IR 05000285/1981007
| ML20004C075 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/13/1981 |
| From: | Boardman J, Randy Hall, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20004C070 | List: |
| References | |
| 50-285-81-07, 50-285-81-7, NUDOCS 8106010484 | |
| Download: ML20004C075 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report:
50-285/81-07 License DPR-40 Occket:
50-285 Licensee:
Omaha Public Power District 1623 Harney Street Omaha, Nebraska 68012 Facility Name: Fort Calhoun Station, Unit 1 Inspection at: Fort Calhoun Station, Blair, Nebraska Inspection conducted:
March 23-27, 1981 Inspectors:
W Wh a /E /f2l J
R' Boardman, Reactor Inspector, Systems ana g&te
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echnical Section (Paragraphs 1, 2, 3, 4 & 7)
h mwn M 5l/ENI
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D. M. Hunnicutt, Cnief, Reactor Projects
'Date Section No. 2 (Paragraphs 1, 5, & 6)
Approved:
[J#
' R. E. Hall, Chief, Systems anc Tecnnical Section Date h!
mA&
/3k?/
D. M. Hunnicutt, Chief Date Reactor Projects Section No. 2 8106010 NY
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Inspection Summary Inspection conducted during the period of March 23-27, 1981 (Recort 50-285/81-07)
X'reas Inspected:
Routine, unannounced inspection including licensee Quality
. Assurance program; licensee audit program; follow up on IE Bulletin 80-11; and IE Oraft Circular concerning Foxboro transmitters. The inspection involved 67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> on site by two NRC inspectors.
Results:
In the four areas inspected, no violations or deviations were found in two areas; five apparent violations were found in two areas (one violation -
failure to maintain records of activities affecting quality paragraph 2; four violations - fatiure to comply with Technical Specifications, failure to comply with procedures, failure to promptly correct conditions adverse to i
quality, and failure to have a comprehensive system of planned and periodic audits paragraph 3).
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_. _.. DETAILS 1.
Persons Contacted Omaha Pubife Power District
- R. L. Andrews, Section Manager, Operations
- J. E. Bentzinger, Quality Assuran::e Engineer, Construction W. G. Gates, Supervisor, Operations
- J. M. Gloshen, Quality Assurance Engineer, Corporate
- R. L. Hyde, Quality Assurance Engineer, Operations
- R. L. Jaworski, Section Manager, Technical Services M. McEwan, Training Coordinator T. J. McIvor, Manager Operational Support Technical Services K. J. Morris, Manager, Administrative Services
- T. L. Patterson, Licensing Administrator G. R. Peterson, Supervisor, Maintenance S. Stevens, Manager Fort Calhoun Station P. Surber, Acting Section Manager, Generating Station Engineering
- F. A. Thurtell, Division Manager, Environmental and Regulatory Affairs
- Indicates presence at exit interview conducted March 27, 1981.
The NRC inspectors also contacted other plant personnel, including clerical, administrative and maintenance personnel.
2.
Licensee Quality Assurance Program The NRC inspector reviewed the licensee's Quality Assurance program and implementing procedures for compliance with the Code of Federal Regulations and the licensee Technical Specifications and FSAR, and discussed with licensee representatives the following cases of an apparent violation of these regulatory requirements and deviations from approved licensee pro-cedures:
10 CFR Part 50, Appendix B, Criterion XVII requires that sufficient records shall be maintained to furnish evidence of activities affecting quality.
Contrary to the above, licensee representatives were unable to demor.-
strate by available records that the follow-up activities affecting quality were documented:
a.
The initial basis for approvals of suppliers is specified in licensee Quality Assurance Procedure QAP No. 5, Revision 1,
" Supplier Qualification," dated December 1,1980, Section 3.1.1.
Licensee representatives were unable to provide records of supplier past performance data on which initial supplier approval was predicated.
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b.
Licensee QAP No. 19 Revision 0, " Indoctrination and Training of Quality Assurance Personnel," approved April 25, 1977, Sections 3.1.4 through 3.1.7 require certain continuing training of licensee Quality Assurance personnel.
Licensee representatives were unable to provide records of all such training such as
" current problems in the industry," "the latest NRC audit findings," and " Regulatory Guides applicable to the Quality Assurance Program."
c.
The preface of the licensee's Quality Assurance Manual states that the Manager - Quality Assurance will cause the QA Manual
"to be reviewed at least annually by the Operations Division, Projects and Construction Division, GSE, and Purchasing...,"
and licensee Quality Assurance Procedures (QAPs) "to be periodically and formally reviewed."
