IR 05000285/1988031

Insp Rept 50-285/88-31 on 880912-16.Violations & Deviations Noted.Major Areas Inspected:Action on Previous Insp Findings,Welding,Design Changes & Mods,Procurement & Receipt,Storage & Handling of Equipment & Matls

ML20205D096
Person / Time
Site:	Fort Calhoun
Issue date:	10/18/1988
From:	Barnes I, Gilbert L, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205C847	List: IR 05000285/1988031 ML20205C844 ML20205C851 ML20205C858
References
50-285-88-31, NUDOCS 8810270058
Download: ML20205D096 (9)

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APPENDIX C U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/88-31 Operating License: DPR-40 Docket: 50-285 Licensee: Omaha Public Power District (0 PPD)

Facility Name: Fort Calhoun Station (FCS)

Inspection At: Fort Calhoun Station, Blair, Nebraska Inspection Conducted: September 12-16, 1988 Inspectors:

L. p.,811bert, Reactor Inspector, Materials

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and Quality Programs Section, Division of Reactor Safety

$w se/lr/Pr p W. M. Mclieill, Reactor Inspector, Materials Date and Quality Programs Section, Division of Reactor Safety Approved: 8-a /a//r/[r I. Barnes, Chief, Materials and Quality Date Programs Section, Division of Reactor Safety Inspection Sumary inspection Conducted September 12-16, 1988 (Report 50-285/88-31)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings; welding; design changes and modifications; procurement; and receipt, storage, and handling of equipment and raterials, f81027005sestorp p m a ovooo m .

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Results: Within the five areas inspected, three violations (failure tc

identify pressure boundary parts as safety-related in a design package,

! paragraph 4; failure to accurately reference the design basis in a purchase

order, paragraph 5; and failure to have adequate certification of

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safety-related components, paragraph 6) and two deviations (failure to meet

commitments to NRC for completing an engineering guide, paragraph 2b; and

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failure to meet comitments to NRC with respect to radiography of the emergency

feedwater tank repairs, paragraph 2e) were identifie '

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DETAILS

, Persons Contacted  !

OPPD  ;

• J. J. Fluehr, Acting Manager FCS  :

! *T. L. Patterson, Assistant Manager, FCS ,

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• T. J. Mc!vor, Manager, Nuclear Projects

• J. J. Fisicaro, Manager, Nuclear Licensing ,

• R. L. Jaworski, Manager Station Engineer r

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• K. J. Morris, Division Manager, Nuclear Operations

• S. K. Gambhir, Division Manager, Production Engineering 7

• C. J. Brunnert, Acting Manager Quality Assurance (QA) and Quality Control (QC)

• 0. W. Dale, Supervisor, QC

• J. L. Kyle, Special Services Specialist

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• J. L. Dyer, Senior QC Inspector ,

• R. Bateman, Supervisor, Procurement QA 1

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• J. Kecy Supervisor System Engineer '

• K. R. Henry, Lead Systems Engineer

. *L. L. Gundrum, Licensing Engineer

! B. E. Eidem. Manager, Mechanical Engineering i

H. J. Faulhber Mana  !

i and Control f!&C)Engineering ger, Electrical Instmntation '

R. S. Katnish, Planner l S. R. Miller, System Engineer

! K. A. Penner. QA Engineer i B. L. Saucier, QA Inspector

J. L. Uden, Senior Engineer j Stone and Webster G. A. Bell, Electrical Engineer ,

NRC

• P. H. Harrell, Senior Resident Inspector

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The NRC inspectors also interviewed other licensee employees during the inspectio '

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• Denotes attendance at exit interview conducted on September 16, 198 j Licensee Action on Previous Inspection Findings (92701 and 92702) i

(Closed) Violation (285/8708-01): Failure to control special i

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processes. The NRC inspector verified that the licensee had

completed the corrective steps comitted to in the response to the i violation which included the evaluation of the welding program by a

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welding consultant, implementation of new welding procedures, addition of a welding specialist to the staff, evaluation of three i

operation incident reports, revisfon of the welder qualification program, implementation of a computerized program for tracking 1 and maintaining welder qualifications, issuance of a new standing ,

order for controlling welding, requalification of all welders, f evaluation of discrepancies in the qualifications for welders and  !

welding procedures, and reinspection and evaluation of flare  ;

l bevel groove weld This violation is close l b. (Closed) Violation (285/8713-01): Failure to qualify a butt-weld

procedure prior to use for installation of seismic wall support !

