ML20211Q311

Insp Rept 50-285/87-02 on 870101-31.Violations Noted:Failure to Establish Controls to Prevent Misuse of Outdated Procedures & to Maintain Procedure for Operation of Onsite 480-volt Distribution Sys in up-to-date Condition

ML20211Q311
Person / Time
Site:	Fort Calhoun
Issue date:	02/13/1987
From:	Harrell P, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211Q231	List: ML20211Q225 ML20211Q233 ML20211Q244 ML20211Q311
References
50-285-87-02, 50-285-87-2, IEIN-86-106, NUDOCS 8703030063
Download: ML20211Q311 (18)

See also: IR 05000285/1987002

Text

.. -

.- .

APPENDIX C

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/87-02 License: DPR-40

Docket: 50-285

Licensee: Omaha Public Power District

1623 Harney Street

Omaha, Nebraska 68102'

Facility Name: Fort Calhoun Station

Inspection At: Fort Calhoun Station, Blair, Nebraska

Inspection Conducted: January 1-31, 1987

Inspector: -[. f- 2//3/f7

, P. H. Harre 1, Senior Resident Reactor Date

Inspector

Approved: / .T I

D. R. Hunter, Chief, Reactor Project Date

SectionB,ReactorProjectsBranch

Inspection Summary

Inspection Conducted January 1-31, 1987 (Report 50-285/87-02)

Areas Inspected: Routine, unannounced inspection including operational safety

verifications, maintenance, surveillance, plant tours, safety-related system

inoffice review of periodic and special

walkdowns, security

reports, followup observations,dentified

on previously i items, followup on a licensee event

report, 10 CFR Part 21 program review, and followup on IE Information

Notice 86-106.

Results: Within the 11 areas inspected, two violations (failure to establish

controls to prevent the misuse of outdated procedures, paragraph 5, and failure

to maintain the procedure for operation of the onsite 480-volt distribution

system in an up-to-date condition, paragraph 6) and one deviation (failure to

place all manual containment isolation valves under administrative controls,

paragraph 2) were identified.

P 2888# E885 6

PDM

. - _ - - _ _ - _ _ _ - _ _

. .

2

DETAILS

1. Persons Contacted

• R. Andrews, Division Manager, Nuclear Production .

• W. Gates, Plant Manager

• C. Brunnert Supervisor, Operations Quality Assurance

• M. Core, Supervisor, Maintenance

J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs

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

• J. Gasper, Manager, Administrative and Training Services

• R. Jaworski, Section Manager, Technical Services

M. Kallman, Supervisor, Security

• L. Kusek, Supervisor, Operations

• K. Morris, Division Manager, Quality Assurance and Regulatory Affairs

• D. Munderloh, Plant Licensing Engineer

• T. McIvor, Supervisor, Technical

R. Mueller, Plant Engineer

• A. Richard, Manager, Quality Assurance

G. Roach, Supervisor, Chemical and Radiation Protection

T. Patterson, Manager, Technical Support

J. Kecy, Acting Reactor Engineer

S. Willrett, Supervisor Administrative Services and Security

• Denotes attendance at the monthly exit interview.

The NRC inspector also contacted other plant personnel, including

operators, technicians, and administrative personnel.

2. Followup on Previously Identified Items

(Closed) Deviation 285/8527-02: Failure to meet a commitment relative to

storage of material in a temporary critical quality equipment (CQE)

storage area.

During an inspection performed by the Safety Systems Outage Modification

Inspection (SSOMI) team in December 1985 problems were identified related

to storage of CQE material in temporary storage areas. The details of the

problems identified by the SSOMI team are presented in Deficiency 2.9.1 of

NRC Inspection Report 50-285/85-29. This item is considered closed as the

problems associated with this deviation will be reviewed during closeout

of Deficiency 2.9.1.

(Closed) Severity Level IV Violation 285/8602-07: Inspection of uranium

hexafluoride (UF6) cylinders was not performed or the inspection was not

completed in accordance with license requirements.

The licensee noted in response to this violation, that the reason for the

missed inspection was that the inspection relied on the memory of an

_

. .- -

. . _ - . - - . - .

. - _ - - .

.. - .

s

3

individual to ensure that the inspection was performed in a timely manner.

In response to this violation, the licensee conducted a survey of all

departments to determine if other required surveillances relied on an

individual's memory in lieu of being entered into a proper tracking

system. This effort was perfomed to ensure other surveillances were not

missed because an individual left the company or failed to remember to

perform the surveillance. The results of the survey indicated that all

other surveillances had been entered into a tracking system to ensure that

surveillances were completed in a timely manner.

This violation also noted that an individual failed to perform an

inspection of the cylinders as required by Materials License SMC-1420.