Licensee representatives could provide no records of these required reviews of these documents.
Discussions with licensee representa-tives confirmed that these reviews were not conducted.
Failure to perform these reviews and to maintain sufficient records to furnish evidence of activities affecting quality constitutes an apparent.
violation of 10 CFR Part 50, Appendix B, Criterion XVII.
(8107-01)
3.
Licensee Audit Program The NRC inspector reviewed the licensee's audit program and implementing procedures for compliance with the Code of Federal Regulations and the licensee Technical Specifications and FSAR, and discussed with licensee representatives the following cases of apparent violations of these regula-tory requirements from approved licensee procedures:
a.
Licensee Technical Specification 5.5.2.8, subparagraph 5.5.2.8.a requires that the licensee's Safety Audit and Review Committae (SARC) perform an audit of:
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"The conformance of facility operation to all provisions con-tained within the Technical Specifications at least once per l
year."
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l (1) Based on a review of SARC Audits 2-78, 79-03, and 2-80, and discussion with licensee personnel, the SARC apparently does noi, audit or have audited all provisions contained within the Technical Specifications at least once a year, nor does there
exist a program to assure total auditing of all Technical Specification provisions.
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An example of this apparent violation is in the area of surveil-lance requirements.
Not only are all surveillance requirements not audited every year, but under paragraphs 3.1 and 3.2 (Tables 3-1 through 3-5), there are 84 surveillances (Table 3-5 has three surveillances shown under item 10).
In three years (1978, 1979, and 1980), only 20 of these 84 surveillances were apparently audited by SARC.
(Surveillances Table 3-1, item 3, Table 3-4, item 4; and Table 3-5, item 7 were apparently audited in both 1978 and 1980, but are included only once in the above count of 20.)
(2) Technical Specification 5.5.2.8, subparagraph 5.5.2.8.c. requires a semiannual SARC audit of "the results of all actions taken to correct deficiencies occurring in facility equipment, structures, system, or methods of operation that affect nuclear safety.
Contrary to the above, the SARC apparently has not audited the licensee's actions to correct deficiencies in the area of non-conformances documented in accordance with Fort Calhoun Standing Order G-18, Revision 3, " Nonconformity Control," dated March 19, 1979, based on the following facts:
(a) The licensee "Miniaudit Summary and Nonconformity (NR)
Status Report February 1981," dated March 9, 1981, lists as open :.ine NRs written between December 16, 1976, and November 10, 1980.
(b) Neither these NRs, nor any other NRs, were discussed in the six SARC audits of " Actions to Correct Deficiencies" per-formed during 1978, 1979, and 1980.
Failure of the licensee to perform audits as required by licensee Technical Specification 5.5.2.8 (subparagraphs a. and c.) constitutes an apparent violation of licensee Technical Specifications.
(8107-02)
b.
10 CFR Part 50, ?'pendix B, Criterion V states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with l
these instructions, procedures, or drawings.
Instructions, pro-l cedures, or 'rawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
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The following cases are examples of apparent violations of this criterion:
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(1) Licensee QAP No. 17, Revision 1, " Audit Planning, Performance, and Reporting," dated December 1,1980, Section 3.8.1 requires a response to an audit within 30 days.
Contrary to the above, response to Audit Report 27-80 documented by Deficiency Report FCI-80-A-0044 was responded to in 43 days.
(2) Licensee QAP No. 18, Revision 0, " Auditor Training and Qualifica-tion," dated April 22, 1977, Section 3.2.5 requires auditors to pass an examination. Contrary to this requirement, one licensee auditor performing miniaudits was not qualified in that he had not taken the required examination.
(3) Licensee QAP No.18, Section 3.2.5 allows the Manager-Quality Assurance to delegate auditor examination to an independent certifying agency but states that the Manager-Quality Assurance
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. shall retain responsibility for conformance of the
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examination and its administration to this standard." The licensee representatives stated that verification had not been performed of conformance of the examination and its administra-tion to the requirements of QAP No. 18, where the examination was administered by an independent certifying agency.
Failure to accomplish activities affecting quality as prescribed in
documented instructions and procedures is an apparent violation of
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10 CFR Part 50, Appendix B, Criterion V.
(8107-03)
c.
