ML20137K556

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Insp Rept 50-285/85-27 on 851201-31.Violation & Deviation Noted:Failure to Display Security Identification Badges Inside Protected Area & Failure to Implement Fluid Sys Cleanliness Control Program,Respectively
ML20137K556
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 01/17/1986
From: Harrell P, Hunnicutt D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137K510 List:
References
50-285-85-27, IEB-83-07, IEB-83-7, NUDOCS 8601240131
Download: ML20137K556 (9)


See also: IR 05000285/1985027

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APPENDIX C

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j U. S. NUCLEAR REGULATORY COMMISSION

! REGION IV

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! NRC Inspection Report: 50-285/85-27 License: DPR-40

3 Docket: 50-285

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! Licensee: Omaha Public Power District

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1623 Harney Street

! Omaha, Nebraska 68102

j Facility Name: Fort Calhoun Station

Inspection At: Fort Calhoun Station, Blair, Nebraska

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Inspection Conducted: December 1-31, 1985

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Inspector: _

P. H. Harrlill, SeritorResident ReTEtor Inspector

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( Approved: /). M. Hunnicutt, Chief, Project Section B, Date '

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8601240131 960117

i PDR ADOCK 05000295

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4 Inspection Summary

Inspection Conducted December 1-31, 1985 (Report 50-285/85-27)

Areas Inspected: Routine, unannounced inspection including operational safety

verification, maintenance, surveillance, followup on previously identified

items, followup on licensee event reports, and followup on IE Bulletin 83-07.

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The inspection involved 102 inspector-hours (including 13 backshift hours)

i onsite by one NRC inspector.

Results: Within the six areas inspected, one violation (failure to display

security identification badges inside the protected area, paragraph 6) and two

deviations (failure to properly implement a fluid system cleanliness control

program and failure to maintain temporary COE storage areas in accordance with
licensee requirements, paragraph 2) were identified.

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DETAILS

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l 1. Persons Contacted

  • W. Gates, Plant Manager

C. Brunnert, Operations Quality Assurance Supervisor

M. Core, Maintenance Supervisor

D. Dale Quality Control Inspector

, J. Fisicaro, Nuclear Regulatory and Industry Affairs Supervisor

M. Kallman, Security Supervisor

L. Kusek, Operations Supervisor

T. McIvor Technical Supervisor

R. Mueller, Plant Engineer

G. Roach, Chemical and Radiation Protection Supervisor

J. Tesarek, Reactor Engineer

  • Denotes attendance at the exit interview.

The inspector also contacted other plant personnel, including operators,

technicians, and administrative personnel.

2. Followup on Previously Identified Items

(Closed) Severity Level V Violation 8421-Olb: Procedures have not been

established to implement the requirements for cleanliness of

I fluid systems.

The licensee has revised Section 6.3, " Cleanliness Control,"

of the Quality Assurance Plant (QAP) to include the appropriate

l requirements and recommendations from ANSI N 45.2.1-1973 and

Regulatory Guide 1.37 Revision 0. Appropriate plant procedures

have been revised to include the QAP Section 6.3 requirements

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for a fluid system closeup inspection. However, the licensee

has not included a procedural requirement required by the QAP

to ensure that fluid systems are capped or sealed except when

needed to carry out operations or m61ntenance activities.

During tours of the plant by the NRC inspector, it was noted

on five different occasions that the auxiliary feedwater (AFW)

system was opened to the atmosphere when no personnel were

working in the area.. The NRC inspector reviewed the maintenance

procedures being used for modification work on the AFW system

and noted that there was no requirement to maintain the system

capped or sealed. The NRC inspector notified licensee

management of the problems noted. The licensee made an

on-the-spot change to the maintenance procedure and closed the

open portions of the AFW system. After notification of these

problems to licensee nanagement, the NRC inspector found

subsequent problems of leaving the system open and unattended

in the same area of activity.

