ML20151B904
| ML20151B904 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/29/1988 |
| From: | Barnes I, Ellershaw L, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151B901 | List: |
| References | |
| 50-298-88-04, 50-298-88-4, NUDOCS 8804120017 | |
| Download: ML20151B904 (12) | |
See also: IR 05000298/1988004
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-298/88-04
Operating License:
Docket: 50-298
Licensee: NebraskaPublicPowerDistrict(NPPD)
P.O. Box 499
Columbus Nebraska 68601
Facility Name: CooperNuclearStation(CNS)
Inspection At:
Inspection Conduc ed:
February 8-12 and February 29 through March 4,1988
2W
Inspectors:
\\L.T E. Ellershaw, Reactor Inspector, Materials
Date '
and Quality Programs Section. Division of
Reactor Safety
$Y
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V
. G. Taflor, Reactor Inspector, Materials
Det7
and Qtlality Programs Section Division of
Reactor Safety
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U/29/PP
Approved:
I. Barnes, chief, Materials and Quality
Date
Programs Section, Division of Reactor Safety
Inspection Summary
Inspection Conducted February 8-12 and February 29 through March 4,1988
(Report 50-298/88-04)
Areas Inspected: Routine, unannounced inspection of:
(1)thelicensee's
quality assurance program implementation including the areas of records
management, document control, receiving inspection of materials and components;
and (2) implementation of 10 CFR Part 21 requirements.
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8804120o17' ego 4o'7
DR
ADOCK'05000298
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Results: Within the two areas inspected, two violations were identified
(failure to perform the required receipt inspection prior to installation of
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parts, paragraph Si and failure to have implementing procedures relative to
10 CFR Part 21, paragraph 6).
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DETAILS
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Persons Contacted
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Licensee Personnel
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- G. R. Horn, Division Manger of Nuclear Operations
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- G. E. Smith, Quality Assurance (QA) Manager
- J. M. Meacham, Senior Manager of Technical Support
- E. M. Mace, Engineering Manager
- G. R. Smith, Licensing Supervisor
- L. E. Bray, Regulatory Compliance Specialist
- H. T. Hitch, Plant Services Manager
- D. Overbeck, Purchasing and Materials Manager
- C. R. Moeller, Technical Staff Supervisor
J. R. Flaherty, Supervisor, Plant Engineering
NRC
- A. B. Beach, Deputy Director Division of Reactor Projects, RIV
- E. J. Holler, Chief, Reactor Project Section C, RIV
- W. O. Long, Project Manager, NRR
- fW. R. Bennett, Senior Resident Inspector, Reactor Project Section C, RIV
.fE. A. Plettner, Resident Inspector, Reactor Project Section C, RIV
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The NRC ins)ectors also interviewed other licensee personnel during the
course of tie inspection.
- Denotes those persons who attended the exit interview on February 11,
1988.
- Denotes those persons who attended the exit interview on March 4,1988.
2.
Annual Quality Program Review (35701)
The NRC inspector reviewed the Updated Safety Analysis Report (USAR)
submitted to the NRC on July 22, 1987, to determine if any of the changes
made affected the licensee's QA program comitments.
It was found that
the QA Program for Operatier.3 is only referenced in the U"AR and
maintained under separate cover.
Changes to this program which are
considered to not reduce comitments are submitted annually to the NRC.
The latest version of the QA Program for Operations was reviewed and it
was found that the changes were not significant.
The NRC inspector
reviewed the qualifications of the operating staff managers and
supervisors presently occupying positions identified in the organization
except for the Division Manager whose qua'ifications were evaluated as
indicated in NRC Inspection Report 50-298/86-02. Technical
Specification (TS), paragraph 6.1.4 requires that plant personnel from the
plant manager down to reactor operators and maintenance supervision are to
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be qualified to the American National Standards Institute (ANSI)
N18.1-1971 requirements, except for the Chemistry and Health Physics
Supervisor who is to be qualified as required by Regulatory Guide 1.8
dated September 1975.
