ML20031B890
| ML20031B890 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/04/1981 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20031B887 | List: |
| References | |
| NUDOCS 8110060189 | |
| Download: ML20031B890 (9) | |
Text
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Omaha Public Power District 1623 HARNEY G O M A N A.
NEBRASKA 68102 m TELE AHON E $36 4000 AREA CODE 402 September 4, 1981 Mr. K. V. Seyfrit, Director U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Reference:
Docket No. 50-285 Inspection Report 81-16
Dear Mr. Seyfrit:
The referenced inspection report identified two violations related to storage and control of Quality Assurance (QA) documents at the Fort Calhoun Station. Omaha Public Power District's response to the two violations is attached.
Sincer ly, I
/
W. C.
nes Divisi n Manager Production Operations WCJ/KJM/TLP:jmm Attachment cc:
U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Omaha Public Power District
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Docket No. 50-285 (Fort Calhoun Station,
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Unit No. 1)
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AFFIDAVII
..... being duly sworn, hereby deposes and says that he is Division Manager - Production Operations of Omaha Public Power District; that he is duly authorized to sign and file with the Nuclear Regulatory Com-mission the attached response to the Notice of Violation identified in NRC Inspection Report 81-16; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
'I N
W. C.
nes Divis Manager Produ ion Operations STATE OF NEBRASKA)
) ss COUNTY OF DOUGLAS)
Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this dry day of September,1981.
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Notary Public SittRAL NOTARY-State of betrasta i
J. T. GLEAsON
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DISTRICT RESPONSE TO IE INSPECTION REPORT 81-16 Violation A.
Failure to Meet Record Retention Requirements 10 CFR Part 50, Appendix B, Criterica XVII states that records shall be identifiable and retrievable and that, consistent with.
applicable regulatory requirements, the applicant shall establish requirements concerning record retention such as duration location, and assigned responsibility.
The licensee Qu.ity' Assurance Manual, Section 1.2 states that the r
Omaha Public Power District connits itself to and complies with..
. the mandatory Quality Assurance program guidelines contained in.
.. WASH-1284, " Guidance on Quality Assurance Requirements During the Operations Phase of Nuclear Power Plants." WASH-1284 in Section B invokes N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants."
ANSI N45.2.9-1974 requires temporary and pemanent record storage facil: ties that shall protect records from deterioration or de-struction by fire and sets forth guidelines,. including the optional retention of duplicate records in separate, remote storage faci-lities. ANSI N452.9-1974 further requires that records shall be accurately retrievable without undue delay, and in Appendix A delineates categories of required records for design, procurement, manufacturing, installation-construction, preoperational, startup test phase, and operation phase.
Contrary to the above, the NRC inspector determined:
1.
On July 7 and 8,1981, that licensee personnel could not retrieve certain licensee records, specifically, Monthly Technical Specification Calculation Sheets (Forms FC-261) for -
1973, Quarterly Technical Specification Calculation Sheets (Forms FC-263) for 1973,1974, and 1978, and monthly film badge or TLD data processing status prior to December 1973.
2.
On July 7, 1981, that the licensee's Quality Assurance records vault did not meet the design requirements of ANSI N45.2.9-1974, Section 5.6, in that the roof was not concrete, the door was not fire rated, and one wall was ' penetrated by an air conditioner.
3.
On July 7 and 8,1981, that licensee " Fuel Inventory Reports" and " Records of Transient or.0perational Cycling ft.r Those Plant Components That Have Been Designated to Operate Safely for a Limited Number of Cycles"- (Plant Useage Data Book),
which are single permanent records, were not stored in the:
Quality Assurance records vault, or in a 2-hour rated file; but were permanently stored in a standard file cabinet in the corporate Quality Assurance office and on a desk top in the control center, respectively. These records are designated as permanent records to-be stored in the Quality Assurance re-cords-vault by licensee Quality Assurance Procedure No. 7 (QAP No. 7), Revision 1, approved August 9, 1978,'" Storage and Retention of QA Records."
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4.
On July 9,1981, that the licensee record retention program defined in Quality Assurance Procedure No. 7 (QAP No. 7),
Revision 1, approved August 9,1978, " Storage and Retention of QA Records," was found La cover only operations phase records.
In addition, the licensee was unable to retrieve installation-construction records relating to Reactor Coolant Safety Valve Response Test Procedures.
5.
On July 7, 1981, that radiographic film (for which no dupli-cate records exist) was stored in the licensee Quality As-surance records vault in wooden containers in lieu of 2-hour fire ratad file containers.
6.
On July 8,1981, that Fort Calhoun Station, Unit No.1 Stand-ing Orders C-2, Revision 6, dated September 30, 1980, " Fort Calhoun 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)," do not require temporary record storage facilities to provide protection from destruction or deterioration as specified in ANSI N45.2.9-1974.