The licensee reviewed other inspections performed by the individual and

found the results of the inspections to be satisfactory. Based on this

review, the licensee determined that the failure of the individual to

i properly complete the UF6 inspection was an isolated case.

The licensee issued a rremo to all individuals within the Technical

'

.

Services group to remind each one that procedural compliance was

mandatory. This memo included a requirement that procedures related to

procedural compliance be read. The memo was then signed by each

individual to signify that the reading assignment had been completed.

The NRC inspector reviewed the documentation associated with this

+ violation. The documentation included completed UF6 inspection reports,

the results of the survey performed by the licensee to verify all

surveillances were properly tracked, the review perfomed to establish

that the improper ~UF6 inspection was an isolated case, and the

read-and-sign memo issued to individuals within the Technical Services

,

group. Based on the documentation reviewed, it appeared that the licensee

i had taken appropriate corrective action and that the action will prevent

recurrence of this type of violation.

'

(Closed) Severity Level IV Violation 285/8603-01: Installation of a valve

j (F0-118) in the emergency diesel generator fuel oil system without use of

i a written and approved procedure.

!

l The licensee performed a review of the original documentation provided by

!

the emergency diesel generator supplier and determined that no

i documentation existed to indicate that F0-118 was provided by the

supplier. The licensee also performed a documentation search for a

procedure or maintenance order that provided instructions for installation

of F0-118. No documentation was located for installation of the valve.

Based on the negative results of the documentation search, the licensee

performed an engineering evaluation to determine that F0-118 could perfonn

its intended safety function. This evaluation also included

Valves F0-116, F0-117, and F0-119. These valves performed the same 4

function in the other fuel oil transfer lines. The results of the

t'

. ~ - - , - , - , - , - - - ,-,-,,-wn --w , - . _y-e, . - - - , .,-,_.-----v--,,---...--.-----i.-------------- _ _m _ __ ---------

_ _

. .

4

evaluation indicated that all the valves could perform their intended

safety function. The NRC inspector reviewed the evaluation and noted no

problems.

The generic aspects of this violation related to modification of a system

without proper documentation was also identified during an inspection

performed by the SSOMI team. Tne details of the SS0MI team finding in

this area are provided in Deficiency 2.2-2 of NRC Inspection

Report 50-285/85-29. The generic aspects of this violation will be

reviewed when Deficiency 2.2-2 is closed.

(Closed) Unresolved Item 285/8614-02: Administrative control of manual

containment isolation valves in branch lines.

Section 5.9.5 of the Updated Safety Analysis Report (USAR) states that

where a system penetrates containment and the system is inactive during

reactor operation, operation of manual containment isolation valves is

under administrative controls. Section 5.9.5 also states that branch line

connections between the containment.and the outside containment isolation

valves are equipped with valves to provide isolation integrity equal to at

least that of the main system. These requirements are provided to ensure

that all potential paths for release of radioactivity from the containment

following an accident are administratively controlled to prevent any

releases.

This unresolved item involved manual isolation valves in branch lines

between the containment and the outside containment isolation valve not

being placed under administrative control. The valves identified by the

NRC inspector were located in system branch lines that are inactive during

reactor operation. The affected branch lines with manual valves were in

the chemical and volume control system (Valves CH-517, CH-518, and

CH-535), main steam system (Valves MS-101 and MS-103), low-pressure safety

injection system (Valve SI-375), and component cooling water system

(Valves AC-1133, AC-1134, AC-857, and AC-858). The failure of the

licensee to place the manual containment isolation valves under

administrative controls is an apparent deviation from commitments made in

Section 5.9.5 of the USAR. (285/8702-01)

As stated in NRC Inspection Report 50-285/86-14, the licensee took

corrective actions to secure the potential release path by locking the

valves or installation of a cap on the end of the branch line for the

valves identified by the NRC inspector. The licensee performed a review

to detemine what valves, other than the ones identified by the NRC

inspector, were located in branch lines and were a potential containment

release path. The valves identified during the licensee's review were

either locked or the branch lines capped, as appropriate. The licensee

has not yet placed any of the valves under administrative controls.

-

,

. .

5

Subseguent to the review performed by the licensee,)the

identifiedtwoadditionalvalves(MS-101andMS-103 in branchNRClines inspector

not

previously identified by the licensee. Upon notification by the NRC

inspector, the licensee locked the valves shut.

3. Licensee Event Report (LER) Followup

Through direct observation, discussions with licensee personnel, and

review of records, the following event report was reviewed to determine

that reportability requirements were fulfilled, immediate corrective

action was accomplished and corrective action to prevent recurrence had

been accomplished in acc,ordacce with Technical Specifications (TS).