It should be noted that within the licensee's
organization, the Division Manager of Nuclear Operations is also the plant
manager. The NRC inspector was informed that the files containing full
background data on the experience and education of the people involved
were maintained in the licensee's General Offices in Columbus, Nebraska,
and were thus not readily availabh for review. As an alternative, the
NRC inspector interviewed the persons presently occupying the following
positions to obtain their own statements of experience and background:
Senior Manager of Technical Support
Operations Manager
Maintenance Manager
Engineering Manager
Radiological Manager
Instrument & Controls Supervisor
The oral resumes of the above individuals were compared to the above
referenced standard.
Each person's education and experienci either
equaled or exceeded the requirements of the standard, in some cases by
several factors.
In one instance, it appeared questionabic as to whether
the TS had been satisfied in regard to the management level required to
have a Senior Reactor Operator's license granted by the NRC. The above
mentioned standard required that the Operations Manager have a license at
the time he either assumed the position or at initial fuel load, whichever
came later.
During the interview with the current Operations Manager, the
NRC inspector was informed that while he, the Operations Manager, had held
a license when he was assigned to the position in early 1986, he had
allowed the license to lapse in November 1987.
Since both the TS and the
above referenced ANSI standard require that each person in the operating
organization undergo training on a recurring 2-year cycle, which is the
same cycle for license renewal, it could be construed that the Operations
Manager as well as other licensed personnel should maintain their licenses
in order to occupy their positions. An organization chart included in the
TS indicated that a position identified as the Operations Supervisor would
have a license,
This position is subordinate to the Operations Manager
and is occupied by a licensed person.
After review with cognizant NRC
personnel, the NRC inspector determined that the TS had been satisfied
which resulted in no further questions.
No violations or deviations were identified in the area of the
qualifications of the licensee's plant staff.
Implementation of the QA
program was inspected with respect to records management; document
control; and receipt, storage, and handling of equipment and materitis.
The results of these inspections are documented in paragraphs 3, 4, and 5
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3.
Records Management (39701)
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The NRC inspector reviewed licensee Operations Procedure 1.9 Revision 9
dated January 18, 1988, "Control and Retention of Records." The procedure
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lists the various types of records generated in conjunction with plant
operations and provide; for interim or active storage of each record with
the originating organization for periods of time ranging up to 2 years.
After the active storage period, the records are forwarded to a records
managanent group for either permanent hardcopy retention or as microfilm
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copies with subsequent destruction of the hardcopy. The NRC inspector
selected examples from the following types of records in both the active
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storage and permanent storage system to establish compliance to NRC
requirements and the licensee's procedure:
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OA Audit Reports
Deficiency Reports
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Reports of Reportable Occurrences
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Minutes of Safety Review Committee Meetings
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Training Records
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Control Room Logs
With the exception of the training records, the records management
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personnel were able to quickly locate specific microfilmed records
seier.ted by the NAC inspector through the use of a computerized indexing
system.
By procedure, the training records are naintained in hardcopy
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form for their full retention period. The NRC inspector was informed that
audit records and the control room logs are generally forwarded to the
records management group as soon as they are closed, even though the above
referenced procedure would allow them to be retained as active records for
up to 2 years and 1 year, respectively.
The NRC inspector noted that the
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records storage area had a considerable number of cardboard file boxes
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stored on shelving and that the area in general would not meet NRC
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Regulatory Guide 1.88 which endorses ANSI Standard N45.2.9 "Collectici
Storage, and Maintenance of Nuclear Power Plant Quality Assurance
Records." The records management personnel indicated that they believed
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that the facility was enerating under an exemption until completion of a
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new storage facility which is under cnnstruction and is currently
scheduled for occupancy in April or May 1988.
Subsequent review of NRC
inspection reports identified that Unresolved item 298/8606-01 was
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documented relative to verification of compliance of the new storage
facility with respect to the requirements of ANSI Standard N45.2.9.
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that the new facility is under active construction, this subject will
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continue to remain as an unresolved item until inspection of the new
facility is performed.
The NRC inspector reviewed Deficiency Reports, Reports of Reportable
Occurrence Safety Review Committee meeting minutes, and training records
that are considered to be in active storage. All were in fire-rated file
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cabinets and were contained in clip files so as to prevent loss of a
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record.
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No violations or deviations were identified in the area of records
management.