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The NRC inspector reviewed the operations incident report and design l l

calculations for evaluating the as-installed butt welds and found the l l evaluation to be acceptable. The NRC inspector verified that new J welding procedures and welding controls were developed in accordance  !

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with AWS 01.1 requirements. The licensee welding specialist prepared the new welding procedures and welding controls under the guidance of i the welding consultant while developing the engineering guide for ,

4 preparation of welding procedures and procedure review. The licensee  !

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also comitted in the response to the violation to complete the l

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3 engineering guide by January 1988; however, the engineering guide, as of September 16, 1988, has not been issued. Based on the actions q taken by the licensee, this violation is closed. The licensee's r 4 failure to complete the committed engineering guide is an apparent  ;

deviation. (285/8831-01)

c. (Closed) Open Item (285/8713-02): Concerns related to notching of l cable tray supports. Production engineering performed an evaluat'on i

and determined that the notching was done during original plant  ;

i construction and therefore no unauthorized notching associated with  !

I rnodifications has been performed. The NRC inspector had no further  !

J concerns with respect to notching cf cable tray supports. This open l

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d. (Closed) Open Item (285/8713-03): Unfilled bolt holes in a

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structural I-beam. The licensee perfonned an engineering analysis of  ;

4 this support which confirmed that the holes have an insignificant (

impact on the safety of the support. This analysis resolved the

! concern of the NRC inspector. This open item is close ,

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e. (Closed) Violation (285/8714-01)

Failure to follow procedure for j radiographic examination. The NRC inspector reviewed the licensee l l

accepted contractor radiographs of the repairs to emergency feedwater

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tank girth weld G1 to verify that the repairs were reradiographed l

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using source side penetrareters. The review confirmed the use of  !

. source side penetrameters. However, it was observed that the .

radiographs did not include all areas repaired. The radiographs of  !

< the repairs at location markers 11-12 and 14-15 did not include all of the repair areas, because the location markers were shifted one <

increment from the zero location used for the original radiograph j i

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The licensee reevaluated the previously accepted contractor radiographs for girth weld G2 and identified additional areas of l

inadequate radiographic coverage of the repairs. This violation is ,

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closed based on reradiography of repairs using source side '

penetrameters being performed. The failure to fully examine the

.1 repair welds is an apparent deviation from the licensee commitment ,

4 that examinations had been completed in that the radiographic film -

did not encompass all repaired area (285/8831-02)

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! Nuclear and Structural Welding (55050 and 55100)

l t j The NRC inspector reviewed the following documents related to the new FCS  !

j welding program: l

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Standing Order G-72, Special Process Control 4  !

• Standing Order G-72A, Welding and Weld Control  !

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• Standing Order G-72B, Qualifications of Welders

• QA/QC Department Manual, QDP-20, Appendix G, Visual Examination

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Procedure

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WeldingProcedureSpecifications(WPSs)andthesupportingprocedure  ;

l qualification reports for the WPSs listed below:  :

WPS 101, 102, and 103 for welding ASME P-1 materials  !

l WPS 501 and 502 for welding ASME P-5 and P-5 to P-1 materials l

WPS 801, 802, and 803 for welding ASME P-8 and P-8 to P-1 materials J

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WPS 120,121,122,123, and 124 for welding AWS carbon steel

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In the areas reviewed, the welding control program and the welding l l4 procedures were consistent with the ASME Codes specified in Standing  ;

, Order G-72. Implementation of the welding control program will be l

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inspected during a future inspectio !