7.
On July 7, 8, and 9, 1981, that the licensee was not micro-filming all records, and that internal audit reports stated microfilming had stopped in mid-1980 even though the licensee had stated to the NRC by letter dated May 24, 1977, as modi-fied by letter of October 10, 1977, that records would be microfilmed and that he would achieve full compliance for records storage by January 1,1978.
This is a Severity Level V violation.
(Supplement I.E.)
(8116-01)
District's Response Finding 1 l
l 1.
Corrective steps which have been taken and the results achieved.
l Over the last year, the District has been developing a Corporate l
Records Management System (RMS) that will provide a permanent fix to the problem of record retrievability. The TERA Corporation, who also installed the Commission's system, is developing and will install the District's RMS. The District is presently adding staff to support implementation of this system. Our present goal is to have the RMS operational by January 1,1982; that is, we would be ready to start logging Fort Calhoun Station (F.C.S.) records into the system. We have designated the F.C.S. records to be of highest priority for incorporation into the RMS. As part of this effort, a detailed review of all F.C.S. records required for retention would be developed to ensure inclusion in the RMS. Upon complete imple-mentation, all required F.C.S. records will be on microfilm and j
easily retrievable.
2.
Corrective steps which will be taken to avoid further violations.
See 1. above.
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%3 3.
Date when full compliance will be achieved.
Full compliance will be achieved when all F.C S entered into the RMS.
.. records are being evaluated and will be provided to the Commission 1981.
c o er 15, Finding 2 1.
_ Corrective steps which have been taken and results achieved.
The upgrade of the QA vault has been a long outstanding cation request.
modification to ensure timely resolution of the noted de modifi-ncies.
2.
_ Corrective steps which will be taken to avoi ' further violations l
The QA vault will be modified to meet the design require I
It should be noted that ANSI N45.2.9-1974 i
ments of superseded by ANSI N45.2.9-1979 has been Our initial evaluation of tre 1974and the District using the newer standard.
standard indicates that a totally new vault may be required; whereas, the 1979 criteria would be less stringent 3.
Date when full compliance will be achieved.
using ANSI N45.2.9-1979The District expects to be in full compliance b required, the QA vault upgrade coult'If ANSI N45.2.9-1974 y 28, 1982, criteria.
criteria is January 1, 1983.
not be completed prior to
_ Finding 3 1.
_ Corrective steps which have ceen taken and the results achieve determine needed revisions to reflect actual storag r er C-2 to The " Fuel Inventory Reports" are maintained by keeping d records.
records at separate locations; one copy for each report is mai uplicate tained at the corporate QA offices and one copy by th Engineer, and QAP-7 will be revised to reflect this n-e Reactor by the plant operators. Usage Data Book" is a working record and m The " Plant Therefore, the District will revise QAP-7 ccessible and Standing Order C-2 to indicate that the " Plant Usage Data Bo will be maintained in the Control Room.
2.
. Corrective steps which_ will be taken to avoid further violations.
See 1. above.
3.
_Date when full compliance will be achieved.
The District will be in full compliance by November 1
, 1981.
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- ema, 3.
Date when full compliance will be achieved.
.s Full compliance will be achieved when all F.C.S.' records are entered into the RMS. The schedule' to achieve this is presently being evaluated and will be provided to the Commission by October 15, 1981.
Finding 2 1.
Corrective steps which have been taken and results achieved.
The upgrade of the QA vault has been a long outstanding modifi-cation request. The District has revised the priority of this modification to ensure timely resolution of the noted deficiencies.
2.
Correcti se steps which will be taken to avoid further violations.
The QA vault will be modified to meet the design requirements of-ANSI N45.2.9.
It should be noted taat ANSI N45.2.9-1974 has been superseded by ANSI N45.2.9-197n r..d the District is evaluating using the newer standard. Our-nitial evaluation of the 1974 standard indicates that a t-new vault may be required; whereas, the 1979 criteria wc sid be less stringent.
f 3.
Date when full compliance will oe achieved.
The District expects to be in full compliance by February 28, 1982, using ANSI N45.2.9-1979 criteria.
If ANSI N45.2.9-1974 criteria is required, the QA vault upgrade could not be completed prior to January 1, 1983.
Finding 3 1.
Corrective steps which have been taken and the results achieved.
The District is presently reviewing QAP-7 and Standing Order C-2 to determine needed revisions to reflect actual storage of records.
