IR 05000285/1981015
| ML20009G627 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/06/1981 |
| From: | Randy Hall, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20009G616 | List: |
| References | |
| 50-285-81-15, NUDOCS 8108040487 | |
| Download: ML20009G627 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report:
50-285/81-15 Docket:
50-285 Licensee:
DPR-40 Licensee: Omaha Public Power District 1623 Harney Street Omaha, Nebraska 68102 Facility Name:
Fort Calhoun Station, Unit 1 Inspection at:
Fort Calhoun Station, Blair, Nebraska Jones St. Offices, OPPD, Omaha, Nebraska Inspection Conducted:
June 15-18, 1981 Inspector: _
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'p.P.Jaudon,ReactorInspector,Systemsand
/Date Technical Section Approved:
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'R. E. Hall, Chief, Systems and Technical Section Dat'e Inspection Summary:
Inspection Conducted June 15-18, 1981 (Report 50-285/81-15)
Areas Inspected:
Routine, unannounced inspection of the nonroutine reporting program and the design change / modification program. The inspection involved 26 inspector-hours by one NRC inspector.
Results: Within the two areas inspected, no violations were noted.
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DETAILS SECTION 1.
Persons Contacted
- R. L. Andrews. Section Manager, Operations
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- J. E. Bentzinger, QA Engineer D. Dale, QC Inspector J. Fisicaro, Supervisor, Administrative Services L. Kopechy, Engineering Aide B. Livingston, Supervisor, Administrative Services
- K. J. Morris, Manager, Administrative Services
- T. L. Patterson, Licensing Administrator A. Richard, Plant Engineer
- S. C. Stevens, Manager, Fort Calhoun Station
- P. M. Surber, Section Manager, Generating Station Engineering
- F. A. Thurtell, Division Manager, Environmental and Regulatory Affairs The NRC inspector also contacted other plant and staff personnel including administrative, clerical, and engineering personnel.
- Denotes presence at the exit interview conducted June 18, 1981.
2.
Nonroutine Reporting Program The NRC inspector reviewed the licensee's program for nonroutine report-fng. The licensee has several procedures concerned with nonroutine etporting.
Each procedure addressed a different aspect of nonroutine reporting. Within the context of this inspection, the three applicable procedures reviewed were:
G-42, Revision 1 (1/18/81), " Reporting of Defects and Non-Compliance to the Nuclear Regulatory Commission" 0-39, Revision 0 (12/31/80), " Procedures for Feedback of Operating Experience to Plant Staff" R-4, Revision 7 (4/15/81), " Operating Incident Reports" The NRC inspector found that Procedure G-42 assigned responsibility and implemented a methodology to identify nonconforming items and to make reports as appropriate.
The NRC inspector had no questions in this area of the inspection.
Review of Procedure 0-39 disclosed that it dealt with information originated within the plant or received from outside sources (e.g.,
vendors, INP0).
By Procedure 0-39, an " operations assessment group" was established.
The operations assessment group was composed of Shift Technical Advisors and coordinated by the Reactor Engineer.
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lug was maintained to track items to be assessed and to assure follow-up action.
The NRC inspector found that the Station Manager was familiar with the log and directly concerned with the assessment of information and follow-up actions (i.e., training, procedure revision, etc.). The NRC inspector had no questions in this area of the inspection.
The NRC inspector found that the licensee had modified his program for internal reporting of " operating incidents" in April 1981; consequently, the NRC inspector concentrated his effort on the licensee's program in this area of the inspection to the period after procedure revision.
The NRC inspector found that operating incidents were serialized and initially controlled by the Shift Technical Advisor until turned over to the Plant Review Committee for review.
From records, this time delay appeared to be one to two working days.
The NRC inspector noted that the Shift Technical Advisor *.sas instructed by procedure to notify the Plant Manager (or designated alternate) if an operation incident report appeared to have the potential for an immediate report to the NRC or other regulatory agency.
From review of completed operations incident reports, the NRC inspector concluded the licensee was not reluctant to identify problems or issues.
The NRC inspector also found that the review of operation incident reports by the Plant Review Committee was detailed.
