ML20148S200
| ML20148S200 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/22/1988 |
| From: | Harrell P, Hunter D, Reis T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148S078 | List: |
| References | |
| 50-285-87-24, NUDOCS 8802020359 | |
| Download: ML20148S200 (23) | |
See also: IR 05000285/1987024
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APPENDIX C-
U.S.LNUCLEAR REGULATORY COMMISSION
REGION IV
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, NRC Inspection' Report: 50-285/87-24 Operating License: DPR-40:
Docket: 50-285
Licensee: Omaha Public Power District (0 PPD)
3623 Harney Street
Omaha, Nebraska 68102
Facility Name: Fort Calhoun Station (FCS)
Inspection At: Fort Calhoun Station, Blair, Nebraska
Inspection Conducted: September 1-30, 1987
Inspector: OR C / 88
P. II. Harrell, Sen'ior Resident Reactor Date
Inspector
2
b yi L A , ,---
T. Reis, Resident Reactor Inspector
Iktle8
Date
Approved: OlbJM
D. R. Hunter, thief, Technical Support Staff
l[LL/88
Date
Division of Reactor Projects
Inspection Summary
Inspection Conducted September 1-30, 1987 (Report 50-285/87-24)
Areas Inspected: Routine, unannounced inspection including followup on
,previously identified items, licensee event report followup, operational safety
verification, plant tours, safety-related system walkdowns, monthly maintenance
observations, monthly surveillance observations, radiological protection
observations, in-office review of periodic and special reports, review of
10 CFR Part 21 program, and followup on IE Information Notices and IE Bulletins
issued for information only.
8802020359 880125
$DR ADOCK 05000285
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-Results: Within the 11 areas inspected, 6 violations ~(failure to properly
' store compressed gas cylinders.;in the auxiliary building, paragraph 5; failure
- to establish a procedure for controlling the~ erection.of temporary scaffolding.
in areas containing-safety-related equipment, paragraph-5; failure to post:
up-to-date 10 CFR Part 21 documentation, paragraph 12) and l' deviation (failure
to implement. interim measures for control of fire-barriers, paragraph 2.m) were
identified.
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DETAILS j
1. Persons Contacted
- R..Andrews, Division Manager, Nuclear Production i
- W. Gates, Plant Manager l
- C. Brunnert, Supervisor, Operations Quality Assurance l
- H. Core, Supervisor, Maintenance
- T.- Dexter, Supervisor, Security
- J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs
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J. Foley, Supervisor, I&C and Electrical Field Maintenance
H. Faulhaber, Manager, Electrical Engineering, Generating Station
Engineering
- J. Gasper, Manager, Administrative and Training Services
- L. Gundrum, Plant Licensing Engineer
- R. Jaworski, Section Manager, Technical Services
J. Kecy, Acting Reactor Engineer
R. Kellogg, Technical Services Engineer
M. Klanderud, Licensing Engineer '
L. Kusek, Supervisor, Operations-
O. Hunderloh, Plant Licensing Engineer
- T. McIvor, Supervisor, Technical
R. Mueller, Plant Engineer
- A. Richard, Manager,-Quality Assurance
G. Roach, Supervisor, Chemical and Radiation Piotection
- R. Scofield, Supervisor, Outage Projects
- D. Trausch, Nuclear Production Engineer
S. Willrett,' Supervisor, Administrative Services and Security
- Denotes attendance at the monthly exit' interview.
The.NRC inspectors also contacted other plant personnel, including operators,
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technicians, and administrative personnel.
2. Followup on Previously Identified Items
a. (Closed) Open Item 285/8623-03: Modification of Exhaust Piping on
the Security Diesel Generator - This item was related to the failure
of the security emergency diesel generator while supplying power to
security equipment. A review by the licensee determined that the
diesel stopped because the air intake filter had become clogged due
to exhaust gasses entering the fresh air intake.
Initially, the licensee indicated that a review would be performed to
determine if a modification to the diesel exhaust piping should be
made. The licensee subsequently determined that a preventive
maintenance (PM) instruction would be issued to require the air
intake filter to be changed monthly. PM EE-24 was issued and
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performed on September 29, 1986, to' change the filter. The licensee
has changed the filter monthly since initiating the PM.
The NRC inspector reviewed the actions taken by the licensee. .It.
appears that the actions taken by the licensee will ensure that the
security diesel will be available when needed. The NRC inspector
noted that the licensee had tested the security diesel weekly since
the event and no further problems were encountered and that during
sustained diesel operations, the licensee personnel have been
instructed to routinely check the condition of the air intake filter.
b. (Closed) Severity Level IV Violation 285/8522-II.F.1.1
(Deficiency 85-22/2.1-8): Incorrect Information on Flow Diagram for
the Main Steam System - This violation noted that Drawing M-252
incorrectly represented the piping arrangement associated with'the
bypass valves and the auxiliary feedwater steam warm-up lines.
In response to this violation, the licensee revised and reissued
Drawing M-252 to correctly represent all lines associated with the
main steam system.
The NRC inspector reviewed and performed a walkdown of the main steam
system to verify that Drawing M-252 accurate.y reflected the plant
as-built conditions. No problems were noted.