10 CFR Part 50, Appendix B, Criterion XVI requires:
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, defi-ciencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the concition is determined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, tha cause of tae condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
Contrary to the above, a review of licensee audits of " Actions to Correct Deficiencies" 1-78, 6-78, 79-02, 79-06, 1-80, and 5-80 covering 1978,1979, and 1980 reflect a pattarn of long-term out-standing corrective action items some of which date back to 1977 and are still open items. While the minutes of SARC Meeting No. 1-81 discuss additional tracking of outstanding corrective action items, these items have been tracked for several years in SARC audit reports.
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The report of SARC Audit 5-80, dated December 18, 1980, further discuases a SARC Task Force which apparently had been assigned to this problem without resolution to date.
In addition, this report of SARC Audit 5-80 contains as Attachments 2 through 5 detailed status reports which the licensee report states are "... for the purpose of drawing SARC attention to the items and hopefully District action toward their resolution." At the time of the inspection, there were still longstanding corrective action items outstanding from these audits.
Failure to take prompt corrective action is an apparent violation of 10 CFR Part 50, Appendix B, Criterion XVI.
(8107-04)
d.
10 CFR Part 50, Appendix B, Criterion XVIII states:
"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the orogram.
The audits shall be performed in accordance with the written procedures or check lists by appropriately trained corsonnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reviewed by management having responsibility in the area audited.
Follow-up action, including re-audit of deficient areas, shall be taken where indicated."
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The following case is an example of an apparent violation of this criterion:
The licensee apparently does not include in his internal
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audit program as prescribed in licensee Quality Assurance Procedue No. 2, Revision 0, " Audit plans," approved April 25, 1977, his supplier approval program as defined and set forth in licensees Procedures QAP No. 4, Revision 0,
" Approved Suppliers List," approved April 25, 1977, and QAP No. 5, Revision 1, " Supplier Qualification," dated l
December 1,1978. These QAPs were implemented to comply with l
10 CFR Part 50, Appendix B, Criterion VII.
Failure to have a comprehensive system of planned and periodic audits to verify all aspects of the licensee's Quality Assurance program and to determine the effectiveness of the program is an apparent violation of 10 CFR Part 50, Appendix B, Criterion XVIII.
(8107-05)
Inscector Observations l
a.
Licensee QAP No. 7, Revision 1, " Storage and Retention of QA Records,"
l approved August 9, 1978, contains, in Appendix A, record retention l
requirements which, by secpe, duplicate Fort Calhoun Station, Unit No. 1
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l Standing Order C-2, Revision 3, " Fort Calhoun Station Quality Assurance
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(QA) Records (Administrative and Operations ONLY)," dated August 30, 1980. QAP No. 7 contains a differing retention requirement for
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" records of normal nuclear unit operation, including power levels
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and periods of operation at each level," from those specified in Standing Order c-2.
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This was a typographical error between the rough and the smooth copy of the last revision of QAP No. 7 and is being corrected by the licensee.
b.
Licensee's Quality Assurance Procedure (QAP) No. 4, Revision 0,
" Approved Suppliers List," approved Aoril 25, 1977, has rut been
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l revised to update Appendix A, " Supplier Listing Page Format," to reflect the format actually being used by the licensee.
The licensee had implemented a computer program for supplier control and is revising nis procedure to reflect this change.
c.
Fort Calhoun Station, Unit 1 Standing Order No. G-18, Revision 3,
" Nonconformity Control," dated March 19, 1979, requires the use of a Nonconformity Report (NR) in lieu of a Deficiency Report (OR) for adverse conditions which, by definition, are within the scope of QAP No.15, Revision 1, " Adverse Condition Reporting and Correction,"
approved August 9, 1978.
This redundancy -in procedures is being eliminated by the licensee.,
d.
Licensee Quality Assurance Manual was reviewed with the following findings:
Section 1.2 states that the Omaha Public Power District commits
itself to and complies with... the mandatory Quality Assurance program guidelines contained in WASH-1283, Revision 1, " Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants"; WASH-1309, " Guidance on Quality Assurance Requirements During the Construction Phases of Nuclear i
l Power Plants"; and WASH-1284, " Guidance on Quality Assurance l
Requirements During the Operation Phases of Nuclear Power Plants."
Contrary to the above, Section 9.0, " Operation Quality Assurance," in Subsection 9.6.2, lists WASH-1284 and ANSI N45.2-1971 as " Informational documents for plant operations." WASH-1283 and WASH-1309 are not listed as reference documents though certain ascects of these documents are applicable during operations phases.
