review ofirecords, the following' event reports were~ reviewed to. determine

ll 'that reportability-requirements were fulfilled, immediate corrective' action-

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was. accomplished, and corrective action to prevent recurrence has been

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accomplished'in accordance with Technical Specifications. ,

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L~ The.'LERs listed below were reviewed and are considered closed. Allthel

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LERs reported an initiation of'the ventilation isolation actuation system'

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h 84-005 84-018

84-006 84-024-

!~ 84-007- 85-004

,84-014 85-005

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! LER 84-005 reported 14 unplanned actuations of the VIAS between: .

i January 1 and May 2, 1984. The LER was submitted bcsed on the LER rule 1

changes that became effective on January 1, 1984._-The rule changes

L required that actuation'of any engineered safeguards ~ features equipment

j- be reported by an LER. Of the 14 actuations. identified, ncne1were due to'

i an actual release problem. Each actuation was due to a spurious't.ip. -

I LERs84-006, 84-014, and:84-018 reported the' initiation of-the VIAS.during

1 the replacement of-an iodine-collector cartridge in. radiation monitor RM-_060.-

In each case, the chemistry technicians-failed to;n'tify o the control; room ~ ,

operator prior to cartridge replacement so:the operator could take RM-060-

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out-of-service. The VIAS initiation was due to background radiation

exposure to the RM-060 detector. A check wassperformed to verify the

, iodine accumulation and gaseous contamination concentrations were less than

minimum detectable. To prevent recurrence, the' licensee has issued a

! revision.to Procedure OI-RM-1, " Radiation ~ Monitors - Normal and Accident

Operations," to require that RM-060 be taken out-of-service during

i cartridge changeout. The licensee has subsequently performed filter.

changeouts without initiation of the VIAS ~ ,

! LER 84-007 reported the initiation of-the VIAS due to high containment-

l airborne' activity.resulting from lifting of the reactor coolant ~ drain tank.

j; relief valve. The relief valve lifted as a result of back leakage past one

or more of the reactor coolant system / safety injection system interface

- check valves while increasing reactor coolant-system (RCS) pressure. No '

_ radioactive-release to the environment occurred. To prevent. recurrence,

i the licensee has ~ issued a revision to Procedure 0I-RC-28, Reactor Coolant f

1. Vent and Leak Test Instructions," to provide additional instructions to the~ '

t operator about minimizing the interface check 1 valve leakage during RCS .

pressurization. The licensee recently. pressurized the RCS at the end of a

j refueling outage and did not experience a similar problem.

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f -LERs 84-0'24,- 85-004, and 85-005 reported VIAS initiations due td operator.,

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1 error. ': Whenever. a'setpoint change or calibration verification activity

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i ;is performed, the operator should depress and hold the reset' buttoni to

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' prevent VIAS actuation.; In these cases, the operator either failed to-

depress the reset ~ button.or released the button _before the alarm setpoint ,

' cleared. To~ prevent recurrence, the. licensee has discussed the importance- -

of proper use of the reset button during. calibration and setpoint adjust- a

ment with the I&C technicians and the operators. The licensee has also =

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issued a revision to Procedure 01-RM-1 to provide / clarification for the >-

radiation' monitor operating instructions.. No VIAS initiations dae to reset

button operation have occurred recently.

No violations or deviations were identified. < t

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' 4. Followup on IE Bulletin * >-

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IE Bulletin 79-01B, " Environmental Qualifications ofiClass.1E Equipment,"[ i

required each licensee to perform a detailed review of the environmental

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. qualification of Class 1E; electrical equipment. The licensee was to- .

fperform this review to verify that the~ equipment will. function'under

postulated accident conditions. The results of the review were submitted

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by OPPD to the NRC. .