4.
Docu:nent Control
(39702)
The NRC inspector reviewed the following licensee procedures pertaining to
document control:
Operation Procedure 1.10, Revision 1. "Document Control"
Operation Procedure 3.7, Revision 2 "Drawing Change Control"
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Operation Procedure 3.8, Revision 1. Drawing Control Procedure"
The licensee's primary drawing control system depends on microfilm
aperture cards updated by the engineering division in the General Office.
The drawing change system depen 6 cn drawings marked with various colors
to denote addition and deletions to the drawing. These marked-up drawings
are attached to a Design Change Notice (DCN) which records the drawing and
revision being changed and the engineering approval. The aperture card
and all official hardcopies of the drawing are annotated to reference the
DCN number. Hardcopy stick type files of drawings are located in the site
engineering work area, in the control room, the instrument & control shop,
the Emergency Operations Facility (EOF), and in the training section area.
The electrical maintenance shop also has copies of electrical elementary
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drawings.
It appe rs, based on the information learned during an
interview with the engineering specialist in general charge of the
aperture cards and the DCN file, that there is not a full distribution of
DCNs with marked-up drawings attached.
In particular, it is understood
that stickfile users in the EOF and the maintenance shops do not have the
immediate access to the marked-up drawings, but rather must go to the
engineering specialist to avail themselves of the marked-up drawings.
The NRC inspector was alsc informed that when the Technical Support Center
is 6ctivated, the enginee. ring specialist must gather a preselected set of
DCNs with the attached marked-up change drawings and proceed from his work
area, which is presently in the training facility outside of the security
controlled area, and go to the Technical Support Center so that the
technical support personnel will have current infoncation on the
egineering status of the station.
The NRC inspector developed a concern with the described system in that it
is very dependent on the users of drawings to take the time to go outside
their work areas, in some cases at a considerable inconvenience, in order
to access current information. The system is also very dependent on the
diligence of the engineering specialist to maintain his files and records
of the changes, since he is the fecal point for management of the system.
While there was no evidence found during the inspection that would
indicate that the system is not be;ng made to work, the NRC inspector was
concerned thst, at sometime in the future, the system could break down.
The NRC inspector suggested *,o the licensee that it attempt to develop a
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change control system that would facilitate attaching change documents
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directly to all user copies of the drawvgi and not depend on the users to
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search out the current information based on ann 0tated data appearing on
his copy.
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Based on the sample of aperture cards, the NRC inspector examined the
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drawing stickfiles located in the engineering work area and in the EOF.
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The drawings in the engineering area agreed with the aperture cards both
as to drawing revision and the listing of outstanding unincorporated DCNs.
It was noted that two drawings in the selected sample were not in the
stickfile but subsequent investigation indicated that they were special
drawings developed for an engineering study and did not represent
information needed to either operate or maintain the facility.
In the
case of drawings in the stickfiles in the EOF, the NRC inspector found
that 3 of 11 drawings in the sample were one revision level out of date.
The drawing annctation of DCNs, however, included the DCNs that were
incorporated into the drawing by the later revision. Assuming that the
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user would access the DCN drawing file, he would have the latest
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engineering status related to the area covored by the drawing. The
engineering specialist in charge of the dr6 wing system explained that his
people update the stickfiles shortly after new copies of the drawings are
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received from the engineering office in the licensee's general office, but
that in some instances the press of other work may delay the updating of
some of the files for several weeks. He didn't believe that this was a
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problem since the DCNs were still referenced on the drawing.
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While no violations or deviations were identified in the area of drawing
controls, the NRC inspector remains concerned with a system that is so
heavily dependent on both:
(a) the users of the drawings taking the
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effort to obtain current information; and (b) ca the engineering
specialist and his associates maintaining fully accessible and current
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files of the unincorporated DCNs. This subject is considered an open item
pending additional NRC review in a subsequent inspection (298/8804-04).
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5.
Receipt, Storage, and Handling of Equipment and Materials (38702)
The NRC inspector reviewed the documents tabulated below in order to
verify that administrative controls exist and that they provide measures
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to assure that received materials and equipment will be examined for
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conformance with requirements specified on the procurement documents.