The LER listed below is closed:

1

86-003 Release of radioactive gas to the auxiliary building (AB)

LER 86-003 reported the release of radioactive gas to the AB due to use of

an inadequate procedure and due to incorrect installation of valves in the

sampling system. The release occurred on May 1, 1986.

At the time of the release, the waste gas sampling system was being

u) graded to replace the analyzers in the system that had become obsolete.

T1e system modification required installation of new valves and tubing to

accommodate the new sampling Janel (AI-110).- To provide a method for

obtaining samples manually, tie system modification instructions issued on

September 9, 1985, included a procedure for s This procedure

provided specific ste)-by-step instructions.Asystem use. continued on

installation

the system, the ste)-)y-step instructions in the installation procedure

became unusable. Tierefore, a revised arocedure (CMP-2.2, Revision 0) was

issued April 15, 1986, as part of the clemistry manual. Procedure CMP-2.2

did not contain the specific step-by-step instructions that were provided

in the installation procedure instructions. For example, one step in

Procedure CMP-2.2 stated that the sample point selector switch should be

returned to " normal" upon completion of sampling activities, but did not

specify what the normal position was. The selector switch could be placed

in lositions A through R. At the time of the release, the chemistry

tecinician left the selector switch in the A position instead of the

R position, which is the normal position. Leaving the selector switch in

the A position, aligned the sampling system to the volume control

tank (VCT) insteac of the nitrogen supply header. This error, in

conjunction with the system not being installed as provided by the system

installation instructions, allowed gas from the VCT to be vented to the AB

causing the AB radiation monitors to alarm, and an eventual offsite

release via the AB ventilation system. Operations personnel quickly

identified the problem and secured the gas release.

During review of the issuance of CMP-2.2, the NRC inspector noted that the

procedure was issued as an on-the-spot change. TS 5.8.3 only allows an

on-the-spot change if the intent of the original procedure is not altered.

Even though the intent of the changed procedure was to sample waste gas,

.. .

6

the configuration of the waste gas sampling system had been significantly

altered, thus making the old procedure obsolete. The issuance of a

revised procedure that provided operating instructions for an altered

system is considered to be a change of intent. On April 24, 1986, the

plant review committee (PRC) approved Procedure CMP-2.2 without making any

changes. The PRC reviewed the temporary change within the 14-day time

period allowed by TS 5.8.3. However, the PRC failed to note that the

on-the-spot change constituted a change of intent and that the procedure

failed to provide detailed step-by-step instructions.

The licensee issued a revision to CMP-2.2 on May 22, 1986, which provided

for proper operation of the AI-110 panel. The NRC inspector reviewed

CMP-2.2 and it appeared that the procedure provided adequate operating

instructions. During the review, minor editorial errors were noted. The

licensee stated the errors would be corrected.

During an inspection performed in December 1985 by the SS0MI team, tha

concern over making on-the-spot changes to procedures which change the

4

intent of the procedure was identified. The details of the SS0MI concern

are provided in Deficiency 2.3-2 of NRC Inspection Report 50-285/85-29.

The example described above of making improper on-the-spot intent changes

to procedures is an apparent violation of TS 5.8.3. .However, since this

violation occurred prior to the SS0MI team inspection and constituted

another example of the failure to comply with TS 5.8.3, this item will be

reviewed when closing Deficiency 2.3-2.

A final design package (MR-FC-84-160) was issued by generating station

,

engineering (GSE) personnel on August 22, 1985. This design package

provided a detailed discussion of the modifications to be performed for

installation of AI-110. The discussion also included a description of the

final system operation. This discussion stated that the solenoid-operated

valves (LCV-262A and B) on the inlet and outlet of the drain flask would

automatically shut whenever the sample pump was turned off. The

requirements provided in the design package were used to develop the

installation procedure (MR-FC-84-160) that was issued on-September 9,

1985.

The installation procedure provided a listing of the parts to be used in

the system modification. The parts listing included solenoid-operated

valves that were manufactured to fail shut. At the time of the release of

gas to the AB, solenoid valves LCV-626A and B failed open. By failing

open, the valves established a flow path from the VCT to the AB via the

gas vent header. In discussions with licensee personnel, it appeared that

fail-open solenoid valves from the old sampling system were substituted

for the fail-closed valves designated for the new sampling system. An

installation instruction change was not issued for this change of system

components. This unauthorized installation caused the installed system

configuration to be in direct conflict with the design package which

required the valves to fail shut.

.

,y y.- r- -r- -- , ---9

,. --. . _ _ , .-- -_ , - -

. . ~ _- - . _ . _. =- . -.

.- .

h

7

t

Subsequent to this occurrence, the licensee made changes in the procedures

controlling installation of modifications at the plant. These changes

required that the individual making a change to an installation package

also review the final design package to verify .that the change does not

conflict with the requirements provided in the ~ design package. If it is

,

discovered that a conflict exists, the individual must ensure that a

revision of the final design package is issued and the appropriate reviews

and approvals obtained. The procedure change for controlling installation

of modifications was made due to concerns identified by the SS0MI team.