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A special team inspection was performed at the licehsee's facilities on~

3 April 29-May'3,-1985, to verify ~ that the licensee had implemented an

electrical equipment qualification (EEQ) program that complies with

10 CFR Part 50.49, the licensee's response to IE Bulletin 79-01B, and

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implementation of deficiencies 91dentified in the. Safety Evaluation Report

itsued by NRR. .The results of the inspection are discussed in-NRC

ILspection Report'50-285/85-09. '

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.During this special inspection, six potential enforcement / unresolved

. items and two open items were. identified. Region IV personnel performed. '  ;

a followup inspection on November:18-22,1985, to verify the items '

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. ,s identified in NRC-Inspection Report 50-285/85-09 had been satisfactorily -

completed. The details of the followup inspection are provided in NRC

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In~spection Report 50-285/85-26.

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4 During .ths followup inspection, it was noted that the licensee-had failed

to fully implement corrective actions for four of the eight discrepancies

' ;^7 , noted in NRC Inspection Report 50-285/85-09. Based on this failure to ' + s -

fully-implement corrective actions for the noted discrepancies', a. manage-; , J

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^~ ment meeting was held between Region IV and-0 PPD personnel .on December 13,- ~

1985.- The purpose of the' meeting was- to discuss what correctivefactions

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were to be.taken by 0 PPD to correct the discrepancies noted in.the; .. ' - -

Region-IV followup inspectionc: Based on this meeting, Region IV issued'a-

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Confirmatory Action' Letter (CAL), dated December 20, 1985, to document .'

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the commitmentsimade by_OPPD management to Region IV management. T _

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' bhe" CAL contained four items that required followup. :The following

idiscussion provides the. details of the followup and closecut of the four

items.

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al Equipment qualification of motors. ,

(Unresolved Item 285/8509-01)-

(1) The licensee was to verify that che_ ventilation grills for the

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Allis-Chalmers component cooling water.(CCW) pump motors __were;

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in place.'and secure, and procedures-have been issued to require'.

. a frequency of~3 months for-intake grill inspection and, ' ,

maintenance.

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The licensee has issued a preventive maintenance:(PM) card toi >

require a quarterly inspection of the grills. .The_PM card-

requires that;the grills be inspected and cleaned'on.all three '

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of the CCW pumps. The licen'see '.ompleted the requirements:of

the PM card on January 6, 1986.

The NRC inspector reviewed the completed PM card to_ verify.the

requirements for inspection ~ har been completed.and that~the.

specified frequency was quarterly. .The inspector also' inspected.

the grills on the three CCW pumps to verify the-grills were clean. .

.and securely in place. No. problems were noted.

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(2). The licensee was also req'uired to' review maintenance' procedures i

for all other EEQ motors and to_ verify the procedures were t

adequate and implemented. If found inadequate, the licensee-

was required to perform the necessary maintenance. -

The licensee obtained an independent third party review of the

manufacturer's maintenance requirements and the licensee's

maintenance procedures from Sargent and Lundy (S&L). . The review

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was performed _to-verify.that the procedures included the

appropriate maintenance activities specified by the manufacturer

and requirements provided in the EEQ package for maintaining-

equipment in'a qualified status. .The results of1the review are

provided below:

. The review found that the-maintenance procedure used for

the safety injection pump motors (i.e., high pressure, '

low pressure, and containment' spray) was adequate. 'However,

S&L-recommended that the-instructions for draining of the-

oil be included in the procedure instead of.a reference made

to the manufacturer's instructions.. S&L-also recommended

-that the procedure be changed to include"an inspection of2

the motor leads and splices for cracks, discoloration, and

other signs of physical damage. .Although not required by

the current procedure, the licensee performed an inspection-

and.resplicing of the motor leads during the:1984 refueling

outage.

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The licensee.has agreed to include both-recommendations in

the maintenance procedure during a future revision. This -

is an open item pending completion of-the procedure revision

for inclusion of the recommendations. (285/8602-01)

- The NRC inspector reviewed Procedure MP-EE-8, "GE 8000

Series Horizontal Induction Motors," . Revision 2, and noted

that all the' required maintenance recommendations were

included. The inspector also reviewed completed PM documen -

tation and verified that-the required maintenance had been

completed at the proper frequency. No problems were.noted

during the review.

