ML20030C173
| ML20030C173 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/30/1981 |
| From: | Boardman J, Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20030C164 | List: |
| References | |
| 50-285-81-16, NUDOCS 8108250462 | |
| Download: ML20030C173 (8) | |
See also: IR 05000285/1981016
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U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
REGION IV
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Report:
50-285/81-16
Docket: 50-285
License: DPR-40
Licensee:
Omaha Public Power District
1623 Harney Street
{
Omaha, Nebraska 68102
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Facility Name:
Fort Calhoun Station, Unit 1
Inspection at:
Fort Calhoun Station, Blair, Nebraska
Inspection conducted: July 6-10, 1981
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Inspector: f
y.jR. Boardman,ReactorInspector,SystemsandTechnical
Date
L5ection
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Approved: M
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'R. E. Hall, Chief, Systems and Technical Section
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Inspection Summary
Inspection Conducted July 6-10,1981 (Report 50-285/81-16)
Areas Inspected:
Routine, unannounced inspection including licensee records
program, licensee on-site review conmittee, QA program annual review, and
follow up on licensee actions on previous inspection findings.
The inspection
involved 31 inspector-hours by one NRC inspector.
Results:
In the four areas inspected, two violations were. found in one area
(violation - failure to meet record retention requirements and violation -
failure to retain records required by Technical Specifications - paragraph 3).
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DETAILS
1.
Persons Contacted
Omaha Public Power District
- R. L. Andrews, Sectit: runager, Operations
W. G. Gates, Supervisor, Gperations
- J. M. Gloshen, QA Engineer
- W. C. Jones, Division Manager, Production Operations
- K. J. Morris, Section Manager, Administrative Services
G. R. Peterson, Supervisor, Maintenance
- S. C. Stevens, Manager Fort Calhoun Station
- P. M. Surber, Acting Section Manager, Generating Station Engineering
- F. A. Thurtell, D"ision Manager, Environmental and Regulatory Affairs
The NRC inspector also contacted other plant personnel, including health
physics, clerical, and administrative personnel.
- Denotes those attending the exit interview.
2.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item (8111-03):
Reactor Coolant pump 3/4" spiral
wound (metal asbestA gaskets on licensee Purchase Order 47921 was not
ordered requiring, ano did not have, certification of acceptable low
limits of sulphur and chlorides.
Subsequently, the licensee has per-
fonr.ed chemical analysis of representative gaskets utilizing Regulatory
Guide 1.36, dated February 23,1973, " Nonmetallic Therral Insulation
for Austenitic Stainless Steel," as a guideline. The results of the
chemical analysis of chloride, 81 ppm; silicate, 800 ppm; and sodium,
34,200 ppm is considered nondeleterious as is the possible maximuc
sulphur content of <300 ppm for the 304 stainless gasket material aad
<200 ppm sulphur for the asbestos portion of the gaskets.
(See OPPD
interoffice memorandum File: TS-FC-81-36, dated May 21, 1981, Subject:
Use of Spiral Wound Flexitallic Gaskets (CG-15C) for RC Pumps at Fort
Calhoun.
This item is closed.
(0 pen) Violation (8107-01):
Failure to Maintain Sufficient Records
to Furnish Evidence of Activities Affecting Quality.
Example 1 was
the licensee's failere to mcintain records of supplier performance
used by the licensee as the basis of initial supplier approval at
the inception of thc licensee's supplier approval program.
Licensee
response to this violation included requalificatior:, or deletion, of
all iritial suppliers. As a result of this requalification program,
32 initial suppliers were deleted for various reasons. Two reasons
appear to have significant quality implications as follows: (1) "no
auditable QA program" and (2) "no authorized distributor documenta-
tion."
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Based on discussions with licensee personnel, the NRC inspector deter-
mined on July 8,1981, that no review of hardware documentation had
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been accomplished for hardware provided by suppliers deleted for the
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two above listed reasons.
Licensee personnel when questioned indicated
that such a review would be performed to assure that quality assurance
documentation provided by deleted suppliers was in fact adequate and
satisfactory in those cases where the supplier was deleted for not
having an auditable QA program cr where there was no authorized distrib-
utor documentation.