No violations or deviations were identifie !

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i 4 Desian Changes and Modifications Procram (37702) {

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The objective of this inspection was to ascertain whether the licensee is l implementing a QA program for the control of design changes and  ;

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modifications that is in confomance with regulatory requirements and t

licensee comitrents. In this regard, the NRC inspector reviewed the QA [

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4 progran description found in Appendix A of the Updated Safety Analysis j Report (USAR), Revision 5 dated July 1988; the CA Plan for FCS Unit 1, j Revision 13 dated August 1,1988; and the following irplementing procedures:

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QA Review of Design Documents, QADP-18, Revision 4, dated April 5

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Station Modification Control, SO G-21 Revision 29, dated t November 19, 1987

Preparation of Design Packages GEG-3, Revision 0, dated November '

1987

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Modification Request Development. A-2, dated February 1988

• Production of Design Description and Evaluation Nuclear

Modifications B-2, dated December 1987

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Independent Design Verification, B-11, dated February 1988 t The NRC inspector reviewed the following sample of four design packages r l for modifications to be performed during the next outage:  ;

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Qualification of Pressurizer Level Control Instrumentation, 86 046,

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Letdown Level & Backpressure Control Valves84-176, dated July 29, t 1988  !

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i Containment Sump Temperature Indication,87-016, dated August 16,  !

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CCW Heat Exchanger Outlet Temperature Indicators Scale Replacement,  !85-142, dated August 2, 1988 l The NRC inspector fcund that a program has been established to control i i modification activities which appeared adequate with the exception noted f j below. The NRC inspector verified that procedures were in place that  ;

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addressed the initiating of a modification, 10 CFR 50.59 reviews,

organizational interfaces, and independent design verification

Post-rodification acceptance testing and acceptance criteria were required  :

by administrative controls. A design package, after issuance as a final  !

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revision, is then subjected to reviews by QA, an independent third party, i and the P16nt Review Ccccittee. The NRC inspector verified accomplishment of these activities by review of the above sample of design packages, i lt was noted by the NRC inspector that Procedure B-2 appears to have I become out-of-date in relationship to the main governing Procedure GEG- l The description of the contents of a final level design package and  !

construction level design package contained in Procedure B-2 were

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I different from that of Procedure GEG-3 and the current practice. The l

! licensee will be revising Procedure B-2 to bring it into line with '

j Procedure GEG-3 and current practic This was identified as an unresolved item. (285/8831-03)

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The OPPD program, as defined in the COE List, requires that American Society of Mechanical Engineers (ASME) Code parts and their components be designated CQE. The CQE designation means that the parts and components are safety-related. In review of Design Package 84-176, it was noted that ,

' Section 11.1, material list, in the final revision of the package did ,

not identify pressure boundary valve body-to-bonnet studs and nuts d

(Items 4 and 8) to be CQE. The valve, LCV-101-1, is a letdown level and back pressure control valve. This list is to be used for procurement of

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material. In this case, material was on hand in the storeroom which had been previously bought as CQE. It was also noted that the independent third party review had not identified this list error. The failure to appropriately classify material requirements in the design package was

] identified as an apparent violation (285/8831-04). An additional concern J

of the NRC inspector was that the process of identification of pressure .

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boundary parts was not systematically addressed by program and was i j dependent on an individual effort.

i 5. Procurement (38701)

j The objective of this inspection was to detemine whether the licensee is

implementing a QA program for the control of procurement activities that

is in confonnance with regulatory requirements and licensee comitment ;

i In this regard, the NRC inspector reviewed the QA program description ;

! found in Appendix A of the USAR, Revision 5. dated July 1988; QA Plan for ,

I FCS Unit 1, Revision 13, dated August 1, 19881 and the following implementing procedures ,

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Review of Procurecent Documents, QADP-10. Revision 4 dated M?y 18, !

