ML20203G635
| ML20203G635 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/28/1986 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 8608010340 | |
| Download: ML20203G635 (22) | |
See also: IR 05000285/1985022
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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W ASHINGTON, D. C. 20555
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July 28, 1986
Docket No. 50-285
MEMORANDUM FOR:
Eric H. Johnson, Director
Division of Reactor Safety and Projects, RIV
FROM:
James G. Partlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
SUBJECT:
FORT CALHOUN SAFETY SYSTEMS OUTAGE MODIFICATIONS
INSPECTION (SSOM')
This memorandum identifies anc' iorwards Potential Enforcement Findings (PEFs)
identified during the design portion of the Fort Calhoun Safety Systems Outage
Modifications Inspection (Enclosure 1) and our evaluations of the licensee's
April 15 and May 22 responses to our design and installation / test inspection
reports (Enclosures 2 and 3, respectively).
We have conducted an in-office review of the PEFs tabulated in the enclosure to
make a preliminary determination'of an appropriate enforcement classification
for each.
Our determination is that the appropriate enforcement classification
for each of the items considered individually is Category IV (Supplement I to
Additional information relating to these findings is
contained in the inspection report dated January 21, 1986 and in the licensee's
response dated April 15, 1986.
The Potential Enforcement Findings were identi-
fied as either deficiencies or unresolved items in the inspection report.
Deficiency D3.-2-7, regarding unstable valve operator supports in the auxiliary
feedwater system steam supply lines, was not evaluated for enforcement action
by this office because we were aware of an investigation being conducted
relative to this item and will defer an enforcement decision until the investi-
gation is completed.
However, we do consider the licensee's actions to be
technically non-responsive for this item.
Enclosure 2, our evaluation of the licensee's response to inspection report
50-285/85-22, was prepared for transmittal to the licensee.
As discussed in
our meeting with your staff on July 9,1986, it was agreed that Region IV
should coordinate the response to the licensee, in view of the various inspec-
tion reports that comprise the SS0MI.
Therefore we are forwarding this docu-
ment to you to provide you with our thoughts regarding, 1) the items we con-
sider to be closed based on the licensee's April 15, 1986 response, 2) our
concerns regarding the items to which we feel the licensee's response is not
adequate and 3) items that, in our opinion, need to be closed out by additional
inspection.
In addition to Enclosure 2, your staff has been provided with the
design inspection team members' individual evaluations of the responses, which
should be useful in your future evaluation and closecut of the report findings.
"
8608010340 860728
ADOCK 05000285
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July 28, 1986
Eric H. Johnson
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Our evaluation of the licer.see's response to inspection report 50-285/85-29 is
provided in Enclosure 3.
Although the general programmatic corrective actions, both long term and short
term, were discussed in the July 10, 1986 enforcement conference held in Region
IV, specific details of the respor:se were not discussed.
As we discussed
by telephone, our evaluations, and any additional concerns or questions you
have, should be transmitted to the licensee prior to meeting with the licensee
to discuss the specific concerns. We recommend a Dallas location for such a
meeting.
A draft transmittal letter is provided in Enclosure 4.
As noted above, our review indicates a need for followup inspection for many of
the items in the design inspection report and the installation / test inspection
report. We suggest that you consider using the original team members for the
design aspects of the reinspection.
We will determine their availability to
assist in the followup inspections.
If you have any questions, please contact
me or James E. Konklin (492-9656).
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James G.
artlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
Enclosures:
1.
Potential Enforcement Findings, Design Inspection
2.
Evaluation of Licensee's Response, Design Inspection Report 50-285/85-22
3.
Evaluation of Licensee's Response, Installation and Testing Inspection
Report 50-285/85-29
4.
Proposed Letter to Licensee
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ENCLOSURE 1
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POTENTIAL ENFORCEMENT ACTIONS
FORT CALHOUN INSPECTION
1.
Contrary to 10 CFR 50, Appendix B, Criterion III, design control has not
been maintained.
The licensee had:
a.
Failed to assure that a design change affecting the post-accident
heat loading of the component cooling water system was subject to
design control measures commensurate with those applied to the
original design (Deficiency D2.2-6).
b.
Failed to assure that design specifications used for plant piping
and equipment were subject to design control measures commensurate
with those applied to the original design (Deficiency D3.1-1).
c.
Failed to assure that operating and accident temperatures developed
as design input fo- piping analyses pursuant to IE Bulletin 79-14
were subject to design control measures commensurate with those
applied to the original design, including provisions for necessary
control of design interfaces (Deficiency D3.1-2).
d.
Failed to assure that the support for modified junction box JB-432A,
which supplies power for auxiliary feedwater turbine steam adMssior.
valve 1045B, was subject to design control measures commensurate with
those applied to the original design (Deficiency D3.2-4).
e.
Failed to provide for verifying or checking the adequacy of the
design inputs, such as load tables used and reliance on earlier
unverified calculations, during the design of replacement station
batteries (Deficiency 05.1-1).
2.
Contrary to 10 CFR 50, Appendix B, Criterion XI, test control was not
established.
The licensee had:
a.
Failed to establish written test procedures which demonstrate that
the accumulators installed to close the auxiliary feedwater steam
admission valves would perform satisfactorily in service in
accordance with requirements and acceptance criteria contained in
applicable design documents (Deficiency D2.1-7).
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b.