. The'S&L review determined that the motor bearings for the.

containment vent fan motors should be lubricated every.

2 years with Aeroshell No. 5 or Chevron BRB No. 2. The

licensee currently lubricates the motors every 6 months

using Chevron SRI No. 2. The licensee has.obtained a letter

from the grease manufacturer stating that Chevron SRI No. 2

is equal to or better than Chevron BRB No. 2 based on

lubrication requirements for the motor.- The letter also

stated that the. Chevron SRI No. 2 will provide adequate-

postaccident lubrication.

S&L also recommended that the motor bearings be changed out

every 100,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of continuous operation. The licensee

estimates that the 100,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operation would end in

approximately 1995. The licencee stated this recommendation

would be added to the appropriate documentation in the near

future. This is an open item pending revision of the

documentation to include the recommendation. (285/8602-02)

. The NRC inspector reviewed Procedure PM-EE-12,'" Vent Air

Fan Motors VA-3A, 3B, 7C, 70, 2A, 2B, 12A, and 12B,"

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Revision 2, and verified that the procedure contains the l

manufacturer's recommended maintenance activities.- The I

inspector also verified that Procedure PM-EE-12:has been l

performed at the required-frequency. No problems were l

noted.

. S&L recommendations for the hydrogen iconitors (VA-81A and

VA-818) were reviewed against the current procedure

requirements. No changes to the current procedures were

required based on the review.

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The NRC inspector reviewed Procedures MP-H2-1, " Post LOCA

Containment Hydrogen Monitoring System Sample Pump Motor

Lubrication," Revision 2; MP-H2-2, " Post LOCA Containment'

Hydrogen Monitoring System Terminal Strip and Hoke-Valve

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Refurbishment," Revision 0;' and MP-H2-3, " Post LOCA

Containment Hydrogen Monitoring System Sample, Pump. Rebuild,"

Revision 0. .No problems were noted.

The'NRC inspector also reviewed Procedure MP-VA-81, " Hydrogen

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Monitors," Revision 0, and noted that this maintenance

procedure allowed the use of.three different greases;

Chevron SRI No'. 2, Shell Oil Dolium R, and Texaco Premium RB. ,

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The only currently acceptable grease that can be used to _

maintain the equipment' qualified is Chevron SRI No. 2. The

licensee has agreed to, revise Procedure.MP-VA-81 to

eliminate the option of using the other two greases.to

prevent inadvertent use of unqualified material or establish

an equivalency with the grease manufacturers. The NRC; .

inspector also noted that Procedure MP-VA-81 required that:

, the craftsperson use 0.75 cubic inches of grease when ,

lubricating the motor. The manufacturer recommends that a

volume of 1.0 cubic inches be used. This is an open item

pending revision of-the procedure to provide the correct

grease type and volume. (285/8602-03)

The NRC inspector reviewed documentation to. verify that

, maintenance had been performed and was done at the required

frequency. The inspector noted, during a review of

Procedure MP-H2-1, that the procedure was' changed on

April 30, 1985, to require a lubrication frequency of every

3 years. The procedure previously stated that the frequency-

was 5 years. The motors should have been lubricated when

the procedure change was completed because the 3 year period

had already expired. The licensee inadvertently overlooked

the requirement and did not grease the motors _until

January 1986. No other problems were noted.-

b. Accuracy of the postaccident monitoring (PAM) instrumentation.

(Unresolved Item 285/8509-02)

(1) The licensee was required to determine the loop uncertainties

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associated with the PAM instrumentation.

The licensee has completed this effort using an independent

third party verified methodology that establishes the uncertainty

for each instrument loop. The methodology esed included the

uncertainty associated with the sensor, indicator,'and allowable

calibration error stated in the calibration procedure. The

results of the review are documented in Operations Support

Analysis Report (0SAR) 85-94.

