IR 05000298/1981006
| ML20004C068 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/12/1981 |
| From: | Boardman J, Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20004C060 | List: |
| References | |
| 50-298-81-06, 50-298-81-6, NUDOCS 8106010478 | |
| Download: ML20004C068 (6) | |
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U. S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT
REGION IV
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Report:
50-298/61-06 Docket: 50-298 Licensee: Nebraska Public Power District Post Office Box 499 Columbus, Nebraska 68601 Facility Name:
Cooper Nuclear Station Inspection at:
Cooper Nuclear Station, Nemaha County, Nebraska Public Power District Offices, Columbus, Nebraska Inspection conducted: April 13-16,1981
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Inspector:
Me J. Jy. Boardman, Reactor Inspector Q)te Sydems and Technical Section Approved:
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R. E. Hall, Chief Date Syst, ems and Technical Section Insoection Summary:
Inspection on April 13-16, 1981 (Report 50-298/81-06)
Areas Inscected:
Rour.ine, unannounced inspection oT~the procurement activities;
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receipt storage and handling program; and the procurement control program.
This inspection involved 29 inspector-hours on site by one NRC inspector.
Results:
In the three areas inspected, no violations or deviations were found in two areas; one apparent violation was found in one area (violation -
failure to comply with procedures paragraph 2).
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DETAILS 1.
Persons Contacted
- R. E. Buntain, Director of Power Supply
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- R. S. Kamber, Assistant General Manager, Power Supply
- J. S. Larson, Quality Assurance Engineer L. E. Lawrence, Maintenance Supervisor
- L. C. Lessor, Station Superintendent D. Marsh, Manager Purchasing
- J. M. Pflant, Director Licensing and Quality Assurance
- F. E. Williams, Manager Quality Assurance V. L. Wolstenholm, Quality Assurance Supervisor The NRC inspector also contacted other plant personnel, including clerical, administrative, and maint: 2nce personnel.
- Indicates presence at exit interview held April 15, 1981.
- Indicates presence at exit interview held April 16, 1981.
2.
Procurement The NRC inspector reviewed the licensee's procedures and activities to determine whether the storage of components, materials and supplies used for safety-related functions was in conformance with the licensee's approved Quality Assurance Program and implementing procedures.
The NRC inspector noted and discussed with licensee representatives the following examples of an apparent violation of regulatory requirements and licensee approved procedures.
10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented procedures and shall be accom-plished in accordance with these procedures.
Sections 1.11.4.3.8 and 1.11.4.4 of Cooper Nuclear Station (CNS) Adminis-trative Procedure 1.11, " Requisitioning, Receiving, Storage of Essential Parts and Components," Revision 16, approved January 7,1981, require an inspector to verify compliance of material and its specified documentation
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with purchase order requirements, and that he document this inspection on the receiving report.
Contrary to the above, the receiving reports for Purchase Orders 164106 and 170221 were not signed as being inspected as required by Administra-tive Procedure 1.11.
Administrative Procedure 1.11 also requires that the "CNS Stores Requisi-l tion" form (Attachment "E" to Administrative Procedure 1.11) be completed as follows:
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Section 1.11.6.1.1 requires that the requisitioner will complete the appropriate section of *.he work document description by provi.ing cross reference to a specific MWR, MOC, etc. Contrary to this require-ment, 8 of approximately 34 stores requisitions reviewed either did not list a specific work document or were left blank in that section.
Section 1.11.6.1.2 requires that the individual issuing the item from stores will indicate the material status as accepted or hold.
Contrary to this requirement, 15 of the approximately 34 stores requisitions reviewed did not have the material status indicated.
Failure to accomplish activities affecting quality as prescribed in
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documented procedures is an apparent violation of 10 CFR Part 50, Appendix B, Criterion V.
(8106-01)
3.
Receipt Storage and Handling Program The NRC inspector reviewed licensee procedures and activities to deter-mine if the licensee was implementing a Quality Assurance Program relating to the control of receipt, storage and handling of equipment and materials that is in conformance with the regulatory requirement of 10 CFR Part 50, Appendix B and commitments in the licensee's FSAR.
During this inspection, the NRC inspector noted 0-rings for which shelf life had apparently expired as follows:
Licensee-Purchase Licensee's Vendor's Shelf Life Expiration Order Number Part Number Batch Number Date, End of 118013 04996 637887 1st Quarter 1980 112572 05067 660460 4th Quarter 1979 127919 05065 5835 3rd Quarter 1980 While the licensee had initiated a program of shelf life control, the program had apparently not been completely defined; procedures prescribing the program had not been issued; and licensee purchase t
orders did not require suppliers to identify shelf life items and l
their expiration dates.
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As stated above, the licensee was in process of initiating a documented program to prescribe necessary actions in this area.
The NRC inspector also noted that licensee Administrative Procedure 1.11, Revision 16 " Requisitioning, Receiving, Storage of Essential Parts and Components," approved January 7, 1981, did not require review, docu-mentation of review, and acceptability of Material Test Reports (MTRs) or other Technical Documentation or test reports by Cc g r Nuclear Station Engineering personnel or by Quality Assurance personnel.
