IR 05000285/1998023

Insp Rept 50-285/98-23 on 981108-1219.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20199E283
Person / Time
Site:	Fort Calhoun
Issue date:	01/07/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199E266	List: IR 05000285/1998023 ML20199E261
References
50-285-98-23, NUDOCS 9901200366
Download: ML20199E283 (17)

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! ENCLOSURO l'

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket No.: 50-285 License No.: DPR-40 Report No.: 50-285/98-23

Licensee: Omaha Public Power District ,

Facility: Fort Calhoun Station j Location: Fort Calhoun Station FC-2-4 Ad P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates: November 8 through December 19,1998 l Inspectors: W. Walker, Senior Resident inspector

! C. Johnson, Reactor inspector N. Salgado, Resident inspector D. Carter, Resident inspector .

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Approved By: D. N. Graves, Acting Chief, Project Branch B l

' ATTACHMENT: Supplemental Information l

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I 9901200366 990107 l PDR ADOCK 05000205 0 PM ,

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EXECUTIVE SUMMARY Fort Calhoun Station

'4RC Inspection Report 50-285/98-23 Operations

Operations personnel c smonstrated excellent command and control of activities during two unexpected fast tra"sfer evolutions from 161 kV power to 22 kV power, which were caused by offsite, weather related events. The inspectors noted that correct procedures were in use and being referenced during the events (Section 01.2).

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The licensee failed to maintain a control element locking clip attached to a fuel assern'oly to ensure that the control element assembly was mechanically coupled to the fuel assembly as required by Technical Specification 2.8(11). The cause was an inadeouate design of the control element assembly locking clip. This nonrepetitive, licensee-identified and corre cted violation is being treated as a noncited violation consistent with Section Vll.G.1 of the NRC Enforcement Policy (Section O8.3).

Maintenance

The maintenance activities observed were conducted in a controlled and professional manner (Section M1.1).

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The curveillance activities observed by the inspectors were completed in a controlled manner and in accordance with procedures (Section M1.2).

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The ins pectors concluded that the observed materia l condition of equipment located in the accessible areas of the auxiliary, radwaste and turbine buildings was good. In addition, it was verified that the licensee had an action plan in place to address leaks identified on the component cooling water system (Section M2.1).

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The licensee failed to m aintain C' arging Pump CH-1B operable after 7 days as required by Technical Specification 2.15(4). This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (Section M8.2).

Enoineerina

The licensee's actions in addressing lockout relay failures in the engineered safoguards logic system were considered tirnely and resulted in continued system operation. The licensee's efforts in developing an action plan to address the existing reliability concern caused by these failures was found to be good (Section E1.1).

Elant Sucoort

• Radiation protection personnel continued to reduce contamination areas and several enhancements were being implemented to inr/ ease worker awareness of radiological conditions inside the radiologically controlled area (Section R1.1).

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Reco_rt Details ( Summarv of Plant Status l

b The Fort Calhoun Station began this inspection period at 100 percent power and maintained j that level throughout the inspection period.

l l l. Operations 01 Conduct of Operations I O General Comments (71707)

l l The inspectors conducted frequent reviews of ongoing plant operations. In general, the l conduct of operations was professional and safety conscious; specific events and noteworthy observations are detailed in the sections below.

I O1.2 Undervoltaae on 161 kV Line Resultina in a Fast Transfer l Inspection Scope (71707)

! The inspectors observed operation's personnel respond to two fast transfers from l 161 kV power to 22 kV power due to a low voltage on the 161 kV line.

1 Observations and Findinas l

l On November 10 and 24,1998, the plant experienced similar evente in which unplanned l fast transfers occurred between the 161 kV and 22 kV power supplies to the 4160V vital ;

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(1 A3 and 1 A4) and auxiliary (1 A1 and 1 A2) buses. Both fast transfers resulted from a i

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dip in voltage on the 161 kV line which were caused by offsite, weather related, event No disruption of equipment operation was noted during these inadvertent fast transfer l

, evolutions.

