IR 05000285/1981030
| ML20040D960 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/06/1981 |
| From: | Hunnicutt D, Kelley D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20040D953 | List: |
| References | |
| 50-285-81-30, NUDOCS 8202020437 | |
| Download: ML20040D960 (11) | |
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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report 50-285/81-30 Docket 50-285 License DPR-40 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: November 1-30, 1981 Inspector:
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D. L. Kelley, Senior Resident Reactor Inspector
{Date Approved by: h IM
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/A/81 D. M. Hunnicutt, Chief, Reactor Project Section 2
' Date Inspection Sunrrary Inspection conducted during period of November 1-30, 1981 (Report 50-285/81-30)
Areas Inspected:
Routine, announced inspection including (1) Operational Safety Verification (refueling mode); (2) Post Refueling Activities; (3) Performance Appraisal Inspection Findings. The inspection involved 84 inspector hours on-site by one NRC inspector.
Results:
Within the three areas inspected, no violations or deviations were identified in two areas. Within the third area (Performance Appraisal Inspection), six violations were identified.
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DETAILS.
1.
Persons Contacted
- S. C. Stevens, Manager, Fort Calhoun Station W. G. Gates, Supervisor, Operations G. R. Peterson, Supervisor, Maintenance
- Denotes those attending exit interview.
The inspector also talked with and interviewed other licensee employees during the inspection. These employees included licensed and unlicensed operators, craftsmen, engineers, and office personnel.
2.
Operational Safety Verification (Refueling Mode)
The inspector performed certain activities to ascertain that the iacility is being operated safely and in conformance with regulatory requirements, and that the licensee's management control system is effectively dis-
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charging its responsibilities for continued safe operation. The inspector's -
activities and findings in this regard are described in the following para-graphs:
a.
Inspection Activities Performed Several Times Per Week (1) Control room observations were made which included the following items.
(a) Licensee adherence to selected Limiting Conditions for Operations (LCO's).
(b) Verification of operator adherence to approved procedures.
(c) Verification of control room and shift manning.
(2)
Review of selected logs and records to obtain information on plant operations, trends, compliance with regulatory require-ments, and assess the effectiveness of communication provided by these logs and records.
b.
Inspection Activities Performed on a Weekly Basis (1) The licensee's equipment control was reviewed for proper imple-mentation by performing the following inspection activities:
(a) Review of maintenance order log and tag-out log to deter-mine the licensee's compliance with LC0's and Technical Specifications action statement.
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(b) Verification of " return to operable status of selected safety-related components and systems."
(2) The inspector toured the plant at various times during the inspection to determine and/or verify equipment conditions, plant conditions, security, safety, and housekeeping.
Obser-
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vations included the following:
(a) General plant and equipment condition (b) Fire hazards (c) Control of combustible material
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(d) Fire watch postings and presence of fire watches when required (e) Physical security (3) The inspector verified that the security plan is being implemented by observing that:
The security organization is properly manned and security personnel are capable of performing their assigned tasks.
Protection Area barriers are not degraded.
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Isolation Zones are clear.
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Vehicles are properly authorized, searched, and escorted
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or controlled within the protected area.
Persons within the protected area display photo identifi-
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cation badges and persons requiring escort are properly escorted.
Vital area physical barriers are not degraded.
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Persons and packages are checked prior to entry into the
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protected area.
The inspector observed several shift turnovers and reviewed several shift turnover sheets.
No violations or deviations were identified.
3.
Post-Refueling Activities The post-refueling activities that occurred during this reporting period consisted of:
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Core verification.
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Upper internals and incere instrument installation.
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Head installation.
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Low pressure hydro.
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The present schedule calls for restart on December 14, 1981.
The remainder of the refueling outage concerns completion of NUREG 0737 items requiring completion by January 1,1992.
No violations or deviations were identified.
4.
Performance Appraisal Inspection Findings The Performance Appraisal Branch of the NRC conducted an inspection of Omaha Public Power District management control of Fort Calhoun Power Station on August 17-28, and September 8-11, 1981.
The results of this inspection are documented in NRC Report 50-285/81-24.
As stated in paragraph three of the NRC inspection cover letter, "While the enclosed report includes observations which may result in enforcement actions, these matters will be followed up by the IE Regional Office."
