ML20058A272

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IE Inspec Rept 50-285/78-12 on 780917-20 During Which 2 Items of Noncompliance Were Noted:Failure to Follow Procedures Re Records Audits & Failure to Follow Tech Specs Re Personnel Qual Audits
ML20058A272
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 10/12/1978
From: Boyter N, Johnson W, Madsen G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058A267 List:
References
50-285-78-12, NUDOCS 7811280062
Download: ML20058A272 (7)


See also: IR 05000285/1978012

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U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF IllSPECTION Atl0 ENFORCEMENT

REGION IV

Report flo. 50-285/78-12

Docket flo. 50-285

License flo. DPR-40

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Licensee: Omaha Public Power District

1623 Harney Street

Omaha, Nebraska 68102

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Facility flame: Fort Calhoun Station, Unit 1

Inspection At: Fort Calhoun Station, Blair, Nebraska

Inspection Conducted: September 17-20, 1978

Inspectors:

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'W. D. Johnson, Reac' tor Inspector

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10[12 /~19

N. C. Royter, Reactor Inspector

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Approved By:

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r./78

~ G. L. Madsen, Chief, Reactor Operations

Date

and fluclear Support Branch

Inspection Sunwary

Inspection on September 17-20,1978 (Report flo. 50-285/78-12)

Areas Inspected: Routine, unannounced inspection cocrencing on a weekend

backshif t of review cccnittee activities, internal audits, plant conditions

observed during a plant tour; and follow up on open items, licensee event

reports, and items of noncompliance. The inspection consisted of 25

inspector-hours on-site and 18 inspector-hours at the corporate office by

two (2) NRC inspectors.

Results: Of the four areas inspected, no apparent items of noncompliance or

deviations were identified in three areas and two apparent items of noncom-

pliance (infractions) were identified in one area (Failure to adhere to

procedures - paragraph 3.b and 3.c; and failure to ccmply with Technical

Specifications requirement for one Safety Audit and Review Consnittee audit -

paragraph 3.a).

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DETAILS

1.

Persons Contacted

R. L. Andrews, Plant Manager

  • J. Bentzinger, Acting QA Manager

L. J. Dugger, Reactor Engineer

J. J. Fisicaro, Supervisor, Administrative

F. F. Franco, Supervisor, Chemical & Radiation Control

J. F. Gass, Training Coordinator

W. G. Gates, Supervisor, Operations

J. M. Gloshen, QA Engineer

  • T. P. Harding, Section Manager, Technical Services

R. L. Hyde, QA Inspector

R. F. Johnston, Shift Supervisor

D. W. Jones, Supervisor, Maintenance

  • W. C. Jones, Section M1 nager, Operations

L. T. Kusek, Supervisor, Technical

M. J. McFadden, Plant Engineer

R. F. Mehaffey, Electrical Engineer

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  • K. J. Morris, Manager, Administrative Services

G. R. Peterson, Supervisor. I&C and Electrical

  • S. C. Stevens, Manager, Operations, Technical Support Services

F. A. Thurtell, Division Manager of Envirormental & Regulatory Affairs

J. Woods, QA Auditor

  • Denotes those attending the exit interview.

2.

Review Comnittee Activities

The inspector reviewed the activities of the Plant Review Committee

(PRC) and the Safety Audit and Review Committee (SARC) to ascertain

whether they are conducted in conformance with the requirements of

the Technical Specifications. Requirements checked included meeting

frequency and quorum, test and experiment review, noncompliance

review, Technical Specification change review, facility operations

review and reportable occurrence review. No items of noncompliance

or deviations were identified in this portion of the inspection.

3.

Internal Audits

The inspector reviewed the licensee's internal audits conducted from

October 1977 to the present to verify that they were conducted in

accordance with the licensee's Technical Specifications, Quality

Assurance Manual, and Quality Assurance Procedures (QAP's) 14,16,

17 and 18.

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a.

Safety Audit and Review ~Corrmittee~ (SARC) Audits

The inspector reviewed the SARC Audit reports for 1977 and 1978

and the records of audits for 1976. The Technical Specification 5.5.2.8.b requires that the SARC perfom an audit of the per-

famance, training, and qualification of the entire facility staff

at least once per year. This specification, at a minimum,

requires that at least two of these audits should have been com-

pleted since January 1976. Contrary to this requirement, this

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audit was perfomed only once (January 1977) during the period

from January 1976 to the present. The licensee's failure to

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adhere to the requirements for an annual SARC audit of perfomance,

training, and qualification of the facility staff constitutes an

apparent item of noncompliance with Section 5.5.2.8.b of the

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Technical Specifications.

b.

