ML20154J514

Forwards Notice of Violation & Notice of Deviation Re Insp Rept 50-285/88-10 on 880314-18.Documents Inadvertently Transmitted to Third Party One Day Before Rept Signed Out

ML20154J514
Person / Time
Site:	Fort Calhoun
Issue date:	05/19/1988
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 8805270025
Download: ML20154J514 (6)

See also: IR 05000285/1988010

Text

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MEMORANDUM FOR: File

FROM: James L. Milhoan, Director, Division of Reactor Safety

SUBJECT: INADVERTENT RELEASE OF DRAFT MATERIAL

The purpose of this memorandum is to place in the PDR copies of documents

related to NRC Inspection Report 50-285/88-10. These documents were

inadvertently transmitted via fascimile to a third party on April 18, 1988,

the day before the report in question was signed out.

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h James . lho n, Director

T Division of Reactor Safety

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APPENDIX A

_ NOTICE OF VIOLATION

Omaha Public Power District

Fort Calhoun Station Docket: 50-285

Operating License: DPR-40

During an NRC inspection conducted from March

NRC requirements were identified. 14-18, 1988, two violations of

resolve deficiencies identified during a surveillance test and failure

licensee

reactor coolant to verify

systemthe

leakcorrect

test. qualifications for an examiner completing a

Policy

(1987), the and Procedure

violations forbelow:

are listed NRC Enforcement Actions " 10 CFR Part 2

A.

Failure To Promptly Resolve Test Deficiencies ,

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quality assurance program requires that a test program sI

established

satisfactorily. to assure that . . . systems and components will perfonn )

documented

satisfied. and evaluated to assure that test requirements ha

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Contrary to the above, Surveillance Test ST-NZ-1 was completed on May 8, i

1987, with anamolies or deficiencies involving 11 nozzles. i

There was not

i an evaluation started of these anomalies or deficiencies

1988. until March 15,

This is a Severity Level IV violation.

(SupplementI)(285/8810-01)

B. j

Failure

Test Evaluationto Use Correct Qualification level of Examiner for Surveillance

i

Section 5.8.1 of the Technical Specifications (TS) requires that written

procedures and administrative policies shall be established, implemented

and 5.2 of ANSI N18.7-1972.and maintained that meet or exceed the minimum

Table 1 of G-26 of the licensee's Standing

Order G-26, R17. "Maintenance Quality Control Program," requires a minimum

level II capability for personnel who evaluate and report test results.

Contrary to the above, Surveillance Test ST-RLT-1, F.1 (leak test) results

were evaluated and reported on May

a lower capability level (Level 1). 29, 1987, by an individual qualified to

This is a Severity Level IV violation.

(SupplementI)(285/8810-02)

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Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District is

hereby required to submit to this office, within 30 days of the date of the

letter transmitting this Notice, a written statement or explanation in reply,

including for each violation: (1) the reason for the violations if admitted,

(2) the corrective steps which have been taken and the results achieved,

(3) the corrective steps which will be taken to avoid further violations, and

(4) the date when full compliance will be achieved. Where good cause is shown,

consideration will be given to extending the response time.

Dated at Arlington, Texas,

this day of 1988.

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APPENDIX B '

NOTICE OF DEVIATION

~0maha Public Power District Docket: 50-285

Fort Calhoun Station

Operating License: DPR-40

Based on the results of an NRC inspection conducted from March 14-18, 1988, a

deviation from your comitment was identified.

The deviation consisted of

failure to continue implementation of corrective actions comitted to in the

response to an NRC violation.

In accordance with the "General Statement of

Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C

(1987), the deviation is listed below:

Failure to Continue Implementation of Corrective Actions

Violation 285/8511-01, dated June 26, 1985, involved failure to account

for six surveillance

ending in July 1984,tests (STs),

in the files.performed during the refueling outage

The licensee's response to this

violation stated, in part, "Each month the surveillance test clerk will

issue a list of STs that are due but not filed and those due but not

completed.