The items listed below are the results of the follow-up by the Region IV staff.
The follow-up has resulted in the issuance of a Notice of Violation con-taining six violations.
The details are listed below and in NRC inspection report 50-285/81-24.
a.
It was noted that the District management involvement in the fire
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protection program was minimal.
The licensee's Technical Specifi-cation requires that fire protection program responsibilities be assigned or designated in procedures for the Assistant General Manager - Production Operations, the Division Manager - Production Operations, and the Section Manager - Operations.
Each of these positions was identified in the Technical Specification as having fire protection program responsibilities.
Failure to assign the responsibilities is a viol'ation against Tech-nical Specification 5.2.2.f.
Technical Specification 5.2.2.f states,
" Fire protection program responsibilities are assigned to those positions and/or groups designated by asterisks in Figures 5-1, 5-1A, and 5-2 according to the procedures specified in Section 5.8 of the Technical Specification."
(81-3001)
b.
The inspector determined that no system exists which provides control of materials from the time the item was issued and removed from the warehouse until the item was installe.
During a tour of the Auxiliary Building, an air-operated diaphragm valve was observed to be lying on a 55 gallon drum.
The valve was not sealed, packaged, or otherwise protected and was not identified as CQE material.
Subsequent investigation by the licensee estab-lished that the valve had been purchased as CQE.
Failure to properly control CQE after issuance is a violation against Criterion VIII of Appendix B to 10 CFR 50.
Criterion VIII of Appen-dix B to 10 CFR 50 requires in part that, " measures be established for identification and control of material, parts, and components including partially fabricated assemblies.
These measures shall assure that the identification of an item is maintained as required throughout fabrication, erection, installation, and use of the item.
These identification and control measures shall be designed to pre-vent the use of incorrect or defective material, parts, and compo-nents." This requirement is amplified in ANSI N45.2.2-1972, and OPPD Quality Assurance Program, Section 17.8.
The licensee had not written implementing procedures addressing this replacement.
(81-3002)
c.
The inspector determined that no comprehensive checklists have been established to define all CQE activities which should be covered by the audit program over a predetermined period of time. Although audit checklists contained some reference to observed problems in the area being audited, most showed little change between successive audits.
The result was that meaningful aspects of some subject areas were not audited, including the following:
Design Document Control, Plant Operating Incident (01)
Reporting Program, Plant Procedure Revicw and Approval, Security Personnel Records and SARC activities, District Headquarters Procurement Activities, QA Records, Electric Operations Division Relay Group Performance, Compliance with Surveillance Requirements and Limiting Conditions for Operation in the Technical Specifications.
Failure to provide comprehensive audit checklists is a violation of Criterion XVIII of Appendix B to 10 CFR 50 and Section 17.18 of the Quality Assurance Program.
Criterion XVIII of Appendix B to 10 CFR 50 states in part, "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 program.
The audits shall be performed in accordance with the written procedures checklists...."
(81-3003)
d.
During the review of the SARC Audit Program, the inspector deter-mined that a scheduled, periodic audit had not been performe.
Audits of the QA Program are required by Technical Specifica-tion 5.5.2.8.d to be conducted at least once every two years.
An audit of the Quality Assurance Program was last conducted by the SARC in January 1979.
An additional audit of the QA Program had been scheduled for June 1981; however, this audit had not been per-formed.
The assigned Audit Chairman stated that he had recommended procurement of outside audit services to accomplish this audit, although no audit by an cutside group had been scheduled.
Failure to conduct the required audits at least once every two years is a violation of Technical Specification 5.5.2.8.d.
Technical Specification 5.5.2.8.d states in part, " Audits of facility activi-ties shall be performed under the cognizance of the Safety Audit and Review Committee.
The audits shall encompass:... (d) the perfor-mance of all activities required by the Quality Assurance Program to meet the criteria of Appendix B,10 CFR 50, at least once per two years." (81-3004)
e.
A review of the SARC minutes for 1980 and 1981, by the inspector, revealed that the subcommittee review of safety evaluations for pro-cedures and procedural changes had not been performed and reported to the SARC as required.
Additionally, the screening process utiliz-ed by the plant staff to determine the safety evaluations requiring SARC review was not formalized and definitive acceptance criteria were not established.
