ML20137F156
| ML20137F156 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/21/1985 |
| From: | Boardman J, Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20137F135 | List: |
| References | |
| 50-298-85-19, NUDOCS 8508260161 | |
| Download: ML20137F156 (6) | |
See also: IR 05000298/1985019
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-298/85-19
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: June 10-14, 1985
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Inspector:
[. Mw/
f(//S~/PT
J. R. Boardman, Reictor Inspettor
Date.
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k Special Projects and Engineering Section
Reactor Project Branch 1
Approved:
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J. 7atflon,,fChief, Pr& ject'Section A,
Date'
ReattoA Pro 3ct Branch 1
Inspection Summary
Inspection Conducted June 10-17, 1985 (Report 50-298/85-19)
Areas Inspected:
Routine, unannounced inspection of the licensee's document
control program and QA/QC administrative program. The inspection involved -
36 inspector-hours onsite by one NRC inspector.
Results: Within the one area inspected (document control), two violations
were identified (failure to have CNS' procedures for control of superseded,
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void, and deleted drawings, and of construction drawings not approved or
certified as "as built," and failure to properly secure safeguards drawings).
Within the one area (QA/QC administrative program), no violatio'ns or deviations
were identified.
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DETAILS
1.
Persons Contacted
- P. V. Thomason, Division Manager Nuclear Operations
- J. M. Meacham, Technical Manager, CNS
D. A. Whitman, Technical Staff Manager, CNS
L. L. Roder, Administrative Services Manager, CNS
- E. M. Mace, Plant Engineering Supervisor, CNS
D. Norvell, Acting Maintenance Manager, CNS
- C. R. Goings, Regulatory Compliance Specialist, CNS
The NRC inspector also interviewed other plant personnel, including
engineering, administrative, and clerical.
- Denotes those present during the exit interview.
2.
License Document Control Program
The NRC inspector interviewed personnel and reviewed licensee procedures
and documents to ascertain if the licensee was implementing a document
control program in conformance with regulatory. requirements, FSAR
commitments and plant Technical Specifications.
a.
Control of Drawings Identified by NPPD Records Administration
Department (RAD) as Archival (Status 2-Void, Superseded, Deleted
or Information Only) or Construction (Status 3-Not Final, Certified,
or As-Built
The NRC inspector reviewed the NPPD official status of CNS drawings.
Based on NPPD procedure RADP-02, Revision 04, dated December 12,1984,
" Drawing Control Procedure," all drawings are assigned one of the
following status codes:
FINAL (Status 1)
1.
As-built
2.
Certified as constructed
3.
Certified
4.
Certified final by vendor and signed
ARCHIVAL (Status 2)
1.
Void
2.
Superseded
3.
Information only
4.
Deleted
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CONSTRUCTION (Status 3)
1.
For bid
2.
Under_ engineering review:
2.1 Not released for fabrication
2.2 For approval only
3.
Approved for construction:
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3.1
Final
3.2
Closed file
3.3
Final certification
3.4
Approved
3.5
Approved as noted
3.6
Approved as fabrication
3.7
Released for fabrication
3.8
Certification for construction
Drawings are, however, identified only by the first digit of the
status code.
CNS personnel told the NRC inspector that they had no~ procedure at
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CNS governing the status code as assigned NPPD General Office
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procedure and that the NPPD procedure is not per se applicable to
CNS.
CNS personnel ignored the codes and considered all drawings on
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the. list as approved. . Numerous safety-related drawings were status 2
(archival) or 3 (construction); examples are drawing CMPHTP 3 " Flow
Diagram Reactor. Feed, Core Spray and Operating Vent Systems"
(status 2), drawing 75046-007, 100.01 through 101-03 Torus Mod / Pipe
Supports, (status 3).
No CNS procedure required documentation or
approval, or of as-built verification, of drawings marked status
"2" or "3" prior to use at CNS.
Failure to have CNS procedures to provide document control of drawings
identified as archival (status 2) or construction (status 3) to
prevent their use as approved drawings is an apparent violation of
10 CFR 50, Appendix B, Criterion V.
(50-298/8519-01)
b.
