IR 05000285/1985029
| ML20199F445 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/26/1986 |
| From: | Barker L, Heishman R, Konklin J, Lloyd R, Murphy M, Saunders A, Whitney L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20199F443 | List: |
| References | |
| 50-285-85-29, NUDOCS 8603280215 | |
| Download: ML20199F445 (52) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT-DIVISION OF INSPECTION PROGRAMS REACTOR CONSTRUCTION PROGRAMS BRANCH Report No.: 50-285/85-29 Docket No.: 50-285.
Licensee: Omaha Public Power District Licensee No.: DPR-40 1623 Harney Street Omaha, NE 68102 Facility Name: Fort Calhoun Nuclear Station Blair, Nebraska
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Inspection At: Fort Calhoun Nuclear Station Inspection Conducted: November 6-8, November 18-22 and December 9-17, 1985 Inspectors: -), f kf "
b2Y-8b-d/L. Bark ~er, Senior Reactor Construction Engineer, Date Signed Inspection Team Leader ik d Reactof D Cet Construction Engineer
' S/26/1C Date Signed
.L.LloyL.aw a.b' &As NM. E. Murph , Project Inspector, R-IV Date Si ned
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~ w~cLeah A. H. Saunders, Reactor Construction Engineer 2h46 Date ' Signed 0 Yu tuMNV KYe(c M .. E. Whitney, Reactor Operations Engineer Dite Signed f
E. Konklin, Chief, Special Programs Section f/26/1C Date Signed Consultants: W. S. Marini, W. H. Robinson, R. E. Serb, M. D..Sulouff Approved By: # 8 Robert F. Heishman, Chief Date Signed Reactor Construction Programs Branch 8603280215 860319 PDR ADOCK 05000285 G PDR INTRODUCTION AND SUMMARY Introduction The following subparagraphs provide introduction to the objectives,' format and focus of the Fort Calhoun Safety Systems 0utage. Modification Inspectio . Objectives This inspection was part of a trial NRC program being implemented to examine the adequacy of licensee management and control of modifications performed during major plant outages. The purpose of this portion of the Safety System Outage Modification Inspection Program was to examine, on a sampling basis, the installation and testing of selected modifications accomplished during the outage. This assessment covered the following areas:
Effectiveness of controls for conducting modification work activities during outages, Accomplishment of modification work activities in accordance with the established procedures and commitments, Proper inspection and testing of completed modifications, and Readiness of affected systems for safe startup and operation of the plant following the outage.
1.1. 2 Report Format and Definitions The areas examined during this inspection are addressed by functional area in the following sections. Deficiencies, unresolved items,'and observations are defined below:
(1) Deficiencies Errors, inconsistencies or procedure violations with regard to a specific licensing commitment, specification, prccedure, code or regulation are described as deficiencie Followup action is required for licensee resolution.
(2) Unresolved Items Unresolved items are potential deficiencies which require.more information to reach a conclusion. Followup action is required for licensee resolu-tion.
(3) Observations Observations represent cases where it is considered appropriate to call attention to matters that are not deficiencies or unresolved items. They include items recommended for licensee consideration but for which there is no specific regulatory requirement. No licensee response is require .- . _
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1. Fort Calhoun Project Organization The Omaha Public Power District is the licensee for the Fort Calhoun Nuclear Station. As such, Omaha Public Power District is responsible for the design, construction and operation of the facility. The utility holds responsibility for the overall plant design, with contract design support from Stone and Webste The original architect / engineer (Gibbs and Hill, Durham and Richardson) is no longer under contract to the licensee. Other firms are occasionally engaged for services. Combustion Engineering designs and provides the nuclear steam supply system. The nuclear steam supply contract is managed directly by Omaha Public Power Distric . Inspection Effort An announced team inspection of installation and testing activities associated with outage modification work was conducted at Omaha Public Power District's Fort Calhoun Nuclear Station during the periods of November 6-8, November 18-22 and December 9-17, 1985. This inspection was part of the Trial Safety Systems Outage Modification Inspection Program. Management controls were evaluated in eleven functional areas using eighteen outage modifications as the basis for the inspectio The trial NRC program is being implemented to examine the adequacy of licensee management control of modifications performed during plant outages. The design inspection and vendor inspection portions of the trial program were completed in September and October 198 The results of those inspections are reported in separate inspection reports. The applicable report numbers are provided in Section 3.2 of this report. This installation and testing inspection involved 912 inspection hours on-site assessing modifications accomplished at Fort Calhoun during the outage as well as planned testing and operational readiness of the plan An additional 160 manhours were spent on-site receiving General Employee Training (GET) and radiological qualification to conduct the inspec-tio The inspection was centered around the 18 outage modifications shown in Table I. These modifications were inspected either partially or in detail as applicable to suit the inspection focus at the time. The inspection was basically hardware and test oriented, however, some programmatic areas, that led to or affected installation of hardware or system testing, were also reviewe This inspection report and identified concerns have been separated into the following functional area Design Change Control - Section Document Control - Section Installation Procedure Controls and Compliance - Section Mechanical / Electrical Installation and Construction Control - Section Welding and ND.E Control - Section *
Maintenance Control and Practices - Section Operations and Test Control - Section Material Control During Storage and Pre-Installation - Section Corrective Actions - Section 2.10 Quality Assurance Audits - Section 2.11 Qualification and Training - Section 2.12-2-1 Overall Conclusions The NRC inspection team concludes that weaknesses exist in the licensee's program for accomplishing outage modification work activities. The team identified concerns in each of the eleven functional areas reviewed and considers that management attention needs to be directed toward resolution of the concerns. The most significant concerns identified were in the areas of (1) engineering evaluations of design changes, (2) nonconforming installations, (3) inadequate quality control, and (4) inadequate material contro These are summarized as follows:
1. The inspection team found that the licensee had failed to perform engineering safety evaluations for a number of temporary or permanent design change The inspectors found that temporary and permanent lead shielding installations were in place on safety and nonsafety-related piping and components for extended periods of time with no documented engineering safety evaluations. The governing plant procedure in this
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area was found to be inadequate in that no controls were placed on accomplishing engineering analyses and safety evaluations prior to installation of lead shielding. In other examples, a tubing fitting was installed through a fire barrier and electrical jumpers were used in safety-related applications for extended periods of time with no documented engineering safety evaluation . The inspection team found installation inadequacies associated with eight of 13 installatio'sn inspected in the plant for modifications accomplished during this outage. The number of discrepancies found indicated a need to improve installation procedures, craft workmanship and practices, and attention to detail by engineers, craft and quality control personne . The team found quality control inadequacies in several functional areas of the inspection. Examples include acceptance of a dye penetrant inspection of a visually unacceptable weld, acceptance of a visually unacceptable end preparation that violated minimum wall thickness requirements, performance of and acceptance of dye penetrant inspections at temperatures below procedure requirements, acceptance of conduit support welds that were not in accordance with design requirements, and approval of procedures with hold points by other. than Level III inspectors. These examples and others identified in the report indicate a lack of effectiveness of quality control personnel and a need for increased. involvement by corporate quality assurance to
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identify and resolve problem . During inspection of safety-related material stored in the warehouse and in temporary storage areas near work locations, the team identified a number of hardware related discrepancies. These included material being damaged while in storage, nonsafety related material being stored in a safety related storage area, material being incorrectly tagged, and level B material being stored in a level C area.
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1.3 Summary of Findings by Functional Areas The eleven management control functional. areas evaluated in the installation and testing portions of the inspection are listed below with the associated findings identified under each heading. Detailed discussions of the findings, with identification number designations, are included in Section 2 of this repor . Design Change Control Based on a limited review of design change control, the team found that engineering safety evaluations were not accomplished for a number of temporary or permanent design changes to the plant. Examples included installation of lead shielding on' safety-related piping and components with no documented engineering analyses or safety evaluations, instal-lation of a tubing fitting through a fire. barrier with no evidence of approved design change documentation or safety evaluation, and use of safety-related electrical jumpers for extended periods of time without engineering documentation or safety evaluation . Document Control Document control was found to be-in accordance with site procedures with the exception of concerns identified with construction package drawing control and lack of documented field changes to support changes made to installation procedures, calibration sheets and calibration procedures. In addition, several procedure changes were found to have not been reviewed by the Plant Review Committee (PRC) within Technical Specification time constraints, and, in one case, a change was implemented prior to PRC review. The team also fcund that construction package documents were not adequately cortrolled and that the use of initials not identifiable to signatures were being used for official record signoff . Installation Procedure Controls and Compliance The team found that installation procedures generally lacked the details required to adequately control installation of modification It was also noted that no governing procedure existed for preparation of installation procedures or test procedures. In' addition, inadequacies were noted in standard plant procedures for installation of cables and electrical seismic supports. Several instances were also a identified by the team in the area of failure to follow procedure The most significant example occurred when a section of the fire protection Halon system was disabled without providing for a continuous fire watch and backup fire suppression equipment. Other examples included a missed procedure hold point, lack-of shift supervisor approvals prior to starting work, and approval of procedures with hold points by other than Level III inspector . Mechanical / Electrical Installation and Construction Controls The team identified concerns with eight installations out of 13 inspected in the plant and considered that mechanical / electrical instal-lation and construction controls were inadequate. Some of the more-4-
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.significant problems ~ noted were span . violations and lack of required seismic ~ supports for instrumentation tubing, incorrect makeup of a flanged joint, safety-related cables tie-wrapped to nonsafety related cables, violations of minimum bend radii for electrical cables, and no objective evidence to verify Foxboro transmitter 0 rings had been replaced to maintain environmental qualificatio . Welding and NDE Control Based on a. limited review of welding and nondestructive examination
. control,-the team found significant inadequacies in the . licensee's program. The-team identified two cases of unacceptable welding and dye penetrant inspection that had been accepted for service, and identified an end preparation that had been welded and accepted for service that violated minimum wall thickness requirements. The team also.found that a flat plate 90 degree fillet weld procedure was used'to accomplish'
skewed fillet welds, plug welds, pipe boss attachment welds'and seal welds. In addition, the. team found that weld fitup requirements for ASME code welding'were not being verified by QC personnel prior to weldin . 3. 6 - Maintenance Control and Practices Inadequate maintenance controls and practices were observed by the team during the inspection. These. included piping damage caused by use of a pipe wrench, damage caused by installing a valve packing gland flange upside down, fasteners installed without full thread engagement, use of inadequate cleanliness barriers, flanged joints not made up properly, and use of unauthorized shim . Operations and Test Control The team identified a concern regarding a battery charger load test procedure which resulted in'an indeterminate test because float and equalizing voltages were not recorded. A functional test procedurc-inadequacy was identified in which the modification was not to be tested in an accident condition. A lack of verification of system depressurization was noted in one case. In another case, the test procedure acceptance criteria did not agree with design test criteria, plant conditions and test acceptance were not required to be verified, and nominal leakages were not being considered in the tes .