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The inspectors responded to the control room during both events and noted that activities were well controlled. Abnormal Operating Procedure AOP-31,"All 4160 volt buses Fed From 22 kV," was open and in use by the control room operators. All

, equipment responded to the fast transfer as planned. The inspectors observed that l frequcnt briefings were held during the events and that the licensed senior operator and

the shift technical advisor were reviewing Emergency Operating Procedures EOP-00,  ;

" Standard Post Tdp Actions," and EOP-20, " Functional Recovery Procedure," in the event that an inadvedent reactor trip occurred with fast transfer capability not available.

l The inspectors noted that during both events the operations personnel discussed the

! i nportance of restoring fast transfer capability as soon as possible and plant-wide announcements were made to restrict access to tha switchgear rooms.

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l l-2- Conclusions Operations personnel demonstrated excellent command and control of activities during two unexpected fast transfer evolutions from 161 kV power to 22 kV power, which were caused by offsite, weather-related events. The inspectors noted that correct procedures were in use and being referenced during the event Miscellaneous Operations issues (92901 and 92700) l l

08.1 (Closed) Violation 50-285/9719-02: inadequate containment integrity verification. On j November 19,1997, the inspectors performed a verification of containment integrity I using Operating instruction OI-CO-5, " Containment Integrity," Revision 11. While !

verifying the integrity of electrical and piping penetrations in the main steam room using

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Checklist Ol-CO-5-CL-D, the inspectors identified that Electrical Penetrations G1-G4 and Piping Penetration H1 were not included on the checklist. The licensee had used inadequate Operating Instruction OI-CO-5 to verify containment integrity in preparation for reactor startup in May of 199 The inspectors verified the corrective actions described in the licensee's response letter, dated January 16,1997, to be reasonable and complete. During the review of Operating Instruction O!-CO-5, the inspectors identified some administrative errors. The licensee initiated Condition Report 199802138 to resolve the administrative error .2 (Closed) Violation 50-285/9719-03: improperly installed locking device. On December 3,1997, the inspectors identified that the locking device on Valve HCV-2812C (raw water inlet to High Pressure Safety injection Pump 2C bearing cooler) did not provide a physical restraint to prevent operation of the valv The inspectors verified the corrective actions described in the licensee's response letter, dated January 16,1997, to be reasonable and complete. No similar problems were identifie .3 { Closed) Licensee Event Report (LER) 50-285/97-010: violation of Technical Specifications while moving spent fuel in the spent fuel pool. On July 31,1997, the 1 licensee was moving fuel assemblies within the spent fuel pool in preparation for the J

upcoming refueling outage. During the fuel movement, Fuel Assembly HA14 had been moved within Region 2 of the spent fuel pool. Technical Specification 2.8(11) required that, due to its enrichment, Fuel Assembly HA14 was required to have a control element I assembly mechanically coupled to it to remain in Region 2 of the spent fuel pool. During i the movement of other fuel assemblies, operators noticed Fuel Assembly HA14 did not l have its control element assembly locking clip attached. The locking clip is the mechanism required to ensure that the control element assembly is mechanically coupled to the fuel assembly. The licensee's immediate corrective action was to place i

Fuel Assembly HA14 into Region 1 of the spent fuel pool, where it would meet Technical Specification requirements. The cause of the missing clip was an inadequate design of the control element assembly locking clip.