During each inspection period, the NRC inspector walks down a
selected safety-related system to verify that the plant drawings
accurately reflect plant as-built conditions. During recent system
walkdowns, the NRC inspector occasionally found errors between the
drawings and the as-built plant, but the errors were of an editorial
nature and did not affect the safe operation of the plant or the
operability of the system. After each walkdown, the licensee
corrected the minor errors noted by the NRC inspector.
c. (Closed) Severity Level IV Violation 285/8529-II.A.2
(Deficiency 85-29/2.2-1): Installation of Temporary Lead Shielding
Without an Engineering Evaluation.- This violation described a
problem where the licensee was installing temporary lead shielding on
safety-related piping without performing an engineering evaluation to
determine if the piping could withstand the stresses caused by the
additional weight of the lead.
The licensee analyzed all locations where lead shielding had been
installed and a documented engineering evaluation was not available
for review at the time tha violation was identified. In each case
reviewed by the licensee, no cases were noted where the installed
piping had been ovec stressed due to the weight of the shielding. In
four of the locations, the licensee opted to leave the shielding
installed. The licensee performed appropriate calculations to verify
that no piping degradation existed. In addition, the licensee
securely attached the shielding to ensure that the shielding would
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not shift or move on the piping. The weight of the attachments was
considered in the engineering evaluations.
The. licensee has established a program through the issuance of-
Procedure 50-G-57, "Installation of Temporary. Lead Shielding," to
. ensure that a proper engineering evaluation was performed and
. documented prior to the. installation of any lead shielding. The
program required that an independent review be performed to verify
that the-required analysis and safety evaluation were completed prior
to approving installation.
The NRC inspector reviewed a selected number of evaluations to verify
that the shielding installed without a documented engineering
evaluation did not affect piping integrity, reviewed the evaluations
and actual installation for the four locations where the shielding
was left installed to verify proper installation, and reviewed
. Procedure 50-G-57 to verify that the licensee had established an
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appropriate program for control of shielding installation.
During the 1987 refueling outage, the NRC inspector reviewed the
installation of temporary lead shielding on several occasions to
verify that an engineering evaluation had been performed and that the
shielding was installed in accordance with the installation
instructions. For each case reviewed, the licensee had properly
installed the shielding.
Based on the review performed by the NRC' inspector, it appeared that
the licensee had performed evaluations for installed shielding and
had established a program to adequately control future shielding
installations,
d. (Closed) Severity Level IV Violation 285/8529-II.A.3
(Deficiency 85-29/2.2-2): Swagelok Fitting Installed Through Fire
Barrier at the Entrance to Room 17 - This item invcived the
installation of a stainless steel Swagelok fitting through a fire
barrier. The licensee could not produce documentation to indicate
that the installation of the fitting was performed in accordance with
an approved plant engineering field change.
The licensee, prior to startup from the 1985 refueling outage,
performed an evaluation and determined that the installation of the
fitting did not degrade the fire barrier. The review of this portion
of the followup on this violation is documented in NRC Inspection
Report 50-285/86-03.
The licensee revised and upgraded Procedure 50-G-58, "Fire Barrier
Protection," to include requirements for identification and
evaluation of all existing fire barrier penetrations. A program for
identification was completed and the evaluations performed on the
penetrations indicated some penetrations were inadequate. The
licensee repaired the inadequate penetrations. The barrier
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containing the stainless steel fitting identified by this violation
was replaced with a new fire door.
The NRC inspector reviewed Procedure 50-G-58 to verify that the
-licensee had establishrd.an adequate program to ensure an evaluation
was performed prior to installing a penetration. It appeared that
the program was adequate. In addition, the NRC inspector performed
numerous plant tours to identify any penetrations that had been
installed without prior approval. No penetrations were identified
during the tours.
e. (Closed) Severity Level IV Violation 285/8529-II.A.4
(Deficiency 85-29/2.2-3): Safety Evaluations for Installation of
Temporary Jumpers had not been Performed - This violation was related
to the. failure of the licensee to perform evaluations.for electrical
and mechanical jumpers and blocks installed in safety-related
systems. It was noted during the inspection that some jumpers had
been installed greater than 18 months.
The licensee performed a review of all electrical and mechanical
jumpers installed at the time of the inspection to verify none of the
jumpers adversely affected the operation of a safety-velated system.
No problems were noted. The li:ensee also revised Procedure 50-0-25,
"Electrical and Mechanical Jumpers and Block Control," to include
requirements previously unaddressed in Procedure 50-0-25. The new
requirements included performance of a documented safety evaluation
prior to installation of a jumper or block, review of jumpers and
blocks for initiation of a design change to make long-term temporary
system changes into permanent system modifications, and
implementation of a tracking system to ensure the design changes are
implemented in a timely manner.
The NRC inspector reviewed the jumper and lifted lead log to verify
that all temporary modification activities performed on
safety-related systems received an evaluation prior to installation
of the modification. During review of the log, the NRC inspector
noted no problems with the performance of evaluations. There were
two temporary modifications that had been installed in systems for
greater than 18 months. In both cases, the licensee had initiated
and scheduled system design changes to make the temporary
modifications permanent. A review of the log also indicated tnat the
Supervisor, I&C and Electrical Maintenance and the Plant Engineer
reviewed the temporary modification log each month to verify that all
installed jumpers and blocks were necessary. The NRC inspector
performed a review of Procedure 50-0-25 to verify that the procedure
appropriately implemented a program that provided adequate control of
temporary jumpers and blocks. Based on the various reviews
performed, it appeared that the licensee had established and
implemented an acceptable program for control of temporary
modifications.