1. Material Control During Storage and Pre-Installation y
The team identified significant concerns in the area of material control, both in temporary storage areas and in the warehouse. These included material being damaged in storage' areas, nonsafety-related material ~.being stored in safety related areas, no QA acceptance cards on material stored in a safety-related area, material incorrectly tagged, level B material' stored in a level C area for up to 19 months, and incomplete material certifications for material designated as acceptable for use. In addition, quality control audits of temporary-5-
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safety-related storage areas were not accomplished on the specified regular monthly basis.
1. Corrective Actions Th? team identified two Cases of inadequate corrective action The first example involved installation of lead shielding without incor-porating identified requirements into the licensee's program for-control of lead shielding, and not resolving previous inspection findings identified by INPO in this area. Tte other example concerned
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the System Acceptance Committee area, and involved a failure to clear or resolve discrepancies identified to plant systems that the committee had accepted.for operation.
1.3.10 Quality Assurance Audits The team identified inar+ uacies during reviews of past QA audits of design change control ar.u control of special processes. 'The QA audits included checks against OPPD procedure requirements only,- field checks were not done, and OPPD procedures were not evaluated against code or ANSI requirements.
1.3.11 Qualification and Training of Personnel Enginaers and maintenance personnel appeared to be qualified to OPPD requirements to accomplish outage modification work. However, concerns were noted in the program concerning a general lack of experience level.and lack of system training for design engineers, and-a lack of nuclear craft training for craft personne .4 Corrective Actions Prior to Restart Identified concerns were discussed with OPPD management throughout the inspection so that corrective actions could be promptly taken to-minimize any potential impact of the findings on- the plant startup schedule. In addition to the corrective actions taken with regard to the lead shielding findings, which include removal of the shielding from mall-bore piping and analysis of the shielding effects on large-bore piping, OPPD agreed that ten other items should be addressed prior to startup. The items include the following:
1. MR 83-158; Air accumulators for YCV-1045 A/ Acceptance criteria required a one-hour test; the functional test was for 30 minute . MR 85-009; Replace EQ related penetration subassemblie No documentation of 0-ring replacement to maintain equipment qualificatio . MR 85-042; Replace MS-10 .
Minimum wall violation on pipe nipple welded to MS-10 . Unknown MR; Tubing fitting installed through a fire barrie No engineering or safety evaluation per 10 CFR 50.5 . Maintenance; HCV-1042C Packing gland flange installed upside down and bent eyebolt . MR 84-061; Union installation on SI-209, 213, 217 and 22 Crater pit on union tail piece pipe for SIT-6 Large flat surface discontinuit . MR 84-140; Delta T Power Process Loops Conduit support welds were not in accordance with desig . MR 85-062; Replacement of CCW Flow Element
% PT inspections accomplished at temperatures below procedure requirement Welds with linear PT indication . MR 84-119; Replacement of instrument inverter Indeterminate test because of lack of documentatio .4.10 MR 84-74A; Fuse protection for limit switche Functional test failed to test modificatio l
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.During the exit meeting on December 18, 1985, OPPD indicated that the necessary corrective actions were either completed or underway on each of the'above items. Prior to plant startup, .0 PPD provided information to the NRC Senior .
Resident Inspector regarding the completion status of all the items. The Senior Resident Inspector has' reviewed selected items to verify the reported statu .g.
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. _ _ - _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ DETAILED INSPECTION FINDINGS List of Deficiencies, Unresolved Items and Observations Item Subject Report /Section D2.2-1 Lack of documented safety. evaluations 2. for installation of lead shielding on safety-related piping and component .2-2 Lack of documented safety evaluation 2. for installation of a penetration fitting through a fire barrier D2.2-3 Lack of documented safety evaluations 2. for electrical jumpers installed for extended time period .3-1 Inadequate control of construction 2. package drawings and drawing lists D2.3-2 Unapproved chang?s to installation 2. procedures D2.3-3 Procedure change implemented prior 2. to PRC approval D2.3-4 Training not accomplished prior to 2. approval of procedure change U2.3-1 On-the-spot changes not approved by 2. PRC within Technical Specification time constraints 02.3-5 Construction package drawing changes 2. without an approved field change 02.3-6 Calibration procedure changes without 2. approved field changes U2.3-2 Lack of calibration record for a 2. pressure source used for safety related channel calibration 02.3-1 HVAC duct support location changes 2. without complete change documentation 02.3-2 Inadequate control of construction 2.3.10 packages and construction package documents 02.3-3 Extensive use of initials in permanent 2.3.10 QA record documents
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Item Subject Report /Section D2.4-2 Failure to follow procedure require- 2. ments 02.4-1 Electrical Standard Procedures failed 2. to adequately cover safety-related work items and QC items 02.4-2 Shift supervisor unaware of installa- 2. tion and removal of electrical jumpers by procedure field change 02.4-3 Lack of governing procedure for prepara- 2. tion of installation instructions or test instructions D2.5-1 Inadequate welding, end preparation, and 2. inspection associated with replacement of valve MS-100 02.5-2 Seismic instrumentation tubing span 2. violations between supports 02.5-3 Inadequate support of seismic instru- 2.5.2
mentation tubing near air regulators 02.5-1 Lack of support at concentrated loads 2. in seismic instrumentation tubing installations 02.5-4 Installation discrepancies found in 2. installation of safety injection tank relief valves D2.5-5 Inadequate flow element flange instal- 2. lation D2.5-6 Installation discrepancies found in 2. 'nstallation of new delta T power
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process loop instrumentation Questionable installation practices relative to
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U2.5-1 2. insta11atin of delta T power process loops cables and panel D2.5-7 Weld inspections not accomplished for- 2. transfomer base welds to the imbedments U2.5-2 Foxboro transmitter 0-ring replacement 2. not documented to maintain environmental qualification 02.5-2 Inadequate retest of SG A pressure 3 i+ch 2. .- _ _ _ _ - .- - _ _ _ _ _ _ _ _ . _- _ _ _ _ _ - .
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Item Subject Report /Section 02.5-3 HVAC support design based on erroneous 2. material thickness D2.6-1 Inadequate welding and nondestructive 2. test inspections D2.6-2 Plant welding accomplished to 2. nonapplicable weld procedures 02.6-1 Welding and Test Record (Form FC-145)' 2. inadequacies 02.7-1 Inadequate maintenance control and practices D2.8-1 Inadequate requirements for recording 2. of data resulted in an indeterminate battery charger load test D2.8-2 Test procedure did not verify design 2. concept under accident conditions 02.8-1 Air accumulator test procedure 2. inadequacies
02.8-2 Verification of system depressuriza- 2. i tion not provided for SIT relief valves D2.9-1 Inadequate temporary storage of safety- 2. related material D2.9-2 Inadequate warehouse storage of safety- 2. related material D2.9-3 Inadequate QC surveillance of temporary 2. safety-related storage areas 02.10-1 Inadequate corrective action for control 2.1 of installation of lead shielding D2.10-2 Inadequate corrective action for 2.1 resolving System Acceptance Committee discrepancies identified to systems accepted for operation 02.10-1 System Acceptance Committee inadequa- 2.1 cies 02.11-1 QA audit inadequacias 2.11 02.12-1 Engineer and craft training program 2.1 weaktiesses
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4 Design Change Control Design change control.was evaluated on a limited basis since the design change process had already been reviewed in detail in the design inspec-tion. In this inspection the. control of lead shielding installations in the plant was considered in detail, but otherwise design change control was not pursued in connection with the selected modifications unless a specific-problem became apparen j 2. Use 'of lead shielding for ALARA considerations was evaluated with regard to whether temporary or permanent design changes had been made to plant systems without adequate design evaluation. The results of this review are provided in Table II and are summarized as follows:
Lead shielding was installed in 25 locations in the plant on both large bore and small bore piping. Examples of safety-rela u d systems affected were Safety Injection, Containment 3 pray, Charging and Radwaste Disposa '
Calculations for static overstressing of piping had been accomplished and documented for only seven of the 25 inst'a11ation *
No calculations (either static or dynamic) had been accomplished for the remaining 18 installation *
No safety evaluations had been done for any of the installation *
Trenty-four of the installations had been installed for unknown periods of time. Some had been installed for at least two and one half years and had been through several operating cycle CFR 50.59 requires that safety evaluations be accomplished f.or i temporary or permanent . design changes to determine whether an unreviewed safety question exists or whether a change to the Technical Specifica-tions is involved. None of the leed shielding installations had docu-mented safety evaluations addressing such factors as piping overstress, structural overstress, operability of safety-related equipment with shielding installed, or safety of adjacent safety-related equipment if the shielding should become dislodged and fal IE Information Notice 83-64, " Lead Shielding Attached To Safety-Related Systems Without 10 CFR 50.59 Evaluations," dated September 29, 1983, addresses lead shielding installations and indicates that failure to analyze for possible seismic and structural effects (both dynamic and static) of lead shielding on safety-related systems constitutes an unreviewed safety question. Seventeen of the lead shielding installa-tions at Fort Calhoun were on safety related system IE Circular 80-18, "10 CFR 50.59 Safety Evaluations For Changes To Rrdioactive Waste Treatment Systems," dated August 22, 1980, also . .
aadresses the need to accomplish safety evaluations in accordance with 10 CFR 50.59 for changes to radwaste systems. Six of the lead shielding installations at Fort Calhoun were on radwaste system In summary, temporary and permanent lead shielding installations were in place on safety and nonsafety-related piping and components with no documented engineering analyses or safety evaluations accomplished to support the installations (Deficiency D2.2-1). Prior to June 1984 no documented procedure existed for control of lead shielding installa-tions. Omaha Public Power District (OPPD) Standing Order (50) G-57,
" Installation of Temporary Lead Shielding," issued in June 1984, allowed lead shielding to be installed prior to engineering evaluation and did not address the need for safety evaluation The problems discussed above occurred in spite of 10 CFR 50.59, IE Information Notice 83-64, IE Circular 80-18 and similar Institute of Nuclear Power Operations (INPO) lead shielding findings at Fort Calhoun in 1982 and 198 This is discussed further under Corrective Actions in Section 2.10.