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The team verified completion of the corrective actions described in the licensee's l closeout of LER 9'7-010 and Condition Report CR 199700956 and considered the actions to be acceptable. These actions incluaed moving the fuel assemblies that had previously required the locking clips to areas in the spent fuel pool that do no require installation of the locking clip and changing procedure and software to assure that the fuel storage locations that would require use of the locking clips are not utilized. This i nonrepetitive, licensee-identified and corrected violation is being treated as a noncited l violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-285/9823-02).

l 08.4 (Closed) Violation 50-285/9720-01: the inappropriate use of operations memorandums to implement procedure changes without performing the requirements of Standing )

l Order SG G 30," Procedure Changes and Generation." The appropriate Department i Heads were directed to evaluate all active operations memorandums using the 1 10 CFR 50.59 safety evaluation process for unreviewed safety questions. A qualified reviewer evaluated the active operations memorandums to determine if l

cross-disciplinary reviews of the memorandums were necessary.

l As a result of this evaluation, the licensee determined that no additional I cross-disciplinary reviews were required. Standing Order SO-13," Operations i Memorandums," was revised to require that operations memorandums have a

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10 CFR 50.59 evaluation performed prior to issuance. The inspectors concluded that '

the licensee's corrective actions were appropriat )

I II. Maintenance M1 Conduct of Maintenance M1.1 General Comments Insoection Scoce (62707)

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The inspectors observed all or portions of the following maintenance activities:

. Removal and Installation of Auxiliary Supply Fan Motor VA-35B

. Weld Repair of Pinhole Leak on the East Raw Water Header

. Repair of West Switchgear Room Condensing Unit VA-90

. Replacement of Undervoltage Relay 27-74/1 A4 l

4 Observations and Findinas i

l The inspectors found the work performed under these activities to be professional and

thorough. All work observed was performed with the work package present and in active use. Maintenance technicians were experienced and knowledgeable of their i

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assigned tasks. The inspectors frequently observed supervisors and system engineers i monitoring job progress, and quality control personnel were present when required by l l procedur Conclusions t

l The maintenance activities observed were conducted in a controlled and professional j manner.

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l M1.2 Surveillance Tests Insoection Scope (61726) i The inspectors observed all or portions of the following maintenance activities:

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! . OP-ST-FP-0001C, " Fire Protectior, System inspection and Test," Revision 6;

. OP-PM-AFW-004, " Third Auxiliary Feedwater Pump Operability Verification," l Revision 15; )

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. EM-ST-ESF-0001," Quarterly Engineered Safety Features Offsite Power Low Signal (OPLS) Sensor Check," Revision 7; l

. SE-ST-AFW-3005, " Auxiliary Feedwater Pump FW-6, Recirculation Valve, and Check Valve Tests," Revision 6; and

. OP-ST-DG-0001, " Diesel Generator 1 Check," Revision 24.

l Observatior 3 and Findinas l

l Surveillance activities were generally completed thoroughly and professionally, Conclusions l

The surveillance activities observed by the inspectors were completed in a controlled manner and in accordance with procedures.

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M2 Maintenance and Material Condition of Facilities and Equipment i

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M2.1 Review of Material Condition Durina Plant Tours inspection Scope (62707)

During this inspection period, the inspectors performed routine plant tours and evaluated

. plant material condition.

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! -5-l Observations and Findinas

, The inspectors observed that the visible materia' condition and housekeeping of l accessible areas of the auxiliary building, the radwaste building, the intake structure, and most areas of the turbine building were goe During a tour of the radwaste and auxiliary buildings, the inspectors noted a packing i leak on radwaste building main fire protection header isolation Valve FP-386. A l deficiency tag had been written and t'le inspectors verified that the valve was in the l planning process for repair. External conditions of Component Cooling Water Pumps AC-3A, AC-3B, and AC-3C were good with no leaks observed. Component Cooling Water Pump AC-3A Discharge Valve AC-102 and Discharge Check Valve AC-101 both had minor leaks. The inspectors discussed with the system engineer the schedule for repair of these valves. The system engineer stated that the repairs would be completed during the next refueling outage scheduled to start on October 2,1999. The inspectors verified that the maintena' ice work documents for completion of the leak repairs were activ The inspectors noted that a pinhole leak had developed on a 20-inch 90-degree elbow i on the east raw water supply header piping. The leak was in the center of the pipe weld '