The above example of a failure to install a system in accordance with

documented instructions is an apparent violation of Criterion V of

Appendix B to 10 CFR Part 50. However, this problem constitutes a similar

problem identified by the SSOMI team. The problem discussed above will be

,

reviewed when Deficiency 2.5.2 of NRC Inspection Report 50-285/85-29 is

closed. ,

Based on the review performed by the NRC inspector, it appeared that the

release of the gas to the AB was partly caused by a chemistry technician

using a procedure that did not provide sufficient detail for the operation

being conducted. The inadequate procedure was issued due to a lack of

attention to details by the individuals who reviewed and approved the

procedure. In combination with an inadequate procedure, the release was

, also partly caused by installation of valves in a system that did not

conform to the requirements stated in the final design package. The

installation of the wrong valves was due to the failure of the GSE

engineers involved with the installation to process a document change for

installation of valves other than the valves required by the installation

instructions. As stated above, the problems identified during closecut

'

of this LER will be reviewed in conjunction with closeout of

Deficiencies 2.3.2 and 2.5.2 of NRC Inspection Report 50-285/85-29.

*

'

No violations or deviations were identified.

4. Operational Safety Verifications

t

The NRC inspector conducted reviews and observations of selected

activities to verify that facility operations were performed in

conformance with the requirements established under 10 CFR, administrative

procedures, and the TS. The NRC inspector made several control room

observations to verify:

. Proper shift staffing

l . Operator adherence to approved procedures and TS requirements

. Operability of reactor protective system and engineered safeguards

equipment

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

switch positions complied with the appropriate requirements

. - -. . - - - . .. - - - . -.- -- _ _ - _ - _ . _ _ - , _ . _ - -- . . . . __

. _ . ._ _

s

. .

, 8

. Proper return to service of components

. Maintenance orders (M0) initiated for equipment in need of

maintenance

. Appropriate conduct of control room and other licensed operators

No violations or deviations were note'd.

-

5. Plant Tours

The NRC inspector conducted-)iant-tours at various times to assess plant

and equipment conditions. T1e following items were cbserved during the

tours:

. General plant conditions

. Equipment conditions, including fluid leaks and excessive vibration

. Plant housekeeping and cleanliness practices including fire hazards

and control of combustible material

. Adherence to the requirements of radiation work permits

.

. Work activities performance in accordance with approved procedures

During tours of the plant, the NRC inspector noted that some of the

procedures posted in the plant were out of date in that the latest

revision was not posted. The licensee )osts drawings and procedures in

the plant to serve as operator aids. T1is documentation assists the

operators in performance of routine and emergency safety-related plant

<

evolutions. The procedures noted by the NRC inspector to be out of date

i

'

included the TS reference sheet for the boric acid heat tracing

temperature readouts posted on the TAR panel, Sheet 2 of Procedure 01-EE-4

.

)osted on Panels AI-42A and AI-428, and Section IV of the Technical Data

300k, which provides setpoints for process and area monitors posted near

4

the area monitors. ThelicenseeestablishedProcedure50-0-41," Control

of Temporary Labels, Curves, Notes, or Instructions Attached to Plant

, Components and Controls," to ensure that operator aids were maintained up

l

to date. This procedure required that the revision of operator aids be

l verified once each quarter. The last revision verification was performed

on October 25-27, 1986. In the case of the documents identified as being

i

out of date,ification

revision ver made in accordance with S0-0-41. For

revisions had been issued si

this reason,

it does not appear that the performance of Procedure 50-0-41 will -)rovide

assurance that the misuse of outdated documents can be avoided. T1e

licensee had not included the out-of-date procedures in the existing

document control system to ensure that the latest revisions were posted in

the plant whenever a new revision to the affected procedure was issued.

i

1

. . -. - . . - . - - . - _ . - . _ - - - . . . - .-. . .- .

.

.

'

t

.

9

i

.

1

Criterion VI of Appendix B to 10 CFR Part 50 requires that measures be

established to control the issuance of documents, such as instructions,

'

procedures, and drawings,Lincluding changes thereto, which prescribe all

i activities affecting quality. - Paragraph 4.1.1 of Section 2.1 of the

i- 11cc.nsee's Quality Assurance Plan requires, in part, that controls be  ;

?

provided to avoid the misuse of outdated or inappropriate documents. It

'

appeared that the licensee has not established measures that will ensure

that outdated documents are not used in the plant in that procedures used

, as operator aids have not been included in the licensee's document control

-

program. This is an apparent violation. (285/8702-02)

i

! Upon notification by the NRC inspector, licensee personnel removed the

! outdated postings and replaced them with the correct revision. Licensee

personnel also performed a review to verify that other. documents posted as

operator aids were the current revision.