Failed to establish written test procedures which demonstrate that
the accumulators installed to close the component cooling water
RCP supply and return containment isolation valves would perform
satisfactorily in service in accordance with requirements and
acceptance criteria contained in applicable design documents
(Deficiencies D2.2-1 and D2.2-3).
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ENCLOSURE 1
3.
Contrary to 10 CFR 50, Appendix B, Criterion VI, document control measures
were not established.
The licensee failed to control the issuance and
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accuracy of system descriptions, nor provided alternate design criteria
necessary to establish design control (Deficiency D2.1-9).
4.
Contrary to 10 CFR 50, Appendix B, Criterion IV, procurement document
control measures were not established.
The licensee failed to:
a.
Assure that applicable regulatory requirements, design bases, and
other requirements which are necessary to assure adequate quality
were suitably referenced or included in documents for procurement of
services associeted with seismic analysis of valves HCV-4388 and
HCV-4380 (Deficiency D2.2-2).
b.
Establish procurement documents which contained provisions to assure
the steam generator nozzle dams were qualified to their governing
seismic requirements (Deficiency D3.2-6).
5.
Contrary to 10 CFR 50.59, changes to the facility as described by the
safety analysis report have been made without the required evaluation to
determine the existence of an unreviewed safety question (Deficiencies
D6.1-1 and D6.2-2 and Unresolved item U6.1-2).
6.
Contrary to 10 CFR 50, Appendix B, Criterion V, documented instructions,
procedures, or drawings were not provided for the installation of seismic
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tubing associated with accumulators for the auxiliary feedwater turbine
steam admission valves (Deficiency D3.2-2).
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ENCLOSURE 2
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Evaluation of Licensee Response to
Fort Calhoun Safety Systems Outage Modifications Inspection
(Design), Inspection Report 50-285/85-22)
D2.1-1 (Deficiency) Lack of Design Analysis to Support Sizing of Air
Accumulators for Valves YCV 1045 A/B.
The licensee's response addresses the concerns identified in the deficiency.
However, this deficiency should remain open pending followup inspection of
functional testing performed by the licensee.
D2.1-6 (Deficiency) Failure to Follow Procedural Requirements for A Normal
Modification Resulting In Lack of Required Design
Verification Review.
The license 9's response is considered acceptable with reservation and with one
correction.
From a safety point of view, the design verification can occur at any time
including just prior to system acceptance.
As stated by the licensee, many
times the final installed design may differ significantly from the original
proposed design.
Normal engineering practice is to use field change requests,
red-line drawings, etc., to modify the design. These documents are design
verified as part of the change request approval cycle such that at any one time
the design released for construction is design verified.
If OPPD chooses to
do verification at the end of installation and testing, and if the verification
is done properly, then from a safety point of view there is no problem.
However, the NRC's reservation is that this is not good engineering practice
because it may cause design verifications at the end of a refueling cycle or
major outage to be rushed through without sufficient thought or proper consid-
eration of safety implications.
In addition, there will be greater emphasis on
rationalizing why the installed work is adequate, rather than seeking the optimum
design solution.
The licensee's proposed actions detailed in the July 10, 1986 enforcement con-
ference seemed responsive to this issue; however, they have not been formally
transmitted to the NRC as commitments.
The licensee incorrectly stated that ANSI N45.2.11 allows design verification
to be done by testing.
Qualification testing of a prototype or initial
production unit is described in ANSI N45.2.11 subsection 6.3.3.
The discussion
in this subsection is clearly related to design of components.
Qualification
testing _ associated with equipment qualification is a good example of the intent
of this subsection.
Typically a production unit or prototype is subjected to
seismic and harsh environments (pressure, temperature, humidity, and radiation)
so that other components can be qualified by reference.
The post-modification
testing of a system is not the intent of this subsection.
During the inspec-
tion, the team noted the licensee's apparent reliance on testing in lieu of
design calculations or analysis to confirm design details.
Post-modification
tests cannot test system performance under all of the adverse design conditions
that the system may be required to experience.
It is clear that post-modifica-
tion testing / functional testing is not routinely performed under the most
adverse conditions (see OPPD Appendix B Item 3).
Post-modification testing
demonstrates that the modifications or changes reasonably produce expected
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ENCLOSURE 2
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results and the change does not reduce safety of operations.
It does not
guarantee that the modified system or component will function under the most
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adverse conditions for which the design was based.
This item should remain
open pending further evaluation of the licensee's use of testing for design
verification purposes.
D2.1.7 (Deficiency) Incor.plete Installation / Testing Procedure in Construction
Package for MR-FC-83-158.
This deficiency should remain open pending followup inspection of functional
testing performed by the licensee.
D2.1-9 (Deficiency) Incorrect System Description Statements.
In the short-term the licensea's action is considered acceptable (i.e. . to warn
potential users that the published volumes of system descriptions may not
accurately reflect the as-installed design).
OPPD has deferred a decision
regarding long-term corrective action pending a generic review of the design
change / modification program.
The NRC considers that the longer term action
should be to maintain these documents, or generate similar docu.nents containing
system design criteria, as sources of design input data concerning the system.
This is especially important in view of the fact that design calculations, if
performed, are stored by modification even though the files are " controlled."
Although the licensee states that design information is available in other
controlled documents, a significant void exists in design basis documentation
(as acknowledged in the licensee's letter).