The Safety and Audit Review Committee also reviewed operation incident reports and, in some instances, requested additional information or directed action.
The NRC inspector had no further questions in this area of the inspection and perceived that the licensee was effectively executing this phase of his nonroutine reporting program.
No violati( s or deviations were noted during this portion of the inspec-tion.
3.
Design, Design Changes and Modifications The NRC inspector's review of the licensee's program for design, design changes and modifications is subdivided into the following five sections:
procedure, testing of modifications, design change backlog, records, and drawing update.
a.
Procedure The licensee's procedure for design, design changes and modifica-
l tions is G-21, Revision 10 (8/28/80), " Station Modification Control."
This procedure was found to be applicable to all generating stations, nuclear and non-nuclear, operated by the licersee; however, some specific requirements in the procedure were applicable to Fort f
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i Calhoun Station only.
The NRC inspector found that the division of
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responsibility in Procedure G-21 appeared to be good in that Generating Station Engineer Ing was responsible for design, the work instructions and draft test procedures; while the site (Plant Review Committee) reviewed the design package.
The NRC inspector concluded that this provided a reasonable crosscheck on the design effort and implemented the Technical Specification require-ment for PRC review, b.
Testing of Modifications The NRC inspactor noted that the final work package, as prepared
by Generating Station Engineering, should include (in accordance with Procedure G-21) draft test procedures as appropriate. The NRC inspector found that the licensee did not meet this requirement in all cases.
For example, by EEAR FC-78-28, the licensee added a new line from the spent regenerant tank to the waste hold up tanks. The licensee did not have a test procedure for this work, but there was a requirement in Step 21 of the work instructions, which stated, " Leak test shall be by initial service method per
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B31.1. QC inspect." Review of ASME B31.1 indicated that a hydro-l static test was required unless one was not #casible, in which case an initial service leak test was an allowed alternative. The NRC inspector established from the licensee's drawings (ll405.M.7 and 9)
that a hydrostatic test was feasible and therefore should have been used.
In a second example, the NRC inspector found that when the licensee replaced feedwater recirculation valves (EEAR FC-79-14)
neither was a hydrostatic test required nor was a procedure included e
in the final design package. A hydrostatic test was added to the work instructions by Fort Calhoun Setpoint/ Procedure 0,.. ige No. 5798,
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but this change stated, " hydrostatic testing of isolated line(s) to maximum work'. 49 pressure of 1500#." The test pressure of 1500 psi did not appear to be the correct test pressure by ASME B31.1, which i
licensee representatives agreed was the applicable Code.
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l Although these two examples did not involve safety-related systems, the NRC inspector concluded that the licensee's failure to follow his own procedures or to select correct tests or test pressures indicated a deficiency in the engineering supprt which could in the future affect safety-related systems.
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c.
Design Change Backlog The NRC inspector found that the licensee had a large and apparently growing backlog of design changes.
Additionally, neither the licensee nor the NRC inspector could detennine an exact number, because several outstanding design changes have apparently been duplicated over the years by resubmission in slightly modified format. One licensee
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representative estimated that the backlog of uncompleted design changes was "about 200".
The NRC inspector concluded that 300 or more was a more accurate figure; this included requests for design changes being evaluated by Technical Services, design changes under preparation by Generating Station Engineering, and design changes not completed or finally closed.
The licensee promulgated a bimonthly report listing all design changes (i.e., those requests released by Technical Services as design changes), but for the reason (duplicates)
stated above, it did not provide an accurate count.
Licensee repre-sentatives stated that there was an effort in progress to identify and eliminate duplicate design changes but did not commit to a completion date. This is considered to be an unresolved item pending licensee action to eliminate duplicate design changes and correct the report of design changes required by Procedure G-21 (8115-01).
The NRC inspector also noted that this bimonthly report is not prepared by Generating Station Engineering as stated in Procedure G-21 but by another department.
This is considered to be an open item until the licensee modifies his procedure to reflect his actual practice in this regard (8115-02).