Quality Assurance Audits

The results of the inspector's review of the reports and records

of the Quality Assurance Audits prescribed in Quality Assurance

Procedure (QAP) 16 are as follows:

(1) Section 3.1 of QAP 16 requires an internal audit on Handling

and Storage of QA Records on an annual basis, and an internal

audit on Fuel Handling / Fuel Management during refueling

periods. The review of records provided documentation of

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completion of the audit on Handling and Storage of QA Records

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in August 1976 and February 1978, but not in 1977. The

licensee's failure to perfom this Quality Assurance Audit

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on Handling and Storage of QA Records in 1977 as required by

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QAP 16 is an apparent item of noncompliance with Criterion V

of Appendix B to 10 CFR 50 as amplified by Section 17.5 of the

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licensee's f1RC approved QA Program. fleither the audit plan

nor audit report could be located for the audit of fuel

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Handling / Fuel Management in 1977. A licensee representative

stated that the audit material had been misplaced and will be

located. This item has been identified as an unresolved item

(Unresolved Item 7812-1).

(2) The review of responses to the Quality Assurance Audits was

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hampered by the lack of adequate records and lack of unifom

methods of response to the audits. Section 3.8.1 of QAP 17

requires a written response to adverse audit findings within

30 days after receipt of the report. The following audit

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reports had no record of responses but a ccmputer printout

listed the status of each audit as " Corrective Action Pending":

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4-78 Surveillance Testing / Technical Specifications,

February 28, 1978

11-78 Calibration Control, April 13, 1978

21-78 Product Control / Receiving Inspection,

June 7, 1978

These itsted audit reports contain instructions to respond

in 30 days to the listed QA Deficiency Reports which were

prepared on deficient items identified by the audit.

According to a licensee representative, the response may

be either a letter written in response to the report or a

written response on the space provided on the QA Deficiency

Report fom. The instructions for use of the Deficiency

Report in Section 3.6.6 of QAP 15 prescribes the use of the

fom itself for response and followup. Therefore, the

expected means of response, verification of timeliness of

responses, and the means of maintaining adequate records of

the status of audit responses and followup actions were not

clear to the inspector. A licensee representative agreed to.

review the administration of followup and correction of QA

audit deficiencies with the objective of increasing the

efficiency of the system. This is an open item (285-254).

c.

Operational Mini-Audits

The operational mini-audits, as described in QAP-14, are being

perfomed as specified and the results are well documented; but

it appears that the responses and followup on deficiencies are

not always adequate or timely. The means of recording responses

varied from letters to vague notes penciled in the margin of the

audit report. Many items appear to be overdue for resolution as

illustrated by the following:

3/25/75

Rusted Component Cooling Lines to CECM's

12/21/77 Containment Integrity & Containment Heating Cooling /

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Ventilation Labeling

12/22/77 Containment Heating Cooling / Ventilation Labeling

11/2/77

Welded 2" Nipple to AC-10C Outlet

4/3/78

Quench Tank Pressure

5/22/78

PRC-M0 Procedure Review / Retention

Section 3.5.3 of QAP 14 requires that a list of outstanding QA

Form No. 4's (mini-audit deficiency reports) be attached to the

monthly Mini-Audit Sumary Report. The Mini-Audit Sumary

Reports for the months February-June 1978 do-not contain

complete lists of all of the appropriate outstanding mini-audit

deficiencies for the month of the report. As an example, the

June 1978 sumary dated July 6,1978, had no outstanding

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deficiencies listed. The licensee's failure to list all out-

standing QA Form 4's in the monthly Mini-Audit Sumary Reports

for February through June 1978 as required by QAP-14 is an

apparent item of noncompliance with Criterion V of Appendix B

to 10 CFR 50 as amplified by Section 17.5 of the licensee's NP.C

approved QA program.

4.

Preparation for Refueling

The inspector reviewed the receipt inspection packages for the new

fuel shipments received on August 18 and 23,1978. Fuel transfer

and core reconstitution and verification procedures were not yet

completed by the licensee. These will be reviewed during a future

inspection. No items of noncompliance or deviations were identified.

5.

Review of Licensee Event Reports (LER's)

Certain LER's were reviewed to ascertain that reporting requirements

were met, that appropriate corrective action was taken, that licensee

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procedures were followed in the review and evaluation of the event,

and to determine the safety of continued operations. The LER's listed

below were reviewed upon receipt in the Regional Office and followed up

on site during this inspection.

LER Number

Subject

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78-17

Diesel Generator

78-22

Diesel Generator

78-24

Diesel Generator

Three reports were reviewed in the Regional Office and no on-site follow

up was conducted. These were numbered 78-13, 78-15 and 78-21. No items

of noncompliance or deviations were identified.

6.

Follow Up on Open Items

(Closed)OpenItem 285/209 (paragraph 6.a Inspection Report 77-01):

Battery room ventilation

Amendment No. 40 to Facility Operating

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License No. DPR-40 for Fort Calhoun Station includes a requirement that

the battery rooms be equipped with air flow monitors and that the

exhaust ducts be modified to prevent the accumulation of hydrogen at

the ceiling. These modifications are to be implemented by December 1978.