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This itea will remain open pending completion of this review by the
licensee.
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3.
Licensee Records Program
The NRC inspector reviewed the licensee's program and implementing
procedures for records for compliance with Appendix B to Part 50 of
Title 10, N de of Federal Regulations; ANSI N45.2.9-1974; and licensee
Technical Sp'cifications Section 5.10.
a.
10 CFR Part 50, Appendix B, Criterion XVII states that records
shall be ider.tifiable and retrievable, and that, consistent with
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applicable regulatory requirements, the applicant shall establish
requirements concerning record retention such as duration,
location, and assigned rf.sponsibility.
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The licensee Quality Assurance Manual, Section 1.2 states that the
Omaha Public Power District commits itself to and complies with
the mandatory Quality Assurance program guidelines contained in
WASH-1283, Revisic
1, " Guidance on Quality Assurance Requirements
During Design and Procurement Phase of Nuclear Power Plants";
WASH-1309, " Guidance on Quality Assurance Requirements During the
Construction Phases of Nuclear Power Plants"; and WASH-1284,
" Guidance on Quality Assurance Requirements During the Operation
Phases of Nuclear Power Plants."
WASH-1284 in Section B invokes ANSI N45.2.9-1974, " Requirements
for Collection, Storage, and Maintenance of Quality Assurance
Records for Nuclear Power Plants."
The followiig are examples of an apparent violation of the records
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requirements of 10 CFR Part 50, Appendix B, Criterion XVII and
ANSI N45.2.9-1974:
(1) 10 CFR Part 50, Appendix B, Criterion XVII requires records
to be retrievable. ANSI N45.2.9-1974, Section 6.2 requires
" accurate retrieval of infe mation without undue delay."
ANSI N45.2.9-1974, Appendix A delineates records to be
retained.
Licensee Quality Assurance Procedure No. 7 (QAP
No. 7), Revision 1, approved August 9, 1978, " Storage and
Retention of QA Records," contains in Appendix A the tabula-
tion of Quality Assurance (QA) records included in the
licensee's QA records retention program.
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On July 7 and 8, 1981, licensee personnel were unable to
retrieve the following categories of permanent records
listed in QAP No. 7, Appendix A:
Fonn FC-261, RM057 Monthly Tech. Spec. Calc. Sheet-GE-LI
for the year 1973
Form FC-263, RM062 Quarterly Tech. Spec. Calc. Sheet GE-LI
for years 1973, 1974, and 1978
(2) ANSI N45.2.9-1974, Section 5.6 sets forth design criteria for
pennanent record storage vaults for protection of records from
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destruction by such causes as fire, and from deterioration.
Basically, the requirements are that the facility be a 4-hour
fire rated facility equivalent to National Fire Protection
Association Class A.
NRC will accept a 2-hour fire rating.
On July 7 and 8,1981, the licensee's Quality Assurance records
vault did not meet the design criteria of ANSI N45.2.9-1974,
Section 5.6 or the optional criteria of National Fire Protection
Association Code 232-1975 permitted by ANSI N45.2.9-1974 (e.g. ,
the roof of the vault was not concrete, the vault door appeared
to be a joiner door and not fire rated, and a self-contained
air conditioning unit penetrated the wall).
The failure of the licensee's Quality Assurance records vault
to meet design requirements was first identified as a deviation
in NRC Inspection Report 75-09. This topic was discussed in
the NRC management meeting reported in NRC Report 7S.03..--
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Licensee Internal Audit Report No. 4-80, dated Janaury 30, 1980,
" Handling and Storage of QA Records Fort Calhoun Station Unit
No.1," Section 5.1.1 states, "The condition of the vault has
not changed.
It is still not an acceptable single record storac
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facility under the requirements established in ANSI N45.2.9."
Licensee Internal Audit Report No. 4-81, dated February 9,1981,
" Handling and Storage of QA Records Fort Calhoun Station,"
Section 5.1.1 states, " Lack of records microfilming since
mid-1979 makes those records stored since that time fall under
the requirements for a single storage facility.