' During tours of the plant, the NRC inspector identified the following:

l . Unsecured gas cylinders were observed in the AB. The type identified

was the large-volume nitrogen cylinders used by the chemistry

department. Upon notification by the inspector, the licensee secured

the cylinders. This is a continuing problem as noted during the last

l

inspection period.

.

f . Room 81 continued to be messy as noted during the last inspection

i period. The room was cluttered with hoses, lengths of rope, wood  ;

scraps, electrical cords, and tools.- The licensee had not provided ,

additional housekeeping attention prior to the end of this inspection

period,

j . Fire Door 1011-1 was found to be nonfunctional in that the door would

not latch at times. This problem was noted during the last

inspection period and the licensee adjusted the door closer to make

the door functional. Subsequent to the adjustment, the door closer

i again failed to operate properly. The licensee replaced the door )

l closer and door latch during this inspection period and it appeared

l that the door operated properly. During the period the door was

nonfunctional, the licensee had established an hourly fire watch in  ;

accordance with the TS.  !

l

! . Evidence was found of smoking in a safety-related area posted as a no s

smoking area. The inspector noted that cigarettes had been crushed

'

out on the floor. 1

l . A boric acid leak was noted where the chemical injection system

penetrates the main feedwater system. The configuration of the

piping insulation on the carbon steel main feedwater line could

, potentially allow the boric acid to enter the area between the

! feedwater piping and insulation undetected. Boric acid in contact i

l with the feedwater line could accelerate the rate of corrosion of the

i

!

- - - . - . . - - -. - . - - - ,- - - _ - . - - .- - -. _ _ - . - - - .

..- . - . - _ . . - .

. -

. .

10

carbon steel piping. The licensee had not taken corrective action to

ensure that boric acid does not contact the feedwater piping prior to

the end of this inspection period.

6. Safety-Related System Walkdowns

r The NRC inspector walked down accessible portions of the following

safety-related systems to verify system operability. Operability was

, determined by verification of selected breaker positions. The systems

were walked down using the drawings and procedures noted:

. Plant electrical 125-Vdc distribution (USAR Figure 8.1-1 and

Procedure OI-EE-3, Checklist EE-3-CL-A)

. Plant electrical 480-Vac distribution (USAR Figure 8.1-1 and

Procedure 01-EE-2,ChecklistEE-2-CL-E)

During walkdown of the 125-Vdc system, minor discrepancies of an editorial

nature were identified between the as-built plant conditions and

Figure 8.1-1. None of the conditions noted affected the operability or

safe operation of the system. The licensee stated the discrepancies would

be corrected.

During walkdown

noted between theof the 480-Vac

as-built plant condi system,tions and Checklist EE-2-CL-E.approxima

The

-

discrepancies included breakers listed on Checklist EE-2-CL-E that were

, not installed in the plant and breakers installed in the plant that were

. not listed on Checklist EE-2-CL-E.

TS 5.8.1 requires, in part, that written procedures be maintained that

meet or exceed the requirements of Appendix A to Regulatory Guide 1.33.

Appendix A to Regulatory Guide 1.33 saecifies that operation of the onsite

480-Vac electrical system be covered )y written procedures.

i

Checklist EE-2-CL-E of Procedure OI-EE-2, " Normal Operation of the

480-Volt System," was established by the licensee to provide instructions

to o)erations aersonnel for reestablishing electrical loads in the plant

in tie event tlat all electrical power was lost to the 480-volt electrical

system.

!

The failure to maintain Checklist EE-2-CL-E of Procedure OI-EE-2 in an

up-to-date status so that the checklist accurately reflects the as-built

i

plant conditions is an apparent violation. (285/8702-03)

In addition to the above, the NRC inspector also noted minor errors of an

editorial nature between the as-built plant conditions and Figure 8.1-1.

, The discrepancies noted did not affect the operability or safe o)eration

of the plant. The licensee stated that the discrepancies would 3e

corrected.

. . - _ _ . . ._ -.

- . . -

. - . .- -_ - -_ -_- _. - - _ . . .

_

.- ..

11

During walkdown of the 480-Vac system, the NRC inspector did not note any

problems associated with alignment of the electrical load breakers on the

480-Vac motor control centers.

7. Monthly Surveillance Observations

The NRC inspector observed selected portions of the performance of and/or

reviewed completed documentation.for the TS required surveillance testing

on safety-related systems and components. The NRC inspector verified the

following items during the testing:

. Testing was performed by qualified personnel using approved

procedures.

. Test instrumentation was calibrated.