on the inside portion of the elbow. The licensee performed ultrasonic thickness testing at 27 locations in the area of the pinhole leak. The thickness measurements ranged from .346 to .370 inches on the upstream side of the elbow and from .246 to .352 inches on the downstream side. Nominal pipe wall thickness is .375 inches. None of the measurements were significantly close to the minimum allowed wall thickness of 0.062 inche The inspectors verified that an action plan was in place to perform weld repairs on both the component cooling and raw water systems. Subsequently, the inspectors witnessed l the completion of the weld repair on the raw water system. No problems were note Conclusions The inspectors concluded that the observed material condition of equipment located in the accessible areas of the auxiliary, radwaste, and turbine buildings was good. In addition, it was verified that the licensee had an action plan in place to address leaks identified on the component cooling water system M8 Miscellaneous Maintenance issues (92902 and 92700)

M8.1 (Closed) LER 50-285/97-002: failure to meet the intent of Technical l Specification 2.15(4). A review indicated that, during 1991 with the plant in Mode 1, Charging Pump CH-1B had been out of service for 10 days 17.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Technical Specification 2.15 established limiting conditions for operations for instrumentation and control systems. Generic Letter 81-12 on the fire protection rule requested Technical Specifications for the surveillance requirements and limiting

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conditions for operation for that equipment not already covered by existing Technical Specifications. On July 31,1989, as requested, the licensee submitted an application for amendment of Technical Specification 2.15 to address the concerns raised in Generic Letter 81-12. The application was written to be consistent with the guidance in NUREG-0212, the Combustion Engineering Standard Technical Specifications. The application for amendment addressed the 7-day limiting condition for operation for the instrumentation on the alternate shutdown panel, but no equipment controls were listed in either the limiting conditions for operation or the surveillance section of the Technical Specification. Charging Pump CH-1B can be controlled from the Alternate Shutdown Panel. Subsequently, in July 1991, Charging Pump CH-1B was removed from service for a period of 10 days 17.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> without complying with Technical Specification 2.15(4), which required, after 7 days, restoration of the components to an operable status or placing the plant in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This violated the intent of Technical Specification 2.15(4)in that the control associated with charging Pump CH-1B at the alternate shutdown panel was out of service for greater than the 7 days allowed by tw specificatio ;

l The charging pumps are credited in the current licensing basis for long-term actions )

necessary to achieve cold shutdown. However, the charging pumps are not credited for mitigating the short-term consequences of any Updated Safety Analysis Report Chapter 14 design basis postulated accidents or anticipated operational occurrence Thus the safety significance of this event was minimal.

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l As corrective actions, the licensee provided guidance to the operating staff to ensure l that the intent of the Technical Specification was met and also performed a review of other components with regard to Amendment 125. No other concerns were identifie The cause of this condition was ineffective communication between the Omaha Public Power District and the NRC regarding Amendment 125 to plant Technical Specification 2.15 and the lack of adequate management review to ensure that the wording of Technical Specification 2.15(4) would meet the intent of the requests of the

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NRC. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-285/9823-01).

M8.2 { Closed) LER 50-285/97-006: loss of all fire suppression due to inoperability of fire pumps. On June 6,1997, with Motor-Driven Fire Pump FP-1 A inoperable, the blocking device used to prevent a start signal from the Pump FP-1 A control circuit to Diesel-

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Driven Fire Pump FP-1B moved out of position, resulting in Pump FP-1B receiving a l start signal. Fire Pump FP-1B failed to start due to sand in the pump. Pump FP-1B was

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declared inoperable on June 6,199 The inspectors determined that the licensee had established appropriate immediate corrective actions by posting continuous fire watches in the required areas of the plant and by aligning the fire main to the water plant for supply water for manual fire suppression.