2. During inspection of MR 84-179 (addition of HCV-1105/1106 to SG isola-tion signal) a swagelok fitting was found.to be installed through the fire barrier at the entrance to room 57 between the Class I switchgear room and the penetration room. The fitting had been installed for several years and was apparently used for calibration of instruments in the switchgear room. This was an apparent unapproved / unauthorized design change to the plant since no documentation could be found to indicate that it had received appropriate engineering review and approval, and that an appropriate safety evaluation had been acccm-plished (Deficiency D2.2-2).
2.2.3. A review of the temporary modification log revealed that safety-related electrical jumpers had been installed for as long as 18 months without any safety evaluations being accomplished. Electrical jumpers installed for long periods of time and not associated with direct maintenance are considered design changes. 10 CFR 50.59 requires safety evaluations for temporary or permanent design changes (Deficiency D2.2-3). In 1982 INP0 identified that a number of jumpers had been in use at Fort Calhoun for extended periods. INPO recommended that a review of all. jumpers be done and the appropriate ones be processed as permanent design changes. This inspection found that the situation still exist In addition, it was noted that shift supervisors did not review the temporary modification log. Instead, the mechanical or electrical supervisor reviewed and signed the log once per month. When a shift supervisor was asked about a specific temporary modification, he was unaware of i l i
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2. 3 - Document Control Control of drawings, review and approval of procedures by Plant Review
- Committee (PRC), and control of pro edure changes were evaluated.spect-fically in this functional are Other items of concern were identified while reviewing the specific selected modification ,
2. A review of drawings and drawing lists for seven construction packages
indicated that drawings were not always c.dequately controlled. The results of the review are provided in Table III. Three of thc seven
- construction packages had the following concerns
MR'85-009 (replace penetration subassemblies) and MR 84-119 (replace instrument inverters) had extra. drawings which were marked "for
, construction" but were not on the drawing lis *
MR 84-119 had incorrect drawing revision numbers, a wrong drawing number in the drawing list, and two drawings which had the same revision number and date but had different information on the *
MR 83-158 (addition of air accumulators) had no P& ids in the construction package when reviewed by the tea These discrepancies were not in accordance with the requirements of SO G-21, " Station Modification Control", or Genarating Station Engineering (GSE) Procedure B-3, " Drawing Production" (beiiciency D2.3-1). The major. concern in cases such as these was that installations could be
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accomplished to incorrect or outdated design requirement . Installation procedures for MR 84-96 (replace HFA relays),-MR 84-51 (replace Dresser-Hancock valves), MR 83-158 (addition of air.accumula-tors) and MR 84-61 (union installation on SIT relief valves) had pen and ink changes and additions without approved field changes or procedure changes as required by SO G-30, "Setpoint/ Procedure Changes" (Deficiency 02.3-2). Also, the procedure for MR 84-61 was significantly revised by an on-the-spot change, which was also not in accordance with SO G-3 In other cases it_could not b~e determined what was changed by procedure or field changes because of nondescriptive explanations on the change cover sheet or annotations in margins of the procedure . Procedure change 13494 to Operating Instruction OI-FW-3 for Steam j Generator Level Control was not reviewed by a quorum of the Plant Review Committee (PRC) prior to implementation of the change. The PRC met on
!' this procedure change six days after implementation. This was in violation of Techn.ical Specifications, Section 5.8.2, which required PRC l approval prior to implementation of procedure cha.nges (Deficiency-D2.3-3).
2.3.4. The training representative signed procedure change 13494 to 0I-FW-3 prior to completion of training. This was contrary to SO G-30 require-ments to complete training associated with a procedure change prior to-signing the change (Deficiency D2.3-4). The signature on the procedure change was dated November 2, 1984 but training sheets were not issued to operators until November 5, 1984.~
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2. A review of the procedure change log for on-the-spot changes revealed the following concerns: l
Calit' ration Procedure change 14765 to CP-ICAM, Calibration Procedure change 14766 to CP-APGM, and Surveillance Test procedure change 15259 to ST-CONT-7 were not returned to the clerk with PRC approval within 14 day G-30 and section 5.8.3 of the Technical Specifications l
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require PRC approval of on-the-spot changes within 14 days of issue of the change. At the~ time of the inspection these changes could not
, be located to determine if they had been signed by PRC or not.
J This was considered to be an apparent violation of_ Technical Specifi-cations (Unresolved Item U2.3-1). Changes 14765 and 14766.were dated May 31, 1985 and change 15259 was dated October 19, 198 *
Four clerical log errors were noted in that on-the-spot changes 15920, 15443, 14961, 14937 were not marked in the log as returned but in fact had been returned for processing. These were dated November
] 85, November 85, July 85, and July 85 respectivel The significance of these findings was that a full PRC review of on-the-spot changes may not be occurring in a timely manner and that the log was apparently not being reviewed to check for such problems as identified abov .3.6. Drawing file number 39881 for MR 84-105 (replacement of 4160/480_ volt transformers) was marked up in ink and a name was signed next to the changes to indicate a clarification in the weld symbology. No field change number was entered, and the planner responsible did not consider l a field change necessary. This violated SO G-30 since changes to installation instructions require an approved change (Deficiency D2.3-5).
2.3.7. In reviewing MR 85-009 (replacement of penetration subassemblies) loop calibration procedures for CP-X/905 and CP-X/902, seven instances were found where procedure revisions were not made in accordance with SO G-30 (Deficiency 02.3-6). The changes on the calibration sheets involved inconsistencies in entering the revisions as well as not attaching the-
- orrect forms.
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2.3.8. While reviewing MR 85-009, it was noted in the loop calibration proce-dure for CP-D/102-2 (pressurizer pressure) that several cross-outs were made for the pressure source (i.e., dead weight tester with pressure j
gage) such that it was not obvious whic.h source was actually use <
Procedure M-26 required that the pressure source used be calibrated before and after use, or calibrated previously within a set number of days. The-calibration record for the pressure source used to calibrate the safety-related channel could not be found. Apparently, no record existed of the device's calibration (Unresolved Item U2.3-2).
2.3.9. In two instances for MR 84-162 (containment HVAC supports), the loca-tion of duct supports along installed ducting was changed from the specified design locations without complete change documentation (Observation 02.3-1). Support A was relocated one inch from the
specified location.at the direction of the design engineer without
- issue.of a field change. Support B was moved approximately four inches-15-
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from the design specified location. A field change was issued for relocation of support B but that document failed to specify the new support locatio .3.10. Other comments relative to document control were noted as follows:
Construction packages & construction package documents were not adequately controlled. The official copy of. installation proce-dures, CQE material cards, and weld process cards were all kept with the construction package which was used for actual construc-tion. There was no logging or control process to maintain control over the official copies (Observation 02.3-2). The team's-concern was with the potential loss of official documents and the subse-quent difficulties associated with reverifying steps and obtaining official sign-off Part of the reason for the concern ~was exemplified by the following:
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MR 85-62 (replace CCW flow element) was lost after issue but was later found after work starte An OPPD Field Supervisor noted that construction packages had been lost and not found in the past.
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Numerous Operat'ing Incident Reports (OIs) had been identi-fied by 0 PPD as missing, some for as long as two and one l half years. The first nine missing OIs were reported on QA Deficiency Report FC1 85-5 Initials instead of signatures were being used extensively for making sign-offs in M0 procedures, installation procedures, and test procedures (Observation 02.3-3). A great deal of the initials were not legible and after a few years probably not identifiable to a qualified perso Illegible initials for permanent QA records are not in accordance with American National Standards Institute (ANSI) Standard N45.2.9 requirement _ Installation Procedure Controls and' Compliance Installation procedure controls were evaluated in detail to assure that regulatory requirements and Technical Specifications requirements were met, procedures were adequate to control and properly install
'the modifications, supporting procedures or documents were adequate to control and properly install the modifications, and that procedures
- were being complied wit . Review of installation procedures in detail revealed the following concerns:
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Procedures were, in general, too simplified or, in some cases, no procedure steps were provided at all. Examples were:
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MR 83-158 (addition of air accumulators) did not provide tubing configuration and accumulator ~ tank location instructions in the procedure. Tank location was considered significant by the team since the engineering calculation accomplished prior to work start was based on floor mounting. Apparently all these instructions were verba MR 85-42 (replace MS-100) provided limited craft direction for valve'_ removal and reinstallation of the replacement valv The instructions amounted to basically, remove the valve and install the new valve, with no reference to precautionary
' statements regarding internal cleanliness control, end prepping requirements, fit up requirements,- valve removal method, pipe and valve nozzle minimum wall thicknesses, QC requirements, and so on. These items were not covered in the procedure nor were they specified in supporting documentation. This modification had several installation problems identified by the team that are discussed in Section 2. MR 83-158 did not reference the Stone and Webster prepared tubing seismic support guideline, " Guidelines for The Installa-tion of Tubing and Tubing Supports For Seismic Instrument Systems," in the procedure. Important installation criteria such as need for axial restraints and additional supports at
'
concentrated loads were likewise not specified. As discussed in Section 2.5.2 several concerns were identified by the team with the seismic support MR 85-62 (replacement of CCW flow element) did not provide instructions for proper flange makeup which may have elimi- ;
nated a. flange leak identified by the team. Items such as
bolt torque, even gasket compression, flange parallellism, bolt elongation, and so on, were not. discussed in the procedure or in any supporting documentation. As discussed in Section 2.5.4, concerns were identified by the team with the-flange installation. Also, instructions were not provided for a ,
cleanliness inspection following pipe drilling for boss instal- !
lations on the 16" line. The original flow element, approxi- J mately 15" long, was lost in the Component Cooling Water (CCW) !
system in the fall of 1984 and was never recovered. No attempt 1
.