Licensee personnel did state that such reviews and acceptance were accomplished.
As presently written, Administrative Procedure 1.11 could be interpreted as requiring the " inspector" performing receiving inspection to be Level II inspector in accordance with ANSI N45.2.6-1973.
Pending issuance of tha revised control procedure this is considered an open item and will be reviewed during a subsequent inspection.
(8106-02)
4.
Procurement Control Program The NRC inspector reviewed the licensee's procedures and activities to determine whether the licensee is implementing a Quality Assurance Program relating to control of procurement activities that is in conformance with 10 CFR Part 50, Appendix B and with commitments in the licensee's FSAR.
The NRC inspector found that while recent purchase orders containe'd clauses specifying access to suppliers' activities and records for audit, and specified that the requirement that the supplier mainhin a program in compliance with the applicable portions of 10 CFR Part 50, Appendix B, ANSI N45.2 and 10 CFR Part 21, certain earlier orders such as 155420 (MIDCO), 171646 (Lakeland Engineering Equipment Company /ASCO) and 176329
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(Anchor / Darling Valve Company) did not contain these clauses.
Licensee representatives stated that there was supplier resistance to acceptance of earlier standard purchase order clauses implementing these requirements.
The clauses which are Attachments "I" tad "J" to Administrative Procedure 1.11, " Requisitioning, Receiving, Storage of Essential Parts and Components,"
were changed by Revision 16 approved January 7, 1981, and these revised clauses are being used.
During the review of the licensee's supplier approval program, an anomoly was disecvered in the case of MIDC0 Pipe and Tube of Bensenville, Illinois.
This supplier is a distributor, who supplies the licensee with numerous essential (safety-related) materials, including pipe fittings. The licensee's policy for supplier certification (or qualification) is to survey the manufacturer, not the distributor.
Specifically, licensee memorandum, dated September 9, 1977, Subject:
" Vendor Qualification,"
states that "... the term ' supplier' is defined as the manufacturing outlet, not the distribution point," and that "in accordance with that definition all future qualification will ba made of ' suppliers' and
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the selection of distribution points for that supplier's product will be of relatively minor importance."
In the case of MIDCO, however, the licensee surveyed and qualified MIDC0 (the distribution point) and not the manufacturing outlets. Although the initial survey of MIDC0 was priorto Seotember 1979 when the term " supplier" was defined to exclude distributors, MIDC0 has twice since been requalified, in November 1979 and July 1980, without survey, and apparent manufacturing outlets used by MIDC0 have not been certified by the licensee since September 1977. The licensee quarterly "NCR Trend Analysis" report for five of the last six quarters showed only one supplier having continuing i
adverse quality trends and that the supplier was MIDCO. MIDC0 was neither an ASME certificate holder, nor included in the CASE program, and neither were three of the four pipe fitting manufacturing outlets used by MIDC0 and selected as a sample by the NRC inspector.
The licensee has indicated his intent to surv9y MIDC0 to assure that there are no nonconformances in the area of subtier supplier control.
A review of purchase orders revealed that one purchase order (147073) to Nebraska Testing Laboratories included the calibration of dead weight tester weights classified as essential. This supplier was a qualified supplier, but not for this attribute.
The licensee apparently had not
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verified that Nebraska Testing Laboratories was also qualified for calibration of dead weight tester weights.
In all cases where supplier certification was not all inclusive of material, equipment or services available from that supplier, the licensee's " Qualified Vendor List" so reflects.
It was noted that the licensee " Qualified Vendor List" now shows for some vendors what may be a limitation such as "H.
L. Crump and Company (Flexitallic Gasketing)." The licensee has indicated his intent to survey this supplier to verify his acceptability for this attribute.
These two instances were considered isolated cases in an otherwise com-
l prehensive program.
Pending completion of the intended surveys and NRC inspector review of the results, this will be considered an open item.
(8106-03)
5.
Independent Insoection
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As part of the NRC inspector's independent inspection effort, an analysis i
was made of the licensee's trend analysis orogram.
For the past six
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quarters, the following areas are shown in the licensee's quarterly
"NCR Trend Analysis" report as exhibiting a continuing increasing (adverse) trend condition:
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a.
Reactor Equipment Cooling b.
Reactor Core Isolation Cooling c.
Radiation Monitoring - Vent d.
Fire Protection e.
Augmented Off-Gas In addition, the licensee's "NCR Trend Analysis" report, dated May 11, 1978, Section 7, " Radiation Monitoring - Vent," states, "The data indicates that the NCRs written on this system have increased steadily since April 1977.
An adverse trend is established." This indicates previous apparent long-term adverse trends in this area.
The licensee, as part of his continuing program, will evaluate the underlying causes of adverse quality trends in these areas.
Results of his evaluation will be reviewed during a future inspection.
This is considered an open item (8106-04).
6.
Exit Interviews Exit interviews were conducted on March 15 and 16,1981, with tnose NPPD personnel denoted in paragraph 1 of this report to summarize the scope of the inspection and the findings.
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