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documents were reviewed to verify that acceptance criteria were clearly
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established and that requirements for documenting the performance of
receipt inspections were delineated. These dacuments were also reviewed
to assure that controls exist with respect to neaconforming items,
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storage, handling of safety-related items, and that responsibilities are
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assigned in writing.
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Document No.
Revision
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Title
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Appendix D
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03/28/87
0.5.1
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02/20/87
Nonconformance and Corrective
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12/31/87
Nonconformance and Corrective
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Action
1.4
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08/13/87
Requisitioning
1.5
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05/7/87
Warehouse Receiving
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.10/15/87
Warehouse Receiving
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01/25/88
Warehouse Receiving.
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. arehouse Marking and Tagging
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07/15/86
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01/19/88
Warehouse Marking and Tagging
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03/26/87
Warehouse Storage.
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12/23/87
Warehouse Storaci
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08/13/87
Warehouse Issue and Return
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02/08/88
Warehouse iriue and Return
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QAP-1400
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06/20/86
Quality Ass.'ance Plan-Procurement
and Control of Essential Spare
Parts Materials and Equipment
In order to assess the implementation of those documents associated with
material acceptance, receipt inspection, storage, and control of the
associated QA records, the NRC inspector selected the following
safety-related items which were observed in storage, and reviewed all
applicable documentation:
a.
Rockbestos Cable
b.
Limitorque Motor
c.
3/32-inch. Type E7018 Electrodes
d.
3/32-inch. Type 316L Electrodes
e.
Relief Valve Gaskets
f.
Spare Part Kits for Asco Valves
g.
I 1/8-8X5 ' xh Heavy Hex Bolts
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I 1/a *.o-inch Heavy Hex Bolts
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inch Heavy Hex Nuts
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y-Inch Elbows, Stainless Steel, Schedule 80
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2-inch 900 Pound Flanges Carbon Steel
The reviewed documentation consisted of purchase orders (P0s), receiving
inspectionreports(RIRs),andtheassociateddocumentationsuppliedby
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the vendor.
It was noted that, in each case, the documentation was
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traceable to the items. All required vendor documentation (i.e.,
Certificates of Compliance or Certified Material Test Reports) was filed
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and readily retrievable.
With respect to the gaskets and spare part kits (e) and (f) above it was
noted that the vendor documentation specified a shelf life.
The NRC
inspector observed that the identification tags attached to the items in
storage contained the shelf life as specified by the vendor. All of the
items (a) through (k) were praperly tagged and identified.
In order to assess the implementation of the procedure pertaining to
control of nonconforming items identified during receipt inspection, the
NRC inspector reviewed a Nonconformance Report (hCR) List maintained by
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the receipt inspector and selected seven open NCRs which would allow for
observation of the items identified in the NCRs.
This would provide
verification that the parts were tagged with hold tags which, in turn,
would cross reference the NCR number. The receipt inspector informed the
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NRC inspector that it was possible for a part to be identified by an NCR
without it being stored in the warehouse; in fact, the part might be
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installed in a system which has been declared operable
It was further
revealedthatncnessentialpartscouldbeusedforreplacementof
essential parts.
This condition is permitted by Plant Services
Procedure 1.8 which allows a requisitioner to requisition an item which is
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in a "Hold" or "Reject" status, or to requisition a nonessential item for
use in an essential application, as long as an NCR has been filled out
addressing the specific situation and is attached to a Warehouse Issue
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Ticket that has been signed by Engineering and by the Division Manager of
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Nuclear Operations.
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To preclude any confusion with respect to the terms essential,
essential-commercial grade, and nonessential, the following paraphrased
definitions, extracted from Quality Assurance Instruction QAl-9, are
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provided:
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Essential - Those items which are essential to the prevention of
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accidents which could affect the public health and safety by the
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release of substantial quantities of radioactivity or which are
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required in the mitigation of the consequences of such accidents,
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Essential-Commercial Grade - Those essential items which are not
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subject to design or specification requirements that are unique to a
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nuclear facility, and are to be ordered from a manufacturer's
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published product description.
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Nonessential - Those items which are not essential for preventing an
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accident which would endanger the public health or safety, and are
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not essential for mitigating the consequences of such an accident.