Security of Safeguards Drawings Which Were Under Document Control
Safeguards drawings were controlled by site engineering and were
kept in a file cabinet with locking bar and padlock. The padlock
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was a key lock and was not a GSA approved combination lock as
specified by NUREG-0794 " Protection of Unclassified Safeguards
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Information Criteria and Guidance, Section 4.1.
The use of an
unapproved lock is a violation of 10 CFR Part 73.21.
(50-298/8519-02) The licensee corrected this violation when it was
identified.
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c.
Periodic Review of CNS Procedures
CNS Procedure 0.4, Revision 1, approved March 21, 1985, " Preparation,
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Review, and Approval of Procedures,"Section III.
Review and
Approval, requires a review of procedures every 2 years ( ET).
The NRC inspector verified that the following procedures which had
not been revised in the past 2 years had been reviewed as required:
Procedure
Title
Revision
Ap3roval
Number
) ate
6.1.2A
IRM Functional Test (Mode
Switch Not in Run)
3
9/9/81
6.1.3
ARRM System Excluding 15%
Trip Function Test
12
3/31/81
6.1.5
RPS High Reactor Pressure
Calibration and Furctional/
Functional Test
13
4/25/83
6.1.10
RPS-Primary Containment
High Pressure Calibration
and Fuctional/ Functional Test
11
3/12/82
No violations or deviations were noted in this area.
d.
Document Control of Contractor and Sub-Contractor Drawings
The NRC inspector reviewed licensee document control of contractor
drawings of roodifications. As a sample he reviewed Signal Hill
Electric Company Sketches, including as-built sketches of seismic
safety-related cable tray supports and hangers prepared for Burns
and Roe as part of the LPCI modification. These were found in the
licensee's document microfilm, cartridge 107, frame 1978 to the end
of the cartridge, and continuing on cartridge 108. The NRC inspector
could not fir.) a procedural flow path for contractor drawings until
incorporatian on NPPD "as-builts," either in this specific example,
or generically.
Since this concern requires further review at both
CNS and at NPPD general offices, it is made an unresolved item
(50-298/8519-03) pending such review by the NRC inspector during a
subsequent inspection.
The NRC inspector also reviewed sample drawings referenced on the
sketches for incorporation of the as-built modifications. The
following drawings were included in those reviewed. All design data
on the sketches could not be found on the drawings. Two of the four
drawings have a status showing that they are "for information only,"
though they are used by CNS as approved drawings.
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Burns & Roe
Revision
Drawing Title
NPPD Status
Drawing Number
Code (See 12a)
3154
14
Reactor Building EI 859'-9"
1 (as-built)
Conduit Plan
4181
4
Reactor and Control Building
2 (Information
Details of Seismic Supports
only)
(Lateral) for Cable Tray and
Conduit Hangers
4473
6
Reactor Building EI 859'-9"
1 (as-built)
and 881'-9" Seismic Support
for Cable Tray and Conduit
Hangers
4479
6
Control Building Cable
2 (Information
Spreading Room EL 913'-0"
Only)
Seismic Supports for
Cable-Tray and Conduit
Hangers
3.
Licensee Quality Assurance (QA) and Quality Control (QC) Administration
Program
The NRC inspector reviewed the licensee's QA and QC program administration
relating to:
a.
Definition of QA/QC program applicability.
b.
Administration of.QA/QC program procedures including:
1) Responsibility for making procedural revisions.
2) Controls to assure review and approval prior to implementation.
3) Methods and procedures for changes, revisions, and for
documentation.
c.
Methods to review the effectiveness of the program.
No violations or deviations were noted. The NRC inspector did n'ote that,
unlike CNS station procedures, the licensee had not required periodic
review and update for QA/QC procedures.
4.
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, violations, or
deviations. The one unresolved item disclosed during the inspection is
discussed in paragraph 2.
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6.
- Exit Interview-
The NRC inspector met with the licensee representatives (denoted in
. paragraph 1) and the NRC senior ~ resident inspector at-the conclusion of
the inspection.
The NRC inspector sumarized the purpose, scope, and
findings of'the inspection.
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