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Approval and Audit of Vendors, QADP-11 Revision 7, dated February 4 ,

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procurement which appeared adequate with the exception noted below. The ;

administrative controls addressed review and approval of docurents, and

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qualification of vendors. The NRC inspector reviewed the following  ;

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purchase orders which were associated with the four design packages sampled above:

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60192 35933 531025

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525515 34123 52355 i

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36793 47334 30803

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50707 72648

It was noted that Purchase Order 35933 to Conax did not accurately reflect

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the applicable design basis for an RTO to be used for Modification 87-016, ;

in that the text did not identify the same USAR seismic floor response i spectra as the design package. The purchase order text referenced j i

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figures 18, 19, 24, and 25. Section 4.3.2 of the design package referenced figures 18, 19, 22, and 24 Figure 25 is for a Design Basis Earthquake with 0.05 damping and figure 22 is for an Operating Basis Earthquake with 0.02 damping. This was identifted as an apparent violatio (285/8831-05) ,

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6. Receipt, Storage, and Handling of Equipment and Materials (38702)

The objective of this inspection was to detemine whether the licensee is

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implementing a QA program for the control of receipt, storage, and handling of equipment and materials that is in confomance with regulatory requirements and licensee comitments. In this regard, the NRC inspector reviewed the QA program description found in Appendix A of the USAR, Revision 5. dated July 1988; QA Plan for FCS Unit 1. Revision 13, dated :

August 1,1988; and the following irrplementing procedures: ,

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Material / Service Acceptance and Receipt inspection. QADP-12, Revision 5. dated May 18, 1988 i *

Receiving, Shipping, Store Control and Storage of Critical Equipment i and Radioactive Material Packaging. Fire Protection Material, and 4 Limited CQE. SO G-22. Revision 27 dated March 14. 1988 i

The NRC inspector found that there was a rogram which addressed receiving

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inspection which appeared adequate with t e exception noted below. The l

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receiving inspection activities perfomed to date on nine of the purchase 1 orders referenced in paragraph 5 were reviewed. The NRC inspector

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verified that inspection was perfortned and documented as required by the j progra '

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] The OPPD program as defined in the CQE List. requires that hardware added l

by modifications be qualified to Institute of Electrical and Electronic !

j Engineers (IEEE) -344 and -323 requirements. Section 11.5 of the final ;

revision of Design Package 86-046 dated August 11, 1988, identified that !

certain stored CQE items (i.e., a teminal block (631-8521) bought on !

. Purchase Order 50707 and a fuse block (631-0858) bought on Purchase e Order 72648) were to be used. The NRC inspector ascertained. howeve '

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that there was no certification of their qualification to IEEE-323 and !

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IEEE 344 requirements on file. This was identified as an apparent i

violation (287/8831-06). The teminal blocks had a certification on file ;

- that was silent in regard to qualification to the IEEE standards. The >

1 fuse block had been dedicated as CQE by an internal memorandum which was f also silent in regard to the IEEE standards. Qualification data for 1 tcminal and fuse blocks was found by the licensee which had not been referenced in the design package, but the model numbers did not match. A concern of the NRC inspector is that some material is in stores that may J

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have been designated as CQE some time ago, but without the benefit of 7

current requirements for certification. If these parts were used in a CQE

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application there may be insufficient certification to the IEEE standard The NRC inspector was shown a check list which had been used in past outages, but not this current outage, which would have caused a review of the certifications and identification of this sort of problem, Unresolved Items Unresolved items are matters about which more infonnation is required in order to ascertain whether or not the items are acceptable, violations, or deviations. One unresolved item concerning discrepancies between two procedures is discussed in paragraph 4 Exit Interview An exit interview was conducted on September 16, 1988, with those personnel denoted in paragraph 1. At the exit, the NRC inspectors surtsnarized the scope and findings of the inspection. There was no information presented to the inspectors that was identified by the licensee as proprietar At the exit interview, the licensee comitted to reradiographing the emergency feedwater tank girth welds G1 and G2 during the next outage.