The " Fuel Inventory Reports" are maintained by keeping duplicate l
records at separate locations; one copy for each report is main-l tained at the corporate QA officer and one copy by the Reactor i
Engineer, and QAP-7 will be revised to reflect this. The " Plant l
Usage Data Book" is a working record and must be readily accessible l
by the plant operators. Therefore, the District will revise QAP-7 j.
and Standing Order C-2 to indicate that the " Plant Usage Data Book" will be maintained in the Control Room.
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l 2.
Corrective steps which will be taken to avoid further violations.
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See 1. above.
I 3.
Date when full compliance will be achieved.
The District will be in full compliance by November 1,1981.
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l Findino 4 District Comment 1
The District does not agree that only operational phase records are covered by Quality Assurance Procedure No. 7 (QAP No. 7).
It was prepared to assure compliance with ANSI N45.2.9-1974, " Requirements for Quality Assurance Records for Nuclear Power Plants," and applies to records of installation-construction as well as operations phase, as specified in Section 1.2, " Application."
The inspector was apparently concerned that Appendix A to QAP No. 7.
addresses only the operations phase records. Appendix A, "Tabuistion of Record Types," does address only operations phase records, as ti.2 Dis-trict believes it should. QAP No. 7 provides procedures to De followed in today's environment, which is the operations phase. All records pre-sently being generated at F.C.S. are operations related and Appendix A provides a list of all appropriate record types. QAP No. 7 provides guidance for District personnel to ident'fy records that must be handled as 4A records. Accordingly, this procedure is oriented towards the operations phase because these are the records being generated. QAP No.
7 as presently written meets the criteria of ANSI N45.2.9-1974. There-fore, the District believes QAP No. 7 provides assurance that all records will be properly maintained.
1.
Corrective steps which have been taken and results achieved, With regard to the inability to retrieve installation-construction records relating to Reactor Coolant Safety Valve Response Test Procedure, please refer to the Finding 1 response.
2.
Corrective steps which will be taken to avoid further violations.
See response to Finding 1.
The incorporation of these records into the RMS will ensure retrievability.
3.
Date when full compliance will be achieved.
See response to Finding 1 and comment above.
Finding 5 1.
Corrective steps which have been taken and retetts achieved.
The District is upgrading the QA vault as detailed in the Dis-trict's response to Finding 2.
2.
Corrective steps which will be taken to avoid further violatici s.
The QA vault will be upgraded to meet ANSI N45.2.9 criteria and the wooden storage boxes will be removed from the QA vault.
3.
Date when full compliance will be achieved.
The District will be in full compliance when the QA vault upgrade is completed, as detailed.in our response to Findir,9 2.
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Finding 6 1.
Corrective steps which have been taken and results achieved.
Standing Orders C-2 and C-3 are being revised to require that temporary record storage facilities provide protection from de-struction or deterioration as specified in ANSI N45.2.9-1974.
Additionally, the District is evaluating storage facility / equipment needs to ensure the availability of adequate qualified temporary storage space.
It should be noted that the implementation of the RMS will significantly reduce the volume of temporary records.
2.
Corrective stept.hich will be taken to avoid further violations.
Additional qualified storage space will be obtained as needed.
3.
Date when full compliance will be achieved.
The District will be in full compliance by January 1,1982.
Finding 7 1.
Corrective steps which have been taken and results achieved.
The RMS presently being developed will include microfilming of all plant records. This system will be implemented as detailed in the District's response to Finding 1.
2.
Corrective steps which will be taken to avoid further violations.
See 1. above.
3.
Date when full compliance will be achieved.
See response to Finding 1.
Violation B.
Failure to Retain Records Required by Technical Specifications Licensee Technical Specification 5.10.2 requires that " records of radiation exposure for all individuals entering radiation control areas" and " records of gaseous and liquid radioactive material released to the environs" shall be retained for the duration of the Facility Operating License.
Contrary to the above, on July 7, 1981, the licensee could not retrieve the following licensee records of individual's radiation exposure and gaseous radioactive materials released to the anvirons:
1.
Pencil Dosimeter Log (Form FC-229) for 1973 E.
Film Badge /TLD Reports prior to December 1973 4
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Waste Gas Releases (Form FC-252) for 1974 This is a Severity Level V violation.
(Supplemcat I.E.)
(3116-02)
District's Response 1.
Corrective steps which have been taken and results achieved.
The plant staff conducted a detailed search of plant locations for the missing records. The missing Pencil Dosimeter Log and Waste Gas Release forms were located and filed. We believe the Film Badge /TLD Reports may be permanently lost and a memorandum will be added to the file records to reflect this status.
2.
Corrective treps which will be taken to avoid further violations.
The implementation of the RMS will prevent similar problems in the
' future 3.
Date when full compliance will be achieved.
The District will be in full compliance upon full implecentation of the RMS, as discussed in our response to Finding 1.
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