(0 pen) Open Item 285/217 (paragraph 5.b, Inspection Report 77-02):

Containment Spray System nozzle testing

Licensee memorandum

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TS-FC-78-356 was reviewed during this inspection. The inspector will

review the engineering evaluations and calculations which formed the

basis for this memorandum during a future inspection.

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(Closed)OpenItem 285/231 (paragraph 4, Inspection Report 77-13):

Revision of SP-flFR-1 and flMA-1

Procedure Change flo. 3470 removes

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the checklists from SP-flFR-1 and refers to those in f1MA-1.

(Closed) Open Item 285/241 (paragraph 3.b, Inspection Report 77-21):

Development of specific fire fighting procedures

Amendment flo. 40

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to facility Operating License fio. DPR-40 for Fort Calhoun Station

includes a requirement that the licensee develop procedures and the

strategies to fight fires in all safety-related areas and areas present-

ing a hazard to safety-related equipment. The completion date for this

item is listed as June 1979.

(0 pen)OpenItem 285/244 (paragraph 6.c, Inspection Report 78-02): Lack

of an administrative system to assure proper and timely revision of

plant procedures in response to Technical Specification and Design

Changes

The licensee has made no apparent progress on this item.

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(Closed)OpenItem 285/246 (paragraph 6, Inspection Report 78-04):

Revision of OI-ES-1-CL-A to include new channels added by DCR 74A-127

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Procedure Change 3307 adds the new level channels for the Safety

Injection tanks to the checklist.

7.

Follow Up on Items of Nonccmpliance

(0 pen) floncompliance (Infraction 1.b, Inspection 77-10): Failure to file

completed design change records in the site records vault

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to prevent further noncompliance which is still incomplete involves the

revision of QAP-7 and 50 C-2 to resolve conflicts between the two

documents with respect to which records are to be stored in the QA

records vault. Revision 1 of QAP 7 was issued on August 7,1978. A

licensee representative stated that the revision of 50 C-2 would be

completed by Septaber 30,1978.

(0 pen) Noncompliance (Infraction 1

Inspection 78-04): Failure to

perfom and document liquid penetrant examination of welds perfomed

under DCR 77-84, SRDC0 77-23

One of the corrective steps to avoid

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further noncompliance involved reminding Quality Assurance and Quality

Control personnel of the necessity for proper documentation of procedure

changes as outlined by Standing Order G-30.

Licensee representatives

were only able to locate training records indicating that one QC person

had received training recently in procedure change methods. The required

training for the other QA and QC personnel has not yet been perfomed

and/or documented. The inspector will review this item during a future

inspcction.

(Closed) floncompliance (Deficiency 1, Inspection 78-06): Failure to

report failure of VA-80A and VA-808

The inspector discussed the

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licensee's response to this item with a licensee representative and had

no further questions.

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(0 pen) Noncompliance (Deficiency 2, Inspection 78-06): Failure to

use required sample size for trisodium phosphate dodecahydrate test

ing

Corrective steps to avoid further noncompliance included

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weighing sample baskets in advance and tagging them with gross and tare

weights. A licensee representative indicated f. hat the above steps

would be included in ST-CHEM-2-F-3, but this pr ocedure had not yet

been revised.

(Closed) Noncompliance (Infraction 3, Inspec+!6n 78-06): Failure to

maintain the required water inventory in the e:ergency feedwater

storage tank

Corrective action for this item included revising

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the Surveillance Log (FC-71) to require recording tank level each

shift and revising 01-RC-3 to add a step and a precaution to insure

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that tank level is adequate prior to heating the RCS above 3000F.

(0 pen) Noncompliance (Infraction 4, Inspection 78-06):

Failure to

log required parameters on Control Room Log Sheet when the plant per-

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formance ccmputer log typewriter was inoperable

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corrective steps to avoid further noncompliance involved the revision

of Standing Order 0-24. This revision had not yet been performed.

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Plant Conditions Observed'Ouring a Plant Tour

Upon arrival at the site during a weekend backshift, the inspector

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observed control room operations, manning and indications; and toured

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accessible areas of the auxiliary building outside the radiation

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controlled area. No items of noncompliance or deviations were

identified.

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Unresolved Items

Unresolved items are matters about which more information is required

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in order to ascertain whether they are acceptable itens, items of

noncompliance, or deviations. An unresolved item, disclosed during

the inspection, is discussed in paragraph 3.b.

10.

Exit Interview

The inspectors met with licensee representatives (denoted in paragraph

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1) on September 20, 1978. At this meeting, the inspectors summarized

the scope and findings of the inspection,

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Subsequent to the inspection, the inspector contacted a licensee

representative by telephone to inform him that the terms " annual" or

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" yearly" are interpreted by Region IV to mean each twelve months plus

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or minus two months.

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