ML20135H924

Insp Rept 50-298/85-21 on 850715-19.Violation Noted:Failure to Have Design Control Procedures for Engineering Input & for Verification of Completion Closure

ML20135H924
Person / Time
Site:	Cooper
Issue date:	08/28/1985
From:	Boardman J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135H911	List: ML20135H910 ML20135H924
References
50-298-85-21, NUDOCS 8509250016
Download: ML20135H924 (9)

See also: IR 05000298/1985021

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/85-21 License: DPR-46

Docket: 50-298

Licensee: Nebraska Public Power District (NPPD)

P.O. Box 499

Columbus, Nebraska 68601

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: Cooper Nuclear Station, Nemaha County, Nebraska

Inspection Conducted: July 15-19, 1985

Inspector: -

Dzw Wh [hayY29, /j(1

J. .' Boardman, Reactor Inspector Vate '

0 ations Section, Reactor Safety Branch

Approved: .d f@l' M , d M $'/2S/'8f

D. M. Hunnicutt, Chief, Operations Section, Ddte '

- Reactor Safety Branch

Inspection Summary

i Inspection Conducted July 15-19, 1985 (Report 50-298/85-21)

Areas Inspected: Routine, unannounced inspection of the quality assurance

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program, records program, offsite support staff, document control, and

follow-up.on previous inspection findings. The inspection involved 36

inspector-hours onsite by one NRC inspector.

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Results: Within one area inspected (design changes) one violation was

identified (failure to have design control procedures for engineering input and

for verification of completion closure), Within the other five areas

inspected, no violations or dev ations were identified.

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DETAILS

1. Person's Contacted

Principal Licensee Personnel

• L. G. Kuncl, Assistant General Manager Nuclear

'*J. M. Pilant, Technical Staff Manager Nuclear Power Group

+P. V. Thomason, Division Manager Nuclear Operations

• R. E. Wilbur, Division Manager Nuclear Services

• G.~A. Trevors, Division Manager Quality Assurance (QA)

+J. M. Meacham, Technical Manager, CNS

+D. A. Witman, Technical Staff Manager, CNS

• J. Weaver, Nuclear Licensing & Safety Manager

• K. C. Walden, Nuclear Engineering Supervisor, Instrumentation & Controls

• K. Done, Nuclear Engineering Supervisor, Mechanical & Civil

S. D. Anderson, Records Manager

+D. Norvell, Acting Maintenance Manager, CNS

• J. S. Larson, Senior QA Engineer .

+C. R. Goings, Regulatory Compliance Specialist, CNS

+G. Horn, O&M

+G. E. Smith, Senior QA Specialist

The NRC inspector also interviewed other plant and general office

personnel, including engineering, administrative, and clerical.

• Denotes presence at exit interview held July 17, 1985.

+ Denotes presence at exit interview held July 19, 1985.

2. Followup on Previously Identified Findings

a. (0 pen) Unresolved Item (50-298/8229-03) - Compliance of CNS records

vault with regulatory requirements and industry standards. This

concern was made an unresolved item pending a complete review of its

design and construction. This unresolved item was followed up during

NRC Inspection Report 50-298/83-26, Section 7, which identified a

specific problem with CNS area designated " Document Storage No. 1."

The licensee has transferred the majority of older records to the

corporate storage vault in Columbus, Nebraska. He has evaluated the

development of a dual records system, and has decided to construct a

new site vault in lieu of having a dual records system. The proposal

for the vault is being submitted in the NPPD fiscal year 1986 budget.

The new site vault will be inspected upon its completion for closure

of this item.

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b. (Closed) Unresolved Item (50-298/8519-03) - Closure of Design

Changes. This item was' originally identified as a concern about

document control of contractor and subcontractor drawings, sketches,

and design data to assure their incorporation on CNS as-built

drawings.

During this inspection it was determined that the management control

for this activity was the NPPD Station Design Change as specified in

Procedures NEPD-10, " Station Design Changes," Revision 9, dated

June 18, 1985, and CNS Procedure 3.4, " Station Design Changes,

Revision 1, dated May 31, 1985. These procedures contain controls to

verify completion closure of design changes. These controls include

incorporation of all changes on NPPD Records Administration

Department.(RAD)controlleddrawings. According to licensee

personnel, comparable design change package closure controls have

always been a procedural requirement.