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i
. was ever made to locate the missing elemen This problem is
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discussed further in Section MR 84-61 (union installation of SIT-relief.. valves) did not
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provide a caution statement or a hold point for verification of protection of valve 0-rings during welding. A vendor pre-pared procedure for installation of the relief. valves included the use of a spacer to hold the 0-ring off the valve seat while welding. Installation problems were also noted with this modification and are discussed in Section 2. MR 84-105 (replacement of 4160/480 volt transformers) required welding to the transformer base in accordance with Generating Station Engineering Electrical (GSEE)-0517, " Installation of Seismic Supports for CQE and Limited CQE Electrical Equipment".
GSEE-0517 required QC to be notified when work started so visual inspections could be completed. The installation procedure had
no hold points or objective evidence to assure visual inspec-tions'would be accomplished by QC. As discussed in Section 2.5.6 the inspections were not performed prior to this revie When interviewed, the design engineer expressed no knowledge of these requirement MR 8A-74A (fuse protection for limit switches)' identified i
specific splice numbers for QC inspection which was contrary to GSEE-0512, " Cabling Splicing Procedure", requirement GSEE-0512, which was. referenced in the procedure, required a 10 percent random inspection. The installation instruction did specify inspection of 10 percent of the total splices but ~
specific splice numbers were identified to the craft and QC for inspection instead of requiring QC to conduct a 10% random inspection of splices. This problem was also noted in MRs85-009 and 84-17 All of the above examples.were not in accordance with SO G-21,.
GSEE-0517 and GSEE-0512 requirements, respectively (Deficiency D2.4-1).
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2.4.2 Review of the selected work packages identified the following. examples of failure to follow procedures:
During accomplishment of MR 81-80 (seismic supports on masonry wall), work proceeded without verification of material adequacy
,
in a QC hold point and the shift supervisor was not notified prior
.to proceeding with drilling holes through the battery room wall for HILTI through wall studs. Both of these items were required by the installation procedur l Nonlevel III inspectors were noted to have been reviewing and
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approving procedures for adequacy c QC hold points. This violated 50 G-21 and S0 G-26A, " Quality Control Program", which required level III certification to review and approve QC hold point .
It was also noted that the engineers writing the procedures were not Level III certifie .. - - .. . ..
MR 84-105 (replacement of 4160/480 volt transformers) called for the fire suppression part of the Halon system to be disabled so that welding could take place without setting off the fire suppres-sion system. A step in the installation procedure had been signed to disable the Halon fire suppression systems in Zones five and six (switchgear room). Later, in the same procedure, the step to disable the Halon fire suppression systems was signed again. Steps in the procedure had not been signed for restoration of the disabled Halon systems. At no time was there evidence that the Halon systems were, in fact, in service during the period of December 6-10, 198 Technical Specifications 2.19 part (8) required that when the Halon systems were~ inoperable, a continuous fire watch must be posted and backup fire supp assion equipment must be provide The Shift Supervisor could not demonstrate that he had directed that a continuous fire watch be established. It was also noted that the Halon system had an inoperable power fail light which would have made it difficult to detect problems with the fire detection part of the syste During performance of work for MR 84-119 (replacement of instrument inverters) Bkr CB-5 and Ckt-33 were required to be tagged out. Tag numbers 85-1078-1 & 2 were issued to perform this work. No shift supervisor approval was found on the sheet as required by Standing Order 0-20, " Station Tagging". The tag had been hung and the work was in progress without Shift Supervisor documented revie The original modification design for MR 84-61 (union installa-tion on SIT relief valves) specified the " nut" portion of the new unions to be welded to the new pipe stubs which connect to the relief valves. Instead, the unions were installed upside down with respect to the installation sketch provided in the construction package. The installed orientation was later deter-mined to be technically acceptable and a field change was prepared to document the change. - However, failure to install the unions as originally designed indicated the craft did not follow the original installation procedur The above. examples were contrary to the requirements of installation
~
procedures, Standing Orders and Technical Specifications (Deficiency 2.4-2).
2.4.3. Review of MR 84-140 (delta T power process loops) revealed electrical Standard Procedure weaknesses as follows (Observation 02.4-1).
Numerous installation problems were noted with this modification as well, which are discussed in Section 2.5.!.
Procedure GSEE-0516, Rev. 3, " Requirements for Installation of j Electrical Cables at the Fort Calhoun Unit No. 1," did not contain !
information relating to several safety-related attributes, whic are typically included in safety-related cable installation proce-dure These include:
I-19-l l
_
- Cable bend radius requirements
-
Cable pulling tension requirements
-
Cable separation requirements
- QC inspection of cable terminations,'rather than a random 10 percent inspection of wire splices specified in GSEE-051 Prccedure GSEE-0517, Rev. 1, " Installation of Seismic Supports for CQE and Limited CQE Electrical Equipment," Section 5.1.3, required that concrete anchors be installed in accordance with manufacturer instructions but did not include accept / reject criteria necessary to install or inspect several attributes-contained within the manufacturer's (HILTI) instruction manua These include:
- Anchor angularity Center-to-center anchor spacing
- Anchor-to-concrete edge distance
Forms used to document QC inspections did not contain sufficient spaces / blocks to indicate the acceptance of individual attribute This made it difficult to determine which attributes had or had not been inspecte As an example, only one space (entitled, Conduit Installation Inspected) was provided for the inspector to document all attributes pertaining to the installation of conduits.
2. MR 84-074A (fuse protection for limit switches) added field change #8 to install jumpers during the test and'to remove the jumpers following the test. No licensed operator review was performed on the field changes. This would allow a design engineer in the field to essen-tially bypass a safety system without the Shift Supervisor being aware of what was occurring. Procedure 50 G-30 did not require that the Shift Supervisor be notified. Although this did not violate a plant procedure, field changes such as this should obtain shift supervisor approval for changes made to equipment under his control in. order to assure safe status and operation of the plant (Observation 02.4-2).
2. No governing OPPD procedure was found to exist for preparation of installation instructions or test instructions (Observation 02.4-3).
General guidelines and direction _should be provided to engineers and supervisors to assure consistent, well prepared instructions addressing such items as format, cleanliness control, QC hold points, verification signatures, welding requirements, craft skill levels, special training or tools, specification of craft skill-to accomplish a task, and so o It was apparent from this inspection that such a procedure was war-ranted based on the number of procedure' problems and installation problems note i
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2. 5 Mechanical / Electrical Installation and Construction Controls This part of the inspection entailed a " hands on" installation inspec-tion of 13 modification packages. The 13 were inspected either partially or in detail depending on the circumstances. Concerns were identified with eight of the installations as discussed below. The installations were evaluated to CPPD design and procedu-al requirements as well as commitments and "g a d practices." Table I identifies the installations inspected and those with identified concerns.
2.5.1. MR 85-042 (replace MS-100): This 1" non-isolable steam header equali-zer valve had been installed, welded, inspected (which included dye penetrant (PT) examination of the welds) and accepted by OPPD. At the request of the team, based on a visual inspection, the lower (non-isolable) weld was reinspected by PT and found to be unacceptabl The weld was ground out, the pipe.end prepped, and the joint rewelded-and accepted again. WMn reinspected by the team, it was noticed that the pipe stub had been excessively ground-on and was noticeably tapered, although the weld was visually acceptable (Deficiency D2.5-1).
The tapered pipe raised concern for violation of minimum pipe wall thicknes Subsequent reinspection by 0 PPD revealed that minimum pipe wall thickness for. schedule 80 pipe had been violated. After engineer-ing review, the pipe wall thickness was determined to be acceptable for the application since the remaining wall thickness exceeded schedule 40 pipe wall requirements. MS-100 concerns are also discussed in Section 2.6.1.
2.5.2. MR 83-158 (addition of air accumulators):
Four examples were found in which the maximum unsupported span requirement of 4'-6" specified in section 4.2.2 of the Stone &
Webster guideline for seismic tubing was violated (Deficiency D2.5-2). The guideline limited cumulative distance between sup-ports on either side of tubing bends to the defined maximum, and it did not specifically permit any span without restraint regard-less of length. The following ancmalies were noted:
- Adjacent to valve YCV-1045A there was a distance to'.alling 5'-6" of unsupported tubing including bend In the branch to instrument air for YCV-1045A, there was a distance totalling 5'-8" of u'nsupported tubing includi.m bend Adjacent to valve YCV-1045B there was a distance totalling 5'-10" of unsupported tubing including bend Adjacent to valve YCV-1045B accumulato'r there was a distance totalling 4'-7" of unsupported tubing including bend Seismic supports to the instrument support frame were not installed adjacent to the " air sets" for valves YCV-1045 A&B. Section 4. of the Tubing Guideline required support to be located "as close as possible" to instrument connections and required attachment of th'at support to the instrument support frame. Such support was not provided in the vicinity of the tubing connections to the regula-
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tors at either valve YCV-1045A or B (Deficiency D2.5-3). In both cases, the first support upstream of the regulators was located at a distance from these connections which exceeded the standard allowable span for the subject tubin The installations were noted-to include two valves and one branch connection at the tubing for both valves YCV-1045A and B. Each valve and branch resulted in concentrated loads for the tubin The installation instruction did not provide for restraint at these types'of concentrated loads (Observation 02.5-1). Also section 3.0, item (g) of the tubing guidelir.e did not address tubing configurations which included valver or other concentrated load The team considered that extra supports should have been provided at the location cf the concentrated loads noted abov . MR 84-61 (union installation on SIT relief valves): The following discrepancies were identified by the team (Deficiency D2.5-4).