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The NRC inspector reviewed the methodology used and the results

obtained from the calculations. No problems were noted.

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(2) The licensee was require'd to compare the established

uncertainties,with the uncertainties allowed by the recently.

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published emergency operating procedures-(EOP). _

The licensee determined which instrumentation loop affected the

action statements contained in each E0P. From this determina-

tion',.a comparison was made between the established loop-

uncertainties and the parameters monitored in the E0P. Based on' ,

a comparison of.what is required by 'the E0P and what is provided

- by the instrumentation loop, no instances were noted where.the.

established uncertainty would not provide the instrument accuracy

, required by the E0Ps. The results of the applied comparisons are

provided in OSAR 86-1.

The NRC inspector reviewed the appropriate documentation and

noted no problems with the method used and.the results obtained.

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(3) The licensee was. required to revise Table 1 of the EEQ manual

to include the values of the uncertainties of instrumentation

loops obtained in paragraph b.(1) above.

The licensee has completed the table,.but has not formal'ly.

issued the table to be included in the EEQ manual. The_ licensee

stated that the EEQ manual would be updated in the near future.

This is an open item pending formal issuance of the-table to be

included in the EEQ manual. (285/8602-04)

The NRC inspector reviewed the completed table and noted no

problems.

l (4) The licensee was required to review calibration procedures for

j adequacy based on the results of the PAM instrument loop-

. uncertainties.

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The licensee included -the value'of the calibration procedure

a - uncertainty in the calculation for the overall loop uncertainty

as discussed in paragraph b.(1).above._.Therefore, the

uncertainty values used for comparison to the E0P requirements

included the uncertainty allowed by the calibration procedure.

As stated above, the NRC inspector noted no problemc.

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c. Replacement of States Company terminal blocks. - (Unresolved

Item 285/8509-04)-

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(1) :The licensee was required to'. replace' terminal blocks associated

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I ' : with the eight transmitter circuits;with nuclear qualified 1

Raychem splices.

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The eight transmitter circuits referred to in the CAL were

identified in the licensee's response, dated October 11, 1985, to

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i Report 285/85-09. The instruments were PT-103X, PT-103Y,- FT-313,.

FT-316, FT-319,- and FT-322. In the NRC followup inspection

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, performed November ~18-22,-1985,- the region-based. inspector.also

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-identified in Report 285/85-26 that two of the four P_T-102'

instrument' circuits contained. terminal blocks that required

replacement. The terminal block locations listed above were '

identified by the_use of_plantidrawings.

The licensee performed a walkdown of-instrumentation circuits

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to verify which circuits contained terminal. blocks. As'a result-

1 of the walkdown,,the licensee identified eight-transmitter

t circuits with terminal _ blocks. The eight identified by the . .

licensee were.not the same that had been previously' identified-by_

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the use of plant drawings. The eight.'. instrument circuits were

FT-313, FT-319, FT-322, FT-332, FT-334,.LT-101Y, PT-115, and.

, C/PT-902. Due to the difference between the plant drawings a'nd

! the actual as-built circuit configuration, the. licensee stated

, that the appropriate drawings would_be revised in the near future-

p to correctly indicate whether or not a terminal block is located -

in the circuit. :This item will. remain open pending revision of

the affected drawings. (285/8602-05).

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The licensee has reviewed all instrumentation circuits and'has-  !

j installed qualified Raychem splices to_ eliminate the terminal

[ blocks, as appropriate. .The block replacement activities were

performed in accordance with MR-FC-85-177.

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i The NRC inspector reviewed MR-FC-85-177 and other. associated

, documentation to verify that splices had beenfinstalled as needed. '

r1 No problems were noted with the actions:taken by the licensee.

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(2) The licensee.was required.to, identify areas whereLthe RTV:

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barrier on terminal blocks had been damaged and to repair any-

damaged barriers using a special process procedure.-

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The licensee inspected all.the-appropriate terminal-blocks-to

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determine which blocks required repair. :The blocks requiring

l _ repair were repaired in accordance with a plant review committee-

approved procedure attached to-Maintenance Order (MO),857481.