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A triggering event in the requisitioning of spare / replacement parts, is the
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issuance of a Maintenance Work Request (MWR), which it identified by a
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Work Item Number.
The MWR provides the basis for requisitioning the item
and also provides for a description of the work to be performed with
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completion dates and signatures.
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The NRC inspector's review of the MWR packages associated with the seven
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NCRs revealed the following information.
Four of the packages involved
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NCRs which were written between July 1987 and February 1988, and addressed
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the use of nonessential parts in essential applications.
In addition, one
of these four also addressed the use of o-rings in which the designated
shelf life had expired.
In each of these cases, the replacement work had
been completed but the NCRs were still open as of this inspection. One
package contained an NCR which was initiated on March 27, 1987, regarding
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the repair of a service water pump motor in which the vendor had not
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provided the required technical report.
The pump motor installation was
completed on April 8, 1987. The technical report was received, reviewed,
and approved, and the NCR subsequently was closed on February 23, 1988.
One package contained an NCR which was initiated on December 30, 1987, and
addressed solenoid rebuild kits for directional control valves in which
the vendor would not certify them as being essential.
The installation of
these kits has not been performed. One package contained an NCR which was
initiated on October 5, 1987, and addressed the use of parts which had
been supplied from an unapproved vendor.
The installation of the parts
was performed on October 3, 1987, and the NCR had not been closed as of
this inspection.
With the exception of the NCR dealing with the need for a technical
report, the dispositions on the remaining six NCRs included the need for
"dedication" of the parts and/or evaluation.
It was explained to the NRC
inspector that dedication meant that a series of steps would be perforined
in order to qualify the nonessential item for continued use in an essential
application.
In an effort to determine the parameters and specifics
associated with the dedication process, the NRC inspector requested that
the implementing procedure for this activity be provided.
The licensee
responded by stating that a dedication procedure did not exist; however,
the need for one had been identified and the necessary actions to develop
one had been taken. Although the basis for the dispositions on the NCRs
appeared adequate, the dedication process is considered to be an unresolved
item pending the completion of the licensee's actions for developing an
implementing procedure and additional NRC inspection (298/8804-03).
The MWR package dealing with the parts received from an unapproved vendor
is identif. 1 by Work Item No. 87-3072 dated October 1, 1987, and pertains
to diesel generator cooling fan blades which had been damaged; thus
initiating the need for replacement blades. The package either contained
or referenced the following:
a Warehouse Hold Tag, NCR 87-135, QA Hold,
and NPPD P0 274945.
The MWR showed that a visual inspection and a liquid
penetrant examination (information only) was performed on those blades
which did not appear to be damaged.
It also showed that repairs were
performed in accordance with Engineering Specification Change (ESC) 8 -061
and work was completed on October 3, 1987, with the diesel generator
signed off as being ready for service on October 5, 1987.
ESC 87-061,
approved on October 2, 1987, addresses a fan blade material change from
The NRC inspector reviewed P0 274945 and the purchase requisition (PR),
vendor documents, the RIR which is identified by the P0 number,
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NCR 87-135, applicable NPPD internal correspondence, and observed four of
the fan blades which had not been used and were stored in the warehouse.
The four blades were identified by a Warehouse Hold Tag dated October 6,
1987, which showed P0 No. 274945, the vendor's identity, the fact that the
blades were on "QA Hold," and NCR No.87-135.
The PR is dated October 2,
1987, and shows Millard Manufacturing Corporation, Omaha, Nebraska, as
being the vendor for 28 fan blades to be made from 6061-T6 aluminum and a
delivery date of October 2, 1987.
The PR also states that the blades are
to be manufactured per the sample which had been provided and that the
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blades are essential-commercial grade.
Subsequently, the PR was amended
on October 5, 1987, with a note which waived standard QA requirements in
lieu of site dedication upon receipt. The dedication was to consist of
one blade being dimensionally inspected for thickness, bend angle, overall
length, and mounted height, a visual verification that the material was
aluminum and that it was stenciled 6061-T6, a hardness check, and a
similarity check of the other 27 blades by visual comparison.
The
confirming P0 was subsequently typed and included the same requirements.
