IR 05000298/1979006
| ML19270H318 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/18/1979 |
| From: | Constable G, Johnson E, Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19270H316 | List: |
| References | |
| 50-298-79-06, 50-298-79-6, NUDOCS 7906260186 | |
| Download: ML19270H318 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-298/79-06 Docket No. 50-293 License No. DPR-46 Licensee:
Nebraska Public Power District P. O. Box 499 Columbus, Nebraska 68601 Facility Name:
Cooper Nuclear Station Inspection At:
Cooper Nuclear Station, Nemaha County, Nebraska and Columbus, Nebraska Corporate Offices Inspection Conducted: March 26-28, 1979 TN-E
- -' i Principal Inspector:
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G. L. Constable, Reactor Inspector Date Other Accompanying N M h -e -
4 s8 l,c1 Personnel:
E. H. Johnson, Reactor Inspector Date Approved by:
hb 9' /f!77 G. L. Madsen, Chief, Reactor Date Operations & Nuclear Support Branch Inspection Summary Inspection on March 26-28, 1979 (Report No. 50-298/79-06)
Areas Inspected:
Routine, announced inspection of document control,
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corporate level quality assurance audits, off-site review committee function, off-site support staff, follow-up on previously identified items of noncompliance, deviations, unresolved items and inspector identified open items.
The inspection involved thirty-four (34)
inspector hours on site by two (2) inspectors.
Results:
No items of noncompliance or deviations were noted in the
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areas inspccted.
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-2-Details 1.
Persons Contacted R. L. Allen, Fire Protection Engineer
- S. D. Anderson, Records Manager L. K. Barnes, Engineer Supervisor
- R. D. Boyle, Engineering Manager
- R. E. Buntain, Director of Power Supply G. Englebert, Supervisor Microfilm Department J. Filbrick, QA Engineer
- J. Larson, QA Engineer M. Olson, Document Control
- J. M. Pflant, Director of Licensing and Quality Assurance W. H. Rushton, Project Engineer 9. L. Torczon, Engineering Technician
- F. E. Williams, QA Manager
- Present at the exit interview.
In addition to the above technical and supervisory personnel, the inspector held discussions with various technical support and administrative members of the licensee's staff.
2.
Document Control The purpose of this inspection effort was to review the licensee's document control program to determine if the items identified in the licensee's internal audit of May 23, 1978, of this area continued to exist.
The inspector also reviewed the status of the implementation at the new computerized document control system.
Extensive discussions were held with key members of the licensee's engineering and records administration staff to determine if they understood their responsibilities for document control and the departmental procedures for this activity.
The inspector also followed a typical drawing revision through the licensee's system from initiation of the drawing change request through to issuance of revised controlled copies of these drawings.
No items of noncompliance or deviations were noted in this area.
Several inspector concerns were identified and discussed with the licensee's staff. These items will receive follow-up during future inspections.
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-3-The records department personnel were not clear on which essential records from the site they had responsibility for.
As an example, one copy of essential purchase orders is specified in QAI-7 to be maintained in the redundant corporate record files.
The records administration department personnel were not sure where these records were maintained.
A records control procedure similar in scope to QAI-7 should be developed outlining the record category, responsibilities for temporary and/or permanent storage for safety-related records at the corporate office.
The inspector noted some interface problems still existed between the engineering department and the records administration department.
This was especially evident in the determinations of the status of vendor drawings from the backlog of plant drawings contained in construction Ncords.
Thus it would be possible for an unrevised vendor drawing to supercede an "as-built" drawing in the file.
The inspector reviewed the computerized drawing index for plant drawings.
It was noted that the status codes for several drawings were apparently in error.
These codes represent the status of the drawing from an "as-built" (code 1) to an infomation only (code 7)
drawing.
The inspector noted that Burns and Roe flow diagrams 2046, 2047, and 2048 indicated status code 7 vice status code 1, whereas, the General Electric process and instrumentation drawing for the RCIC cvstem was designated as an "as-built" when its status was for inft sn only.
The inspector noted that the codes are due for a review when the new computerized document control system is adopted.
The inspector noted that the licensee lacks a unified _ listing of drawings which are to be maintained in an "as-built" configuration.
Many facility drawings (arrangements, certain isometrics, and such)
could be identified as "infomation only" drawings, whereas, other drawings (such a flow diagrams, control schematics) must be maintained in an "as-built" configuration since they are routinely used for plant operation and maintenance.
By this means a manageable system of controls could be developed to insure the maintenance of essential drawings in an "as-built" configuration and the remaining drawings updated as conditions permit.
3.
0. porate Level Quality Assurance Department Audits The purpose of this inspection effort was to review the licensee's corporate staff quality assurance department audit program and the completed audits of activities at the corporate office and at the Cooper Nuclear Station. The inspector reviewed completed audits 2318 147
_4 conducted by the corporate office quality assurance department staff for the period May 1978, to March 16, 1979.
Five completed audits were reviewed covering the following areas: station jumper log; security; emergency drill; design control; and document control.
No items of noncompliance or deviations were noted. The following areas of concern were noted by the inspector and were discussed with members of the licensee's staff.
On May 23, 1978, the results of a QA department audit of document control was fowarded to Quality Assurance Manager in a memorandum signed by the lead auditor.
In this memorandum, the lead auditor suggested that a fomal written response be required from the heads of the departments involved in the audit (i.e. records and engineering).
A request for such a response was not fomardej to these individuals.
The Assistant General Manager responsible for records administration did respond to the audit (since he had apparently received a carbon copy of the audit report). This response did not address any specific corrective actions for the specific items noted in the audit since the records department had been undergoing a reorganization.
This response did indicate that a reaudit of this area would be requested by January 1,1979.