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-The NRC inspector reviewed the M0 and attached. documentation. .

L No problems were noted. The: inspector did note that:the licensee

had not.taken any action to ensure that'the RTV seal:is replaced.

if disturbed during future maintenance or modification workJ

ThisLitem will remain open pending a change to the appropriate

procedure to include an RTV repair-requirement.= (285/8602-06)-

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d. Rockbestos Pyrotrol III cable qualification. ~(Unresolved

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Item 285/8509-05)

-The licensee'was required to formalize aging analysesIfor heat rise

I factors for the cables to the vent fan motors.and include' the analyses

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in the EEQ file. -

The licensee has. performed an analyses on the:Rockbestos cable. .The <

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analyses indicate that the cable.is qualified.for the-life of.the

plant when the heat rise factors.are included. .The analyses were

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independently reviewed by-S&L and determined to'be adequate.1The

results of the aging analyses are documented in OSAR 85-93.

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The'NRC inspector reviewed the analyses. No problems were noted.

Although there has been six new open items identified during this, . -

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inspection, the items do not affect the current-qualification of the.

equipment. The open items designate' actions that_sust be completed by-the'

. licensee to ensure that all the supporting. documentation has~been completed

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{ and actions to ensure that the equipment remains qualified in the future

j have been taken.

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! Based on the-documentation reviewed and discussions with plant and

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engineering personnel, it appears that the~ equipment-has been satisfac--

t torily qualified for service in harsh environments. IE Bulletin 79-01B is-

considered closed.

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No violations or deviations were identified.

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5. Followup on a Regional Request'

Based on a request from Region IV,.the 'NRC inspector reviewed the

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l licensee's activities associated with the onsite' storage of UF6.

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! The UF6 cylinders were received in October 1982,'and stored in a remote,. '

L onsite location approximately 700 feet, west northwest of the plant

control room. The cylinders are located inside a locked,-fenced storage- ,

area. _ -The storage ' area contains 52 cylinders, each containing'approxi -

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, .mately 21,000 pounds of UF6. The area is, appropriately marked with limited

access'and radiological control signs. Access to the area is controlled by

E site: security personnel. No other materials are stored or other activities.

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. performed within 100. feet of the UF6: storage area.

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-12-

The requirements for storage and maintenance of theUF6 cylinders are

provided in Materials License SMC-1420, issued September 3, 1982. The

NRC inspector reviewed the license requirements to determine what_ actions

- are required to be performed by the licensee. After-determination of the

license requirements,.the NRC inspector reviewed the licensee's procedures

, to verify that the requirements have been implemented. The procedures

reviewed included Special Procedure SP-UF6-1,." Uranium Hexafluoride Storage

Cylinder External Visual Inspection," ' Revision 1; Abnormal ' Operating'

Procedure A0P-28,' " Uranium Hexafluoride Incident," Revision 5; and Security

Procedure SCP-14, '.' Patrol Procedures," Revision 5. Based on the review of

the above procedures, it appears that the licensee has implemented the

requirements contained in the materials license.

The NRC inspector reviewed licensee documentation and performed area ' walk

throughs' to verify that the licensee is performing the requirements stated

in Procedures.SP-UF6-1, AOP-28, and SCP-14. The NRC inspector performed

the following:

. Toured the storage area and verified no combustibles were stored

inside the area, no flammable liquids were stored within 100 feet of

, the area, and no vegetation was growing in the area. -

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. Inventoried the UF6 emergency kit to verify the kit contained all

the items required by the materials license (i.e., rubber gloves,.

head covering, wooden pegs, an extra fill valve, blanket, and a

self-contained breathing apparatus),

i . Reviewed Detex clock records for the Detex clock station located at

. the storage area gate to verify security personnel observed the area

at least once per shift.