Both documents were stamped with a "QA Hold" which stated that the vendor
wasnotontheapprovedsupplierlist(ASL).
The PR contained an
additional QA note dated October 5, 1987, which stated that "the P0 to
Millard Manufacturing was discussed in October 2,1987, S0RC (Station
Operations Review Coninittee) meeting for approval of ESC 87-61.
NCR to be
written to document ASL concern and issuance of material from QA Hold."
The NRC inspector verified that these concerns were written in NCR 87-135
on October 5, 1987.
The available vendor documentation consisted of a Millard Manufacturing
Corporation P0 dated October 1, 1987, to Vincent Metals in Omaha,
Nebraska, for one sheet of 0.125-inch thick aluminum 6061-T6, and a
Millard Manufacturing Corporation packing slip dated Octuber 2, 1987,
showing 28, 0.125-inch thick aluminum 6061-T6 fan blades.
The previously mentioned dedication requirements were documented as having
been performed by someone other than the receipt inspector on October 2,
1987. One of the steps addressed visual verification that the 28 blades
were aluminum and stenciled 6061-T6. However, with respect to the four
blades observed in the warehouse by the NRC inspector and the individual
who performed the dedication, the only discernible stenciling consisted of
T6 (heat treated condition) on one blade and "Made In USA" on another.
No
understanding could be arrived at as to why these four blades were not
stenciled or how the stenciling was removed.
The RIR shows the P0 number (274945), the vendor (Millard Manufacturing
Corporation), and the description (fan blades).
It shows that the
following warehouse receipt inspection activities were performed and were
acceptable: physical damage, cleanliness, quantity verified, and
dimensions verified.
The receipt inspector signed and dated the RIR on
October 6, 1987.
In addition, the individual who signed the dedication
performance sheet also signed the Technical Data Inspection portion of the
RIR on 'ctober 6, 1987.
The number of fan blades which are represented by
the RIR is not stated and could not be determined. However, the RIR was
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completed at the time the four fan blades were sent to the warehouse and
after the other 24 had been installed.
With respect to NCR 87-135 dated October 5, 1987, the disposition required
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the performance of a root cause analysis, a QA evaluation of the vendor
for placement on the ASL, a dedication of the material by performance of
the steps addressed on the P0, and for engineering to provide
justification for installing the materiel while on QA Hold.
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of this inspection, the root cause analysis has not been completed.
The
item dealing with placement of the vendor on the ASL was addressed in an
NPPD internal memorandum which states that Millard Manufacturing
Corporation was piaced on the ASL effective February 9,1988.
The
memorandum stipulated, however, that procurement documents must state
"Dedication Required" which is in lieu of Item 1 of the standard QA
requirements.
It should be noted that Item 1 is a requirement for a
vendor to maintain and apply a program which is in compliance with the
applicable portions of Appendix B to 10 CFR Part 50.
It would appear that receipt inspection was not performed by the receipt
inspector on all 28 fan blades and that material identification can not be
verified on at least four of the fan blades due to stanciling not being
visible.
These conditions constitute an apparent violution (298/8804-01).
6.
10 CFR Part 21 Inspection
(36100)
This inspection was meant to determine whether the licensee had
established and implemented procedures and controls which provide for
evaluating deviations, assuring that defects or failures to comply are
reported to the NRC, and that records applicable to these activities are
established and maintained.
The NRC inspector requested the licensee to identify those procedures
which had been established in order to implement the requirements of
The licensee responded that procedure (s) had not been
adopted pursuant to the regulations of 10 CFR Part 21; however, they were
aware of this condition and were taking the necessary actions to be in
compliance.
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The NRC inspector war informed that an implementing 10 CFR Part 21
procedure was in a draft stage and was currently being reviewed by
corporate management. The licensee estimated that it might be
2 to 3 months before the document was finalized, issued, and implemented.
This failure to have procedures as required by 10 CFR Part 21 is a
violation (298/8804-02).
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7.
Exit Interview
The NRC inspectors held exit interviews with the licensee and NRC
personnel denoted in paragraph 1 on February 11 and March 4, 1988, to
,
discuss the areas inspected and the findings.
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