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In the response to this violation, the licensee stated, in a

letter to the NRC dated March 15, 1985, that standing orders

and/or procedures would be revised or developed as required to

more formally implement the requirements and recommendations of

ANSI N 45.2.1-1973. The licensec's failure to provide revised

procedures for requiring fluid systems be maintained capped or

sealed and the licensee's failure to implement this requirement

during'nodification activities is an apparent deviation to

i commitments made to the NRC. (285/8527-01)

(Closed) Severity Level IV Violation 285/8429-01: Deficiency

report / quality report (DR/QR) responses were not received within

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the 30-day requirement.

The NRC inspector reviewed a sampling of DR/QR reports to

determine if responses had been provided within the 30-day

requirement. No cases were noted where the response was

received more than 30 days from the date of issue of the DR/QR.

The licensee has established a program to ensure that responses

are received within the required time period. This program

includes issuance of a monthly DR/QR status report that

indicates all responses due and the individual responsible for

submitting the response, weekly distribution of the DR/QR status

list to all individuals on the list, and discussion by the

operations quality assurance supervisor of outstanding responses

with the plant review committee (PRC) members at the PRC

meetings. The licensee has made the appropriate procedure

changes to establish this program.

(Closed) Severity Level IV Violation 285/8501-01: Failure to follow

procedures for control of temporary critical quality equipment

(CQE) storage areas.

The NRC inspector randomly checked temporary CQE storage areas

on December 5 and December 23, 1985, to verify that storage of

materials in the areas was being done in accordance with

licensee procecural requirements. During the December 5 tour,

the NRC inspector noted that five of the nine areas checked did

not meet the licensee's requirements. Each area contained one

or more of the following problems: piping not capped or sealed,

, non-Q material stored in the area, purchase order numbers not

being transferred to remaining pieces when stock is cut, and

trash accumulation in the area. The noted problems were

discussed with licensee management personnel on

December 6.

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The NRC inspector also reviewed the quality control (QC) log to

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verify that the areas were inspected at least monthly by the

j onsite QC department. No problems were noted. The NRC inspector

l checked the temporary QC storage areas again on December 23 and

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found that three of the six areas did not meet the licensee's

requirements.

The licensee's response letter, dated March 28, 1985, to this

! violation stated that steps would be taken to ensure that the

problems identified by the violation would be corrected and that

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the areas would be maintained. The licensee's failure to

maintain the temporary CQE storage areas in accordance with

licensee requirements is an apparent deviation to commitments

made to the NRC. (285/8527-02) -

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3. Licensee Event Report (LER) Followup

Through direct observation, discussions with licensee personnel, and

review of records, the following event reports were reviewed to determine

that reportability requirements were fulfilled, immediate corrective

action was accomplished, and corrective action to prevent recurrence has

been accomplished in accordance with Technical Specifications.

The following LERs are closed:

l 84-008 Tube rupture in the 'B' steam generator

84-015 Polar crane carried load over reactor coolant system

! LER 84-008 reported a steam generator tube failure during a plant startup-

l from a refueling outage. The tube failure occurred in May 1984,'while

performing a hydrostatic test of the reactor coolant systen. The plant

was shutdown and the necessary repairs were made. The plant was

subsequently restarted and operated from July 1984, until September 1985

(cycle 9), when it was shutdown for refueling.

The licensee, in conjunction with Combustion Engineering, performed an

analysis to determine the cause of the tube failure. The results of the

l analysis indicated the failure was caused due to caustic-induced

l intergranular stress corrosion cracking. To minimize the possibility of

I additional tube failures, the licensee instituted programs during cycle 9

' to minimize caustic buildup in the steam generators. These programs

consisted of enhanced contrcl of contaminants entering the condensate and

feedwater systems, initiation of more restrictive secondary chemistry

guidelines and operating limits, improvements in steam generator

monitoring capabilities, and a soak / blowdown treatment process during

system startup to reduce the amount of contaminants in the steam

genera tor. The licensee also instituted a program to require an

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independent review of eddy current data. An independent review of the

data had not been performed during past eddy current tests.