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. Verified that a ' walk-through' inspection had been performed every

i 6 months and that noted abnormalities were corrected.

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. Verified that radiation surveys of the area were performed at least

biennially and that records of the surveys had been retained.

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. . Verified that a detailed cylinder inspection had been performed

biennially and that records of the inspection had been retained.

Verified that cylinder inspection data sheets had been completed for

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the inspection performed biennially.

. Verified that a procedure had been issued for emergency response to

a cylinder rupture accident.

. . Verified that training had been given to station personnel required

to respond to a UF6 cylinder leak,

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"The NRC inspector' found' all of the above items to 'be:s'atisfactory, except

for the items' listed below:

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. The NRC. inspector requested.to see documentation of the' results ofE

the 6-monthe ' walk-through' inspections. The licens'ee could not.

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j; find documentation to indicate that the 6-month inspection,due in;

. April 1985,_had been. performed. LThe licensee discussed the inspection

I- with licensee personnel involved:in.UF6 inspection activities and. '

l could not locate an individual that had performed the_ inspection. ,

Based on the. lack of documentation and the inability to locate an

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F individual that may have performed _the inspection, it: appears the~

6-month inspection was not performed. This-is an apparent violation.

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.- . During a review of.the documentation for the 6-month, ' walk-through'

j inspection performed in October 1985,1the NRC' inspector noted that the 4

a completed procedure stated _that the individual performing the inspec-

l' tion had not entered the fenced storage area to perform the

rs l' walk-through' inspection. The 6-monthLinspection requires, in part,'

that the cylinders be checked for new gouges, dents,-or cracks in the

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walls, heads, skirts, and stiffening' rings, and _that the.end plug lead -

-seal wires are intact. Based on a review of the area by the NRC 3

[ inspector, Ji.t is apparent _ that all cylinders cannot be checked for -

! the above conditions without entering the storage area. The.NRC,

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inspector also.noted that the completed procedure was reviewed and'

approved by the same: individual that performed the inspection. The

failure to perform'all the-steps required by a procedure isfan

t apparent violation. -

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i . The NRC-inspector reviewed the biennial. inspection documentatio'n for *

i. the'in'spection performed in October 1982. During this review, the

! NRC inspector noted that the procedure had not been. completed,.but

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referenced a surveillance plan completed by quality' assurance (QA).

The NRC inspector reviewed the QA.sttrveillance plan-and noted that it1

was not obvious that the plan included all the attributes required by

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j the biennial inspection procedure because the plan was in a checklist

1: form instead of the step-by-step instruction form used by the proce -

l dure. The NRC inspector discussed exactly which steps in the inspec-

t tion procedure had been completed with the QA' inspector.that performed' .

l the surveillance. . Through discussions with the individual,:the NRC.

- inspectorLestablished that all inspection requirements had been' ,

0 performed except the QA inspector did not-inspect the valve ports for

[ possible plugging with UF6 or. contamination from other' uranium salts

or foreign material, nor did.the-QA inspector complete the inspection

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data sheets for each cylinder. This is an apparent violation.

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. The three discussions provided above are examples of i failure to-

follow procedures and constitute an apparent violation. (285/8602-07)

. Based on the results of the documentation review performed by the NRC

inspector, the licensee decided to perform a detailed inspection of the

cylinders and the storage area in accordance with the requirements provided

in Procedure SP-UF6-1 for a biennial review. The inspection was performed

on January 15 and 17,1986. The NRC inspector accompanied licensee

personnel on the inspection to observe the inspection performance and to

inspect the cylinders. During the inspection, the licensee found three

discrepancies. The three items are discussed below:

. . Each cylinder is supported.by three cradles constructed from railroad

ties to prevent the cylinder from touching the ground. On one of the-

cylinders, one of the railroad ties supporting one end of the cylinder

has decayed and is being crushed by the weight of the cylinder. The-

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cylinder is not yet touching the ground. The licensee has issued a

maintenance order (MO) to replace the decayed railroad tie. This item

remains open pending replacement of the tie. (285/8602-08)

. The acceptance criteria for the cylinders states that the threaded

plug on one end of the cylinder should have at least one but not more

than five threads showing. The plug on one cylinder _had six threads

showing. The licensee contacted the vendor and the vendor stated that

a plug with six threads showing was acceptable.