The' specific area of concern originally . identified by-the NRC

inspector was the seismic restraints for cable conduits and trays

installed as part of the LPCI modification, Design Change 76-2,

accomplished in 1977.

Resolution of the Specifically Identified Problem

During this inspection, the licensee identified to the NRC. inspector

a general problem with loadings on safety-related cable hangers in

the cable spreading room, and the possibility that a more widespread

problem exists outside the cable spreading room with loadings on

seismic supports for safety-related cable hangers.

This problem was documented in licensee notes on a meeting held at

the NPPD Columbus general office on June 27, 1985. These minutes

provide the licensee's program to resolve the subject concern

relative to cable spreading room seismic cable hangers. The target

completion date for having all hangers analyzed, and design changes

approved, but not implemented is December 1,-1986. At that time,

NPPD will assess whether other areas at CNS need to have their "as

built" condition verified for cable . seismic hangers.

No Generic Program Plan Projected to Verify "As Built Design Changes"

No licensee program was planned to evaluate the "as built" condition

for design changes other than cable seismic restraints. The NRC

inspector determined from licensee personnel that no NPPD general

office or CNS Quality Assurance (QA) Audit of Design Changes had ever

identified a programmatic problem in the: completeness, adequacy, and

correctness of design change package closures. CNS QA had not'

audited this attribute, Corporate QA included it but without

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definitive detailed checklists. Recently CNS QA had begun an

informal increased surveillance of such closures.

Review of Selected Design Changes

The NRC inspector selected, and reviewed, two closed design change

packages which had been identified in NRC Inspection

Reports 50-298/83-26 and 50-298/84-21 as not having had offsite

review committee (SRAB) review.

Design Change 77-130

The NRC inspector reviewed one closed package for Design

Change 77-130 " Blind Flanges on Scram Discharge," which was

accomplished in 1982. The applicable design specification was

USAS B31.7-1969 " Nuclear Power Piping." The following apparent

nonconformances were noted:

(1) The flanged, gasketed joints had no design bolt-preload

specified, or installation preload recorded. Under loading or

overloading of bolts or gaskets can degrade system integrity.

(See ASME 1977,Section III, Division I, Article XIII .1000).

(2) The specified bolting was ASTM A193 (bolts) and A194 (NUTS),

which were approved by USAS B31.7-1969. Warehouse withdrawal

requisitions show Grade 8 (SAE) bolts and nuts were used. These

i Grade 8 bolts and nuts are not approved by B31.7, nor by other

documentation.in the design change data package. The

ct. tification of the bolting material in accordance with B31.7,

Section 1-723.1.2, was not in the ' completed package (or in the

purchase order), though retention for the life of the plant is

required by USAS B31.7, Section 700(e).

Design Change 78-016

The second closed package reviewed by the NRC inspector was for

Design Change 78-016, for replacement of an 8" blind flange en the

bottom of the torus with flanged and welding fittings, an 8" posi-sea 1

valve, an 8"x6" reducer, and a 3" blind flange. Loss of this assembly

during a design base accident could result in loss of all water in

the torus. The following were apparent'nonconformances:

The existing flange attached to' the torus penetration was designed

for use with an 0-ring, USAS B31.7-1969 and ASME BPV Code 1977,

Section III, both specify USAS ( ANSI). Specification B16.5 " Steel Pipe

Flanges and Flanged Fittings." B16.5 (1973 and 1977) specify that

flanges for spiral-wound metal asbestos ("flexitallic") gaskets be ,

raised face with either a serrated-concentric

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or serrated-spiral finish. No engineering evaluation of this

nonconformance was found by the NRC inspector.

Preload for bolting of gasketed joints was not specified, as was

discussed with Design Change 77-130.