. The TS limiting conditions for operation were met.

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

accomplished.

. Test results conformed with TS and procedure requirements.

. Test results were reviewed by personnel other than the individual

directing the test.

. Deficiencies identified during the testing were properly reviewed and

resolved by appropriate management personnel.

The NRC inspector observed and/or reviewed the documentation for the

following surveillance test activities. The procedures used for the test

activities are noted in parenthesis.

. Monthly auxiliary feedwater pum) check (ST-FW-1-F.2)

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

. Monthly AB air filtering units test (ST-VA-4-F.2)

. Adjustmentofradiationmonitorsetpoints(CP-050-15)

No violations or deviations were identified.

8. Monthly Maintenance Observations

The NRC inspector reviewed and/or observed selected station maintenance

activities on safety-related systems and components to verify the

maintenance was conducted in accordance with approved procedures,

regulatory requirements, and the TS. The following items were considered

during the reviews and/or observations:

- )

e' s

12

. The TS 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 applicable.

. Functional testing and/or calibrations were performed prior to

returning components or systems to service.

. Quality 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 PRC inspector reviewed and/or observed the following maintenance

activities:

. Repairoffiredoor1025-4(M0864475)

. Sealing of gaps and holes in the control room boundary (M0 864097)

. Testing of control room for the capability to maintain a positive

pressure (M0864005)

. Drilling of holes in cable spreading room for cable pulls (M0 870005)

. Hydrostatic testing of steam generator nozzle dams (M0 864673)

No violations or deviations were identified.

l

'

9. Security Observations

The NRC inspector verified the physical security plan was being

implemented by selected observation of the following items:

l . The security organization is properly manned.

. Personnel within the protected area (PA) display their identification

badges.

l . Vehicles are properly authorized, searched, and escorted or

controlled within the PA.

. Persons and packages are properly cleared and checked before entry

l

into the PA is permitted.

l

!

l

. .

13

. The effectiveness of the security program is maintained when security

equipment failure or impairment requires compensatory measures to be

employed.

No violations or deviations were identified.

10.- Inoffice Review of Periodic and Special Reports

Inoffice review of periodic and special reports was performed by the NRC

resident inspector and/or the Fort Calhoun project inspector to verify the

following, as appropriate.

. Reports included the information required by appropriate NRC

requirements.

. Test results and supporting information were consistent with design

predictions and specifications.

. Determination that planned corrective actions were adequate for

resolution of identified problems.

. Determination as to whether any information contained in the report

should be classified as an abnormal occurrence.

During review of reports, NRC personnel. identified 10 CFR Part 21 reports

submitted by suppliers or vendors that appeared to be applicable to the

licensee's facility. The NRC resident inspector provided copies of these

reports to the plant licensing engineer for review of applicability by the

licensee. The reports provided are listed below.

. A re) ort from the Foxboro Company, dated October 7, 1985, related to

the landling of N-Ell and N-E13 transmitters.

. A report from the Virginia Electric and Power Company, dated

November 12, 1986, related to defective steel products supplied by

Inland Steel, a subsupplier of the Rockwell Engineering Company.

No violations or deviations were identified.

11. Followup on IE Information Notice (IEN)86-106

IEN 86-106 was issued by the NRC to alert licensees of a potentiall

generic problem related to pipe thinning in balance-of plant (80P) y

systems. The purpose of this followup was to datermine what actions had

been taken or will be taken by the licensee to address this generic issue.

The NRC resident inspector met with licensee representatives to establish

what actions were performed in the past related to checking for wall

thinning in B0P systems, and what actions were planned for the future. In

e y

.n .

, ,

- '

. . m

,

_

_

,

.

.

14

e

-

<

!

these aiscussions, the licensee stated thEt testing on the Resi

extractidn~ piping had been performed in the past to detect any ' wall

thinning problems. '

The licensee is ctirrently in the process of establishing a, program foi -

testing additional B0P systcas. The systems to be tested include steam,

feedwater, heater drains, heater vents, and blowdown piping. These

systems were selected because of possible two-unase-flow conditions. ,

'

Ultrasonic testing will be performed at approximately 160 preselected-

locations where engineering evaluations indicate the greatest potential

for failure exists. This program will be established prior to and the

testing performed during the upcoming refueling outage. The proposed '

program is described in Procedure PM-PIPE-1 and will be presented to the ,.

plant review committee prior to the refueling outage for approval. The

outage is scheduled to run from March through May 1987.

The licensee stated that'the results of the tests will be evaluated and at / -

that time, decisions will de made as to what corrective actions are >

appropriate. The NRC inspector will review the results of the tests

performed by the licensee. This is an open item pending c epletion of

this review. (285/8702-04) '

No vioiations or deviations were identified.  ;

12. 10 CFR Part-21 Program Review /

A review of the licensee's program established to meet the requirements of

10 CFR Part 21 was performed. The review included the following elements:

. Procedures have been establisheA and are adequate to ensure proper

implementation of 10 CFP Part 21 requirements.