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f. (Closed) Unresolved Item 85-29/2.5-2 of NRC Inspection
Report.50-285/85-29: No Documentation Available for Replacement of
0-rings in Foxboro Transmitters .This unresolved item identified
that the licensee could not produce documentation for replacement of
the-'0-rings.in Foxboro transmitters following instrument calibration.
The calibration procedures used by the licensee required 0-ring
repla_ cement in order to maintain the equipment qualification of the
transmitters.
The licensee replaced the 0-rings in all Foxboro transmitters prict
to plant startup from the 1985 refueling outage. Each 0-ring
replacement was documented by an informal notation in the calibration
procedure for each instrument and by completion of a Form FC-198
"Electrical Equipment Qualification / Qualified Life Program
Information Sheet." In addition, the licensee made changes to all ,
affected calibration procedures to require that formal entries be
made to record the part and purchase order numbers for the 0-ring
used, and a verification sign-off that the transmitter cap was
torqued to the proper value. By including this information in each
calibration procedure, the licensee established a method for easily
retrievable documentation for verification of 0-ring replacement.
The NRC inspector reviewed a selected sample of completed calibration
procedures that were performed during the 1985 refueling outage to
verify that documented evidence existed to indicate that the 0 rings
were properly replaced. The NRC inspector also reviewed selected
calibration procedures to verify that changes had been made to
require documentation of 0-ring replacement in each calibration
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procedure. No problems were noted.during the reviews.
g. (Closed) Severity Level IV Violation 285/8529-II.F.1.b
(Deficiency 85-29/2.8-1): Failure to Properly Perform a Battery
Charger Test - This. violation was related to the failure of the
licensee to perform an adequate test of Battery Charger 3. The test
did not require that data be taken at specific time intervals;
therefore, no evidence existed that the battery charger could meet
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the established acceptance criteria.
In response to this violation, the licensee reperformed the test on
the battery charger during the 1987 refueling outage in accordance
with Maintenance Order (MO) 871643. The M0 provided specific
instructions for testing that included the concerns identified by the
inspection team. The concerns were starting time of test, initial
float and equalizing voltages, voltage values recorded at regular
intervals, final float and equalizing voltages at test completion,
and completion time of test. The licensee reviewed the test results
and determined that the battery charger was capable of meeting its
intended safety function.
The NRC inspector reviewed MO 871643 to verify that the licensee had
established an appropriate test for the battery charger. The review
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included verification that the appropriate data was taken, the
acceptance criteria were clearly established, and tne test results
verified that the battery charger was capable of performing its
operational requirements. Based on the results of the review
performed, it appeared that the licensee had taken appropriate
actions to verify proper operation of the charger.
h. (Closed) Severity Level IV Violation 285/8529-II.I.4, II.I.5, and
II.I.6 (Deficiency 85-29/2.9-1): Failure to Properly Store Material
in Temporary Critical Quality Element (CQE) Storage Areas - This
violation involved the failure of the licensee to. ensure only
properly designated CQE material was stored in temporary CQE storage
areas. CQE storage areas were erected inside the plant to provide
storage for items that had received quality assurance (QA) inspection
and required segregated storage in accordance with ANSI standards.
In response to this violation, the licensee revised
Procedure 50-G-22, "Storage of Critical Element and Radioactive
Material Packaging, Fire Protection Material, and Calibration
Equipment." The procedure revision established new requirements for
placing or storing parts and materials in the temporary CQE storage
areas. The procedure required that an entry on a storage area log
sheet be made and verification established to ensure that the
material was CQE prior to placement in the storage area.
The NRC inspector reviewed Procedure 50-G-22 to verify that the
procedure had properly implemented requirements to prevent storage of
non-CQE material in temporary CQE storage areas. During the past
12 months, the NRC inspector also performed an inspection of various
temporary CQE storage areas located in the plant. During the
reviews, the NRC inspector verified that the material stored in the
areas was CQE material; the material was properly identified; the
material was properly stored with respect to cleanliness control, as
appropriate; and no non-CQE material was stored in the area. No
problems were noted with the procedure revision or storage of
material in the temporary CQE areas.
i. (Closed) Severity Level IV Violation 285/8529-II.I.3
(Deficiency 85-29/2.9-3): Failure to Perform Surveillances of
Temporary CQE Storage Areas This violation was related to the
failure of the quality control (QC) department to perform
surveillances of temporary CQE storage areas. The monthly
surveillance reqJirements Were established by Proceduro S0-G-22 and
no documentation existed to indicate the surveillances were being
performed.
The licensee revised Procedure S0-G-22 to establish a program for
tracking the surveillances performed to verify the adequacy of
temporary CQE storage areas. The revision to the procedure
implemented Form FC-1068 that provided a historical .ecord for
surveillance performance for each storage area. Form FC-1068
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required a surveillance of each storage area monthly during plant
operations and weekly during the high activity period of a refueling
outage.