The relief valve for SI tank 6B had the wrong relief valve instal-led on it according to the manufacturer's label plate (i.e., label plate was stamped SI 221 instead of SI 217).
The valve label plate for SI 221 conflicted with the valve number on the brass identification tag attached to the valv The union on SI tank 6B had a large crater pit in the lower pipe weld which appeared to be visually un'cceptabl a This weld was previously PT examined and accepted by QC personne See Section
't 2.6.1 for further discussion on this defec The union tail ph. + ;e for SI tank 6B had a large flat surface
.,
discontinuity (3/8"xs/4") as well as other. surface discontinuities of less size and depth. The large surface discontinuity-raised concern for violation of minimum pipe wall thicknes The union tail. piece pipe for SI tank 6D was also covered with surface discontinuities apparently caused by a pipe wrenc . MR 85-62 (replacement of CCW flow element): The installation procedure had a signoff to verify that the flange was not leaking. However, the joint was found to be leaking during this inspection. It was also noted that the flange faces were out of parallel by approximately:.030" (Deficiency D2.5-5). Other problems are discussed in Section 2. .5.5. .MR 84-140 (delta T power process loops): The following discrepancies were identified by the team (Deficiency D2.5-6).
Safety-related cable EC10483 (Channel C) was tie-wrapped to 1onsafety-related cables 1152A and 1152B in panel AI-216, which was not in accordance with the Updated Safety Analysis Report (USAR), Section 8.5. Safety-related cable ED10484 (Channel D) was tie-wrapped to nonsafety-related cable 1152A in panel AI-217, which was not in accordance with the USAR, Section 8.5. . - - - _ _ _ . . ,
Welds on conduit supports FC-84-140-006, -008, and -009 were accepted by QC~ personnel but did not conform to the configurations specified by the design details. The design' called for a unistrut to be fillet welded to a beam but, in fact, the unistrut had been moved to the edge of the beam and seal welded instead.
Conduit installations had been accepted by QC personnel even though deficiencies existed and, in many cases, construction activities were not yet complete. An example of this condition was a 1-1/2" diameter conduit containing cables EC11504, EC11505, EC11506, and EC11507 which was accepted with the following conditions present:
.
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All required supports were not yet installed (the design details for one support were not yet issued by engineering).
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Conduit was not strapped to one installed suppor Nuts on concrete wedge anchors did not exhibit adequate thread engagemen A required square washer on a concrete wedge anchor was missin Condulet covers were missin Due to unavailability of approved safety-related material, temporary nuts were installed.
In addition, the following questionable installation practices were observed, although specific counter requirements in the licensee's procedures were not identified in all cases (Unresolved Item U2.5-1).
Cables EC10483 and EC10484 (locations above) were bent severely back upon-themselves. This was not consistent with' manufacturer's recommendations and standard industry practices with regard to cable bend radiu The procedure step for torquing of the wedge anchors in panels AI-214 and AI-215 was signed off by QC but the " Seismic Support Data Sheets" required by GSEE-0517 were not filled out to include the required data and acceptance signature The procedure step for the welding of the support frames for panels AI-214 and AI-215 was signed by QC but the applicable sections of the " Seismic Support Data Sheets" required by GSEE-0517 had not been filled out by QC personnel.
The anchorage of panels AI-216 and AI-217 was accepted by QC, but panel bases were not flush with the concrete mounting surface Washers were used as shims without being noted or reported to reported to engineering for review and resolution. Subsequent design review indicated that corrective measures were needed, and have been accomplishe .5.6. MR 84-105 (replacement of 4160/480 volt transformers): Weld inspec-tions were not accomplished by QC as required by GSEE-0517 for the transformer base welds to the embedments (Deficiency D2.5-7). Section 5.2.2 of GSEE-0517 required-that QC be notified when work was starting and that visual-inspections be accomplished by QC. No weld inspection sheets were in the procedure when reviewed-by the team. Apparently QC had'not been notified of work starting other than by their initial concurrence on'the procedure.
2.5.7. MR 85-009 (replacement of penetration subassemblies):
Several instruments were being recalibrated because their connec-tions had passed through the penetrations being replaced by MR 85-009. Review of calibration procedure CP-A/102-3 for pressurizer pressure transmitter, 102A, revealed that the safety-related transmitters were opened.to make adjustments but 0-rings may not have been replaced as required by the transmitter manufacturer (FOXBORO) to maintain environmental qualification of the transmit-ters. The calibration procedures contained statements regarding the requirement to replace the 0-rings if the transmitters were disassembled, but.no objective evidence existed to document 0-ring replacement (Unresolved Item U2.5-2). This concern involved about 74 transmitter Calibration of pressure switch 902A (SG A pressure) was accom-plished by calibration procedure CP-A/902-3 in conjunction with the loop checks for MR 85-009. During the checks,-it was found that the trip point of the safety-related pressure switch never cleare Maintenance Order (MO) 852934 was written to repair the switch and required a surveillance test to be performed. No specific retest of the repaired switch was specified by the M0. The surveillance test would not adequately prove the alarm set point and reset function of the' switch. In effect, the switch would never get checked again (Observation 02.5-2). The switch was part of the Engineered Safeguards Features System.
2.5.8. MR 84-162 (containment HVAC supports): The three modified HVAC support designs which comprised this modification utilized existing support steel which attached to the supported duct. Two of the three design sketches for supports A and B identified this existing material as 2 x 2 x 1/4 inch angle. The sketch for the third support, support C, included a weld designation of 1/4 inch 1.1/16 inch, which implied that the material thickness was also'1/4 inch. The team found the material installed to be 2 x 2 x 3/16 inch angle (Observation 02.5-3). The design engineer confirmed that the design was based on the erroneous 1/4 inch thicknes .
2. 6 Welding and NDE Control Modifications which required ASME code welding and nondestructive examina-tion (NDE) were examined to determine the adequacy of NDE methods used including interpretation of results, applicability of weld procedures used to accomplish nuclear welding, and documentation of weld record informa-tio .6.1. Three modifications were examined which involved ASME Code welding and NDE. The following welding an~d NDE control concerns were noted (Deficiency 02.6-1):
MR 85-42 (MS-100 replacement): A previously QC accepted socket weld (via PT. examination) was rejected based on information from a visual inspection by the team and reaccomplishment of the PT examinatio During repair of the rejected weld joint, the con ~
necting pipe nipple was ground to the point at which the pipe no longer met minimum wall criteria. This problem was also not realized by OPPD until a second visual inspection by the tea MR 84-061 (union installation on SIT relief valves): A large pit was noticed in a previously QC accepted weld (via PT examina-tion) associated with valve SI 217. The team requestad a~
re-examination of the weld. OPPD QC personnel examined the weld, noted the pit, filed on the pit to fair in or remove the defect and then re-PT inspected the wel The weld was found to be acceptable after the minor repair action *
MR 85-062 (replacement of CCW flow element): The temperature
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of the CCW system was between 47 and 51 F at the time .that initial pts were accomplished and accepted on wel_ds associated with this modification. This was in violation of the FT procedure found in 50 G-26A, Appendix F which required a minimum temperature of 60 The pts were reaccomplished at the request of the team which resulted in two of the four welds being rejected because of linear indication .6.2. Inadequate and nonexistent weld procedures were noted during review of the construction packages. OPPD had only nine basic weld procedures to accomplish all nuclear welding .in the plant. These are listed in Table IV. From the limited sample.of modifications reviewed invciving welding, the following concerns were noted (Deficiency D2.6-2):
,
A skewed fillet weld was installed using a 90* fillet weld proce-dure in MR 84-162 (containment HVAC supports).
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A misdrilled hole in a support baseplate was plug welded using a j
90 fillet weld procedure in MR 84-162 (containment HVAC supports).
, Partial penetration pipe boss welds to CCW 16" piping were accom- l i plished using a 90 fillet ~ weld procedure in MR 85-62 (replacement
.of CCW flow element).
A fillet weld procedure ~was used to accomplish a seal weld in MR 85-62.(replacement of CCW element). I l-25-
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2.6.3. A number of inadequacier, were identified relative to completion of the Welding and Test Conti-ol Record, .Fonn FC-145 of 50 G-12 (Observati'on 02.6-1).
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No instruction existed in 50 G-12 to indicate how the weld record form should be filled out. Consequently, there was little consis-tency in the information entered by the welder or QC inspectors.
- No place existed on the weld record form for QC to verify fitup requirements for ASME Code welds. It was not apparent in this inspection, for all welds and records reviewed, that QC verifica-tion of satisfactory weld fitup was being accomplished and docu-
- mented. No signoffs were found in installation procedures and no addenda to Form FC-145 were found to document weld fitup.
.
Every " Welding and Test Control Record" associated with the HVAC support modification (MR 84-162) had base material thicknesses recorded as 1/8", which did not relate to any material. thicknesses associated with the HVAC support Form FC-145 did not contain a space for in process QC verification of an acceptable PT inspection of the root pass required by Weld Procedure Specification #4. .It was also not apparent from the inspection that QC verification of an acceptable PT of the root pass was being accomplished and documented. .No signoffs in instal-
,
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lation procedures were noted, and no addendums to' Form FC-145 were noted to document the required PT inspections. Consequently, accomplishment of root pass PT inspections were not auditable.
