IR 05000285/2003008
| ML031681308 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/17/2003 |
| From: | Gody A Division of Reactor Safety IV |
| To: | Ridenoure R Omaha Public Power District |
| References | |
| IR-03-008 | |
| Download: ML031681308 (18) | |
Text
une 17, 2003
SUBJECT:
FORT CALHOUN STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 50-285/03-08
Dear Mr. Ridenoure On May 8, 2003, the NRC completed an inspection at your Fort Calhoun Station. The enclosed report documents the inspection findings, which were discussed on May 8, 2003, with you and other members of your staff.
This inspection examined activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
On the basis of the sample selected for review, which included 166 condition reports and 8 work orders, there were no findings of significance identified during this inspection. Overall, the team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution program. However, the team identified vulnerabilities in the licensees methods for processing 10 CFR Part 21 reports and cross-referencing work orders to condition reports.
Omaha Public Power District -2-In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Anthony T. Gody, Chief Operations Branch Division of Reactor Safety Docket: 50-285 License: DPR-40
Enclosure:
NRC Inspection Report 50-285/03-08
REGION IV==
Docket: 50-285 License: DPR-40 Report No.: 50-285/03-08 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates: April 28 through May 8, 2003 Team Leader: H. Bundy, Senior Operations Engineer, Operations Branch Inspectors: M. Murphy, Senior Operations Engineer, Operations Branch J. Kramer, Senior Resident Inspector, Projects Branch C Approved By: Anthony T. Gody, Chief Operations Branch Division of Reactor Safety
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SUMMARY OF FINDINGS
IR 05000285-03-08; Omaha Public Power District; 04/28 - 05/08/03; Fort Calhoun Station; biennial baseline inspection of the problem identification and resolution.
The inspection was conducted by region-based inspectors and the senior resident inspector.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
Identification and Resolution of Problems The team concluded that the licensee was effective at identifying problems and putting them into the corrective action program. The licensees effectiveness at problem identification was evidenced by the relatively few deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period.
However, the team identified vulnerabilities in the licensees methods for processing 10 CFR,
Part 21 reports and cross-referencing work orders to condition reports. The licensee effectively used risk in prioritizing the extent to which individual problems would be evaluated and in establishing schedules for implementing corrective actions. Corrective actions, when specified, were implemented in a timely manner. Licensee audits and assessments were found to be effective. On the basis of interviews conducted during this inspection, workers at the site felt free to input safety findings into the problem identification and resolution program (4OA2).
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (PI&R)
Effectiveness of Problem Identification
a. Inspection Scope
The team reviewed items selected across the seven cornerstones of safety to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. Specifically, the team selected 166 condition reports and 8 work orders from thousands that had been issued between October 2001 and April 2003. The team also reviewed 12 licensee audit and self-assessment reports, including several addressing various aspects of the PI&R program.
The effectiveness of the audits and assessments was evaluated by comparing the audit and assessment results against self-revealing and NRC-identified findings. In addition, the team reviewed the licensees response to 13 NRC noncited violations or findings, 4 licensee event reports, 6 NRC regulatory information summaries, 11 NRC information notices, and 4 vendor 10 CFR Part 21 reports.
The team evaluated the condition reports and NRC findings to determine the licensees threshold for identifying problems and entering them into the corrective action program.
Also, the licensees efforts in establishing the scope of problems were evaluated by reviewing pertinent control room logs, work requests, self-assessment results, system health reports, trending reports, and action plans. The industry experience information was reviewed to assess if issues applicable to Fort Calhoun Station were appropriately addressed. The condition reports and other documents listed in the Attachment were used to facilitate the review.
The team also conducted walkdowns and interviewed plant personnel to identify other processes that may exist where problems and findings could be identified. The team reviewed work requests and attended the licensees daily work control meeting to understand the interface between the corrective action program and the work control process.
b. Findings and Observations
The team determined that the licensee was effective at identifying problems and entering them into the corrective action system. This was evidenced by the relatively few deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee during the review period. Licensee audits and assessments were of good depth and identified issues similar to those that were self-revealing or raised during previous NRC inspections. Also, during this inspection, there were no instances identified where conditions adverse to quality were being handled outside the corrective action program.