The NRC inspector reviewed Procedure S0-G-22 to verify that an
appropriate surveillance program for storage areas had been
established. The NRC inspector also reviewed Form FC-1068 to verify
that surveillances had been performed on a monthly or. weekly
frequency, as appropriate. During review of Procedure 50-G-22 and
Form FC-1068, no problems were noted. It appeared that the licensee
had established and implemented an acceptable program for the
surveillance of temporary CQE storage areas.
j. (Closed) Severity Level IV Violation 285/8529-II.J.1
(Deficiency 85-29/2.10-1): A Program for Installation of Temporary
Lead Shielding had not been Established - This violation documented
the failure of the licensee to establish a program for installation
of temporary lead shielding on safety-related systems.
This violation is discussed in paragraph 2.c of this inspection
report. Based on the discussion, this violation is considered
closed.
k. (Closed) Severity Level IV Violation 285/8614-01: Failure to
Maintain Cable and Cable Tray Installations in Accordance with Design
Documents - This violation was related to the failure of the licensee
to maintai.) the installation of safety releted cable and cable trays
in accordance with the design documents that originally installed the
cable and trays. The proble.ns noted in this violation were the
failure to maintain cable tray covers properly installed and
overfilling of a tray with power cables.
The licensee took actions to ensure that the installation of
safety-related cable trays complied with design documentation. The
actions taken by the licensee included a walkdown of all trays to
ensure all covers were properly installed. The walkdown was
performed in accordance with the instructions provided by MO 862038.
The licensee established a computerized system for the cable and
conduit schedule. Using the computerized schedule, the licensee
established that the cables installed in Tray Section 21S were
satisfactory. The cables were determined to be satisfactory based on
cable derating factors. Prior to establishment of a computerized
schedule, the licensee used a criteria based on cable and tray
cross-sectional area. The licensee also revised the appropriate
sections of the Updated Safety Analysis Report (USAR) Figure 8.5-1 to
reflect the change to the computerized system. Drawing 11405-E-151
provided instructions for installation of cable trays. This drawing
has been deleted and USAR Figure 8.5-1 has been implemented for cable
tray installation instructions.
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The NRC inspector-reviewed the actions taken by the licensee to
verify that they were appropriate. The items reviewed are listed
below:
. Reviewed'the calculation performed by the licensee and' verified
that the cables installed in Tray 215 did not exceed the limits
specified for cable derating.
. . Reviewed USAR Figure 8.5-1-to verify that the licensee had
changed the figure to reflect the newly established computerized
conduit and cable schedule.
. Walked down various cable trays in the auxiliary building and in
containment to verify that covers were properly installed, no
loose objects were in the trays, divider plates were securely
fastened, and' cables were tied down.
Based on the reviews performed, it appeared that the licensee had
taken appropriate actions to ensure cables and cable trays were
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installed in accordance with design requirements and had taken
actions to ensure the cables and cable trays were maintained in a
satisfactory condition.
1. (Closed) Open Item 285/8702-05: Review of the Audit Performed by the
Licensee in the Area of 10 CFR Part 21 Activities - This open item is
related to an audit performed by the licensee in the area of Part 21
activities. During an inspection performed by the NRC inspector in
January 1987 the inspector noted various problems with the licensee's
implementation of their Part 21 activities. The NRC inspector noted
that the licensee's QA department had found the same problems during
an audit performed in December 1986.
The NRC inspector reviewed the close out of the deficiencies
identified by the licensee. The review was performed to verify that
the QA department had addressed the specific problem noted and had
ensured that adequate action had been taken to prevent recurrence.
The deficiencies noted by the QA department were a systematic and
generic problem with issuance and control of procedures and
instructions related to Part 21 reporting responsibilities, and a
systematic and generic problem related to training of parsonnel in
each individual's responsibilities for reporting Part 21
deficiencies. Based on the review, it appeared that the QA
department performed adequate close out of the audit findings.
m .~ (0 pen) Severity Level V Violation 285/8710-01: Failure to Provide a t
Continuous or Hourly Fire Watch for Nonfunctional Fire Barriers -
This violation identified a problem where the licensee failed to
provide a fire watch for a nonfunctional fire barrier. The failure
to provide a fire watch was a violation of TS 2.19(7).
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In response-to the viol'ation, the licensee stated that
Procedures SCP-14, "Patrol Procedures," used to define
responsibilities of the security guard during plant tours, and
150-0-38,'"Firewatch Duties and Turnover Procedures," used for the
. establishment of_ fire watches, would be revised to ensure that an
effective program was implemented. The licensee revised
Procedure 50-0-38, but had not completed implementation of corrective
actions due to Procedure SCP-14 not being revised.
In response to this violation, tSe licensee also stated that a memo
would be issued to all personnel with unescorted access as an interim
measure. The purpose of the memo was to make each individual aware of
his/her individual responsibilities in maintaining fire barriers
fully functional. The interim measure was to be taken until changes
could be made to the appropriate procedures to establish permanent
corrective action.