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2.7 Maintenance Control and Practices Overall' maintenance control was not a major functional area of review for this inspection, however, observed maintenance practices were evaluated during'various plant tours associated with review of the-selected modification packages and programmatic' areas. The following poor practices were noted (Observation 02.7-1): ,
The packing gland flange on valve HCV 1042C was installed upside down which resulted in deformation of the gland eyebolt Valves MS-282 and 292 (main steam safety valves) were found instal-led with fasteners without full thread engagement. The same condition was noted on the line flange for MS-28 A red plastic bucket was used as a cleanliness barrier inside the valve body of FCV-1102 when disassembled for repair A loose rag was used as a cleanliness barrier covering FCV-1101 operator internals with no craft presen *- Various open tubing ends were noted as being left unattended without tape or caps'to cover openings to prevent entry of foreign materia Limitorque covers were noted as being left off unattended valves for extended periods of tim The component cooling water system was noted to have a problem with sand and gravel accumulations.in the system. The. plant engineer indicated that a maintenance order had been written stating there was sand in the reactor coolant pump seals and that no operational checks were periodically performed to detect sand and gravel. No turbidity or suspended solids checks were performed on component cooling water system either. From this information it was apparent that the internal cleanliness of the CCW system was in question, with no apparent plans to control or mitigate the prob-le Apparent use of a pipe wrench was noted to secure SI piping while tightening unions in MR 84-61 (Section 2.5.3) causing noticeable surface discontinuitie It was noted in MR 85-62 (Section 2.5.4) that a flanged gasketed joint was not made up properly in the'CCW syste Poor quality welding and poor end prep quality were noted in MR 85-042 for replacement of valve MS-100 (Section 2.5.1).
Use of unauthorized and unacceptable shim material was noted in~
mounting of electrical panels for MR 84-140 (Section 2.5.5).
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. __ Operations and Test Control Test procedures were evaluated'for selected modifications considering such factors.as functional tests required to assure the modifications would in fact perform functionally, that functional tests performed were in addition to standard system integrity tests or hydros as applicable, and that interactions with other systems during normal operations and event conditions were considered. This part of the inspection was limited in scope since all test procedures had not been prepared or issued at the time of the inspection. The intent of the inspection was to also observe testing in progress, however, little testing occurred during the inspection timeframe. The following concerns were identified.
2.8.1. MR 84-119 (replacement of instrument inverters): Battery charger
- 3 load test procedure did not identify logging of data to verify acceptance criteria (float and equalizing voltage) which resulted in indeterminate test results (Deficiency D2.8-1). The test procedure required that the charger output should be stable and within values specified after operating under rated load conditions for one hour. No data was taken (nor was any required to be taken) to document that_the charger had performed for one hour within the values specified in the acceptance criteria. In addition, the acceptance criteria, which was listed separately in the back of the procedures, was not identified to the procedure steps to which it applied. Upon' review of the completed procedure, it was not obvious which procedure step accomplished which portion of the test requirements to satisfy the acceptance criteria.
2.8.2. MR 84-74A (fuse protection for -limit switches): The test procedure required only stroking of the valves, which woul.d not verify the design concept of the circuit modification. The test did not consider proving
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the circuit changes by also testing for operability with the fuses removed, which could be a more realistic accident condition (Deficiency D2.8-2). OPPD ga' reed to test procedure enhancements which would fully verify operability of the modification.
2.8.3. MR 83-158 (addition of air accumulators): The following observations were identified by the team during review of this construction package (Observation 02.8-1).
Valves YCV-1045 A&B by initial design criteria should stay closed 1-hr. The test procedure acceptance criteria identified a time of 30 minutes. The design criteria was later changed to 30 minutes following discussions with the tea *
Plant conditions required for testing and test acceptance criteria were identified as notes to the procedure with no objective evidence that they were in place and acceptabl 'The test procedure did not consider nominal system air leakag'es and therefore would not necessarily prove the accumulator would function under degraded conditions resulting from an acciden .8.4. MR 84-61 (union installation on SIT relief valves): The installation procedure did not provide verification of system depressurization for -
the SI tanks prior to relief valve removal.(Observation 02.8-2).
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-. Material Control During Storage and Pre-Installation The inspection team examined the storage of Critical-Quality Element (CQE) material 'in the Fort Calhoun warehouse and in temporary storage areas located within the plant. Documentation to verify material traceability of stored items was examined, in addition to QA control of CQE material and CQE storage areas for conformance with licensee
'
commitments and requirement . Three temporary Critical Quality Element (CQE) storage areas were ,
inspecte The following concerns were noted:
Temporary CQE Storage Area #4: Loose electrical-cable identi-fled by CQE card as Item W-71, STK #611-1850 Reel #C-1093 & P0
- 42148 was being crushed by a large reel of electrical cabl Temporary CQE Storage Area #17: Two electrical components were found stored in Area #17 without any CQE cards attached which was not in accordance with SO G-22 requirements. It was later dis-covered that these two components were non-CQE and were improperly stored in a CQE area which also violated SO G-22, " Storage of Critical Element and Radioactive Material Packaging, Fire Prctec-tion Material, and Calibration Equipment". Label plate identifica-tion for the components was as follows:
(a) GE switchgear GV-4.16-250 413-36507 l 836C138 G21 1/75 (b) GE switchgear GV-4.16-250-1200A 836C138 G20 2/75 413-38986-1
Temporary Storage Area #14: Three electrical penetration subassem-blies were found stored in Area #14 without any CQE cards attached which was in violation of S0 G-22. Identification for the compo-nents was as follows:
(a) PN7M56-12000-03 Pen #E9-13 P.O. 07233 WO 7-M5600 (b) PN7M56-12000-03
,
Pen #E2-6 P0 7233 W0 7-M5600 (c) PN7M56-12000-03 Pen #E2-11 PO 7233 WO 7-M5600
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All of the concerns identified above were contrary to ANSI Standard N45.2.2 requirements for nuclear material storage and handling (Deficiency D2.9-1). It was-also noted during this inspection that no procedure existed for placement, control and removal of material in-temporary CQE storage areas. In view of the significar.ce of maintain-ing proper condition of. quality material until installed, a procedure with detailed requirements appeared to be warrante . The following concerns were noted involving storage of CQE material in
, the Fort Calhoun warehouse:
a
Three examples of materials that had tags that did not agree with material markings and other documentation were n'oted as .follows:
(a) Relays - MR 78-56 (quantity ~four)
Doc # 45240-Model 7022PB 125VDC SER #80082367
(b) Relays - MR 78-56 (quantity - four)
Doc # 45240 Model 7012 PF 125VDC SER #80082373 (c) ASCO Solenoid Valve (quantity - two)
Code #NP8320A185V Doc #54884 MR-84-77 Four examples of CQE material that was required to be stored in Level B areas but were incorrectly stored in Level C areas for 10 months; 17 months, 18 months-and 19 months, respectively, were noted as follows:
(a) Relay lockout (quantity see note)
Code #12HEA61C243 P0 536881 (b) Sleeve (quantity - see note)
STK #13.3728 Lot N3275 Code #WCSF 115-40N P0 5496 (c) Byron Jackson 0 ring (quantity - see note)-
STK #606.9010 P/N 11-28 Doc #534817 (d) Foxboro Power Supply (quantity - see note)
Code # Device Tag #725C/ Unit Tag #B/LQ-904 PO 05105
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One example of incomplete material certifications was noted wherein the required hardness and mechanical properties were not listed on the Certified Material Test Recor /8" x_8 Nuts (quantity - see note)
STK #621.4501 Code #2H ASTMA194 Occ #49041 Note: The actual quantities for the above five groups of material were not recorded due to the large numbers of each ite In some cases several pallets or boxes or material were involve All of the examples identified above were not in accordance with ANSI N45.2.2 requirements (Deficiency D2.9-2).
2.9.3. Review of the log for surveillance of temporary CQE storage areas by QC revealed that surveillances were generally not meeting the monthly requirement of SO G-22 (Deficiency D2.9-3). Table V provides a listing of each temporary storage area and their respective surveil-lance date(s).
From Table V it was apparent that temporary storage areas-1, 3, 4, 5, 14 and 15 were overdue for surveillance as required by 50 G-22. Also the July 1985 surveillance for area three was three months late and for area 15 the July 1985 surveillance was two month's late. This was also not in accordance with SO G-22.
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2.10 Corrective Actions Corrective action was not a specific area of review for this inspec-tion. The basis for concerns in this. area was limited to cases of problems or problem areas being identified by 0 PPD, or to OPPD, and appropriate actions not being taken'to fully resolve them. Corrective actions were considered only in conjunction with the selected modifi-cations and programmatic areas of the inspection. The following inadequate corrective actions were note .10.1. In 1982 INP0 identified that Fort Calhoun had no program for lead
. shielding installations and that engineering evaluations should be performed for those installations in place and a program developed for future installations. A reevaluation by INP0 in 1983 indicated that-
" design and safety reviews are not documented" for lead shielding
'
installations. In addition, as discussed in section 2.2.1, IE Information Notice 83-64 and IE Circular 80-18 provided clarification of the requirements of 10 CFR 50.59 with regard to lead shielding and system design change Based on the results of this inspection as summarized in section 2. and Table II, it is apparent that the INP0 findings and the information provided in IE Information Notice 83-64 and IE Circular 80-18 have not been acted on by OPPD. Lack of correction of identified discrepancies represents inadequate corrective actions on the part of the licensee (Deficiency 2.10-1).
2.10.2. Review of System Acceptance Committee (SAC) activities revealed that no corrective action system existed for_ clearing or resolving discrepan-
- cies identified to systems that had been accepted for operatio Specific review of SAC accepted modifications from January to June.1984 produced 26 modifications that had been accepted with discrepancies as shown in Table VI. No documentation was available that had followed these discrepancies and assured that they were in fact resolved in a timely manner. Identification of discrepancies with no system for assurance of completion and management review was~ considered to be 1 inadequate corrective action on the part of the licensee (Deficiency 02.10-2).
The team accomplished a limited check of six..of those modifications i with SAC discrepancies in Table'VI, and found that the discrepancies identified in the SAC meetings had been cleared with the exception of a missing valve identification tag on MS-338.'