The NRC inspector reviewed logs maintained by Generating Station Engineering listing the status of design change requests (EEARs)
and design changes.
These logs indicated the following for 1980 and 1981 through the date of the inspection:
1980 1981 No. of EEARs received by Technical Services and not rejected 136
No. of EEARs fowarded by Technical C-Services for design change action
24 No. of design changes cumpleted on site
2 No. of design changes completed (drawings, updated, etc.)
1 Licensee representives informed the NRC inspector that the logs from which the above information was drawn were new and not necessarily
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yet reflective of actual status.
The NRC insper. tor concluded that, considering the number of design changes outstanding from years prior to 1980, the estimate of a backlog of design changes numbering about 300 was reasonably accurate.
The NRC inspector further con-cluded that the licensee's committment of engineering support resources had apparently not been at a level to preclude the buildup of this large backlog of design changes and that there was no direct evidence that engineering support for Fort Calhoun was commensurate with the engineering support needs for the nuclear generating statio _ _ _ - _ _ _ _ _ _.
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d.
Records
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In reviewing the records for completed design changes, the NRC inspector found apparent discrepancies in the Welding and Test i
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Control Records Form FC-145.
The nature of the discrepancies
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was apparently incomplete, inconsistent or conflicting entries
in the nondestructive test section of the Forms FC-145 when these
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forms were compared to other portions of the records. The NRC inspector resolved the specific discrepancies he had noted by inter-views with the Quality Control inspectors involved; however, the NRC inspector did not find that the licensee had definitive instruc-tions for the use af Form FC-145.
Furthermore, the NRC inspector
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noted that Procedure G-21 specified Generating Station Engineering
was responsible for the coi.,pleted record package for design changes.
This requirement is also delineated in licensee Procedur.; C-2, Revision 6 (9/30/80), " Fort Calhoun Station Quality bsurance (QA)
Records," and QAP-7, Revision 1 (8/7/78), " Storage and Retention of QA Records." The NRC inspector concluded from discrepancies noted in Forms FC-145 and from the fact that design change records were found which contained misfiled or extreeous information (e.g.,
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correspondence on PORV testing filed with a.:ed pump design change)
that the licensee had not established uniform or minimum standards for design change record packages. This is an unresolved item pending licensee action to promulgate definitive instructions for the
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use of Form FC-145 and for the content and review of completed design
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change record packages (8115-03).
e.
Drawing Update l
The NRC inspector noted that the licensee had a long history of problems with resource allocation to drawing revision (IE Inspec-tion Report 76-03) and with the timeliness of drawing revision i
(IE Inspection Report 79-08).
Licensee representatives informed the NRC inspector that difficulty was still being experienced in updating drawings in a timely manner, especially in the area of electrical drawings. The licensee's Procedure G-21 establishes that six weeks is the normal revision time. The NRC inspector also noted that the licensee had no program or methodology to update any drawings on site after a design change had been completed until the formal drawing revision was issued, but that there apparently was an unofficial mark up of drawings on site in some instances after a design chango was made.
The NRC inspector expressed his concern to licensee management that
l operators and other plant steff were faced with the potential of
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J reacting to a casualty or emergency situation with incorrect drawings and that the unofficial (and uncontrolled) mark up of drawings was widespread.
Licensee representatives stated that a plan to unify all
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drafting personnel under a single supervisor was being considered.
The stated purpose cf this proposed organizational change was so that a more efficient use cf drafting personnel could be realized. The NRC inspector concluded that there was an apparent chronic deficiency in engineering support in this area.
This is an unresolved item (8115-04) pending evaluation of licensee action to reorganize and apply resources more effectively in this area.
4.
Unresolved items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. The unresolved items dit ?osed in this report are:
Nunter Subject 8115-01 Duplicate Design Changes (paragraph 3.c)
8115-03 Records of Design Changes (paragraph 3.d)
8115-04 Timeliness of Drawing Update (paragraph 3.e)
5.
Exit Interview An exit interview was conducted June 18, 1981, with those Omaha Public Power District personnel denoted in paragraph 1 of this report. At this meeting, the scope of the inspection and the findings were summarized.
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