In followup on this violation, the NRC inspector noted that the
licensee had not yet issued the memo. The failure to issue the memo
that provided interim measures for ensuring nonfunctional fire
barriers were provided appropriate attention is an apparent deviation
from a commitment made to the NRC. (285/8524-01)
As detailed in NRC Inspection Report 50-285/87-20, the licensee has
continued to experience problems in maintaining fire barriers in a
functional status. These problems were discussed with licensee
management during the exit interview.
n .- (0 pen) Unresolved Item 285/8710-05: Performance of a Calculation to
Verify Sufficient Trisodium Phosphate Dodecahydrate (TSP) is Stored
in Containment - This unresolved item was related to the performance
of a calculation for verification that sufficient TSP was inplace in
containment. The calculation was to be performed to evaluate the
discrepancy between the TS and the USAR as to the quantity of TSP
needed in containment in the event that containment recirculation was
initiated. Prior to plant startup in June 1987 the NRC inspector
reviewed a preliminary calculction that verified the proper amount of
TSP was stored in containment. At the time of the review, licensee
personnel stated that a formal calculation would be completed in the
near future (i.e., 2 or 3 weeks). The NRC inspector has requested at
various times since review of the preliminary calculation, to review
the final calculation; the licensee has not yet completed the formal
calculation to verify the TSP in containment was adequate. This item
remains open pending completion of the formal calculation by the
licensee and a review of the results by NRC personnel.
3. Licensee Event Report (LER) Followup
Through direct observation, discussions with licensee personnel, and
review of records, the following event reports were reviewed to atitennine
that reportability requirements were fulfilled, immediate corrective
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action was accomplished, and corrective action to prevent recurre. ice had
been accomplished in accordance with TS.
The LERs listed below are closed:
-87-005 Unplanned actuation of the ventilation isolation actuation
system (VIAS) via Radiation Monitor RM-061
87-006 Unplanned initiation of the containment pressure high
signal (CPHS) during surveillance testing
87-020 Unplanned actuation of the VIAS via Radiation Monitor RM-050
-A discussion of the closeout of each LER is provided below:
a. LER 87-005 reported inadvertent actuation of the. VIAS during
calibration of Radiation Monitor RM-061. The VIAS was initiated when
the technician pushed RM-061 back into the monitor cabinet and a
loose screw caused a momentary loss of signal. The loss of the
signal caused initiation of the VIAS. All appropriate systems
functioned normally. The technician tightened the screw.and the VIAS
cleared.
The licensee issued MO 871159 to check and tighten the screw
terminations on the other process monitors. No other screws were
found that were loose. In addition,-during routine calibration
activities, technicians verify that all connections are tight.
The NRC inspector reviewed the actions taken by the licensee. Based
on the review, it appeared that the licensee had taken appropriate
actions to correct the cause of the event and to prevent recurrence.
b. LER 87-006 reported the initiation of the containment pressure high
signal (CPHS) during performance of a local leak rate test for the
containment pressure sensing penetration. All appropriate safety
equipment functioned normally. CPHS was initiated due to a contract
technician error during performance.of the pressure test. The
technician inadvertently opened the sensor isolation valve prior to
bleeding the test pressure off the sensing line. The technician
failed to follow all notes and steps contained in the procedure being
used. Upon becoming aware of the event, the technician bled the
pressure off the sensing line to clear the CPHS.
The licensee instructed all contract and licensee technicians of the
importance of ensuring all notes and steps of procedures were
followed. The licensee committed in Violation 285/8710-04, which was
related to an error in performance of a local leak rate surveillance
test, to conduct training for contract and licensee personnel
performirg leak rate testing. This training should ensure that tests
are performed properly during the next refueling outage.
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The NRC inspector reviewed Procedure ST-CONT-3, "Type C Local Leak
Rate Test," to verify that'the proper instructions had been provided
to the technicians. No problems were noted. The NRC inspector
reviewed the actions taken by the licensee.and it appeared that the
actions W re appropriate for correcting the problems related to this
event and that the proposed training will prevent recurrence.
c. LER 87-020 reported the unplanned actuation of the VIAS during plant
startup. The VIAS was initiated due to a containment radiation high
signal that was caused by an alarm on Radiation Monitor RM-050. All
appropriate systems functioned normally during the VIAS. .The
licensee took immediate action and verified no particulate radiation
was present in containment and no release occurred.
The licensee reviewed the cause of the initiation of the VIAS and
noted that the setpoints for RM-050 had not been reset from the
shutdown value to the operating value prior to commencing plant
startup. To ensure that the setpoints were reset at the appropriate
point during plant startups in the future, the licensee made a
procedure change to require resetting of the setpoints.at a reactor
coolant system temperature of 395 F, the minimum temperature at which
the hydrostatic test of the reactor coolant system may be performed-
during startup.
The NRC inspector reviewed the actions taken by the licensee and it
appeared that appropriate actions were taken to ensure that no
particulate radiation was released to the atmosphere. The NRC
inspector reviewed Procedure 01-RC-3, "Reactor Coolant System
Startup," and verified that a change had been. issued to require t e
setpoints to be raised from the shutdown to operating values at
395 F. Based on the review performed by the NRC inspector, it
appeared that the licensee had taken actions to prevent recurrence of
L this event.
d. In May 1987, the licensee identified problems with the welds on the
emergency feedwater storage tank (EFWST). In May 1987, a conference
j. was held in the Region IV offices to discuss the problems associated
with the EFWST welds and the licensee's planned corrective actions.
Four days after the meeting, the NRC inspector requested that an LER
be submitted to the NRC detailing the problems found with the EFWST.