. Documentation required by 10 CFR'Part 21 has been posted in areas

where safety-related work activities are conducted.

. Specification of the application of 10 CFR Part 21 requirements in

applicple procurement documents.

.. Evaluation a self-identified deviation, condition, or circumstance

was performed'by the licensee for determination of. reportability

under the requirements of 10 CFR Part 21.

~

,

. Evaluation by-the licensee of a condition, deviation, or circumstance

reported by vendors or suppliers to determine the affect of safe ,

operation of the facility.

. Verification that facility modifications were performed when the

licensee's evaluation indicated that a modification was appropriate.

The NRC ins)ector re.'iewed the procedures established by tue licensee to

implement t1e requirements of 10 CFR Part 21. The documentation reviewed

i

i

.. .

i

15

included Procedure 50-G-42, "Re

Nuclear Regulatory Commission," porting

Revision of Defects

6; Procedure and

H-2, Noncom)liance

" Report of to the

Defects and Noncompliance to the Nuclear Regulatory Commission,"

Revision 0; and Procedure QADP-19, "10 CFR 21, Reporting Defects and

Noncompliances," Revision 2. Procedure S0-G-42 3rovides reporting

instructions for persons assigned to the alant, )rocedure H-2 provides

instructions for individuals working in t1e Omaha offices, and, s

ProcedureQADP-19providesthequalityassurancedepartmentinstructions

for reporting defects. Based on the review of these procedures, it

appeared that they adequately implement the evaluation and reporting

requirements of 10 CFR Part 21. The NRC inspector discussed with ITcensee

personnel, the reason for having three different procedures that address

thesamesubject. Licensee personnel stated that three procedures were

implemented because the procedures provide reporting instructions for

three different groups within the licensee's organization. Tae NRC

inspector suggested that the licensee consider establishing one procedure

that will provide instructions for all personnel thus eliminating possible

confusion as to which procedure is aapropriate for each group within the

organization. The licensee stated tlat a review for establishing one

procedure would be performed.

The NRC inspector reviewed the postings required by 10 CFR Part 21 to

verify the appropriate documents of the latest revision had been posted.

The review included verification of )ostings at the )lant site, Jones

Street offices, and at the Brandeis auilding. The NRC inspector noted no .

problems except that the posting of 10 CFR Part 21 and the implementing

procedure at the Brandeis building were not the current revision. Upon

notification by the inspector, licensee personnel promptly posted the

current revisions of both documents.

The NRC inspector reviewed a selected sample of the available

documentation for evaluations performed by the licensee for

self-identified conditions, deviations, or circumstances. Eased on this

review, it appears that the licensee is performing an adequate review.

The licensee issued a 10 CFR Part 21 report based on self-identification

of a condition in March 1986. This report was related to the failure of

disc guide assembly springs in Valcor valves. The licensee initiated

documentation for replacement of the springs during the 1987 refueling

outage.

The NRC inspector also reviewed a selected sample of the evaluations

performed by the licensee for deviations, conditions, or circumstances

identified by vendors or suppliers. The evaluations were aerformed to

determine the applicability of the identified problem to tie safe

operation of the facility. The evaluations reviewed by the NRC inspector

are listed below:

. A Gibbs and Hill report dated March 17, 1986, identified five

problems associated with the Comanche Peak Steam Electric Station.

The report was sent to the licensee as Gibbs and Hill was the

architect-engineer for the Fort Calhoun Station. The report

,

s . ,

• ,

V.

x

p

s

I

16

,

7

identified problems associt.ted with the seismic qualification of the

-

containment spray recirculation lines, cooling of containment

t

, pressure instruments during an accident, radiation detectors in the

component cooling water system not being safety-grade instruments,

3's'ervice water discharge lines being classed as non-nuclear. safety

,

'

, grade, and an inadequate acceptance test procedure for the instrument

air systemc The licensee evaluated each of the five problems and

m

,

, determined that the problems were not applicable to the facility.

.- A ' report issued by the Franklin Institute Research Laboratory on

^ July 26,1983, related to the qualification testing of Fisher

Typc-304 switch assemblies. The licensee performed an evaluation

(licensee reference o)erational support analysis report (0SAR) 83-21)

e and detemined that tie switches sent to Franklin were not the

'

". y correct ones-and subsequently provided the appropriate switches. The

". o testing performed on the replacement switches was satisfactory.