In addition, many of the systems
have been so altered by past modifications it would be practically an
impossible task to review all of those modifications to establish the current
design arrangement if system descriptions (or design criteria) did not exist.
This item remains open pending inspection of the licensee's short-term correc-
tive actions and definition of long-term actions.
The long-term actions detailed in the July 10, 1986 enforcement conference
appeared responsive to this concern.
02.2-1 (Deficiency) Incorrect Design Input in Calculation Associated with
MR-FC-81-218.
A new calculation which is checked, verified, and approved will resolve the
team's concerns regarding accumulator volume, minimum air pressure, and docu-
mentation by the checker.
However, the licensee has not performed functional
testing to demonstrate that the valves in question will remain shut for a pre-
determined period of time under worst case conditions.
The team is concerned
that, due to air leakage through fittings and joints and through check valves
which do not seat properly, a margin of 40% may not be sufficient.
The team
noted that the air accumulator installation was not properly tested after modi-
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fication (See Deficiency D2.3-3) and that surveillance testing is not performed
to demonstrate the capability of the Critical Quality Element portion of the
instrument air system to close these valves and maintain them closed for a pre-
determined period of time without loss of function.
The NRC acknowledges the
licensee's statements regarding the desire not to introduce unwanted transients
during facility operations, but does not consider this objective and adequate
functional testing to be mutually exclusive.
For example, the functional ade-
quacy of this modification could be tested when the plant was otherwise shut down.
This item will be reinspected.
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ENCLOSURE 2
D2.2-2 (Deficiency) Incomplete Consideration of CQE and Seismic Class I
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Requirements for Portions of MR-FC-81-218.
The licensee's response addresses the concerns identified in the deficiency.
This item should remain open pending completion of OPPD's evaluation associated
with IE Information Notice 85-84 and subsequent inspector followup.
D2.2-3 (Deficiency) Incomplete Installation / Testing Procedure Performed for
MR-FC-81-218.
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The licensee's response is acceptable, in part.
The licensee's lack of commit-
ment to functionally test that portion of the instrument air system associated
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with HCV-438B and HCV-4380 remains a concern.
Because these are containment iso-
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lation valves, the ability of the instrument air system to function should be
demonstrated by testing.
These concerns are heightened by the shift supervisor's and design engineer's
concerns regarding the possibility that valve cycling during system operation
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would cause unacceptable transients in the system.
If the system design is such
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that this is the case, a significant safety concern exists and should be promptly
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corrected, rather than subject the plant to an unacceptable (unexpected) transient
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during the course of an accident when the safety feature is relied upon to
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function.
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D2.2-5 (Deficiency) Incorrect Information on Instrument Air Diagram.
The licensee's response is considered in conflict with good engineering practice.
The NRC is concerned with the licensee's position that if an item is not safety-
related it does not need to be shown on a design document. The P&ID is a principal
design document.
Information should be accurately recorded because this drawing
is the basis for design and operation decisions.
This item should remain open pending further NRC review of the licensee's practice
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of not maintaining P&ID's consistent with the installed physical arrangement.
D2.2-6 (Deficiency) 10 CFR 50.59 Safety Evaluation Based upon an Incorrect
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Assumption and Analysis Methodology.
The licensee's response is considered inadequate.
First, the Fort Calhoun USAR
is not adequately enough controlled to be used as a source of design input for
design analyses.
The USAR is only updated yearly and no means exist to inform
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design personnel which items in the USAR are incorrect.
If the USAR is to be
used as a design document, a system must exist and be available to all 0 PPD
design personnel to ensure that errors in the USAR are documented between
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revisions. The changes to the USAR must also be controlled in a manner similar
to that of design drawing and calculations.
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The technical specification basis states the heat removal capacity available
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from the CCW system.
It is recognized that the added heat load was small, but
10 CFR 50.59 does not specify the threshold of significance.
However, the
safety evaluation should have recognized that the modification decreased the
margin of safety compared to the basis on a technical specification. Although
the safety evaluation recommendation regarding securing safety-related equipment
was not implemented, the team noted that other " recommendations" made by design
engineers are critical to preclude the introduction of unreviewed safety
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ENCLOSURE 2
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questions.
For example, the vital ac inverter modification safety evaluation
assumed inoperability of an inverter if the bus was powered by interruptable
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ac power.
If such an assumption is incorporated into the cperating procedures
and the operators are thus precluded from powering more than one inverter
supplied bus,at a time from interruptible ac power, then an unreviewed safety
question is not introduced.
It is not clear that engineering assumptions and
recommendations in safety evaluations are adequately controlled, and that, for
example, guidance would have been provided to caution operators from powering
more than one bus from interruptible ac power.
The lack of access to original design analyses or the failure to prepare com-
parable design analyses in the absence of such design analyses was the major
concern of this finding.
The licensee did not provide specifics as to corrective
measures and has instead offered to study the problem.
It should be noted that
the lack of access to OPPD calculations as well as original design calculations
was a concern of the team.
The licensee's actions regarding short- and long-term use of the FSAR and design
input information, and regarding enhancement of the safety evaluation process,
appear responsive.
These were not provided in their response but presented at
the enforcement conference.
This item should remain open pending implementation
of these corrective actions.
D3.1-1 (Deficiency) Plant Design Specifications.
OPPD resolution of deficiency 3.1-1 is contingent on the results of OPPD's
review of the Design Change / Modification program which includes a review of the
control and use of design inputs, and the maintenance and use of design basis
information.