Licensee personnel stated that an LER would be sent.
In September 1987, the NRC inspector requested a copy of the LER on
the EFWST. Licensee personnel stated that the LER had not yet been
issued. In addition, licensee personnel stated that the problems
with the welds on the EFWST were not reportable under the
requirements of 10 CFR Part 50.73; therefore, an LER was not issued
within the 30-day requirement specified in Part 50.73. Subsequently,
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the licensee issued LER 87-022, dated September 25, 1987, detailing
the problems identified with the EFWST. The LER was issued as a
voluntary report by the licensee.
When the NRC inspector reviewed'the circumstances associated with
this. event, it appeared that a 30-day event report should have been
initiated by the licensee. This item remains unresolved pending a
review of the licensee's LER program to verify that.the program
. properly implements the reporting requirements of 10 CFR Part 50.73.
(285/8724-02)
No violations or deviations were identified.
4. Operational Safety Verification
The NRC inspectors 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 inspectors made several control room
observations to verify the following:
. _ Proper shift staffing
. 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
. Proper return to service of components
. H0s initiated for equipment in.need of maintenance-
. Appropriate conduct of control room and other licensed operators
. Management personnel toured the control room on a regular basis
No violations or deviations were identified.
5. Plant Tours
The NRC inspectors conducted plant tours at various times to assess plant
and equipment conditions. The following items were observed during the
tours:
. General plant conditions, including operability of standby equipment,
were satisfactory.
l
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. Equipment was being maintained in proper condition, without fluid
leaks and excessive vibration.
. Plant hous'ekeeping and cleanliness practices were observed, including
no fire hazards-and the control of combustible material.
. Performance of work activities was in accordance with approved
procedures.
. Portable gas cylinders were properly stored to prevent possible
missile hazards.
. Tag out of equipment was performed properly.
. Management personnel toured the operating spaces on a regular basis.
. The auxiliary feedwater pumps were not steam bound.
During plant tours, the NRC inspector noted the following:
. A seismic support for a safety-related cable tray.in Room 81 had been
removed and not reattached. The support was attached to the tray but
was not affixed to a structural member. The NRC inspector requested
the licensee provide a drawing that would indicate whether or not the
tray support should be' installed to maintain seismic qualification of
the tray. The licensee stated that a drawing showing.the location of
tray seismic supports did not exist. The licensee could not
establish, prior to the end of this inspection period, whether or not
the support was required for the cable tray. This item remains
unresolved pending a review by the licensee to determine if the tray
support is required and to establish why no drawing exists that shows
the location of seismic supports for safety-related cable trays.
(285/8724-03)
. During a tour cf the auxiliary building on September 21, 1987, the
NRC inspector identified a problem where two large nitrogen
compressed gas cylinders had been secured to a support for a
safety-related pipe snubber. The snubber was attached to the
-
recirculation line for the safety injection and containment spray
pumps. The NRC inspector also noted that a large nitrogen bottle
pressurized to 1600 psig was attached to a handrail, in the vicinity
of safety-related equipment, with a 3/8-inch nylon rope; that 4 gas
cylinders were tied in a group to a cylinder storage rack with a
3/8-inch nylon rope; and a welding cart containing an oxygen and
acetylene compressed gas cylinder, without caps, was stored,
unsecured in an area with safety-related equipment.
Criterion V of Appendix B to 10 CFR Part 50 states, in part, that
activities affecting quality shall be prescribed by documented
' procedures of a type appropriate to the circumstances and shall-be
accomplished in accordance with these procedures.
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Paragraph 1.0 of Section 6.4, "Housekeeping;" of the licensee's
Quality Assurance Plan (QAP) states, in part, that this plan section
specifies the quality assurance requirements for housekeeping
controls'for protection of equipment. Paragraph 4.5 of QAP
Section 6.4 states, in part, that. instructions which implement this
plan section shall be contained in the station standing orders.
Standing Order (50) G-6, "Housekeeping," was issued to implement the
requirements of QAP Section 6.4. Paragraph 3.3.4 of 50-G-6 states,
in part, that gas cylinders shall be properly stored in the auxiliary
building, with caps installed, unless in use or use is intended
within a short period of time.
Contrary to the above, the licensee failed to properly store gas
cylinders in the auxiliary building, as noted by the four examples
discussed above, in that cylinders were secured to a safety-related
seismic support; cylinders were secured using a 3/8-inch nylon rope,
an unapproved storage method; and cylinders were left. uncapped and
unsecured in the auxiliary building. This is an apparent violation.
(285/8724-04)
As documented in past inspection reports issued by the NRC resident
inspector, the licensee has continued, over the last 6 months, to
encounter problems with storage of gas cylinders in the auxiliary
building. Early in this inspection period, the licensee issued a
memo to the appropriate personnel to alert the individuals of the
problems previously experienced with the storage of gas cylinders.
It appears that issuance of the memo did not provide adequate
corrective action to prevent recurrence of this problem. The
licensee, upon notification by the NRC inspector, took actions to
properly secure the gas cylinders.
. Housekeeping in the auxiliary building continued to require
additional licensee attention. Bags of miscellaneous material were
stored in various locations. Room 59 was noted to have a large
accumulation of bagged material.