An examination of recent safety evaluations for procedures revealed that numerous significant changes had been made to procedures during 1979 - 1981, and SARC review of the safety evaluations was not conducted.
Failure to review safety evaluations is a violation of Technical Spec-ification 5.5.2.7.a.
Technical Specification 5.5.2.7.a states,
"The Safety Audit and Review Committee shall review:
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The safety evaluations for 1) procedures, equipment or systems and 2) tests or experiments completed
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under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question." (81-3005)
f.
The inspectors, during their review, noted several I Mtinces where the licensee failed to follow approved procedurec
.ited below are the examples identified by the inspectors:
Electrical jumpers and blocks were requ. eo ( _.s controlled
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in accordance with Standing Order 0-25, 2 Electric.el Jumpers Control," Revision 6.
Nuisance alarms in the Control Poom were disabled by pulling the associated electrical card controlling the alarm in question, without conducting a proper safety evaluatio.
Licensee representatives did not recognize this action as
" lifting of leads" and, as a result, did not document the disabling of alarms in the jumper log in accordance with Standing Order 0-25.
This resulted in no management review being conducted beyond the Shift Supervisor.
Quality Control (QC) personnel were required, by Standing
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Order G-26, " Maintenance Quality Control Program," Revision 5, to review surveillance test procedures biannually to ensure that quality control requirements were incorporated into the procedures as appropriate.
Interviews with QC personnel revealed that these reviews were not conducted as required, primarily as a result of insufficient manpower.
Document review and interviews revealed that the updating of
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the CQE list was not effective.
All controlled copies of the CQE list were logged as having the latest changes entered; however, several of the controlled copies were found to contain out-of-date revisions.
Additionally, the CQE list referenced out-of-date drawings.
Station Standing Order G-22, " Storage of Critical Quality
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Elements," Revision 3, Section 3.5, required that hazardous chemicals, paints, solvents, and other materials of a like nature be stored in well ventilated areas which are not in close proximity of CQE items.
The storage of bags of boric acid crystals, oil drums, and paint inside or adjacent to the CQE storage area was considered in conf.ict with this requirement.
An observed discrepancy in the audit program was the failure
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to properly document audit findings in a manner which pro-vided for a written response or follow up review of corrective actions.
Section 3.6.3 of QAP 15, " Adverse Condition Report-ing and Correction," Revision 2, specified the use of a deficiency report (QA Form #2) or QA report (QA Form #4) to effect corrective actions arising from QA audits.
However, several significant audit findings were not documented in a manner which required a written response.
The following were examples:
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Several missing 1980 surveillance test records (QA Audit 3-81)
Anomalies identified by surveillance tests not corrected
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by initiating a Maintenance Order (MO) or Operations Incident (01) report (QA Audit 3-81)
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Numerous discrepancies in security personnel records
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(QA Audit 6-81)
Training not offered for off-site Emergency Plan support
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personnel (SARC Audit 6-80)
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Unused security key cards not kept in a locked container or location (SARC Audit 79-05)
Safety-related design change packages not sent to QA for
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review as specified in standing orders (QA Audit 26-81)
Incomplete or inadequate design reviews (QA Audit 26-81,
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item 6.1.7)
QAP 17, " Audit Planning, Performance, and Reporting," Revision 1,
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requires persons having direct responsibilities for the perfor-mance of activities being audited not be involved in the selection of the audit team.
Also, QAP 17 states that SARC audits will be performed under the guidelines provided in that QAP.
Observations in this regard revealed that some audits involved the use of auditors having responsibilities in the areas being audited, including the following:
Assignments for the last two SARC audits of the fire pro-
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tection program included an auditor to whom the TS assign responsibility for the program.
The Division Manager - Production Operations and the
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Station Manager were assigned as team reembers for a SARC Audit (6-80) of the Site Emergency Plan, an activity for-which these individuals were accountable.
A SARC Audit (3-80) of facility performance, training, and qualifications also included the Division Manager - Production Operations and the Section Manager - Operations (audit team leader).
These positions were also responsible for plant staff per-formance (it is listed as one of the primary responsibilities in the job description for the Section Manager - Operations).
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Auditors for the last two scheduled SARC audits of the QA program were selected and assigned by the SARC Chairman, who was also the QA Manager.