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-7-The licensee's long-term corrective actions to prevent recurrence were:

. Appropriate plant procedures were revised with guidance to ensure that, when a fire pump is started for any reason, it will be allowed to run for a least several minutes;

. Perform more frequent surveillance (biweekly) to run the diesel fire pump (FP-18) to evaluate and determine the adequacy of the pump's monthly surveillance;

. System and design engineering personnel performed an evaluation of the overall reliability of FP-1 A and FP-1B. From the evaluation the licensee proposed Engineering Change Notice ECN 97-209 to add a sparging system to Pump FP-18, and returned the sparging system for Pump FP-1 A back to service; and The inspectors concluded that the licensee's corrective actions had been appropriat M8.3 (Closed) Insoection Followuo item 50-285/9715-03: criticality monitors; application for exemption of 10 CFR 70.24. The licensee applied for an exemption to 10 CFR 70.24 by letter dated August 29,1997, as supplemented by letter dated October 23,199 The NRC staff approved this request for exemption in a letter dated February 6,199 The inspectors concluded that the review and approval by the NRC staff were appropriat Ill. Enoineerina E1 Conduct of Engineering l

E Enaineered Safeauards Control Relavs Insoection Scope (37551)

l The inspectors performed a review of the performance and reliability of the engineered ]

safeguards relays designated as 86 lockout relays. These relays are energized to i release a mechanicallatch which then allows a spring to charge the state of associated contacts. These relays can only be reset manually after all trip signals are removed. At l Fort Calhoun,68 of these relays are in service.

l Observations and Findinas At the Fort Calhoun Station the engineered safeguards relays in use are General Electric HEA relays. The inspectors performed a historical review of the number of

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failures of lockout relays from 1973 to the present time. The results are documented in i the following table.

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! FAILURES CONTACT BINDING LOCKOUT BINDING TOTAL 1973 1 0 1 l

1974 1 0 1 1975 1 1 2 1976 0 1 1 1977 1 1 2 ,

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, 1978 1 2 3 l l 1

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1979 0 1 1

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I 1983 0 1 1 1984 1 3 4 1985 1 4 5 1986 0 0 0 1987 0 0 0 1988 0 1 1 1989 1 5 6 1990 1 2 3 1991 0 3 3 1992 1 2 3 1993 1 1 2 1994 0 1 1 l

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, 1996 3 0 3

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1997 1 0 1

} 1998 0 3 3 TOTAL 15 39 54

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l From 1973 to the present,54 failures of 86 lockt,ut relays have been identified through i testing or normal operation. These failures can be divided into two categories:

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A mechanical binding of the relay shaft resulting in the failure of the relay to l change state resulting in coil damage due to overheating (accounts for 39 of 54 failures), and '

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A single contact failed to change state when the relay was actuated (accounts ,

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for 15 of 54 failures).

l The inspectors discussed with the licensee the actions which had been taken to address i

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these failures and any planned future actions. Since a large percentage of the relay  ;

failures occurred in the relays which were tested most frequently, a facility license l change was approved allowing quarterly testing verses monthly testing of the relay l l Also, most of the original relays were scheduled to be replaced prior to the l 1999 refueling outage, in addition a recommendation was provided to the Nuclear Projects Review Committee to modify the cabinets containing the lockout relays by

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installing an air filtration system on the cabinets to filter the air and minimize the amount of dirt and dust reaching the relays. This recommendation was not approved due to the fact that agreement could not be reached on whether the air filtration system would actually provide a reliability improvemen ,

On June 26,1997, the 86 lockout relays were placed under paragraph (a)(1)of the Maintenance Rule due to the failure rate showing an increasing tren ,

The following goals were established for returning the 86 lockout relays to monitoring  !

under paragraph (a)(2) of the Maintenance Rule:

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A probability risk analysis was completed and determined that 86 lockout relays must be considered risk significant;

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Some contacts of some relays could be considered nonrisk-significant on a case-by-case basis; however, this was evaluated as not being very feasible;  :

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Replace 18 lockout relays not previously replaced during the 1999 refueling outage; and

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Examine the possibility of implementing additional preventive maintenance l activities to reduce failure rate i