. Dead vegetation in the storage area was beginning to accumulate and

will need to be removed in the near future. The licensee has issued

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an M0 for removal of the vegetation. This item will remain open

pending removal of the vegetation in and around the. storage area.

(285/8602-09)

Although various discrepancies were noted during this inspection, it does

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not appear that any of the discrepancies affect the structural integrity

of any cylinder, nor do the discrepancies pose any potential hazards to the

health and safety of the public that have not been previously addressed in

the Safety Evaluation Report issued by NRR.

6. Followup on a 10 CFR Part 21 Report

In December 1985, Commonwealth Edison submitted a 10 CFR Part 21 report to

the NRC regarding the electrical equipment qualification of the internal

wiring.for Limitorque valves. The problem concerned inadequate documenta-

tion of the qualification of wiring for the valve torque and limit switches.

Without the proper documentation, it could not be substantiated that the

-valves were qualified for operation in a harsh environment. Regio 1 IV

management notifiet the licensee-of the Part 21 report on December 24, 1985.

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The-licensee immediately started a review of all Limitorque valves in the

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j plant to determine which ones would beTaffected by the identified. _.

.. . discrepancy. Out of the total 'of 33 Limitorque valves installed inL the . .

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plant,'the licensee identifled.28 that'were required to' operate in a harshE

, , environment. . The licensee issued Procedure MR-FC-85-220 to provide- _.1

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instructions for. the inspection and replacement, as . appropriate, Lof all

internal wiring in the Limitorque valves,

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4 The licensee-inspected thelvalve wiring.to determine which. wires were not:

e ,. - considered qualified. The determination of qualification was based on

being able to . identify the source oflthe' wire used.. If.the wire was

! labeled Raycheci Flantrol or Rockbestos Firewall, it was considered l qual.i-

i fled. If the. wire had no label or was made~by.a different manufacturer,.

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the wire was replaced. ,

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j The licensee completed the inspection.and replacement of wiring in all  ;

E 28 Limitorque valves prior to exceeding 2 percent-power. In one.of the-

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valves', the licensee replaced the motor leads as it could not be determined- [

i that the installed wiring was qualified. The licensee inspected _the wiring -!

that was replaced and noted no problems that would have caused the valve. =t

j not to operate in an accident condition. 'The-wiring contained no cracks,

j breaks, discoloration, or other physical damage.

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j The NRC inspector reviewed the completed procedure and also observed thei.

inspection and replacement of wiring in a valve. [

No violations or deviations were identified. ,

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l 7. Cold Weather Preparations

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During plant tours, the NRC inspector observed plant systems susceptible *

i to extreme cold weather to verify the systems were operating properly.  :

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j The licensee has had problems in the past with'.the condensate storage tank'

F indication freezing up. : Additional _ heat tracing was provided and no .

! . additional problems have occurred. .The licensee has also'had problems with

the sprinkler piping in the emergency diesel generator room freezing. The:

licensee has made modifications and has not experienced additional problems.

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[ The NRC inspector did not identify any problems from the effects of.the  ;

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cold weather on any safety-related systems.

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No violations or deviations'were identified. .

!- 8. Plant'Startup from Refueling

The NRC inspector reviewed and observed licensee activities associated [

with plant'startup from a refueling outage that commenced on

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l September 27,1985. : During this. review,- the NRC inspector:

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Reviewed completed procedures for core' physics tests ~

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with approyed procedures and regulatory requirements.- P'

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No violations or deviations were identified. >

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9. Operational Safety Verification

The NRC inspector conducted the rev'fews and obserystions described below-

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-to verify that facility operations were performed.in conformance with'the-

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requirements established- under 10 CFR, administrative procedures, and tip ^

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Technical Specifications. - The NRC inspector made several: control room [ *

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observations to verify:,

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. Proper. shift manning

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Operability of reactor protective system and engineered safeguards

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

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switch positions complied with the appropriate. requirements <

f . Proper return to service of components )

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. Appropriate conduct of control room and other licensed operators ,

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No violations or deviations were noted. -e s .'