However, the team identified the following minor issues in problem identification. During review of control room logs, the team identified two deficiencies for which work requests were not appropriately written. The linkage between work orders and condition reports was not explicit. Condition report numbers were often not entered on the work order and it usually took a lot of effort by the licensee to locate associated condition reports.
This issue was raised during a previous NRC inspection and Condition Report 200103426 was initiated to address it. The principal action was to stress the importance of capturing this type of information in work packages with planners. It appeared the desired result was not achieved.
The team identified a vulnerability in determining plant applicability of defective components identified in vendor reports submitted in accordance with 10 CFR Part 21.
In essence, the licensees staff relied on plant vendors to specify that any defective parts that they had identified had been purchased for Fort Calhoun Station.
For Report 2002-07-0 involving General Electric J-Core molded case circuit breakers (MCCBs), the vendor stated that since some licensees may have obtained those devices through other dedicating entities, that they were not assured that they had knowledge of all end users and that they were providing the information to the NRC for appropriate action. In this instance, the licensees staff had purchased similar devices for Fort Calhoun Station as commercial components and subsequently dedicated them for safety-related applications, and the vendor did not have knowledge of these safety-related applications.
The team informed the licensees staff that the NRC recognizes that the vendor may not have knowledge of all potential installations of components such as these, particularly when a third party vendor is involved. The NRC places all 10 CFR Part 21 reports on the NRC web page with the expectation that licensees will review them for potential applicability at their plants. Pursuant to this policy, Part 21 Report 2002-07-0, which discussed these MCCBs, had been placed on the NRC web. Because of its policy of only reviewing 10 CFR Part 21 reports submitted directly to it by its vendors, the Fort Calhoun Station staff was not aware of this report until the team questioned its applicability to the Fort Calhoun Station. In response to these questions, the licensee determined that it had installed similar MCCBs in safety-related applications and initiated Condition Report 200301597 to perform an operability determination. The licensee determined that the affected breakers were manufactured from 1997 to present. Similar breakers had been procured for the Fort Calhoun Station and dedicated for safety-related use prior to 1997. These breakers did not exhibit the characteristics of concern discussed in the subject 10 CFR Part 21 report.
Earlier in the inspection, the team had expressed concern that the licensee could fail to receive 10 CFR Part 21 reports because vendors might not be able to trace the applications of all components because of considerations similar to those discussed above. The licensee had issued Condition Report 200301543 to address that concern.
2. Prioritization and Evaluation of Issues
a. Inspection Scope
The team reviewed approximately 166 condition reports and supporting documentation, including root cause evaluations, to ascertain whether the licensee identified and considered the full extent of conditions, generic implications, common causes, and previous occurrences. The team also reviewed the other documents cited in Section 4OA21a to evaluate whether issues applicable to Fort Calhoun Station were properly prioritized and evaluated.
b. Findings and Observations
Based on a review of the licensees records, the team concluded that it effectively prioritized and evaluated issues. However, the team identified examples where the evaluation of issues was not appropriately comprehensive and/or not properly documented.
For example, its evaluation of Regulatory Information Summary 2003-06, High Security Protected and Vital Area Barrier/Equipment Penetration Manual, was not documented in a condition report as required by Procedure NOD-QP-21, step 6.1. In response to team questions, the licensee initiated Condition Report 200301599 to address its failure to write a condition report and Condition Report 200301611 to enter the information in the regulatory information summary into the condition report system.
In evaluating NRC Information Notice 2002-018, Condition Report 200202280 did not adequately describe the effect of sparging nitrogen in the condensate storage tank on the net positive suction head of Auxiliary Feedwater Pump 54. In addition, the effect of the nitrogen cover gas in the emergency feedwater storage tank on the safety-related auxiliary feedwater pumps was not evaluated. The condition report was appropriately revised to address the deficiencies in the evaluation.