. During a tour of the plant on September 9, 1987, the NRC noted that
the licensee had erected two temporary scaffolding sections adjacent
to the EFWST. One section of scaffolding was a free-standing
structure and the other section was attached to the EFWST
instrumentation lines. The NRC inspector requested a copy of the
safety evaluation that addressed the affect of the nonseismically
installed scaffolding on the EFWST, should a seismic event occur.
The: licensee stated that a safety evaluation had not been performed
and that no procedure existed to require an evaluation be done when
erecting temporary scaffolding in safety-related areas.
The scaffolding was erected to facilitate work on the nitrogen supply
line for the EFWST in accordance with Modification
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Request (MR) FC-86-56. MR-FC-86-56 stated that scaffolding should be
erected, as needed, to perform the modification work.
l
Criterion V of Appendix B to 10 CFR Part 50 states, in part, that
activities affecting quality shall be prescribed by procedures of a
type appropriate to U4e circumstances.
Paragraph 4.7.2 of Section 5.1, "Control of Plant Design and
Modification," of the licensee's QAP states, in part, that
appropriate procedures shall be used for modification activities.
Contrary to the above, the licensee failed to implement a procedure
for control of the erection of temporary scaffolding in areas
containing safety-related equipment; therefore, no evaluation was
performed to address the potential affect of nonseismically installed
scaffolding on safety-related equipment during a seismic event. This
is an apparent violation. (285/8724-05)
The NRC inspector notified the licensee of the existence of the
scaffolding on September 9, 1987. The licensee completed removal of
the scaffolding on September 14, 1987.
. During a plant tour on September 25, 1987, the NRC inspector noted
that licenseo personnel had stored tool boxes, large cabinets, small
parts cabinets, and a small crane in the safety-related east and west
switchgear rooms. In discussions with licensee personnel, it was
determined that the electrical shop was being moved so the current
shop facility could be expanded. When the move occurred,
electricians had stored their tools and parts in the switchgear
rooms. Upon notification by the NRC inspector, licensee personnel
immediately removed all tools and parts from the switchgear rooms.
The NRC inspector discussed the need to ensure that unsecured objects
were not stored in any safety-related areas witt. licensee management
at the exit meeting.
6. Safety-Related System Walkdowns
The NRC inspector walked down accessible portions of the following
safety-related emergency diesel generator 1 and 2 systems to verify system
operability. Operability was determined by verification of selected valve
and switch positions. The systems were walked down using
Procedures 0I-DG-1, Revision 22; 01-DG-2, Revision 22; and the drawings
noted below:
. Fuel oil system (Drawing M-262, Revision 23)
. Air start system (Drawing B120F07001, Revision 4)
. Lubricating oil system (Drawing B120F03001, Revision 4)
. Jacket cooling water system (Drawing B120F04002, Revision 1)
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During the walkdowns, the NRC inspector noted that valves designated by
procedure did not correspond correctly with the system drawings. Due to
the nature of the errors, system safety and operability were not degraded;
however, the NRC inspector expressed concern to the licensee that the
errors were not internally found with 22 revisions existing to the
operating procedures. Licensee personnel verified the errors and had them
corrected immediately.
'
No violations or deviations were identified.
7. Monthly Maintenance Observations
The NRC inspectors 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:
. 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 w'ere 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 NRC inspectors reviewed and/or observed the following :paintenance
activities:
. Installation of Fire Door 1007-11 (M0 853356)
. Troubleshooting of high temperature trip on Emergency Diesel
Generator (EDG) No.2
. Repair of pilot valve for radiator exhaust damper on EDG No. 2
(M0 874509)
. Repair of the emergency diesel fuel oil storage tank level indicator
(M0 874516)
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. Testing of a battery charger (M0 871643)
No violations or deviations were identified.
8. Monthly Surveillance Observations
The NRC inspectors 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 inspectors 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 personne? other than the individual
directing the test.
. Deficiencies identified during the testing were properly reviewed and
resolved by appropriate management personnel.
The NRC inspectors observed and/or reviewed the documentation for the
following surveillance test activities. The procedures used for the test
activities are noted in parenthesis.
. Monthly test of an emergency diesel generator (ST-EST-6-F.2)
~
. Local leak detection test of the personnel air lock (ST-CONT-2-F.1)
. Pressurizer pressure channel check (ST-ESF-1-F.2)
. Recirculation actuation logic test (ST-ESF-13-F.2)
. Auxiliary feedwater valve alignment check (ST-FW-1-F.1)
. Reactor coolant system low flow trip check (ST-RPS-3-F.2)
No violations or deviations were identified.
9. Radiological Protection Observations
The NRC inspectors verified that selected activities of the licensee's
radiological protection program were implemented in conformance with the
, facility policies and procedures and in compliance with regulatory
requirements. The activities listed below were observed and/or reviewed:
. Health physics (HP) supervisory personnel conducted plant tours to
check on activities in progress.
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. ~ Radiation work permits contained the appropriate information to
. ensure work was performed in a safe and controlled manner.
. Personnel in radiation controlled areas (RCA) were wearing the
required personnel monitoring equipment and protective clothing.
. Radiation and/or contaminated areas were properly posted and
controlled based on the activity levels within the area.
. Personnel properly frisked prior to exiting an RCA.