Attachment B, item 2 of OPPD's response, Lack of Design Basis
Records, indicates tnat OPPD has factored the concern of design basis records
into the overall review of the Design Change Modification program.
At the con-
clusion of this review, OPPD should provide evidence to confirm that contract
763 has either been withdrawn from use by design personnel, or revised and issued
to design personnel as a controlled document.
The licensee stated in their response that the information contained in the con-
tract specification is contained in other, controlled documents.
This information
was not made available to the team during the inspection.
Regardless of this,
a long-term action detailed by the licensee at the enforcement conference was
reconstitution of necessary design basis information.
Reinspection should be
performed to verify the existence of controlled documents which contain the
comprehensive piping specification information used by design engineers.
D3.1-2 (Deficiency) DesignTemperaturesiorSafety-RelatedPiping.
OPPD's specific resolution of this item is contingent upon the review of the
Design Change / Modification program which OPPD is currently conducting.
At the
conclusion of this review, OPPD should provide evidence to confirm that the
marked up piping and instrumentation diagrams containing operating and accident
temperatures have been withdrawn from use by design personnel, and replaced by
a controlled documer:.
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ENCLOSURE 2
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U3.1-3 (Unresolved Item) Small Bore Pipe Support Spacing.
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OPPD's response to this item does not formally reconcile the discrepancy between
the support spacing criteria specified by the contractor performing the field
routing and USAR Appendix F, subsection F.2.5, for piping runs which penetrate
the containment shall or are otherwise connected to it.
OPPD should provide
the specific actions taken or planned to resolve this issue.
The NRC understood
(during preliminary review of the licensee's corrective action discussed in the
response letter) that this issue was to be formally reconciled during a complete
review for Unresolved Safety Issue A-46.
No such commitment was made in the
licensee's response.
U3.2-1 (Unresolved Item) MR-FC-84-61 Design Input Source and Use.
This item should remain open pending reinspection to confirm that modification
request FC-84-61 has been revised to properly document engineering judgment and
to document and reconcile design basis information.
D3.2-3 (Deficiency) MR-FC-84-162 Calculation.
This item should remain open pending OPPD's preparation or identification of a
controlled document for use by design personnel which specifies shop and field
surface preparation of Seismic Category 1 materials.
03.2-6 (Deficiency) Steam Generator Nozzle Dams.
This item should remain open pending review of the procedure that Nuclear Production
Division is developing to provide guidelines for the purchase of critical
quality element (CQE) materials and services.
D3.2-7 (Deficiency) YCV 1045B Valve Restraint.
The NRC considers OPPD's response to this item to be unacceptable.
The team
notes that (Item 1 of OPPD response) the valve operator strut is attached to a
stair post, in apparent violation of the seismic requirements which USAR
Appendix F Subsection F.1.3 imposes on supports associated with Seismic Class I
equipment.
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OPPD noted that they obtain valve weights and dimensions directly from the
vendor, instead of retrieving the appropriate valve vendor drawing from a con-
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trolled data base.
However, OPPD did not provide any documentation to sub-
stantiate the weight and center of gravity dimension for valve operator YCV
1045B which OPPD used to stress analyze portions of the auxiliary feedwater
system.
The team reiterates that the supports adjacent to valve YCV 1045B were
overloaded with respect to specific OPPD support loading criteria.
However,
OPPD did not address this team concern in Item 6 of the OPPD response.
This item should also remain open pending NRC inspection of controlled instruc-
tions for use by 0 PPD piping analysts and designer which incorporate the
recommendations of OPPD's review of the Design Change / Modification program.
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ENCLOSURE 2
U4.3-2 (Unresolved Item) ESF Bypass Switch Keylock Provision.
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In modification MR-FC-81-102, three engineered safety feature bypass switches
were to be added in each of two locked, metal enclosures.
The unresolved
aspect of this concern was whether the technical description and design evalua-
tion of the modification contained all of the equipment requirements necessary
to establish an unambiguous design configuration that would help assure that
only one engineered safety feature channel could be bypassed at any given time.
Omaha Public Power District's response states that the design modification met
the administrative control requirements of section 4.14 of IEEE Standard 279-1968,
and that use of different key combinations was not considered necessary to comply
with applicable requirements.
While bypass annunciation was provided to alert the operator, the response does
not address whether the design modification would prevent concurrent bypass of
redundant engineered safety feature channels.
Section 4.11 of IEEE Standard
279-1968 requires system level compliance with the single failure criterion
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when one channel is bypassed or removed from operation.
Omaha Public Power
District should be requested to provide confirmation that the present design of
the modification conforms with the single failure criterion by preventing con-
current bypass or removal from operation of redundant engineered safety feature
channels.
U4.4-1 (Unresolved Item) Design Basis Physical Separation Within Panels.
Additional information is still needed to resolve these separation questions.
In 1978, modification MR-FC-77-40 added redundant engineered safety feature
undervoltage protection components in separate enclosures within panel CB-4.
Physical separation of redundant safety-related metallic-shielded wiring external
to these enclosures was not provided since no commitment had been made with
respect to IEEE Standard 384-1974 or Regulatory Guide 1.75; however, Omaha
Public Power District stated that this modification was installed in accordance
with the original construction criteria derived from IEEE Standard 279-1968.
For MR-FC-77-40, Omaha Public Power District is requested to provide an analysis
to demonstrate that a USAR commitment in section 7.3.1.b for separation of
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engineered safeguard controls has been satisfied.