Issues regarding emergency diesel generator starting air valves raised in Noncited Violation 02-03-01 were addressed in Condition Report 200200475. It was stated in the condition report that all four valves were replaced last year when, in fact, one was replaced in 1988, one in May 1999, one in May 2002, and the one, which was the subject of the condition report, was replaced in December 2001. No condition report was associated with the valve replaced in May 1999. The licensee initiated Condition Report 200301598 to address the inaccurate information in Condition Report 200200475.
3. Effectiveness of Corrective Actions
a. Inspection Scope
The team reviewed the condition reports, audits, assessments, and trending reports described in Section 4OA21a above to verify that corrective actions related to the issues were identified and implemented in a timely manner commensurate with safety, including corrective actions to address common cause or generic concerns. A listing of specific documents reviewed during the inspection is included in the Attachment to this report.
The team evaluated the timeliness and adequacy of operability determinations and evaluations. The team reviewed corrective actions planned and implemented by the licensee and sampled specific technical issues to determine whether adequate decisions related to structure, system, and component operability were made.
b. Findings and Observations
The team concluded that implemented corrective actions for those conditions reviewed were effective.
4. Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The team interviewed a substantial number of individuals from the licensees staff, which represented a cross-section of functional organizations and supervisory and nonsupervisory personnel. These interviews assessed whether conditions existed that would challenge the establishment of a safety-conscience work environment. The team also sampled safety-related concerns placed into the licensees employee concerns program to ascertain that the licensee had provided appropriate responses. The employee concerns program provided an alternate method to the corrective action program for employees to raise safety concerns, with the option of remaining anonymous.
b. Findings and Observations
The team identified no findings related to the safety-conscience work environment at the facility. The team concluded, based on information collected and reviewed from the interviews, that employees were willing to identify safety issues and enter them into a corrective action system.
4OA6 Exit Meeting
The team discussed the findings with Mr. Ross Ridenoure and other members of the licensees staff on May 8, 2003. Licensee management acknowledged that proprietary materials examined during the inspection had been returned. No proprietary information is discussed in this report.
ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee D. Bannister, Plant Manager R. Clemens, Division Manager, Nuclear Assessments W. Gates, Vice President, Nuclear J. Herman, Manager, Nuclear Licensing E. Matzke, Engineer Station Licensing E. Morris, Coordinator Employee Concerns Program R. Phelps, Division Manager, Nuclear Engineering Department T. Pilmaier, Manager, Corrective Action Group R. Ridenoure, Division Manager, Nuclear Operations Division H, Sefick, Manager, Security and Emergency Protection NRC L. Willoughby, Resident Inspector
DOCUMENTS REVIEWED
PLANT PROCEDURES
Document Title Revision
SO-R-2 Condition Reporting and Corrective Action 22
FCSG-24 Corrective Action Program Expectations 2
AOP-15 Loss of Flux Indication or Flow Streaming 5
NOD-QP-31 Operability Determinations and Safety Analysis for Operability 22
(SAO)