Each

indicating the supervisor

status of each will

test.be required to respond to this list by

This status list will then be

compiled and presented to the Plant Review Committee (PRC) by the

Supervisor-Technical indicating those tests not completed /not filed and

the action taken to assure completion / filing by the end of the next

monthly review period."

Contrary to the above, in deviation to that written comitment, a status

list indicating the action taken to assure completion / filing by the end

of the next monthly review period did not exist for a delinquent ST list

dated March 2, 1988, which showed 11 STs dating from August 22, 1986, t

through the end of the 1987 spring refueling outage, as being delinquent

for filing. (285/8810-03)

Omaha Public Power District is hereby requested to submit a written statement

or explanation to this Office within 30 days of the date of the letter

transmitting this Notice. This reply, should include for each deviation:

(1) the reason for the deviation if admitted, (2) the corrective steps that

have been taken and the results achieved. (3) the corrective steps that will be

,

taken to avoid further deviations, and (4) the date when full compliance will

be achieved. Where good cause is shown, consideration will be given to

extending the response time.

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Dated at Arlington, Texas,

this day of 1988.

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of test results records for each procedure. The TS surveillance

requirements or IST component together with the associated test procedures

reviewed by the NRC inspector are tabulated in the Attachment.

The NRC inspector determined that the required tests were being scheduled

and performed as required in accordance with approved procedures.

Acceptance criteria were specified in the procedures and, with the

exceptions discussed below, the records stated satisfaction of acceptance

criteria. Appropriate instructions for returning equipment to service

following testing were given. Some problems involving failure to complete

timely reviews of completed test records are discussed in Section 2.a.

above and an example is given below.

The NRC inspector discovered that completed Procedure ST-NZ-1,

Section F.1, for flow testing containment spray nozzles noted anomalies

and deficiencies which had not been formally reviewed and dispositioned.

Specifically, it was noted that ten nozzles were not tested because of

inaccessibility and that one nozzle was not working properly. The test had

been completed on May 8, 1987, and was listed as delinquent for filing in

the list updated on March 2, 1988. The failure to evaluate the anomolies

or deficiencies with these nozzles is an apparent violation of 10 CFR i

Part 50, Appendix B, Criterion XI, and the approved quality assurance I

program. (285/8810-01)

The NRC inspector discussed the deficiencies noted in the test record for

ST-NZ-1 with plant management on March 15, 1988. The NRC inspector  !

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expressed concern that the plant was restarted with the operability of the

containment spray system undetermined. A second conc. n expressed was

that the licensee's administrative procedures for followup on test

deficiencies were apparently not followed. The Supervisor-Maintenance

initiated an Incident Report on March 16, 1988, to address the test

problems noted. It contained the results of a preliminary safety analysis

i

which indicated that over 100 spray nozzles must be plugged before the i

design flow rate of 5100 gpm would be decreased. The NRC inspector had no

further safety concerns on this test.

During the inspection, the NRC inspector requested records verifying the

appropriate qualification level of examiners who completed reactor coolant

system leak testing on May 29, 1987, and on June 1, 1987, in accordance

with Procedure ST-RLT-1, Section F.1. Because these records were not made

available prior to the exit, it was discussed as an unresolved item.

Copies of qualification records were subsequently forwarded by the

licensee to the NRC Region IV office on March 22, 1988. The qualification

record for the examiner completing the test on May 29, 1987, indicated he

had only an ANSI N45.2.6, level I qualification for hydrostatic testing.

Paragr6ph F.1.b.(2)(a) of ST-RLT-1 states that examiners must be qualified

in accordance with ASME Section XI, Article IWA-2000. Paragraph IWA-2212

of Article IWA-2000 requires the use of VT-2 visual examination for leak

testing. Subarticle IWA-2300 requires qualification of personnel

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