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The Operations Quality Assurance Engineer (0QAE), and the auditors reporting to him, had conducted several audits which included verification of actions for which the OQAE was responsibl.
The licensee's program for certifying QA auditors and. lead
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auditors was defined in QAP 18, " Auditor Training and Qualification," Revision 0, which was. consistent with ANSI N45.2.93-1978.
The licensee's QA organization included six certified lead auditors, three of whom were the Corporate, Operations, and Construction QA Engineers. These six lead auditors conducted essentially all internal and external QA audits. All of the lead auditors had attended a contractor-provided lead auditor course which was indicated-by interviews and a course description to have provided effective training.
Examination of auditor certification records, however, disclosed the following discrepancies:
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The credit point system established in ANSI N45.2.23-1978, and QAP 18 was used to establish the qualifications of lead auditors based upon education and experience.
The records indicated, however, that three of the six lead QA-auditors had been awarded point credits for an associated degree based upon " equivalent" training received.
No provision for point credits based on equivalent training was included in either QAP 18 or ANSI N45.2.23.
Available records indicated that only one of the six lead
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auditors had participated in five audits prior to certifi-cation as a lead auditor.
Section 3.1.1 of Quality Assurance Procedure 19 required that
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" orientation in the quality assurance areas will be provided for applicable OPPD personnel, including applicable upper management." Section 3.1.2 of the same procedure required that
" personnel will receive indoctrination on the eighteen (18)
criteria given in 10 CFR 50, Appendix B,... NRC Regulatory Guides; and ANSI N45.2, series standards on quality assurance."
A review of the training program at the Fort Calhoun Station and at OPPD headquarters revealed that the quality assurance indoctrination training described above had not been conducted.
Section 17.2.4 of the licensee's FSAR, which is a part of the
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latest Quality Assurance Program submission, dated February 24, 1981, further stated that "... personnel performing quality affecting activities are required to possess documented evidence that they are trained and qualified in the principles and techniques of the activity being performed."
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Training and retraining programs for all licensee personnel performing activities affecting quality had not been promulgated or implemented as demonstrated by the following examples:
Other than GET, an initial training and retraining program
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had not been developed for engineers in Generating Station Engineering who performed safety-related engineering acti-vities in support of the Fort Calhoun Station.
Other than GET, there was no established retraining
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program for Engineers in the Technical Sr:rvices Section who performed safety-related engineering tasks.
Section 5.1.2.2.a of the OPPD Fort Calhoun Nuclear Power Station,
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Unit No. 1 Training Manual, dated June 1, 1981, requires that a Test Engineers Technical Training Program be established.
A review of the training program at the Fort Calhoun Station revealed that this training program for Test Engineers had not been implemented.
A lack of documented design verification was identified by the
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OPPD Quality Assurance Department (Audit #27-80).
As a result of the QA Audit, design verification was started in the mechan-ical/ piping areas; however, design work in the electrical area was not being routinely verified.
Furthermore, action was not being taken to ensure that all design work performed before the QA Audit was correctly verified and documented.
Examples of this lack of documentation are found in the following Design Packages:
DR #FCl-80-A-0043 DR #FCl-80-0-0029 DR #FCl-80-A-0045 DR #FCl-80-A-0044 Failure to follow approved procedures is a violation of Criterion V of Appendix B to 10 CFR 50.
Criterion V of Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,... and shall be accomplished in accordance with these instructions, procedures, or drawings."
(81-3006)
The licensee has responded by letter (OPPD to NRC Region IV) dated November 20, 1981.
The response addressed those areas identified in NRC Report 50-285/81-24, as "below' average." The violations identified in this report as 81-3003, 81-3004, and eight of the eleven examples of 81-3006, were discussed.
The inspector has reviewed the responses that address the above violations.
The
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inspector has no further questions concerning violations 81-3003, 81-3004, and items c, and e through k of 81-3006. These items are considered closed.
Violations 81-3001, 81-3002, 81-3005, and the remaining parts of 81-3006, will remain open pending response by the licensee.
5.
Exit Interview The inspector met with Mr. S. C. Stevens, Manager, Fort Calhoun Station, on November 30, 1981, to discuss the. scope and findings of this~ inspection.
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