The licensee reaffirmed the commitment to the " WASH" documents and l
l will clarify the Quality Assurance Manual.
e.
Licensee QAP No. 8, Revision 0, " Qualifications for Construction Inspectors," approved April 25, 1977, covers only "... qualifications
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of OPPD QA Construction Inspectors." With the cancellation of Fort Calhoun Station, Unit 2, it appears that the need or scope for this procedure should be re-evaluated.
The licensee is cancelling this procedure.
f.
Licensee QAP No.15, Revision 1, " Adverse Condition Reporting and Correction," dated August 7,1978, fails to include in its scope the use of licensee QA Fonn No. 4a, "Non-Routine Quality Assurance Audit (Miniaudit)," which is the required fann for use by the licensee at an operating plant.
Licensee QAP No.15 also states, in Section 3.6.1, "On-the-Spot Corrective Action," that the iicensee QA representative can verbally identify without documentation discrepancies which can be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and do not apparently require management action.
" Management action" is not defined, but all such discrepancies must be reported to. the Manager, Fort Calhoun Station for action. Action by the Manager, Fort Calhoun Station could be construed to be " manage-ment action." Also,10 CFR Part 50, Appendix B, Criterion XVI does not contain such exclusions from documenting conditions adverse to ge *.l i ty.
The licensee is revising the procedure to clarify its iMent elative to "on-the-spot corrective action" and the use cf Fann 4a.
g.
Licensee QAP No. 5, Revision 1, " Supplier Qualification," dated December 1,1980, Sections 3.1.2.d and 3.1.4.e state that for qualification or Nconfirmation of qualification of suppliers
" acceptance by other means as being qualified to be added to, or continued on, the current suppliers' list, such as inputs from...
NRC White Book."
(The "NRC White Book" is NUREG-0040.)
The only NRC approvals shown in Section III of NUREG-0040 consist of Architect Engineering firms. No other infomation in NUREG-0040 indicates supplier acceptability. Approval of suppliers based on l
NUREG-0040 would be inappropriate, since NUREG-0040 states not only l
(1) that the infonnation contained therein is neither adequate nor intended to stand by itself as a source of infonnation concerning qualified suppliers, but also (2) that the Region IV inspections will not relieve the licensees or acplicants from any inspection / verification responsibilities required by criterion VII.
The licensee stated that lluREG-0040 is not used to approve suppliers ano that QAP No. 5 is being revised to clarify this point.
h.
Licensee QAP No.17, Revision 1, " Audit Planninn Performance, and Reporting," dated December 1,1980, does not differentiate between miniaudits and other audits, but certain sections such 2. 3.4 do not l
appear to be appropriate for miniaudits.
Procedure QAP No.17 is in the process of revision to clarify the requirements for miniaudits.
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The licensee had never performed an audit of the SARC for its compliance with involved requirements.
INPO will audit this area in June 1981.
j.
Licensee Quality Assurance Procedure No. 2 Revision 0, " Audit Plans,"
approved April 25, 1977, does not include in Section 3.13. " Procure-ment Control Licensee Nuclear Purchasing Procedure No.1 (NPP No.1),"
but this procedure has been audited by the licensee and QAP No. 2 is being revised to reflect NPP No.1.
5.
Licensee Actions Related to IE Bulletin No. 80-11 a.
Requirements
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IE Temporary Instruction (TI) 2515/37, dated July 3,1980, requires that the licensee's actions related to the design of masonry (concrete block) walls in the proximity of safety-related systems or having attachments from safety-related systems (IE Sulletin No. 80-11, dated May 8,1980) be verified by on-site inspection.
The NRC inspector reviewed the licensee's responses to IE Bu11stin No. 80-11, dated July 3,1980, with attachments and January 29, 1981, with attachments. The NRC inspector verified that the licensee's corrective actions, calculations, and evaluations of safety-related concrete masonry walls and/or safety-related equipment and systems associated with the concrete walls met the design and functional
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- dequacy required by IE Bulletin No. 80-11. The NRC inspector a
verified that these concrete masonry walls met their respective
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intended functions by discussion with a civil engineer, who was
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cognizant in this area; by visual inspection of representative walls l
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conducted by the NRC inspector; and by review of licensee calculations and the assumptions used in the calculations and evaluations.
b.
