ML20135H924
| 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: |
| References | |
| 50-298-85-21, NUDOCS 8509250016 | |
| Download: ML20135H924 (9) | |
See also: IR 05000298/1985021
Text
.
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
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.
4
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.
we m m ik.
,
-
r
l
l
l
.,
.
l
l
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.
,
L
.
3
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
.
-
-
.-
W
'
.
4
definitive detailed checklists.
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
Grade 8 bolts and nuts are not approved by B31.7, nor by other
i
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
~
i
- - .
- -
.
^ - '
.
5
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.
.
-
.-
,.
,
c
,
.
'
.
6
I
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
l
w
'
.
7
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)
Procedure.
-
Procedure
Number
Title of Procedure
Revision
Date
QAP-001
Restart Test Program
3
03/06/85
QAP-200
Station Operation
7
12/07/84
QAP-300
Refueling, Fuel Storage and Shipment-
5
08/16/84
i
QAP-600
Surveillance Testing
6
07/25/84
QAP-1700
Design Changes
6
03/15/85
,
!
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
Materials," dated May 4,1980, appeared to need updating to specifically
,
address Environmental Qualified (EQ) components and parts, and to
-incorporate controls to support commitments to NUREG-1000, " Generic -
,
Implications of ATWS Events at the Salem Nuclear Power Plant," subsequent
,
to the present outage. .
!-
4
-
)
.
8
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, superseded,
systems, structures, and components were archival
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.
i
1
-
.
9
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.
Y