During a plant tour on September 11, 1987, the NRC inspector found a door
to a very high radiation area unlocked. This matter was referred to a
Region IV health physics specialist. The details of this item are
provided in NRC Inspection Report 50-285/87-21.
No violations or deviations were identified.
10. In-office Review of Periodic and Special Reports
In-office review of periodic and special reports was performed by the NRC
resident inspectors 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.
The NRC inspectors reviewed the following:
. Refueling outage inservice inspection results, dated August 31, 1987
. Cycle 10 fuel performance report, dated September 2, 1987 <
. Refueling outage Type B and C local leak rate test summary, dated
September 3, 1987
. Monthly Operations Report, undated
. August Monthly Operating Report, dated September 14, 1987
No violations or deviations were identified.
.
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11. Review of-10 CFR Part 21 Program
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. established and are adequate to ensure proper
implementation of 10 CFR 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
applicable procurement documents.
. Evaluation of 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 inspector reviewed the procedures established by the licensee to
implement the requirements of 10 CFR Part 21. The. documentation reviewed
included Procedure 50-G-42, "Reporting of Defects and Noncompliance to the
Nuclear Regulatory Commission," Revision 7; Procedure H-2, "Report of
Defects and Noncompliance to the Nuclear Regulatory Commission,"
~
Revision 1; and Procedure QADP-19, "10 CFR 21, Reporting. Defects and
Noncompliances," Revision 3. Procedure 50-G-42 provides reporting
instructions for individuals working in the Omaha offices, and
Procedure QADP-19 provides the quality assurance department instructions
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 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 postings at the plant site, Jones
Street offices, and at the Brandeis building. The NRC inspector noted
that the posting of 10 CFR Part 21 and the implementing Procedure (H-2) at
the Brandeis building were not the current revision. The NRC inspector
also noted that Section 206 of the Energy Reorganization Act of 1974 was
not posted. During the previous review performed by the NRC inspector in
January 1987, as documented in NRC Inspection Report 50-285/87-02, it was
also noted that the material required to be posted by Part 21 was out of
date. The licensee stated at that time that all posting would be updated.
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Section 21.6 of 10 CFR Part 21 states, in part, that each entity subject
to the regulations of this part, shall post current. copies of the
following documents where activities subject to this part are conducted.
The documents include the regulations in this part, Section 206 of the
Energy Reorganization Act (ERA) of 1974, and procedures adopted pursuant
to the regulations in this part.
Section 7.6.2 of Procedure H-2, "Reporting of Defects and Noncompliance to
the Nuclear Regulatory Commission," states, in part, that the following
documents shall be posted in conspicuous places at the Fort Calhoun
Station, Jones Street Station, and Generating Station Engineering offices:
10 CFR Part 21, Section 206 of the ERA of 1974, and Procedure H-2.
Contrary to the above, the licensee failed to post the latest revision of
the Part 21 regulations and the licensee's implementing procedure, and
failed to post Section 206 of the ERA at the Brandeis building (the
Generating Station Engineering offices). This is an apparent violation.
(285/8724-06)
The review performed in this area was not completed prior to the end of
the inspection period. Tht review will be continued during a future
inspection.
12. Followup on IE Information Notices and IE Bulletins Issued for Information
Only
The NRC inspector reviewed the licensee's system established for
processing IE Information Notices and IE Bulletins issued for information
only. This review was perfonned to verify that the licensee had received
the notices and bulletins; the notices and bulletins were distributed to
the appropriate personnel for review; and that any actions determined to
be appropriate during the review, had been taken.
The NRC inspector reviewed selected notices and bulletins issued during
the latter part of 1986 and 1987 to verify appropriate action had been
taken. No problems were noted by the inspector for those items reviewed.
No violations or deviations were identified.
13. Unresolved Item
An unresolved item is a matter about which more information is required in
order to determine whether it is acceptable, a violation, or a deviation.
Two unresolved items are discussed in paragraphs 2.d and 5.
1
Item Paragraph Subject l
285/8724-02 3.d Review of licensee's program to
implement reporting requirements
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285/8724-03 5 *
. Improperly installed seismic
support for a safety-related
cable tray
14. Diesel Generator Shutdown and Water Ingress Into the Instrument Air System.
On September 23, 1987, Diesel Generator No. 2 (DG-2) shutdown due to high
coolant temperature. Licensee investigation revealed that the air
operated exhaust damper for the diesel generator radiator did not appear
to hade fully opened as designed. The cause of damper malfunction appears
to be the presence of a sticky lime like residue which cause the air pilot
valve to stick. It is significant that on July 6,.1987, water was-
introduced into the instrument air system flooding that portion of the
system below the auxiliary building elevation 1025 feet. A separate
inspection was conducted by the Region IV Resident Inspectors in
preparation for an enforcement conference concerning both the DG-2 failure
and the introduction of a significant quantity of water in the instrument
air system. For further detail see NRC Inspectior Report 50-285/87-27 and
License Event-Report 05000285-025.
15. Exit Interview
The NRC inspectors met with Mr. R. L. Andrews (Division Manager, Nuclear
Production) and other members of the licensee staff at the end of this
inspection. At this meeting, the NRC inspectors summarized the scope of
the inspection and the findings.
.