More recently, modification MR-FC-81-102 was prepared to add engineered safety
feature bypass switches, and separation details were based on criteria stated
in IEEE Standard 384-1981 to the extent practicable within the constraints of
the existing panels.
Omaha Public Power District's response is based on IEEE
Standard 384-1981 section 7.2.2.2 in that a control switch may be justified as
an acceptable isolation device provided that section 7.2.2.1 requirements have
been satisfied.
In this particular modification, the control switch has been
assumed to be an acceptable isolat. ion device, but this assumption has not been
demonstrated by analysis and qualification test as required by the IEEE Standard.
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For MR-FC-81-102, Omaha Public Power District is requested to provide the analysis
of Class 1E circuits and qualification test results for the control switch to
demonstrate the justification for not meeting a minimum separation distance.
To
the extent that current and future modifications assume credit for metallic-
braided wiring as a separation barrier in lieu of physical separation, qualifi-
cation analysis and test results should be provided.
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ENCLOSURE 2
05.1-1 (Deficiency) Battery Sizing Calculation.
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The NRC should review the latest and 1985 revised load profile calculations and
documentation to substantiate the new load profiles.
The NRC should also inspect
the test procedures and the results of these battery discharge tests which
demonstrate the acceptability of the modified battery.
D5.2-1 (Deficiency) Fire Wrap Protection for Cable Raceways.
The NRC should inspect the loading calculations for the MCC feeder cables and
the formal and revised de-rated ampacity calculations for fire wrapped cables.
Cable routing and raceway details should also be reviewed.
The NRC also reviewed the licensee's response to the following deficiencies
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and unresolved items and considers the responses acceptable. Confirmatory
inspection of the licensee's corrective actions may be conducted.
D2.1-2 (Deficiency) Seismic Requirements Not Specified in MR-83-158 Procurement
Documents.
D2.1-8 (Deficiency) Incorrect Information on Flow Diagram For Main Steam System.
U2.1-10 (Unresolved Item) Use of Fluorocarbon-Elastomer Material in High
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Radiation Environments.
D3.2-2 (Deficiency) MR-FC-83-158 Installation Procedure.
D3.2-4 (Deficiency) Junction Box Supports.
04.3-1 (Deficiency) Limit Switch Circuit Protection by Fusing, MR-FC-84-74A.
D4.5-1 (Deficiency) Drawing Changes by Procedure A-9, MR-FC-82-178.
U4.5-3 (Unresolved) Battery Room Fire Hazard Analysis.
U5.1-2 (Unresolved) Battery Chargar/DC Bus Coordination.
D6.1-1 (Deficiency) Safety Evaluations for Non-Safety-P. elated Systems Described
in the USAR.
U6.1-2 (Unresolved) Safety Analysis for Emergency Modifications.
D6.2-2 (Deficiency) Modifications to AFW Turbine Steam Supply Valves.
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ENCLOSURE 3
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Evaluation of Licensee Response to Fort Calhoun
Safety Systems Outage Modifications Inspection (Installation / Testing)
Inspection Report 50-285/85-29
02.3-2 (Deficiency) Unapproved changes to installation procedures
OPPD did not believe that D2.3-2 was a deficiency and requested that the
finding be reclassified as an observation because the annotations were made in
accordance with procedures.
The inspection team was not aware of OPPD procedures
which control the use of " pen and ink" changes and indicate a threshold point
at which S.0. G-30 is/is not applicable.
Review of procedures which control
pen and ink changes should be accomplished prior to closecut of the deficiency.
On-the-Spot procedure change #15500 was essentially a complete re-write of the
previous revision and deleted the depressurization verification requirement,
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which the inspection team considered to be a safety issue.
02.3-3 (Deficiency) Procedure change implemented prior to PRC approval
The licensee's response is inadequate.
One purpose of the Plant Review
Committee (PRC) is to meet as a committee (quorum) to discuss procedure changes
including possible interactive effects of those changes.
These requirements
cannot be satisfied by individual reviews.
OPPD's response clearly indi-
cated that implementation of the procedure change took place two days prior to
PRC quorum review of the proposed procedure change.
S.0. G-30 as written or
interpreted should be revised to be in compliance with section 5.8.2 of the
Technical Specifications.
D2.3-5 (Deficiency) Construction package drawing changes without an approved
field change
The licensee's response is inadequate.
The location of the weld was not
clear on the drawing and an individual took the initiative to clarify or
interpret the. welding instructions shown on the drawing without following the
change process outlined in S.0. G-30.
The inspection team considered the weld
clarification and subsequent welding a possible design deviation from the
intent of Westinghouse which may affect the seismic qualification of the trans-
former.
D2.4-1 (Deficiency) Installation procedures were not in accordance with S.0.
G-21, GSEE-0517 and GSEE-0512
OPPD's response is inadequate. The corrective action specified by the licensee
was limited to reviewing the personnel qualification program to ensure only
qualified people were allowed to perform the tasks assigned.
No mention was
made concerning possible corrective action to improve procedures in either
detail or quality.
The following is in response to OPPD's specific comments:
l
ENCLOSURE 3
MR-FC-83-158 - OPPD indicated that tubing was field routed by verbal communi-
,
cation between the design engineer / planner and craft, and that this was in
accordance with ANSI N18.7-1976.