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l The inspectors discussed all of the above actions with the licensee and were informed l

, . that during a recent meeting of engineering management an additional activity was l

being investigated. The proposed plan was to have an outside consultant review all of  ;

I the information on the 86 lockout relays and perform a failure analysis with l j

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recommendations for addressing the 86 lockout relay failure l l

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-10- ' Conclusions The licensee's actions in addressing lockout relay failures in the engineered safeguards logic system were considered timely and resulted in continued system operation. The licensee's efforts in developing an action plan to address the existing reliability concern caused by these failures was found to be goo IV. Plant SuDDort R1 Radiological Protection and Chemistry Controls R Radioloaically Controlled Area Housekesoina l Inspection Scope (71750)  !

l The inspectors assessed housekeeping inside the radiologically controlled are Observations and Findinas During the inspection period, the inspectors made numerous housekeeping tours throughout the radiologically controlled area. In general, the inspectors noted that housekeeping was good. Especially notable was the continued reduction of contaminated areas within the radiologically controlled are Also the radiation protection department is in the process of implementing several  !

I enhancements to the radiation protection program. These enhancements include simplifying the survey maps at the radiologically controlled access point to increase the workers' understanding of radiological conditions they are about to enter and changing ,

radiological posting signs for high radiation and restricted high radiation areas. The new, differently shaped signs should heighten worker awareness of elevated radiological {

condition l l Conclusions Radiation protection personnel continued to reduce contamination areas and several enhancements were being implemented to increase worker awareness of radiological ,

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conditions inside the radiologically controlled are . __ ___ _ ___- _ -____ __ _ ___ ___-_ ______

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-11-V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the exit meeting on December 21,1998. The licensee acknowledged the findings as presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie l

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C ATTACHMENT j l SUPPLEMENTAL INFORMATION f

PARTIAL LIST OF PERSONS CONTACTED l Licensee

l - K. Dowdy, Senior Production Planner

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D. Dryden, Station Licensing Engineer .

J. Foley, System Engineer .

! M. Guinn, Reactor Physics and Reactor Engineering  !

! M. Puckett, Acting Manager, Radiation Protection

! C. Schaffer, System Engineer l J. Solymossy, Plant Manager D. Spires, Manager, Quality Assurance and Quality Control INSPECTION PROCEDURES USED IP 37551: Onsite Engineering i IP 61726: Surveillance Observations l

! IP 62707: Maintenance Observations l lP 71707: Plant Operations  :

i IP 71750: Plant Support Activities e

IP 92700 Onsite Followup of Written Reports of Nonroutine Events at Power Reactor

! Facilities IP' 92901 Followup Operations l

IP 92902 Followup Maintenance l

! ITEMS OPENED. CLOSED. AND DISCUSSED l

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! 50-285/9719-02 VIO Inadequate Containment integrity Verification (Section 08.1)

50-285/9719-03 VIO Improperly Installed Locking Device (Section 08.2)

! 50-285/97-010 LER Violation of Technical Specifications While Moving Spent Fuel

in the Spent Fuel Pool (Section 08.3)

( 50 285/9720-01 VIO The inappropriate Use of Operations Memorandums to j Implement Procedure Changes (Section 08.4) ,

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2-50-285/97-002 LER Failure to Meet the Intent of Technical Specification 2.15(4)

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(Section M8.1)  ;

- 50-285/97-006 LER Loss of all Fire Suppression due to inoperability of Fire Pumps (Section M8.2) l 50-285/9715-03 IFl Criticality Monitors; Application for Exemption of 10 CFR I

70.24 (Section M8.3)

Opened and Closed l

50-285/9823-01 NCV Failure to Meet the Intent of Technical Specification 2.15(4)

(Section M8.1)

j 50-285/9823-02 NCV Violation of Technical Specifications While Moving Spent Fuel l in the Spent Fuel Pool (Section 08.3)

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