NOD-QP-21 Operating Experience Review (OER) Program 15
AOP-01 Acts of Nature 14
FCSG-7 Human Performance 4
FCSG-25 Department Review Board 1
EPIP-OSC-2 Command and Control Position Actions/Notifications 41
EPIP-RR-17A TSC Administrative Logistics Coordinator Actions 20
EPIP-RR-22 Protective Measures Coordinator/Manager Actions 21
FFD-100 Fitness For Duty Program 10
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Document Title Revision
OI-RC-2A RCS Fill and Drain Operations 37
OP-1 Master Checklist for Plant Startup 67
OP-ST-RC- Reactor Coolant System (RCS) Leak Rate Test 22
3001
OP-ST-SHIFT- Operations Technical Specification Required Shift Surveillance 81
0001
PED-QP-3 Calculation Preparation, Review and Approval 7
PED-QP-5 Engineering Analysis Preparation, Review and Approval 15
PED-QP-14 Use of Engineering Judgement 3
QAP-5.1 Control of Plant Design and Modifications 8
RERP- Radiological Emergency Response Plan 16
APPENDIX A
RW-217 Packaging of Non-waste Radioactive Materials 6
RW-300 Shipping Radwaste and Radioactive Materials 8
SECOP-28 Accountability and Evacuation 7
SO-G-58 Control of Fire Protection System Impairments 31
SO-G-91 Control and Transportation of Combustible Materials 17
SO-G-103 Fire Protection Operability Criteria and Surveillance 15
Requirements
SO-O-1 Conduct of Operations 54
SO-M-10 Foreign Material Exclusion 25
CALCULATIONS
FC05336, Net Positive Suction Head Available for AFW Pump, Revision 1
FC06871, Diesel Generator Fuel Inventory, Revision 0
WORK ORDERS
00019232-01 00104181-01 00137883-02
00032851-01 00120770-01 00142744-01
00103960-01 00137883-01
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CONDITION REPORTS
199900484 200103410 200200468 200201512 200202893 200300025
199900844 200103426 200200475 200201525 200202902 200300042
199902692 200103573 200200478 200201531 200202903 200300093
200000116 200103646 200200498 200201618 200202918 200300110
200000128 200103736 200200522 200201736 200202973 200300117
200000943 200103751 200200546 200201738 200202978 200300172
200001151 200103752 200200597 200201742 200203024 200300263
200001462 200103772 200200598 200201761 200203067 200300396
200001661 200103774 200200604 200201927 200203217 200300401
200100852 200103787 200200632 200201952 200203364 200300402
200101116 200103861 200200632 200201958 200203366 200300408
200101186 200200076 200200642 200202238 200203381 200300420
200101477 200200093 200200707 200202280 200203691 200300452
200101518 200200111 200200783 200202286 200203698 200300623
200101692 200200134 200200814 200202289 200203773 200300665
200101733 200200142 200200855 200202326 200203791 200300722
200102190 200200218 200200876 200202350 200203797 200300747
200102192 200200258 200200899 200202386 200203848 200300748
200102404 200200281 200200939 200202500 200203879 200300749
200102522 200200304 200200941 200202592 200203923 200300797
200102588 200200306 200200967 200202593 200203931 200300888
200102887 200200310 200201010 200202610 200203988 200301032
200102960 200200317 200201037 200202647 200204129 200301258
200103167 200200326 200201187 200202682 200204316 200301543
200103285 200200373 200201230 200202743 200204411 200301598
200103340 200200379 200201251 200202835 200300002 200301599
200103355 200200404 200201296 200202836 200300003 200301611
200103378 200200464 200201441 200202875
AUDITS AND ASSESSMENTS
2-QUA-075, SARC Audit Report No.1 - Quality Assurance Program, August 22, 2002
03-QUA-025, SARC Audit Report No. 11 - QA Records/Procedures/Document Control,
March 26, 2003
2-QUA-114, SARC Audit Report No. 13/30 - Procurement Control and Material Identification
Control, December 18, 2002
2-QUA-082, SARC Audit Report No. 45 - Corrective Action Program, September 27, 2002