ANSI N18.7-1976 requires that modifications
be performed in accordance with written procedures, documented instructions or
drawings as appropriate.
Considerations are given to craft capabilities when
determining the required level of detail of the procedures.
The use of verbal
instructions (procedures) to install safety related equipment o* to relate
design criteria, acceptance criteria, or material requirements, does not satisfy
the requirements of S.0. G-26A or Appendix A of the Quality Assurance Program.
MR-FC-85-62 - OPPD indicated that a pre-job meeting was held to ensure that
cleanliness of the system was maintained, however, verification of cleanliness
after drilling through the 16 inch pipe was not accomplished.
The meeting
also discussed bolt tightening requirements and fitup requirements, however,
the flange faces were found to be out of parallel by approximately .030 inch
(using a caliper) and the joint was leaking.
OPPD indicated that the loss of the existing flow element was not part of the
modification since it was not known at the time of design, and that a safety
analysis was performed to ensure that the loss of the flow element did not
introduce an unresolved safety question.
Information made known to the inspec-
tion team during the inspection indicated that the flow element was lost in the
Fall of 1984, while the modification to replace the element was initiated in
1985, which appears to contradict the above statement.
Also, the analysis to
determine whether an unreviewed safety questicn existed regarding the lost flow
element was not performed until questions were raised by the inspection team.
Over a year had elapsed from the time that the element was lost to the point
when the analysis was actually performed.
MR-FC-84-61 - OPPD stated that craftsman knowledgeable in the requirements to
safely w Fd in the vicinity of the valve were available.
OPPD does not indi-
cate that these welders were actually used to perform the welds, that the
vendor recommended prerequisites for the welding were known by the welders, or
that the vendor's welding procedure was used.
5.0. G-21 indicates that the
planner is responsible for specifying any special tools, skills, processes, and
suitable environmental conditions for accomplishing the activity, and the
prerequisites to be satisfied for a given activity.
Reliance upon memories of
welders to establish vendor-recommended welding prerequisites (rather than
planner generated procedures) is inadequate.
MR-FC-84-74A - OPPD indicated that " random inspection" means random selection
of a minimum of 10% of the specified splices including appropriate hold points
for QC.
Procedure GSEE-0512 step 4.2 states:
" Notify QC prior to beginning splice procedure.
NOTE:
Plant QC shall inspect a minimum random sample of 10%
of the conductor splices for conformance with these
procedures."
It is clear from reading GSEE-0512 that QC shall be notified prior to beginning
a splice procedure (i.e. 100% of splices).
The procedure is also clear that QC
is to randomly select 10% of those splices, and to perform an inspection.
If
OPPD does not intend to have QC notified prior to each splice activity and to
have QC perform a 10% random (unbiased) inspection, then procedure GSEE-0512
should be revised.
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ENCLOSURE 3
D2.4-2 (Deficiency) Failure to follow procedure requirements
.
The following is in response to OPPD's specific comments:
MR 81-80 - OPPD did not believe that the finding associated with MR 81-80
regarding QC (QA) hold points for material verification prior to installation
was a deficiency and requested that the finding be reclassified as an observa-
tion.
It was the understanding of the inspection team that QC (QA) verifica-
tion of material acceptability was required by the procedure prior to installa-
tion and not at some later date.
This particular finding should remain open
until additional information can be reviewed.
MR 85-105 - The modification procedure ord not control or provide status of
the Halon fire suppression system as required.
A continuous fire watch was not
established as required.
Technical Specifications also require that backup
fire suppression equipment must be provided when the Halon system is inoper-
able. OPPD did not adequately respond to the concerns noted, in either expla-
nation or corrective action.
,
,
,
MR 84-119 - 5.0. G-20 requires a shift supervisor signature for tagging'out of
equipment.
Tags were hung and work was in progress without the shift superviscr's
review and approval.
OPPD did not adequately respond to this concern and did
not recommend corrective action.
OPPD's review of D2.4-2 indicated that each of the findings cited was an
isolated case. The SSOMI revealed that over 50% of the modifications reviewed
during the outage exhibited concerns in which procedures were not being fol-
lowed.
Individual specific situations involving a procedure deviation may be
considered isolated occurrences,'however, the generic concern of inadequate
procedure observance should be a concern to OPPD and warrant corrective action.
D2.5-1 (Deficiency) Inadequate welding, end preparation, and inspection
associated with the replacement of valve MS-100
It was the understanding of the NRC inspectors that none of the deficiencies
associated with the installation of value MS-100 was identified by 0 PPD's
QC inspectors prior to their being notified of the concerns by the S50MI
inspection team.
Regarding the concern involving violation of minimum wall,
OPPD indicated that an OPPD QC inspector had also observed and reported this
condition.
The 550MI inspection team was not informed of that during the
inspection.
The effectiveness of OPPD's corrective action should be reviewed
during followup inspections.
02.5-2 (Deficiency) St.i mic instrumentation tubing span violations
between supports
OPPD did not believe that a deficiency existed and that D2.5-2 should be
reclassified as an observation because the tubing was installed in accordance
with applicable requirements and procedures.
OPPD stated that the tubing
supports were not installed in accordance with the Stone and Webster guideline,
that the planner was aware of the deviation and that calculations were
requested to be performed to justify the support spacings that were used.
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s
EECLOSURE 3
The NRC inspection team was not informed of any 0 PPD initiated action being
-
taken to resolve problems associated with MR-83-158 prior to the time that NRC
concerns were voiced to 0 PPD.