It is question-
able whether or not the vault meets all the requirements of
ANSI N45.2.9, Paragraph 5.6.1 for a single storage facility.
For some documents, such as the radiographs, a single storage
facility is the only solution, but they should not be stored
in cardboard or wooden boxes which contribute to the fire
hazard in the vault."
(No known work was done to upgrade the vault between the
1980 and 1981 licensee audits.)
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(3) As an alternative to records storage in a fire rated vault,
ANSI N45.2.9-1974 permits equivalent protection such as a
fire rated file container. NRC accepts a 2-hour rated fire
container meeting NFPA No. 232 (Class B) without additional
NFPA provisions.
QAP No. 7, however, requires essentially
all permanent records to be stored in the QA records vault.
On July 7 and 8, licensee permanent records " Fuel Inventory
Reports" and " Records of Transient or Operational Cycling
for Those Plant Components That Have Been Designated to
Operate Safely for a Limited Number of Cycles" were found
not to be permanently stored in the Quality Assurance records
vault.
The latter record is known at Fort Calhoun as the
Plant Useage Data Book and was kept in the Control Room.
The " Fuel Inventory Reports" were permanently stored in the
corporate Quality Assurance offices.
Not only were these
records not permanently stored as required by QAP No. 7,
but the " Fuel Inventory Reports" were stored in a standard
nonfire rated file cabinet and the Plant Useage Data Book
was located on a desk top in the Control Room.
(4) Another alternative record storage method permitted by ANSI
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N45.2.9-1974 is the maintenance of duplicate records stored
in separate remote locations. The licensee committed to
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this method in response to NRC Inspection Report 77-05 as
documented in licensee letter dated May 24, 1977, as modified
by licensee letter dated October 7, 1977. The licensee stated,
"The system for transferring records to the vault, inspecting
them, and indexing them has been performing satisfactorily for
more recent records; however, it is unknown if all the early
plant records are available in the vault. The records storage
will soon be reorganized, with microfilming to start in July
1977. When completed, January 1,1978, the records should
meet all raquirements and be much more accessible, and that
full compliance would be achieved by January 1,1978."
On July 7, 8, and 9,1981, NRC discussions with licensee per-
sonnel, review of vault inventory and the records program,
and review of Internal Audit Reports 4-80 and 4-81 covering
handling and storage of QA Records Fort Calhoun Station
showed that microfilming was not complete. On factor may be
the licensee's apparent failure to enforce the requirement
of QAP No. 7 and Standing Orders C-2, Revision 6, dated
September 30,1980, " Fort Calhoun Station Quality Assurance
(QA) Records," and C-3, Revision 6, dated March 2, 1978,
" Fort Calhoun Station Quality Assurance (QA) Records (Chemistry
and Radiation Protection ONLY)," that permanent storage will
be in the vault and that records will be transferred to the
vault in a timely manner. Another factor may be that the
specific person, organization or function responsible for
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transferring records to permanent storage is not designated.
In some cases, such as the monthly TLD data processing status,
there are apparently multiple copies of records.
For the years
since 1974, the monthly TLD data processing status has not been
sent to the vault.
The 1974 monthly TLD records were sent to
the health physics organization, but when questioned, health
physics personnel stated that their record was actually only a
copy and the original was retained by another organization.
It is noted that licensee Procedure QAP No. 7 does not discuss
or authorize the use of the duplicate records and microfilming
in lieu of permanent storage in the Quality Assurant a records
vault.
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(5) ANSI N45.2.9-1974, Appendix A identifies records to be retained
and included in the licensee's Quality Assurance Records Program
including records for design, procurement, manufacturing,
installation-construction, preoperational and startup testing
and cperation phase.
On July 9,1981, licensee Procedure QAP No. 7 ir cluded in its
record retention program, as delineated in its Appendix A, only
operation phase records.