01-QUA-102, SARC Audit Report No. 61 - Conformance of Facility Operations, November 29,
2001
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2-QUA-096, SARC Audit Report No. 61 - Conformance of Facility Operations,
October 10, 2002
Self-Assessment on Identification and Resolution of Problems - January 6-10, 2003"
SA-02-005, Self-Assessment on Corrective Action - Cause Analysis
SA-02-016, Self-Assessment on Self-Assessment Program, December 10, 2002
2-QUA-086, Self-Assessment SA-02-042 on Common Cause Analysis of NAD Condition
Reports
NED-RE-02-039, Cycle 20 Maintenance Rule Periodic Assessment of Maintenance
Effectiveness (6/1/2001 - 3/31-2002), December 1, 2002
SA-03-010, Nuclear Safety Culture Self-Assessment (SOER 02-04)
OPERATING EXPERIENCE REPORTS
Information Notice 02-012, Submerged Safety Related Electrical Cables
Information Notice 02-001, Metalclad Switchgear Failures and Consequent Loss of Offsite
Power
Part 21 2002-005, Cutoff Switch in AK15, AK25, and AKR-305 Circuit Breakers
Part 21 2002-007, Early Trip of J-Core Molded Case Circuit Breakers (MCCB)
LER 2002-003-0, Inadequate Cable Separation Resulting in Noncompliance with 10CFR50
App. A
LER 2002-004-0, Inadequate Procedural Guidance Resulting in Noncompliance With 10CFR50
App. R
2002-001-00 Contraband Found in a Vehicle During Protected Area Search
2002-002-00 Inappropriate Use of Manual Operator Actions Cause Systems to be Inoperable
NRC Information Notice 2002-14, Ensuring a Capability to Evacuate Individuals, Including
Members of the Public, From the Owner-controlled Area
NRC Information Notice 2002-18, Effect of Adding Gas into Water Storage Tanks on the Net
Positive Suction Head for Pumps
NRC Regulatory Issue Summary 2002-07, Clarification of NRC Requirements Applicable to
Worker Fatigue and Self-declarations of Fitness-for-duty
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NRC Regulatory Issue Summary 2002-16, Current Incident Response Issues
NRC Regulatory Issue Summary 2002-21, National Guard and Other Emergency Responders
Located in the Licensees Controlled Area
NRC Regulatory Issue Summary 2003-04, Use of the Effective Dose Equivalent in Place of the
Deep Dose Equivalent in Dose Assessments
NRC Regulatory Issue Summary 2003-06, High Security Protected and Vital Area
Barrier/Equipment Penetration Manual
Part 21 Report 2002-18-0, Norgren R18 Relieving Style Pressure Regulating Valves
Part 21 Report 2002-33-01, Westinghouse/Cutler-Hammer Type B Thermal Overloads
OTHER
Quarterly Trend Report, 4th Quarter 2002
2-029, Plant Review Committee Minutes, Revision 1, May 8, 2002
2-046, Plant Review Committee Minutes, Revision 1, June 19, 2002
Training Lesson, MGT02-06, Safe Electrical Work Practices
Program Plan for FCS CEDM Seal Housings, Revision 1
Omaha Public Power District - Fort Calhoun Station CEDM Seal Housing Eddy Current
Examination, Dated June 2001
Omaha Public Power District - Fort Calhoun Station CEDM Seal Housing Eddy Current
Examination, Dated January 2003
Training Lesson Plan MGT 0207, Conduct Effective Observations and Effectively Coach
Workers
Vendor Manual TM B580.0130, Technical Manual for Byron Jackson Pumps Type DVMX
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Information Request 1 - March 2003
Fort Calhoun PIR Inspection (IP 71152; Inspection Report 50-285/03-08)
The inspection will cover the period of October 1, 2001 to March 31, 2003. All requested
information should be limited to this period unless otherwise specified. The information may be
provided in either electronic or paper media or a combination of these. Information provided in
electronic media may be in the form of e-mail attachment(s), CDs, or 3 1/2 inch floppy disks.
