ML20205M671
| ML20205M671 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/22/1986 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| IEC-80-18, IEIN-83-64, LIC-86-192, NUDOCS 8704020456 | |
| Download: ML20205M671 (63) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536-4000 May 22, 1986 LIC-86-192
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1 Mr. Robert D. Martin i
Regional Administrator
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U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Tx. 76011
Reference:
(1) Docket No. 50-285 (2) Letter dated January 21, 1986, from J. M. Taylor to B. W. Reznicek - Safety System Outage Modification Inspection (Design) 50-285/85-22 (3) Letter dated March 19, 1986, from J. M. Taylor to B. W. Reznicek - Safety System Outage Modification Inspection (Installation & Testingl 50-285/85-29 (4) Letter dated April 15, 1986, from B. W. Reznicek to J. M. Taylor - Safety Systems Outage Modification Inspection (Design) 50-285785-22
Dear Mr. Martin:
Safety Systems Outage Modification Inspection (Installation and Testing) 50-285/85-29 Reference (3) transmitted the subject Safety System Inspection Report which documented the results of a pilot in:pection program conducted by a team composed of NRC headquarters Inspection and Enforcement (I & E) and contractor personnel. The inspection of the installation and testing phase of the 1985 refueling outage modifications completed the overall trial inspection program and supplements the inspection report covering the design phase (Reference 2).
The purpose of the installation and testing portion of the trial safety systems outage modifications program was to inspect the installation and testing of selected modifications accomplished during the 1985 refueling outage.
Reference (3) identified corrective action for specific items which OPPD plan-ned to complete prior to plant startup following the outage.
These corrective actions were primarily short term actions to address specific concerns identi-fled during the inspection. OPPD completed the corrective actions as planned prior to plant startup.
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R. D. Martin LIC-86-192 Page 2 Reference (3) did not require OPPD to provide a response to the inspection findings. However, we have had conversations with your staff and believe that additional information will assist your staff in reviewing the inspection report. Reference (4) noted that a response to Reference (3) would be forth-coming by May 15, 1986.
Subsequent conversations between Mr. J. E. Gagliardo and my staff resulted in the addition of information to this response, and hence, a weeks delay. Therefore, an item-by-item response to deficiencies and unresolved items is provided in the Attachment.
Review of the inspection report has determined that certain programmatic weak-nesses exist in OPPD's modification program. As discussed in Reference (4),
actions to improve the modification process will be the subject of the Syste-matic Review of Design Change / Modification Program that has been established at OPPD. Where appropriate, this systematic review program has been identified in OPPD's response to specific findings which require long term corrective action to improve the modification program.
The Design Change / Modification Review Committee is actively performing a review of the complete modification program at OPPD. An Executive Steering Committee and a Working Group comprise the Review Committee. At the first meeting the Review Committee established a more conservative design change / modification program as interim action until the Review Committee has completed their review and appropriate recommendations have been completed. An Executive Order has been issued by the Executive Steering Committee to implement the interim act-ions. Any delays or exceptions to the Order must be approved by the Executive Steering Committee. The following is a summary of the actions imposed by the Order.
- 1. Any deficiencies or discrepancies noted by the System Acceptance Commit-tee (SAC) shall be corrected and accepted within 90 days of the initial SAC acceptance of the Modification.
This is applicable to modifications completed after June 1, 1986.
- 2. An independent review (per the QA Plan) will be performed on all design changes to safety-related structures, systems, and components as part of completing final design package. This review will be completed prior to the construction package being accepted by Plant Review Committee.
If a field enange or procedure change is necessary an additional independent review will be done. This independent review will be completed prior to the SAC acceptance.
- 3. The following items will be completed by August 31, 1986:
a.
All outstanding SAC deficiencies will be closed out for modifications completed prior to June 1, 1986.
b.
All emergency modifications will be reviewed and marked up drawings made available to GSE for preparation of after-the fact design packages, if required.
Ar R. D. Martin LIC-86-192
-Page 3 i
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The existing backlog of EEAR's/ Modifications will be viewed with the intention of significantly reducing the backlog. This applies
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to modifications completed prior to June 1, 1986.
4.
The schedule for normal modifications after June 1,1986 is as follows:
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a.
Material must be on site 30 days prior to start of scheduled construction.
b.
Any normal modification request must be in the hands of 1
engineering 18 months ahead of scheduled construction.
i c.
Construction packages for non-refueling normal modifications must be at the Fort Calhoun Station 30 days prior to start of scheduled construction.
d.
Construction packages for refueling normal modifications must be at the Fort Calhoun Station 60 days prior to start of scheduled i
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construction.
l 5.