Despite the level of attention given MR-83-158
during the design inspection part of the SS0MI, the installation was not in
accordance with design requirements and additional engineering reviews had to
be performed to accept the as-built configuration.
Documentation that supports
OPPD's corrective action, including engineering calculations and reviews,
should be reviewed by the NRC.
D2.5-4 (Deficiency) Installation discrepancies found in installation of
safety injection tank relief valves
OPPD did not believe that D2.5-4 was a deficiency and requested that the
deficiency be reclassified as an observation since an engineering analysis was
performed on the surface discontinuities and that the weld was PT'd and found
to be acceptable.
During the SSOMI, the inspection team requested several welds which were
previously PT accepted to be re-PT'd for evaluation.
The inspection team
requested the weld associated with SI tank 6B to be reinspected.
A written
response from a QC inspector stated that the indication was filed on but not
totally removed, however, it passed PT.
There appears to be some confusion as
,
to whether the PT was ever accomplished as requested.
OPPD should be able to
produce the NDE results for the inspection performed on 12-16-85. The engi-
neering analysis which accepted the surface discontinuities should also be
reviewed for adequacy.
D2.5-5 (Deficiency) Inadequate flow element flange installation
OPPD stated that at the time the craft signed off the step in the installation
procedure the flange wasn't leaking and that OPPD uses leakage as the primary
criterion when installing flanges.
OPPD also stated that the flange faces
were visually determined to be parallel by the modification planner.
Upon walkdown of MR 85-62 the inspection team noticed that the flange was
leaking and that the flange faces were visually out of parallel and assumed
this to be the cause for the leakage.
Measurements were later taken using a
caliper and the flange faces were determined to be out of parallel by approxi-
mately .030 inch.
It is requested that
documentation be reviewed which would
verify that the CCW system was at normal operating pressure at the time of
craft sign-off for nonleakage.
D2.5-7 (Deficiency) Weld inspections not accomplished for transformer base
welds to the imbedments
OPPD stated that the procedure for MR-FC-105 did not have a signoff in the
procedure body itself to document QC notification prior to performing work.
However, QC was notified prior to the start of work and did perform the
required visual inspection.
Clarification of the actual events surrounding the QC inspection should be
provided by OPPD.
The inspector who reported the concern recalls the follow-
ing:
i
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ENCLOSURE 3
.
- An NRC inspector wat present during the welding
A QC inspector was not present during the welding
.
The welder did not know whether the weld was to be inspected, and
asked the NRC inspector whether he knew
'
1
Several times during the inspection, the inspection team requested
that the inspection records be produced, however, the records
could not be found
The planner / engineer was not aware of the inspection requirements
specified in GSEE-0517 section 5.2.2
There appears to be inadequate control and documentation o, the inspection
effort.
Corrective action regarding this deficiency was not addressed by OPPD.
D2.6-1 (Deficiency) Inadequate welding and nondestructive test inspection
OPPD accepted the overall deficiency but rejected the individual finding
involving MR 84-061.
OPPD contended that QC inspected the weld and determined
that the crater pit was not sufficient to reject the weld, and that testing
verified the acceptability of the welds.
It appears that OPPD is relying upon
the original PT results, which were accepted as satisfactory, and that the
re-PT inspection requested by the NRC may not have been accomplished.
See
response to D2.5-4.
Additional followup will be required to better determine the sequence of
events and which inspections were actually performed.
D2.8-1 (Deficiency) Inadequate requirements for recording of data resulted
in an indeterminate battery charger load test
OPPD did not believe that D2.8-1 was a deficiency and requested that the
finding be reclassified as an observation because the test was accomplished
according to procedures.
In response to the above, the inspection team notes that the test procedure
required that data be obtained to document that the inverter and battery
combinavion was capable of performing for at least one hour at the proper
voltages. The. test performed did not specifically record data to verify
acceptance.
The test data should have included:
starting time of test
initial float and equalizing voltages
voltage values recorded at regular intervals (e.g. , eve'ry
five minutes) during conduct of the test
final float and equalizing voltages at the completion of the test
- completion time of test.
No data was taken to demonstrate that the system performed adequately during
the test or that the duration of the test was controlled and documented.
It is
also not clear whether the modification test performed met the requirements of
-5-
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ENCLOSURE 3
- .
D2.8-2 (Deficiency) Test procedure did not verify design concept
under accident conditions
-
OPPD accepted the deficiency but did not believe that a generic concern existed
and therefore did not specify any corrective action.
The inspection team,
however, believes that corrective action is required as evidenced by concerns
involving MR 84-119, MR 83-158 and MR 84-74A.
Modifications to plant compo-
,
nents or systems should be adequately tested to verify acceptability of the
l
intent of the modification and to ensure that modifications do not adversely
l
affect the design basis or the safety of operations.
D2.9-2 (Deficiency) Inadequate warehouse storage of safety-related material
0 PPD indicated that the items identified by the inspection team were
improperly stored, however, OPPD had implemented a project to verify the
adequacy of CQE material and storage.
OPPD also indicated that QA had
previously identified the concerns of D2.9-2 and was in the process of taking
corrective action.
Because of the action taken OPPD requested that the
deficiency be reclassified as an observation.
The inspection team was not informed that OPPD had identified the same concerns as
those of D2.9-2 and had implemented corrective action.