(6) ANSI N45.2.9-1974 requires single copy records to be protected
from destruction by such cause as fire when in permanent storage
with a storage method equivalent to a 4-hour fire rating. The
NRC will accept a 2-hour fire rating.
On July 7,1981, licensee radiographic film was stored in the
vac.. in wooden boxes and records were stored in cardboard
transfer files.
It is noted that the NRC position is that even
when a vault meets a 2-hour fire rating, records must be stored
in fully enclosed metal cabinets and that even open steel shelv-
ing is not permitted.
The problem of storage of radiographic film being a problem area
was identified in licensee Internal Audit Report 4-81, " Handling
and Storage of QA Records Fort Calhoun Station." This situation
was not made a deficiency and no corrective action was required
by this licensee audit report.
(7) ANSI N45.2.9-1974 requires tempcrary record storage facilities,
as well as permanent facilities, to provide protection from
possible destruction by causes such as fire and requires storage
to provide protection equivalent to a 4-hour fire rating, which
NRC will allow to be reduced to a 2-hour fire rating.
On July 7, 8, and 9,1981, licensee Quality Assurance and health
physics records were in temporary storage in file cabinets and
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metal drawers which were not fire rated.
Licensee Standing
Orders C-2 and C-3 do not require fire-rated protection for
records in temporary storage.
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Failure to have retrievable records and to meet the requirements of
ANSI N45.2.9-1974 constitute an apparent violation of 10 CFR Part 50,
Appendix B, Criterion XVII.
(8116-01)
b.
Licensee Technical Specifications, Section 5.10.2 lists records which
shall be retained for the duration of the Facilities Operating License.
Included are (1) records of radiation exposure for all individuals
entering radiation control areas and (2) records of gaseous radioactive
material released to the environs.
On July 7, 8, and 9, licensee personnel were unable to retrieve
(1) Forms FC-229 Pencil Dosimeter Logs for 1973, (2) Film Badge /TLD -
reports prior to December 1973, and (3) Form FC-252 Waste Gas Releases
Quarterly Technical Specifications requirements for 1974.
It was
verified that licensee personnel received exposure in 1973 by reviewing
the record of an employee who received exposure in October 1973.
Failure to retain records of individual exposure and records of gaseous
release to the environs is an apparent violation of Section 5.10.2 of
the licensee Technical Specifications.
(8116-02)
4.
Annual Review of QA Program
The NRC inspector reviewed the following procedure changes since the last
.nnual review to verify conformance with 10 CFR Part 50, Appendix B, and
the licensee's Quality Assurance Manual:
QAP 2, Revision 2, " Audit Plans," May 1,1981
QAP 4, Revision 1, " Approved Suppliers List," May 1,1981
QAP 5, Revision 2, " Supplier Surveillance," May 1,1981
QAP 6, Revision 1, "QA Surveillance," May 1,1981
QAP 9. Revision 1, " Surveillance of In-Service Inspection," January 25,
1980
QAP 10, Revision 1, "Non-Destructive Evaluation (NDE) Personnel
Administration," January 25, 1980
QAP 14, Revision 1, " Operational QA Mini-Audit Program," May 1,1981
QAP 15, Revision 2, " Adverse Condition Reporting and Correction,"
May 1,1981
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QAP 16, Revision 3, " Internal Audit Cycle for QA Program," May 1,
1981
QAP 19, Revision 1, " Indoctrination and Training of Quality Assurance
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Personnel," May 1,1981
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QAP 22, Revision 1, " Visual Examination Procedure," February 28, 1980
QAP 23, Revision 0, " Fire Protection," January 25, 1980
No violations or deviations were identified.
5.
On-Site Review Committee
The NRC inspector performed a review of the licensee's Plant Review
Committee (PRC) to ascertain whether the on-site review functions were
conducted in accordance with Section 5.5.1 of the licensee's Technical
Specifications. The PRC meeting of July 7,1981, was attended and
its minutes reviewed.
No violations or deviations were identified.
6.
Exit Interview
An exit interview was conducted on July 10, 1981, with those OPPD
personnel denoted in paragraph 1 of this report to summarize the scope
of the inspection and the findings.
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