Based on review of applicable documents and attendance at two SAC
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meetings, the following were also noted (Observation 02.10-1):~ (1) no I documented procedure existed for SAC activities; (2) SAC member attended the meetings with little prior preparation; (3) the process seemed to depend on how well prepared and/or knowledgeable the GSE planner happened to be for all phases of the work accomplished and of documentation requirements to support the work accomplishe ,
2.11 Quality Assurance Audits Based on the large number of inadequacies identified by the team in the areas of design control and control of special processes, a limited review of Quality Assurance (QA) aud;ts no. 16 and 17 for design change control in May 1984 and no. 24 for control of special processes in February 1985 was accomplished. The following concerns were identified with regard to the audits (Observation 02.11-1):
The audits consisted of only paper checks against OPPD procedures for such items as presence of all. forms and signature ~*
No field checks of installations were accomplishe Audit attributes checked only for OPPD procedure requirements and not that procedures or work were in accordance with the applicable ANSI standards or code *
Minimal time and personnel were expended to accomplish the' audits (1.e., two people for two days for design control).
In view of the design control problems identified in the design inspec-tion and the design and the welding and NDE problems identified in this inspection, it appears that improvements in OPPD QA audits are neede The audits reviewed by the team did not identify any of the relevant issues identified in these inspection l l-34-l l
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2.12 Qualification and Training of Personnel-Qualifications and training of some individuals involved with the work packages selected for review in Table I were evaluated. The intent was to verify that those individuals performing work in accordance with the selected work packages were properly trained and qualified at the time of work accomplishment. Determination of personnel quali-fications and training was mada by review of personnel records, training records, certification records and interview of selected individuals. Selection was based on involvement of generating station engineering, operations and maintenance personnel with the work pack-ages of interest. Maintenance personnel included both site assigned craft and the OPPD maintenance craft temporarily assigned for the duration of the outage.
2.12.1. Nine GSE design engineers were interviewed. They were all grade engineers in various disciplines. The average experience level in design engineering with OPPD was four years. Two of the engineers had previous experienca of five or more years with an architect-engineer firm. They all had had the General Employee Training (GET) at the site at a red or blue badge level and were current in their site trainin All had completed the GSE self-study training stipulated by the OPPD-GSE training manual. There was no special training provided for the outage except for one engineer who received outside training in EQ requirements.
2.12.2.-Five operations engineers on site were interviewed. They were all graduate engineers with an average of four and one half years experience with OPPD. Two were qualified as STA and one as a licensed SR0. One engineer received special training given by GE concerning problems related to replacing the 4160/480 volt transformers. Another engineer received special training in use of the 3M fire blankets and Dow Corning penetration seals, and was working on making the membership grade of fire protection engineer. All were red badge qualified under GET.
2.12.3. Interviews of maintenance personnel, including supervisory personnel, revealed a wide range of educational background and experience level ~
All personnel had received and were current in GET with badge levels dependent on access requirements associated with the work package There was no specialized training provided for the technical aspects of outage wor However, a pre packaged handout was distributed to all supervisory personnel at the beginning of the outage, and a. review session was conducted by the maintenance supervisor with all. levels of supervisory personnel. In turn, the packages were reviewed by maintenance supervisors with the maintenance craft. The handout covered the general work schedule, maintenance items, and design change packages. It also included a review of applicable standing orders.
2.12.4. A review of personnel records and training and certification records confirmed the information obtained in the individual interviews. All individuals appeared to be qualified to all specified OPPD requirements to accomplish outage modifications. However, the team identified concerns in the following areas (Observation 02.12-1):
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The experience level of the des'ign. engineers appeared limited with little substantial plant or nuclear systems training provide They were largely responsible for complete design of all modifica-tions at the station with little previous nuclear experience or training. The lack of nuclear experience and training was evident i
by the mistakes and inadequacies identified in several of the
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modifications that were evaluated .in detail in.this inspection.
- Examples included
- not understanding total system operation or interactions with other systems; relying heavily on craft exper-i- tise; not providing detailed written installation instructions, and
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not considering all facets of testing and test requirement There was no nuclear' craft qualification or training program to
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certify craft personnel as a " nuclear craft."' The only trainin was through the ranks to a standard journeyman craft level. Many
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of the craft personnel were acquired through the union hall. Many of the problems identified.uncer maintenance control (section F). ~
and installation. control (section D) point to inadequacies in the qualification standards of craft performing safety-relatad maintenance activitie i J
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-.- . .-. _ -- - - . . . TABLE I .
LIST OF MODIFICATIONS REVIEWED MR Number MR Description Discipline Reviewed 81-80 Seismic Supports on Masonry Wall Mechanical
! 83-158** Addition of Air Accumulators for Mechanical
! YCV-1045A and B 84-51 Replacement of Class 1 and 2-- Mechanical Dresser-Hancock Valves 84-61** Union ~ Installation on SI-209, 213, Mechanical 217, 221
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84-74A* Fuse Protection For Limit Switch Electrical
- Circuits-84-92 SG Nozzle Dams Mechanical
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84-96 Replacement of Safety-Related Electrical HFA Relays 84-105** Rep'acement of 4160/480 Volt Electrical Transformers ~
- 84-114 Replacement of Solenoid Valves- Electrical ,
With Class 1E Valves 84-119* Replacement of Instrument Inverters Electrical.
l 84-140** Delta T Power Process Loops Electrical
- . 84-162** Containment Ventilation Duct Supports Mechanical i
84-179* . Addition of HCV-1105 and 1106 to SG Electrical
~ Isolation Signal
- 85-009** Replacement of Containment Penetration Electrical
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Subassemblies i
i 85-24* Rerouting of Cables in Containment Electrical to Meet Appendix R Requirements
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85-25* Fire Wrapping. Power Cables to Meet Electrical-Appendix R Requirements 85-42** Replace Dresser-Hancock Valve MS-100 Mechanical
! 85-62** Replacement of CC Flow Element -Mechanical i
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- installation inspection accomplished
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- installation inspection discrepancies noted-37-
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T TABLE II LEAD SHIELDING INSTALLATIONS Safet Pipe Lead Engineering Location Related Bore Weight Date Calculation Safety Number System (CQE) Size (Lbs) Installed (Static / Dynamic) Evaluation 1- Safety Yes Large 60 10/28/83 Static Only None Injec.
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3 Component Yes Large 360 Unknown 2 Static Only None Cooling Water 4 Charging Yes Large 30 Unknown 2 Static Only None Safety' 1 5 Yes Large 30 Unknown Static Only None Inje Safety 1 6 Yes Large 30 Unknown Static Only None Inje '
7 Waste No Large 30 Unknown 2 None None Disposal 8 Waste 1 Yes Large 50 Unknown None None Disposal 9 Waste 1 No Small 50 Unknown None None Disposal 10 Waste 1 No Small 30 Unknown None None Disposal 11 Charging Small 1 No 50 Unknown None None 12 Charging 1 Yes Small 90 Unknown Static Only None 13 Charging 1 Yes Small 30 Unknown None None
.
14 Charging 1 Yes Large 150 Unknown None None Charging 1 15 Yes .Large 700 Unknown None None Charging 1 16 Yes Large 60 Unknown None None Charging 1 17 Yes Large 30 Unknown None None Charging 1 18 Yes Large 30 Unknown Static Only .None
~19 Charging Yes Large 100 ~ Unknown None .None I 20 Charging Small 1 No 60 Unknown None None
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i TABLE II - (Continued)
LEAD SHIELDING INSTALLATIONS Safety Pipe Lead Engineering Location ~ Related Bore Weight Date Calculation Safet i System Installed
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Number (CQE) Size (Lbs) (Static /Dynam1M Evaluation 21 Charging Yes Large 100 Unknown 3' None None 22 Charging Yes Large 30 Unknown 3 None None
23 Charging No Small 270 Unknown None Hone
25 Waste No Large '30 Unknown None None Disposal 26 Waste No Large 350 Unknown * None None Disposal 32 Contain- 4 Yes Large 50 . Unknown None None ment Spray.
Footnotes:
2 Found 04/06/83 Found 12/01/83
Found 01/27/84 '
Found 09/20/84
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TABLE III DOCUMENT CONTROL CONSTRUCTION PACKAGES AND DRAWINGS A. Construction Packages reviewed:
MR 83-158 Addition of Air Accumulators for YCV-1045A and B 84-61 Union Installation on SI-209, 213, 217, 221 84-92 SG Nozzle Dams84-119 Replaceinent of Instrument Inverters- 84-162 Containment _HVAC Duct Supports85-009 Replacement of Containment Penetration Subassemblies 85-42 Replacement of MS-100 B. Drawing Discrepar.cies:
Drawing #/ File #
MR #. in Construction Package Discrepancy 85-009 Conax 2325-7684L Issue A Not shown on drawing list but in package .
marked "for construction"84-119 File # 39843 Not shown on drawing File # 14673 list.but in' package-marked "for construction"84-119 File # 12234 Rev. A Incorrect revision, Rev. B shown on drawing list 84-119 File # 9414 Rev. B Incorrect revision, Rev. A shown on drawing list 84-119 File # 39840 Drawing list had wrong drawing number 84-119 Fi'e # 14672 2 drawings existed with the same revision but information on drawings
.was different 83-158 2 P& dis not in construc-tion package when reviewed-40-
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TABLE IV LIST OF OPPD NUCLEAR WELD FROCEDURES Weld Procedure Specification #1
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Groove Design: Single Vee Base Materials: Carbon Steel to carbon steel Base Material Thickness: .0626" .750" Process: SMAW - Manual
,
Weld Procedure Specification #1, Supplement A Groove Design: Double Beve Base Materials: Carbon steel to carbon steel Base Material Thickness: .0626" .750" Process: SMAW - Manua Weld Procedure Specification #1, Supplement B Groove Design: Double-Vee Base Materials: Carbon steel to carbon steel Base Material Thickness: .0626" .750" Process: SMAW - Manual
Weld Procedure Specification #1-A
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Groove Design: Single Vee Base Material: Carbon steel to carbon steel Base Material Thicknessi 3/16"-1" Process: SMAW - Manual Weld Procedure Specification #1-B-Groove Design: Fillet (90*) .