No such reaudit occurred.
The next audit of document control is currently scheduled for June through July 1979, over thirteen months from the time the first audit findings were released.
In response to these concerns the licensee's quality assurance department staff indicated that a new QA Audit / Surveillance Report form was currently in use to formalize the system of following up on corrective actions.
Each noted discrepancy of an audit is docu-mented on a separate form which specifies the raquirement, the auditor's recommendations, a place for the audited party to respond with his corrective actions and a sign off block for approval by the auditor. This fom has been in use for about six months, it has not yet been incorporated into a QA department procedure. The inspector noted that there is no central log of these reports so that overdue responses can be traced. The inspector reviewed completed report foms for a design control audit performed in August 1978.
Some of the corrective action replies indicated that no action was taken.
These responses were signed off by the QA department auditor in the approval block without any justification as to the acceptability of the response.
Other corrective actions were signed off as approved with no follow-up by the QA department.
The licensee's QA department staff indicated that improvements were necessary in the documentation of audit findings and the follow-up of these findings.
This area will receive continued inspection emphasis during future inspections.
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-5-4.
Off-Site Review Committee The purpose of this inspection effort was to verify that safety evaluations and committee review functions are conducted in accordance with regulatory requirements.
The inspector reviewed the activities of the Safety Review and Audit Board for August 1978, through March 1979.
No items of noncompliance or deviations were noted.
5.
Off-Site Support Staff The purpose of this inspection effort was to review off-site support staff activities to verify that responsibilities and authorities are understood, that appropriate lines of communication exist between on-site and off-site functions and to verify that members of the off-site support staff are appropriately qualified.
The inspector reviewed the Mechanical and Civil Engineering Department and it was observed that only 12 of the 18 positions in the group are presently filled.
No items of noncompliance or deviations were noted.
6.
Follow-up on Previously Identified Items of Noncompliance and Deviations The purpose of this inspection effort was to review the licensee's corrective action for previously identified items of noncompliance and deviations.
This review was made to determine that the on-site staff had received the licensee's response to the item of noncompliance and that responsibility for the corrective action had been assigned.
Further, this review determined whether or not the corrective action and completion date committed to in the licensee's response letter to each item had been accomplished as described.
No items of noncompliance or deviations were noted during this review.
The following is the status of those items reviewed.
Closed (Deviation 7605-1), turbine building sprinkler design. The design for sprinklers on the turbine building side of the cable spreading room cable penetrations has been finalized and the sprinklers are being installed at present.
Closed (Deviation 7707-1), redundant record file for safety related records. The required records have been duplicated and placed in the vault in the Columbus General Office.
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-6-Closed (Noncompliance, Report 50-298/76-02, Infraction B), redundant record file. The corrective action for this item is the same as for Deviation 7707-1 above.
Closed (Noncompliance, Report 50-298/77-06, Infraction B), periodic fire brigade team training.
In his letter of May 11,1978,(NPPD letter from J. M. Pilant to DOR, NRR) the licensee committed to the staff position regarding fire brigade team training.
Closed (Noncompliance, Report 50-298/77-07, Infraction A), SRAB review of the audit program.
Revision 2 of the SRAB procedures contains the requirements for the proper review of the SRAB audits program.
Closed (Noncompliance, Report 50-298/78-03, Deficiency B), revision notices for QA program revisions.
The QA department has adopted a revision notice to accompany each QAI or QAP revision to indicate whether this is a significant revision.
The latest revision to the Quality Assurance Manual will delete this requirement.
Closed (Noncompliance, Report 50-298/78-13, infraction A), SRAB review of required activities.
The licensee has developed and is using a mechanism to ensure that SRAB conducts the review of activities required by technical specifications.
Closed (Noncompliance, Report 50-298/78-13, Infraction B), failure to follow procedures for control of completed design change package.
The licensee has completed the corrective actions specified in his letter of September 19, 1978.
Closed (Noncompliance, Report 50-298/78-17, Deficiency B), completion of required training for operators.
The licensee's corrective action for this item was reviewed during inspection 50-298/79-01, Details, paragraph 5.
7.
Follow-up on Unresolved Items and Inspector Identified Open Items Resolved (Unresolved Item - URI 7507-2) Written Policy Which Limits the Use of Open Flames or Ignition Sources.
The licensee's proce-dure covering welding activities requires a fire watch when the location of the welding is such that the welding might introduce a fire hazard.
Cutting operations are to be controlled by the use of a maintenance work request.
Resolved (URI 7507-1) )fritten Policy on Electrical Cable Seal Testing.
The licensee's procedures for secondary containment testing prohibit the use of flames.
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-7-Resolved (URI 7507-4) Uritten Policy for Considering the Affects of Nearby Cabling and Piping in Construction / Maintenance / Modification Activities.
The licensee has revised the procedure which governs minor design change / design change MDC/DC activities.
Each MDC/DC must be accompanied by a fire hazard analysis to its demonstrate that the design change will not introduce any fire hazard not already compensated for.
Resolved (URI 7507-6) Written Policy on the Use of a Monitor in Areas Adjacent to Work Involving Ignition Sources. The action for this item is discussed above in the resolution of URI 7507-2.
Closed (Reference IE Report 76-03, Details, paragraph 5). This item raised the question of fire hose testing per the National fire codes.
The testing of fire hoses has been added to the technical specifica-tions(T.S.4.18.A.3.b).
Closed (Reference IE Report 77-07, Details, paragraph 4). The licensee has completed his review of safety related drawings to determine that all such drawings are "as-built".
8.
Exit Interview The inspectors met with licensee representatives (See Details 1) at the conclusion of the inspection.
The scope and findings of the inspection were discussed.
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