Bolting material was specified as A-193 (bolts) and A194 (Nuts),

per SA 350. Material should have been specified SA193/SA194. There

was no warehouse withdrawal requisition showing the nuts, or the.8"

and 6" spiral-wound, metal-asbestos gaskets used.

Torus Drain Flanges

By telecon on August 2, 1985, the NRC inspector asked CNS engineering

personnel to reverify the design of the replacement blind flange, and

the material of the replacement 0-ring installed by NPPD contract 82-18

with Dravo Utility Constructors, Inc. on the other torus drain

connection. A replacement blind flange was ordered for that job

without specifying surface finish, or specifying the dimensions of

one of the two 0-ring grooves. The flanges were apparently ordered

with incorrect 0-rings (Nitrile in lieu of silicone rubber).

Verification of the design, and actual, balt preload was also requested.

Summary and Conclusion

As discussed above, licensee Procedures NEDP-10 and CNS Procedure 3.4

contain controls to verify completion closure of design changes.

These procedures did not contain adequate specificity to prevent the

occurrence of such nonconformances and concerns as were found by the

NRC inspector, and had been identified by the licensee as early as

1983 in the case of seismic cable hangers in the cable spreading

room. As presently structured, licensee audits had not identified

this problem area. Licensee engineering groups had not issued an NCR

on the identified general problem of seismic cable supports.

The existence of licensee procedures having inadequate specificity to

. assure compliance of all design and verification activities involved

in safety-related CNS design changes was the root cause of the

identified problems. verification of completion closure of design

changes, and in engineer.ing accomplishment of requirements, such as

bolt preload. 10 CFR Part.50, Appendix B, Criterion V, requires that

all activities affecting quality, shall be prescribed by documented -

procedures which shall include ~ appropriate quantitative and qualitative

acceptance criteria for determining that important activities have

been accomplished satisfactorily.

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Failure to have procedures covering all activities relating to design

changes is a violation of 10 CFR Part 50, Appendix B, Criterion V.

(50-298/8521-01)

3. Quality Assurance Program Annual Review

This inspection was to determine that revisions to the licensees

implementing procedures are in conformance with the latest approved

docketed QA Program, and that the program implemented was in conformance

with regulatory requirements, commitments, and industry guides and

standards.

In conjunction with this inspection, the NRC inspector reviewed the

offsite review committee, the licensees records system, document control, ~

and, as independent inspection effort, technical adequacy of design

changes, and design change package closures for completeness, and freedom

from apparent errors.

The NRC inspector reviewed the following licensee QA Procedures:

Quality Assurance Instructions (QAls)

Procedure Procedure

Number Title of Procedure Revision Date

QAI-1 Guidelines for Preparation and Issuance of 8 10/05/83

Quality Assurance Documents

QAl-2 Controlled Distribution of Quality Assurance 13 11/21/83

Documents

QAI-3 Definition of Terms 7 05/31/84

QAI-4 General ~ Guidelines - Quality Assurance 12 01/30/84

Surveillance _

, QAI-5 General Guidelines - Quality Assurance 18 05/02/84

- Audits

QAI-6 Personnel Qualifications and Training for QA 10 10/05/83

Assignments

QAI-7 Quality Records Retention, Storage, and 15 04/24/85

Disposition

QAI-10 Non-Conformance Reporting, Issuance, Control 10 06/01/84

! and Corrective Action

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Procedure Procedure

Number Title of Procedure Revision Date

QAI-11 Delegation of Specific Responsibilities 9 11/21/83

-QAI-12' Guidelines for Audit Frequency and 12 10/05/83

Scheduling

QAI-13 Requirements for QA Review of Quality- 8 10/05/83

Related Documents

QAI-14 Disposition of Non-Conformance Materials, 5 10/05/83

Parts and Components

QAI-15 Responses to NRC Publications- 8 10/22/82

QAI-16 Supplier Approval 10 04/23/85

QAI-17 Guidelines for Indoctrination & Training -2 12/28/83

of Quality Assurance Personnel

QAI-18 Stop Work. 0 06/12/84

Quality Assurance Plans (QAPs)

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Number Title of Procedure Revision Date