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10. Plant Tours

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l The NRC inspector conducted plant tours at.various times to assess plant .

and equipment conditions. . The following. items were ob~ served during the:

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l. tours:

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. Equipment 1 conditions inclu' ding fluid-leaks and excessive vibration ~

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. Pladt hous'ekeeping and. cleanliness practices including fire hazards-

and control .of combustible material

. .The physical _ security plan was being implemented in accordance with; ,

-the station security plan

. Adherence to.the requirements of. radiation work l permits

. Work activities being performed in accordance with approved procedures

No violations or deviations were-identified.

11. Safety-Related System Walkdowns

The NRC _ inspector walked down ' accessible ' portions of the following.

safety-related systems to verify system operability. Operability was

determined by verification of valve and switch positions. :The systems

were walked.down using the drawings and procedures 'noted:

High pressure safety injection (Procedure OI-SI-1, Revision 33,'and-

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Drawing E-2866-210-130,-Revision 32)

. Low pressure safety injection (Procedure 01-SI-1, Revision.33,"and.

Drawing E-2866-210-130, Revision 32)-

During the walkdowns, the NRC inspector noted minor discrepancies?ofEan

editorial nature between the drawings,' procedures, and plant as-built -

conditions. None of the conditions noted affected the operability or safe

operation of the system. Licensee personnel l stated that the noted minor

discrepancies would be corrected.

No violations or deviations were identified.

12. Monthly Maintenance Observation

-r The NRC inspector reviewed station maintenance activities;of safety-related

systems and components to verify that maintenance was conducted:in,

accordance.with approved procedures, _ regulatory requirements, -and;the

Technical Specifications. The following items were considered ~during the

reviews:

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. The 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, as

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applicable

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

returning components or systems to service

. Q"'lity control records were maintained

. Activities were accomplished by qualified personnel

. Parts and materials used were properly certified

. Radiological and fire prevention controls were. implemented

The NRC inspector reviewed the following maintenance activities:

. Inspection of Foxboro transmitters for junction boxes and terminal

blocks (M0 857359)

. Changeout of motor leads for valve HCV-1042C (M0 860097)

.

Inwection of RTV barrier on terminal blocks (M0 857481)

No violations or deviations were noted.

13. Monthly Surveillance Observation

The NRC inspector observed the Technical Specification required

surveillance testing on safety related systems and components. The NRC

inspector verified the following items during the testing:

. Testing was performed usies c proved procedures

,

. Test instrumentation wt . 24i rated

._ Limiting conditions for operation were met

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

accomplished

. -Test results conformed with Technical Specification and procedure

requirements

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, . . Test results were reviewed by' personnel other than the individual

Edirecting:the test

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.. Deficiencies identified during the testing were properly' reviewed

and resolved by appropriate. management personnel

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, The NRC inspector witnessed the following' surveillance test activities.

.The_ procedures used for the. test activities are noted.

. Emergency. diesel generator monthly test (Procedure ST-ESF-6-F.2)

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. Auxiliary- feedwater pump and remotely-operated valve monthly check'

.(Procedure ST-FW-1-F.2)-

-No violations or_ deviations were identified.

- 14.~ Exit Interview

4

The NRC inspector met with Mr. W. G. Gates (Station Manager)Lat the end'

of this inspection. At this meeting, the inspector summarized the scope =

of:the inspection _and the findings. The NRC: inspector also met with OPPD

'

personnel on January.14, 1986, to provide the results of the EEQ' portion

of this inspection. See paragraph 1 for a list of attendees.

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