Please provide the following information to Howard Bundy in the Region IV Arlington office by
April 7, 2003:
1. Summary list of all condition reports of significant conditions adverse to quality opened
or closed during the period
2. Summary list of all open condition reports which were generated during the period
3. Summary list of all open condition reports which were generated prior to the latest
refueling outage
4. Summary list of all condition reports closed during the specified period
5. A list of all corrective action documents that subsume or "roll-up" one or more smaller
issues for the period
6. List of all root cause analyses completed during the period
7. List of root cause analyses planned, but not complete at end of the period
8. List of plant safety issues raised or addressed by the employee concerns program
during the period
9. List of action items generated or addressed by the plant safety review committees
during the period
10. All quality assurance audits and surveillances of corrective action activities completed
during the period
11. A list of all quality assurance audits and surveillances scheduled for completion during
the period, but which were not completed
2. A list of all corrective action activity reports, functional area self-assessments, and non-
NRC third party assessments completed during the period
13. Corrective action performance trending/tracking information generated during the period
and broken down by functional organization
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14. Current revision of the following procedures: SO-R-2, Condition Reporting and
Corrective Action; NOD-QP-19, Cause Analysis Program; NOD-QP-20, Human
Performance Enhancement System Program; NOD-QP-21, Operating Experience
Review Program
15. Any additional governing procedures/policies/guidelines for:
1. Condition Reporting
2. Corrective Action Program
3. Root Cause Evaluation/Determination
16. A listing of all external events evaluated for applicability at Fort Calhoun during the
period
17. Condition Reports or other actions generated for each of the items below:
1. All LERs issued by Fort Calhoun during the period
2. NCVs and Violations issued to Fort Calhoun during the period
18. Safeguards event logs for the period (may review onsite)
19. Radiation protection event logs
20. Current system health reports or similar information
21. Current predictive performance summary reports or similar information
2. Corrective action effectiveness review reports generated during the period
Information Request 2 - April 2003
Fort Calhoun PIR Inspection (IP 71152; Inspection Report 50-285/03-08)
The inspection will cover the period of October 1, 2001 to March 31, 2003. All requested
information should be limited to this period unless otherwise specified. The information may be
provided in either electronic or paper media or a combination of these. Information provided in
electronic media may be in the form of e-mail attachment(s), CDs, or 3 1/2 inch floppy disks.
Please provide the following information to Howard Bundy in the Region IV Arlington office by
April 21, 2003:
1. LERs: 02001
2. Regulatory Information Summaries (RISs): 03-006
3. Information Notices: 02-014,02-012, 02-001
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4. Part 21 Reports: 02-05-0 (ADAMS ml020650058), 02-07-0 (ADAMS ml020990033), 02-
18-0 (ADAMS ml022190534), 02-33-1 (ADAMS ml023600023)
5. NCVs: 02-04-01, 02-04-02, 02-08-02, 02-03-01, 02-03-02, 01-06-01, 02-0379
6. Findings: 02-03 (Failure to Properly Install Fire Protection Sprinkler Heads in Diesel-
Driven AFW Pump Room)
7. Condition Reports: 01-3772, 02-0475, 02-0464, 02-0111, 01-3787, 02-0379, 02-0522,
2-1251, 02-2238, 02-3797, 02-4316, 02-0306, 02-0597, 02-1618, 02-2592, 02-2593,
2-2978, 02-3914, 03-0093, 03-0722, 03-0888, 01-3426, 01-3410, 01-3340, 01-3355,
01-3378, 03-0452, 02-0218, 02-0258, 02-0281, 02-1187, 02-1296, 02-2326, 02-2386,
2-2406, 02-2647, 02-2682, 02-2835, 02-2875, 02-2973, 02-3366, 02-3703, 02-3879,
03-0172, 03-0401, 03-0402, 03-0546, 03-0747, 03-0748, 03-0749, 00-0128, 00-0116,
00-1213, 01-1477, 01-1518, 01-2404, 01-2522, 01-2588, 01-2887, 01-3285, 01-3573,
01-3646, 01-3774, 02-0142, 02-0404, 02-0498, 02-0598, 02-0642, 02-0876, 02-0918,
2-0939, 02-0941, 02-1010, 02-1230, 02-1441, 02-1525, 02-1531, 02-1736, 02-1738,
2-1952, 02-2280, 02-2289, 02-2350, 02-2592, 02-2836, 02-2902, 02-2903, 02-3256,
2-3364, 02-3698, 02-3988, 02-4129, 03-0042, 03-0396, 02-2610
8. Miscellaneous
a. HIT report concerning PRC Action Item 31130
b. Any information on RCS hot leg flow streaming issues
c. Any information on raw water system (including CCW heat exchangers)
erosion/corrosion issues
d. Any information on CRDM seal housing eddy current testing