The licensee performed eddy current tests on the steam generator tubes

during the refueling outage currently in progress. Based on the results

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of the test, the licensee plugged 16 tubes in the ' A' steam generator and

17 tubes in the 'B' steam generator. All the tubes plugged, except for a

total of five in both generators, were plugged due to denting. The

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remaining five tubes (two in the ' A' steam generator and three in the 'B'

steam generator) were plugged due to identified defects. None of the

identified defects were in the same area where the previous tube rupture

occurred.

The licensee intends to maintain the recently established programs to

minimize the probability of another tube failure.

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LER 84-015 reported an occurrence where the polar crane carried a load

greater than 250 pounds over the reactor coolant system (RCS) when the

pressurizer temperature was greater than 225 degrees F. This was a

violation of the station Technical Specifications. To prevent recurrence,

the licensee has added a note to the procedure for RCS vent and leak test

operating instructions to electrically tagout the polar crane prior to

exceeding 225 degrees F in the RCS. In addition, the licensee has also

installed a sign on the breaker for the polar crane noting the same

requirement. The NRC inspector noted that the breaker was tagged out

during the recent plant heatup as required by the procedure,

j No violations or deviations were identified.

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4. Followup on IE Bulletin 83-07

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IE Bulletin 83-07, " Fraudulent Products Sold by Ray Miller, Inc.,"

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provided the licensee with infonnation regarding fraudulent material sold

by the Ray Miller Company. The licensee was requested to V:rify that they

had not used any material supplied by Ray Hiller.

The NRC inspector reviewed the licensee's response to IE Bulletin 83-07 to

verify that the responte was adequate and that the actions comitted to by

the licensee have been completed. The licensee has reviewed their quality

assurance (QA) records and verified that they have not received any

, fraudulent products from any of the companies listed in the bulletin. The

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licensee has also received a letter, dated March 22, 1984, from Combustion

Engineering stating that no Ray Miller material was supplied to the

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No violations or deviations were noted. This bulletin is considered

closed.

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5. Operational Safety Verification

The NRC inspector observed control room operations, reviewed cpplicable

logs, and conducted discussions with control room operators. The

inspector verified the operability of selected emergency systems, reviewed

tag-out records, verified proper return to service of affected components,

and ensured that maintenance requests had been initiated for equipment in

need of maintenance. The inspector also verified implementation of

radiation protection controls during observation of plant activities.

Na violations or deviations were identified.

6. Physical Plant Security and Safeguards

The NRC resident inspector accompanied the NRC region-based, safeguards

inspector on his routine, unannounced inspection. This effort was

performed to increase the sensitivity and knowledge level of the resident

inspector in the areas of security and safeguards. The resident inspector

also made spot checks to verify that the physical security plan was being

implemented in accordance with the station security plan. During tours of

the plant, the NRC inspector noted that some individuals inside the

protected area were not displaying their security badges in plain sight.

The NRC inspector notified the licensee of the problem. The licensee

posted a sign at the entrance to the protected area and issued a memo to

all badge holders to remind everyone of the requirement to wear their

badges in plain sight. Subsequent to these actions by the licensee, the

NRC inspector nuted on three different occasions, individuals not

displaying their security badges in plain sight. Failure to display a

security bad e is an apparent violation of Standing Order G-39.

(285/8527-03

7. Plant Tours

The NRC inspector toured accessible areas of the unit to observe plant

equipment conditions, including potential fire hazards, fluid leaks, and

excessive vibration. The inspector observed plant housekeeping and

cleanliness conditions during the tour.