Base Materials: Carbon steel to carbon steel ;
Base Material Thickness: 3/16"-1" Process: SMAW - Manual Weld Procedure Specification #2
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Groove. Design: Single Vee Base Materials: 300 series ' stainless-steel to 300 series stainless steel i Base Material Thickness: .0625"-1.812" Process: SMAW - Manual Weld Procedure Specification #3-Groove Design: Single Vee- 4 Base Materials: '300 series stainless steel to 300 series. stainless steel -
Base Material Thickness: .0625" .560" Process: GTAW - Manual-41-
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TABLE IV - (Continued)
LIST OF OPPD NUCLEAR WELD PROCEDURES
Weld' Procedure Specification #4 Groove Design: Single Vee Base Materials: 300 series stainless steel to carbon steel Base Material Thickness: .0625" .560" Process: GTAW - Manual Weld Procedure Specification #5 Grcove Design: Single Vee Base Materials: 300 series stainless steel to 300 series stainless steel Base Material Thickness: .0625" .560" Process: GTAW-Root /SMAW - Fill-Manual Weld Procedure Specification #6 Groove Design: Single Vee .
Base Materials: Carbon steel to carbon steel
' Base Material Thickness: .0625" .750" Process: SMAW/GTAW - Manual Weld Procedure Specification #6, Supplement A Groove Design: Double Vee Base Materials: Carbon steel to caroon steel Base Material Thickness: .0625" .750" Process: SMAW/GTAW - Manual Weld Procedure specification #6A Grcove Design: Single Vee Base Materials: Carbon steel to carbon steel Base Material Thickness: .1875"-1.00" Process: SMAW/GTAW Weld Procedure Specification #6B Groove Design: Single Vee Base Materials: Carbon steel to carbon steel Base Material Thickness: 3/16"-1-1/8" Process: GTAW/SMAW - Manual
~ Weld Procedure Specification #7 Groove Design: Single Vee Base Materials: Carbon steel to carbon steel Base Material Thickness: .0625" .750" Process: GTAW - Manual-42-
TABLE IV - (Continued)
LIST OF OPPD NUCLEAR WELD PROCEDURES
Weld Procedure Specification #8'
Groove Design: Compound' Bevel Base Materials: A335 P22 to A335 P22 Base Material Thickness: .0625"-4.25" Process: .GTAW (Root)/SMAW (Fill) - Manual
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Weld Procedure Specification #10 Groove Design:. Single Vee Base Materials" Carbon steel tc A335 P22-Base Material Thickness: .0625"-4.5" Process: GTAW (Root)/SMAW (F111) - Manual
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TABLE V LIST OF TEMPORARY CQE STORAGE AREAS-Temporar Surveillance NRC Inspection Storage Area Date(s) Date 1 09-26-85 11-22-85'
10-17-85 11-22-85 3 04-18-85 11-22-85 05-06-85 11-22-85 06-13-85 11-22-85 10-17-85 11-22-85 4 09-27-85 11-22-85 10-01-85 11-22-85 10-17-85 11-22-85 5 09-27-85 11-22-85 10-17-85 11-22-85 9 01-22-85 '11-22-85 02-08-85 11-22-85 03-05-85 11-22-85 04-18-85 11-22-85 05-06-85 11-22-85 06-13-85 .11-22-85 10-17-85 11-22-85 10 09-16-85 11-22-85 .
10-17-85- 11-22-85 11 10-10-85 11-22-85 10-17-85 11-22-85 12 10-01-85 11-22-85 13 10-14-85 11-22-85 10-21-85 11-22-85 14 10-14-85 11-22-85-10-21-85 11-22-85 15 02-02-85 11-22-85 02-08-85 11-22-85 03-05-85 11-22-85 04-18-85 11-22-85 05-01-85 11-22-85 06-13-85 11-22-85 09-26-85 11-22-85 10-17-85 11-22-85 10-21-85 11-22-85-44-
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TABLE V - Continued LIST OF TEMPORARY:CQE STORAGE. AREAS Temporary : Surveillance' NRC Inspection Storage Area' Date(s) Date 16' 09-27-85 11-22-85 10-15-85 11-22-85 10-17-85 11-22-85 10-25-85 11-22-85 17 '11-20-85 11-22-85-
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TABLE VI LIST OF MODIFICATIONS WITH SAC DISCREPANCIES MR # Subject Comments-
.83-150 Reroute MSIV Leakoff Lines MS-338 tag'not attached
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as required 79-171B Pzr Safety Valve Loop Seal TS snubber list was updated 84-90 PORV Reset. Demand OP-10 issued e 83-116 VLPMS OP & CP issued
82-178 HEPA Carbon Filter Delta P Indicator Action complete 83-159 SG Support Plate 83-49 HCV-884A Seat Material 4 76A-04 SG Feedwater Bypass Valve Controls' OI issued 83-32 Qual. of Foxboro Transmitters 82-91 SG Blowdown Rad Monitor 83-31 HCV-348 Shaft Change 80-10 Install Drain Valve 84-74 Fuse Protection 84-004 Upgrade Limit Switches i 79-147 Trip Circuit Bypass for Aux. Bld Wide Range Excore Detectors 70-66 Qual. of Backup Instrumentation
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83-50 Turbine Drain Valve Controls 82-95 Offsite Radwaste Processing
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03-73 Replace Waste Gas Release Valves i-82-169 Nitrogen Blanket on EFWST 81-99 HJTC Pressure Boundary 83-56 ' Hydrogen Purge Valves83-146 Relocation of PT-105-
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79-81 PORV Activation.Setpoints 82-96 Ventilation. Mod
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1 BACKGROUND
4 3.1 MEETINGS
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The following list identifies licensee representatives and NRC personnel
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at.the. exit meeting and key individuals. contacted during the inspection.
j 3.1'.1 Exit Meeting R. Andrew's R. Liebentritt 1- J. Fisicaro' K. Morris J. Gasper P. Surber W. Gates F. Thurtell R. Jaworski
]..
l NRC and Consultants i . . .
- P. Harrell . M. Murphy i D.-Hunnicutt J. Partlow-
, J. Konklin W. Robinson-
R. Lloyd A. Saunders W. Marini A. Thadani j E. Tourigny
[ 3. OPPD Coordinators and Contacts
C. Brunnert S. Gambhir M. Core W. Gates E. Eidem T. McIvor J. Fisicaro R. Mueller i
H. Tackett l
In addition to the above personnel, numerous other engineers, inspectors and supervisors were also contacted.
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3.2 DESIGN AND VENDOR INSPECTION REPORTS 3. Design Report Safety Systems Outage Modification Inspection (Design) 50-285/85-22
' dated January 21, 198 ~
3. Vendor Reports Vendor Compone'nt/ Service Inspection Report Date Nuclear Energy Steam Generator 99900762/85-01- 12/6/85 Services (NES) Nozzle Dams
Westinghouse 4160/480 Volt 99901031/85-01 1/23/86 (NSID) Transformers Elgar Cor Inverters 99900871/85-01 12/27/85 Power Conversion Battery. Chargers 99900741/85-01 7/3/85 Products Dresser-Hancock Valve Components 99900054/85-01 12/13/85 Industries Dietrich Flow-Measurement 99901034/85-0 /31/86 Standard Element r
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i 3.3 REFERENCES
'The following documents.are referred.to specifically in the repor SO G-21,'" Station Modification Control"
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i SO G-22, " Storage of Critical Element and Radioactive Material Packaging, Fire Protection Material, and Calibrating Equipment" SO G-26A, " Quality Control Progra ,"
SO G-30, "Setpoint/ Procedure Changes" SO G-57, " Installation of Temporary Lead Shielding"
- GSE Procedure B-3, " Drawing' Production" l
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GSEE-0512, " Cabling Splicing Procedure"
.GSEE-0516, " Requirements for Installation of Electrical Cables at the Fort Calhoun Unit No. 1" GSEE-0517, " Installation of Seismic Supports for CQE and Limited CQE Electrical Equipment"
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3.4 DOCUMENTS REVIEWED The types of documents listed below were reviewed by the team inspectors to the extent necessary to satisfy the inspection objectives. Reference to specific procedures and drawings are contained within the body of the repor . Updated Safety Analysis Report 2. Technical Specifications 3. Quality Assurance Plan 4. Quality Assurance Manual-5. Critical Quality Equipment List 6. Standing Orders 7. Maintenance Procedures 8. Maintenance Orders 9. Final Design Packages 10. Construction Packages 11. Operating Instructions 12. Operating Procedures 13. Emergency Procedures 14. Installation Procedures 15. Test Procedures 16. Surveillance Test Procedures 17. Calibration Procedures 18. Operating Incident Reports 19. GSE Manual 20. Modification Drawings 21. As-Built Drawings 22. Welding Procedures l 23. Personnel Qualification Records ;
l 24.' Material Traceability Records ;
25. Standard Procedures .
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3.5 DEFINITIONS ALARA As Low As Reasonably Achievable-ANSI American National Standards Institute CCW Component Cooling Water CP Calibration Procedure CQE Critical Quality Element EP Emergency Procedure EQ Environmental Qualification F degrees Fahrenheit GET General Employee Training GSE Generating Station Engineering GSEE Generating Station Engineering Electrical HVAC Heating, Ventilsting and Air Conditioning IE Office of Inspection and Inforcement INP0 . Institute of'Naclear Power Operations M0 Maintenance Order MR Modificat' ion Request MS Main Steam NDE Nondestructive Examination -
01 Operating Instruction OP Operating Procedure .
OPPD Omaha Public Power District P&ID Piping and Instrumentation Diagram P0 Purchase Order PRC Plant Review Committee PT Dye Penetrant Inspection QA Quality Assurance QC Quality Control SAC System Acceptance' Committee SG Steam Generato SI Safety Injection SIT Safety Injection Tank SO Standing Order SR0 Senior Reactor Operator STA Shift Technical Advisor STK Stock T Temperature-USAR Updated Safety Analysis Report WPS Weld Procedure i
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