QAP-001 Restart Test Program 3 03/06/85

QAP-200 Station Operation 7 12/07/84

i QAP-300 Refueling, Fuel Storage and Shipment- 5 08/16/84

QAP-600 Surveillance Testing 6 07/25/84

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QAP-1700 Design Changes 6 03/15/85

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QAP-2200 SRAB Activities 1 03/06/85

No' violations or deviations were identified during the review. The NRC

i inspector discussed with licensee personnel the fact that QAI-9,

" Guidelines for Establishing Quality Classifications of Components and

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Materials," dated May 4,1980, appeared to need updating to specifically

address Environmental Qualified (EQ) components and parts, and to

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-incorporate controls to support commitments to NUREG-1000, " Generic -

Implications of ATWS Events at the Salem Nuclear Power Plant," subsequent

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4. Licensee Records Program

This inspection was to review the licensee's program for control of

records for compliance with Regulatory requirements, conunitments, and

industry guides and standards.

During this inspection, the following licensee procedures were reviewed:

Procedure Procedure

Number Procedure Title Revision Date

RADP-01 -Record Section Operating Procedure 4 08/10/84

RADP-02 Drawing Control Procedure 4 12/12/84

RADP-05 Vault Control and Security 3 10/15/84

RADP-06 Preparation, Review and Approval of 5 01/10/85

Procedures

RADP-07 Receipt and Disposition of Documents 5 06/05/85

RADP-09 Personnel Training in RAD 2 04/17/85

RADP-10 Vendor Manual Control Procedure 0 12/07/84

CNS 1.9 Control and Retention of Records 2 05/06/85

For discussion of the CNS records storage vault, see paragraph 2,

unresolved item (50-298/8229-03).

Temporary record storage was not reviewed during this inspection, but will

be reviewed during a subsequent inspection.

5. Document Control Program

During followup of NRC Inspection Report 50-298/85-19, the NRC inspector

identified that CNS personnel had ignored drawing classifications assigned

by the NPPD Columbus general office (violation 50-298/8519-01). These

used for safety-related

classificationsshowedthatcertaindrawingsbeing(void,

systems, structures, and components were archival superseded,

deleted or information only) or construction drawings (not certified or

verified as "as built"). Some of the archival and contruction drawings

were control room drawings.

At the beginning of this inspection, the NRC inspector discussed this

concern relative to the acceptability of control room drawings and their

acceptability to use in response to operational and unusual events, and

accidents.

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The licensee committed to verify control room drawings necessary for the

safety of plant operations prior to plant start-up.

6. Licensee Offsite Support Staff

This inspection reviewed offsite engineering, QA and records

administration. In addition to QA procedures identified in paragraph 3,

and Records Administration procedures detailed in paragraph 4 of this

report, the following Nuclear Engineering procedures were reviewed for

compliance with regulatory requirements and industry standards:

Procedure Revision

Number Procedure Title Number Date

NEDP-01 Preparation, Review, Control and 6_ 11/01/84

Issuance of NED Procedures

NEDP-03 Preparation of NPPD Design Criteria 1 01/11/83

(B0DD)

NEDP-07 Preparation of NED Specifications 2 05/07/85

NEDP-08 Preparation of Drawings for Cooper 1 08/13/82

Nuclear Station

NEDP-09 Station Safety Evaluations 1 10/02/84

NEDP-10 Station Design Changes 9 06/18/85

NEDP-14 Document and Correspondence 2 10/21/83

Control

The NRC inspector reviewed Audit G84-04, QAP 1700 " Design Control,"

performed August 27 through September 26,194, and Audit G84-05, QAP-1400

" Procurement Control, performed November 19 through December 11, 1984.

Audit G84-04 required six followup audits without final closure, while

Audit G84-05 had required four without final closure. Discussions with

licensee personnel. indicated that these were isolated cases and that the

underlying problem had been corrected.

No violations or deviations were identified during the review.

7. Exit Interview

Exit interviews were held on July 17, (at Columbus) and July 19,1985,(at

CNS) with the personnel denoted in paragraph 1 of this report. At these

meetings the scope of the inspection and findings were summarized.

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