The NRC inspector walked down the accessible portions of the containment

spray system. The walkdown was performed using Procedure OI-CS-1,

Revision 14, and Drawing E-2866-210-130, Revision 32. During the

walkdown, the NRC inspector noted discrepancies between the system

operating procedure, drawing, and the as-built plant. The discrepancies

noted were of a minor editorial nature. Licensee management was notified

of the discrepancies and stated '. hat the appropriate documentation would

be corrected.

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During the previous inspection period, the NRC inspector performed a

walkdown of various systems. The items noted during the walkdowns were

still being resolved at the end of the previous inspection period. The

licensee provided the NRC inspector the appropriate information regarding

the items. Based on this input, the discrepancies noted were of a minor

editorial nature, except for one item. During the walkdown, the NRC

inspector noted that there was a new valve installed on the emergency

diesel generator fuel oil filter. This unnumbered valve was not shown on

the drawing, nor was the talve listed on the valve lineup. The NRC

inspector requested to see the documentation related to installation of

the valve. The licensee las not yet provided the documentation. This

item is unresolved pending a determination of whether or not the valve was

installed per appropriate documentation. (285/8527-04)

During plant tours, the NRC inspector noted that two fire barriers were

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not functional, as defined by the Technical Specifications. Fire Door

1007-8 was not completely closed due to a hose running through the door

1 and the guillotine fire curtain above Fire Door 1007-5 was inoperable

j due to a hose running through a ventilation port. The NRC inspector

i requested to see documentation to verify that an hourly fire patrol had

been established and was in effect at the time of the discovery by the NRC

inspector. The licensee had not located the necessary documentation.

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This item remains unresolved pending whether or not an hourly fire watch

had been established. (285/8527-051

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No violations or deviations were identified. .

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8. Monthly Maintenance Observation

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' Station maintenance activities of safety-related systems and components

listed below were observed to ascertain that they were conducted in

accordance with approved procedures, Regulatory Guides, and industry codes

or standards; and in conformance with Technical Specifications.

The following items were considered during this review: the limiting

conditions for operation were met while components or systems were removed '

l from service; approvals were obtained prior to initiating the work;

i activities were accomplished using approved procedures and were inspected

as applicable; functional testing and/or calibrations were performed prior

! to returning components or systems to service; quality control records

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were maintained; activities were accomplished by qualified personnel;

parts and materials used were properly certified; radiological controls 7

l were implemented; and fire prevention controls were implemented.

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Maintenance orders (M0s) were reviewed to determine status of outstanding

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jobs and to ensure that priority is assigned to safety-related equipment

maintenance which may affect system performance.

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The following maintenance activities were observed:  ;

. Replacement of packing in valves HCV-1103, FW-169, and FW-170

(M0 851570, 851471, and 851507, respectfully)

. Coupling of the control element assemblies (f10 852446, Procedure  !

MP-RC-10-7)

. Inspection of auxiliary feedwater storage tank interior (M0 852785)

. Replacement of jumper wires in Limitorque motor-operated valves

(MR-FC-85-77)

No violations or deviations were identified.

9. Monthly Surveillance Observation

The NRC inspector observed the Technical Specification required

surseillance testing on the station battery (Procedure ST-DC-1-F.1) and I

verified that testing was performed in accordance with adequate

procrcures, test instrumentation was calibrated, limiting conditions for ,

operation were met, removal and restoration of the affected components j

were accomplished, test results conformed with Technical Specifications 1

other than the individual directing the test, and any deficiencies l

identified during the testing were properly reviewed and resolved by I

appropriate management personnel. The inspector also witnessed portions of l

the shutdown margin verification (Procedure ST-SDM-1-F.1'. l

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No violations or deviations were identified.

10. Unresolved Items

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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.

Two unresolved items are discussed in this report in paragraph 7.

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11. Exit Interview j

The NRC inspector met with Mr. W. G. Gates (Plant Manager) at the end of  !

this inspection. At this meeting, the inspector sunnarized the scope of  :

the inspection and the findings. l

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