OPPD should provide
documentation (nonconformance reports, audits, surveillances and corrective
actions) to support the above remarks.
D2.9-3 (Deficiency) Inadequate QC surveillance of '.emporary
safety-related storage areas
OPPD stated that QC inspections were not missed nor late according to
procedures and requested that D2.9-3 be reclassified as an observation.
S.O. G-22 clearly indicates that a periodic inspection of all temporary CQE
storage areas should take place at least once each month.
The term " month" is
commonly understood to be a period of time of approximately 30 days.
Based
upon the records available this interpretatior; would indicate inspection
problems with seven of the 13 temporary storage areas.
OPPD should produce
documentation to clarify when the areas were opened and closed, or other
auditable records that to indicate that control of CQE areas was being main-
tained.
It appears that S.0. G-22 is either inadequate or is not being fol-
lowed.
The NRC also reviewed the licensee's responses to the following deficiencies
and unresolved items and considers the responses to be acceptable.
Confirmatory
inspection of the licensee's corrective actions may be conducted.
D2.2-1 (Deficiency)
Lack of documented safety evaluations for installation of
lead shielding on safety-related piping and components.
D2.2-2 (Deficiency) Lack of documented safety evaluation for installation of a
penetration fitting through a fire barrier.
D2.2-3 (Deficiency) Lack of documented safety evaluations for electrical
jumpers installed for extended time periods.
o
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.
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.
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%
ENCLOSURE 3
D2.3-1 (Deficiency) Inadequate control of construction package drawings and
,
drawing lists.
-
D2.3-4 (Deficiency) Training not accomplished prior to approval of procedure
change.
U2.3-1 (Unresolved
On-the-spot changes not approved by PRC within Technical
Item)
Specification time constraints.
D2.3-6 (Deficiency) Calibration procedures changes without approved field
changes.
U2.3-2 (Unresolved
Lack of calibration record for a pressure source used
Item)
for safety-related channel calibration
D2.5-3 (Deficiency) Inadequate support of seismic instrumentation tubing
near air regulators
D2.5-6 (Deficiency) Installation discrepancies found in installation of new
delta T power process loop instrumentation
U2.5-1 (Unresolved
Questionable installation practices relative to installa-
Item)
tion of delta T power process loops cables and panels.
U2.5-2 (Unresolved
Foxboro transmitter 0-ring replacement not documented to
Item)
maintain environmental qualification
D2.6-2 (Deficiency) Plant welding accomplished to nonapplicable weld procedures
D2.9-1 (Deficiency) Inadequate temporary storage of safety-related material
D2.10-1 (Deficiency) Inadequate corrective action for control of installation
of lead shielding
,
D2-10-2 (Deficiency) Inadequate corrective action for resolving System
Acceptance Committee discrepancies identified to systems
4
-
accepted for operation
i
1
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ENCLOSURE 4
'
8
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UNITED STATES
,[ \\ g (' i
NUCLEAR REGULATORY COMMISSION
g. .
f. j
WASHINGTON, D. C. 20555
k.u /
....
Docket No. 50-285
Omaha Public Power District
ATTN: Mr. Bernard W. Reznicek
President and Chief Executive Officer
1623 Harney Street
Omaha, Nebraska 68102
Gentlemen:
SUBJECT:
SAFETY SYSTEMS OUTAGE MODIFICATION INSPECTION; REPORTS
50-285/85-22 AND 50-285/85-29
This refers to your letters, dated April 15, and May 22, 1986, in response to
our letters dated January 21, and March 19, 1986 which respectively forwarded
the design portion and installation / test portion of the Fort Calhoun Station
Safety Systems Outage Modification Inspection conducted by the NRC's Office of
Inspection and Enforcement.
These inspections were part of a trial NRC program
being implemented to examine the adequacy of licensee management and control of
modifications performed during major plant outages.
Thank you for informing us of the corrective and preventive actions documented
in your letter.
In addition, we appreciated the opportunity to discuss your
short and long term corrective actions in the conference at our office on
July 10, 1986.
Certain of the items require additional information, review and/or reinspection
)
to assess their acceptability.
The enclosure to this letter describes these
items, including specific concerns regarding individual responses.
A meeting on August 7, 1986 has been planned to discuss the particular inspec-
tion findings and remaining specific concerns regarding your responses.
The
enclosed evaluation of your responses is provided to assist in your preparation
for this meeting.
Formal enforcement action relating to the subject report will be sent to you
following the meeting on August 7, 1986.
Resolution and followup inspection for the items in the enclosure will be
handled by the Region IV Office.
The NRC may perform confirmatory inspections
of certain items addressed in the subject inspection reports.
In addition the NRC will monitor your short and long term corrective actions
described in your letters, including the results and conclusions of the system-
atic review of the design change / modification program and your increased
emphasis on completion of design work as part of pre-outage planning.
-1-
%
ENCLOSURE 4
Omaha Public Power District
,
In accordance with 10 CFR 2.790 (a), a copy of this letter, the enclosures,
and your letters dated April 15, and May 22, 1986 will be placed in the NRC's
Public Document Room.
Should you have any questions concerning this letter, please contact me or
Mr. Dorwin A. Hunter (817-860-8103) of this office.
Sincerely,
SIGNATURE
Enclosures:
1.
Fort Calhoun Inspection Items Requiring Reinspection and/or
Additional Information
cc w/ enclosures:
See next page
.
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