Licensee's Evaluation Methods
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The licensee used applicable building design codes as stated in the
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FSAR, Volume 2. Section 5.11. " Structures Other Than Containment,"
l (pages 5.11-1 through 5.12-1) and the 1979 Uniform Building Code, Earthquake Zones 2 and 3.
The loads and load combinations, the material properties, the design allowables, and the methods of i
calculations were acceptable in that these parameters were taken
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from applicable FSAR statements and governing codes. Assumptions used appeared to be conservative.(Example:
the collar joint shear strength for mortor was assumed to be zero for the calculations and evaluations).
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c.
General Discussion The NRC inspector performed a visual inspection (examination) for representative concrete mansonry walls to determine whether the licensee had evaluated all of the concrete masonry walls which support Seismic Category I pipes, Seismic Category I attachments l
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other than pipes, or are in the proximity to safety-related systems.
Licensee's plan views of each elevation level indicated a total of 42 concrete masonry walls.
Records and selected inspection of Type I and II walls indicated that four concrete masonry walls (Type I)
were reinforced single wythe (one concrete block width) and were the perimeter and dividar walls for the station battery rooms, eighteen concrete masonry walls (Type II) were unreinforced single wythe walls with mortor joints, and the other twenty walls (Type III)
were stacked solid concrete without mortor joints.
The NRC inspector selected six representative concrete masonry walls from the plan views for detailed visual inspection (examination). A visual inspection of each of these six concrete masonry walls was performed to verify that each of these walls had been evaluated by the licensee, as required by IE Bulletin No. 80-11.
From the inspec-tion results of these six concrete masonry walls out of a total of 22 (Type I and Type II) that could be involved in safety-related systems (either by attachment to the walls or in the proximity of safety-related systems), it appears that the licensee met the require-ments of IE Bulletin No. 80-11.
d.
Insoection (Examination)
The NRC inspector selected the six concrete masonry block walls listed below for inspection and determined that none of the selected walls should have a significant adverse effect on safety-related systems or components (electrical, piping, HVAC, or instru-mentation) during a postulated OBE or DBE. None of the 42 concrete masonry walls directly support any safety-related equipment.
None of these 42 walls function as a load bearing wall.
The complete failure of a wall should not affect safety-related equipment.
Concrete Masonry Wall Primary Plant Plan Description View Description Plan Number Elevation t
Battery Room Walls and Ground Floor Plan 11405-A-6 1007'
Divider Wall Heat Exchanger Room #14 Basement Floor Plan 11405-A-5 989'
(shutdown cooling heat exchanger)
l Waste Gas Compressor Room Basement Floor Plan 11405-A-5 989'
Corridor by Reactor Operating Floor Plan 11405-A-8 1036'
Control Room Spent Fuel Pool Heat Basement Floor Plan 11405-A-5 989'
Exchanger Control Room Panels Ground Floor Plan 11405-A-6 1007'
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6.
IE Oraft Circular - (Scheduled to be issued to all licensees in April 1981)
Discussion The NRC was advised by the Foxboro Company (Foxboro), Foxboro, Massachusetts, of two deficiencies in certain E-10 Series Foxboro Transmitters which could adversely affect their operation during postulated accident conditions.
Foxboro reported that these deficiencies involved the improper use of certain wire insulation and an unsuitable capacitor in the amplifier section of these identified transmitters. OPPD was informed of these two deficiencies by the Foxboro Company by a letter, dated March 12, 1981.
The NRC inspector discussed these two potential deficiencies that could affect certain Foxboro 10-50 milliampere transmitters with licensee personnel.
The information obtained from the licensee is listed below and a copy was for-warded to Mr. V. D. Thomas, IE:HQ, on March 31, 1981. The following list represents a 10-50 ma N-E10 and E10... MCA, MCA/RR, -/MCA/RRW transmitters or Part No. N0148PW amplifiers with Foxboro had been able to identify as being shipped to Fort Calhoun station either directly or through an agent:
Serial No./Part No.
Tag No.
N0148PW (Amplifier)
None 4201579 FT-1109 4201580 FT-1110 4201580 PT-105 4201581 PT-115 4201582 LT-901A 4201583 LT-901B 4201584 LT-901C 4201585 LT-901D 4201586 LT-904A 4201587 LT-9048 420156d LT-904C 4201589 LT-9040 4203969 LT-101T 4205440 Blank 7.
Exit Interview An exit interview was conducted on March 27, 1981, with those OPPD personnel denoted in paragraph 1 of this report to summarize the scope of the inspection and the findings.
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