,

. A report issued by Pacific Scientific on September 30, 1982, related

A to testing of their snubbers by other vendors causing damage to the

snubbers. Based on the evaluation (licensee reference OSAR 82-29)

perfomed by the licensee, the affected snubbers were sent to Pacific

Scientific for testing. The tests indicated the snubbers performed

1 satifactorily. The NRC inspector reviewed the licensee actions

related torthis' deviation and noted no problems.

'

'

q

. , On September 12, 1983, Comsip reported that the catalyst bed used in

their hydrogen analyzers would not meet environmental equipment

' qualification requirements. The licensee performed an evaluation

(licensee: reference OSAR 83-16) and determined that the hydrogen

analyzers ' installed at the plant contained the specified catalyst

bed. The licensee issued modification instructions and replaced the

. catalyst bed with a bed that met the appropriate requirements. The

.3, NRC inspector reviewed the documentation associated with this

i d deviation and noted no problems.

t

l During this review, it was noted that the NRC had identified three 10 CFR

,

Part 21 Reports issued by suppliers or vendors that the licensee did not

i have a record of receiving or evaluating. The NRC inspector provided

copies to the licensee for their review and evaluation. The reports

iF

l, ,

provided by the NRC inspector included the following.

ie

On June 6, 1986, Atwood and Morrill issued a report related to

'

't .

'

failure of the closing springs in their main steam isolation valves.

Licensee personnel stated that the report was not received. On

>

~

v September 15, 1986, the NRC issued IE Information Notice (IEN) 86-81

, that discussed the same defect as was discussed in the Atwood and

l Morrill report. The licensee reviewed IEN 86-81 and determined that

it was not applicable to the Fort Calhoun Station as the licensee

i does not have Atwood and Morrill valves.

,

. - - - _ -_ . - __

. ~. . - .- -- - - .-. . - . .

. . - .

2

-

17

~

. A report from Promatec, dated February 17, 1986, related to defective

fire barrier seals.

2 -. A re) ort from Northeast Utilities, dated May 25, 1984, related to

crac(s in charging pump blocks.

A report from the Technology for Energy Corporation, dated July 19,

~

.

1985, related to a higher than acceptable defect rate in Model 914-1

valve flow monitor modules.

'

During a review of the status of 10 CFR Part 21 Reports identified by the

NRC as applicable to the Fort Calhoun Station, NRC inspector noted that

',

the licensee had not established an adequate tracking system to identify

which reports had been reviewed. If the licensee reviews a 10 CFR Part 21

Report and determines that it is not applicable to their facility, no

record is maintained to verify that a review was performed. The licensee

has established the OSAR system for tracking of items that have been

reviewed, but does not include all reviews in this system. For this

reason, a definite determination could not be made as to whether the

licensee received and/or reviewed specific 10 CFR Part 21 Reports.

Licensee personnel stated that all 10 CFR Part 21 Reports received for

review would be entered into the 0SAR system in the future.

The NRC inspector also reviewed licensee actions related to the

specification of 10 CFR Part 21 requirements in procurement documents. In

'

reviewing approximately 40 purchase orders, no examples were noted where

10 CFR Part 21 was not appropriately included in the procurement

t

documentation. However, in discussions with licensee personnel, it

appears that some confusion exists as to when 10 CFR Part 21 should be

applied to purchase order documentation. The NRC inspector determined

that the confusion existed due to no training being given to employees in

l

application of 10 CFR Part 21 requirements.

The NRC inspector reviewed an internal audit performed during December 15

I

through December 23, 1986. The audit, issued on January 22, 1987, was

performed by the licensee's quality assurance group to verify that the

requirements of 10 CFR Part 21 were being properly implemented within the

licensee's organizations. The results of the audit identified the same

types of problems as was noted by the NRC inspector. The problems

identified were related to the following areas.

. A systematic and generic problem with the issuance and control of

procedures and instructions related to 10 CFR Part 21 reporting

responsibilities. (Deficiency Report (DR) FC1-87-003)

. A systematic and generic problem related to training of employees in

application of 10 CFR Part 21 requirements. (DRFC1-87-004)

Since the licensee's quality assurance group had identified the same type

problems as the NRC inspector prior to the performance of the NRC

inspection, no violations or deviations were written. The NRC inspector

. . . _ - . _ _ _ . _ __ _ _ _ . . _ _ _ _ _ _ . . _ . _ _ _ _ , , - _ _ _ _

s

.. .

18

will review'the corrective actions taken by the licensee for the internal

audit deficiencies during a future inspection in this area. This is an

open item 285/8702-05)

actions. p(ending completion of the NRC's review of the corrective

No violations or deviations were identified.

13. Exit-Interview

The NRC inspector met with you' and other members of the licensee staff at

the end of this inspection. At this meeting, the NRC inspector summarized

the scope of the inspection and the findings.

.

,

f

!

!

i

l