Criteria will be established for determining SAC reviews. This will j
be completed prior to June 30, 1986.
i The Working Group is performing an indepth programmatic review of OPPD's modification process. The following topics are being addressed by the Working Group:
i 1.
2.
USAR 3.
Design Basis Documents 4.
Testing Requirements 5.
QA/QC Involvement 6.
Procurement 7.
Systems Acceptance Committee 8.
Emergency and Minor Modifications 9.
Reviews and Approvals 10.
Pre outage Planning j
- 11. Training and Qualification 12.
Field Changes 13.
Proper Documentation Discussion of these items are scheduled throughout the months of May and June.
The last discussion is scheduled for' June 18, 1986. The Working Group will be finalizing its recommendations and preparing the report during the last aart of
.i June.
The Working Group will provide a schedule for implementation of tie i
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.r R. D. Martin LIC-86-192 Page 4 recommendations as part of the report. The report is scheduled to be presented to OPPD Vice Presidents by June 30, 1986.
i If you desire clarifications or additional information, please do not hesitate to ask.
Sinegrely, 4
I R. L. Andrews l
Division Manager i
Nuclear Production l
RLA/HMT/me Attachments i
cc: LeBoeuf, Lamb, Leiby & MacRae James Taylor, NRC Director, Office of Inspection & Enforcement 1
i D. E. Sells, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector i
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i ATTACHMENT A
e D2.2 Deficiency - Lack of documented safety evaluations for installation of lead shielding on safety-related piping and components.
Temporary and permanent lead shielding installations were in place on safety and nonsafety-related piping and components with no documented engineering anal-yses or safety evaluations accomplished to support the installations.
Prior to June 1984, no documented procedure existed for control of lead shielding in-stallations. Omaha Public Power District (0 PPD) Standing Order (S0) G-57,
" Installation of Temporary Lead Shielding," issued in June, 1984, allowed lead shielding to be installed prior to engineering evaluation and did not address the need for safety evaluations.
The problems discussed above occurred in spite of 10 CFR 50.59, IE Information Notice 83-64, IE Circular 80-18 and similar Institute of Nuclear Power Opera-tions (INPO) lead shielding findings at Fort Calhoun in 1982 and 1984. This is discussed further under Corrective Actions in Section 2.10.
OPPD'S RESPONSE Preliminary guidelines were issued to calculate acceptable shielding loads shortly after the problem was identified by INP0 in 1982.
The Plant Engineer was provided a method of calculating shielding loads by Generating Station Engineering (GSE) to ensure that the installation would meet certain predefined criteria.
If a condition was so complex that these methods could not be used to determine loadings, GSE was requested to analyze the loads.
Procedure Change 10235 was implemented in April, 1983 to amend Standing Order G-17 to 4
require the Plant Engineer to review proposed lead shielding installation prior to its installation.
It has been determined that it was due to lack of emphasis in our procedures for doing 10 CFR 50.59 analyses for temporary modifications that these analyses were not completed for installation of lead shielding.
It was interpreted that adherence to guidelines was adequate to perform the function of the safety evaluation.
i Significant changes were made to Standing Order G-57, Installation of Temporary Lead Shielding, in March, 1986. The Standing Order has been rewritten using INP0 Good Practice TS-411, Temporary Lead Shielding, as a guideline.
The new procedure outlines specific types of analyses which should be considered before installing temporary shielding and requires a safety evaluation be performed and attached to the Temporary Shielding Request Form. The Plant Engineer or his alternate must sign the Temporary Shielding Request Form, giving his concur-rence for the shielding to be installed after ensuring the required analysis and safety evaluations are performed and attached.
Procedures have also been enacted to ensure that lead shielding that is ap-proved for installation in accordance with SO G-57 will be properly secured and supported in accordance with seismic and structural design requirements.
Health Physics, Maintenance and Plant Engineering personnel have been trained on the procedures to install temporary lead shielding. A walkdown of plant areas was completed to verify that temporary lead shielding has been identified.
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.r 02.2 Deficiency - (Continued)
OPPD'S RESPONSE (Continued)
In addition to the above, the following corrective actions have been completed:
Except for the following, lead shielding has been removed from identified locations.
a) Temporary shielding log numbers 1,6, and 7, - An engineering analysis was performed for the shielding at these three locations. The analysis indicated that the installation of this lead shielding has not imposed unacceptable loads on the piping and supports. The 10 CFR 50.59 safety evaluations for the three locations where lead shielding is still in place have been completed.
Design verification review and system accep-tance by the plant staff will occur in accordance with OPPD procedures.
b) During the walkdown of Room 60, a permanent installation of lead shielding on a 1" pipe was discovered in the CVCS.
Records indicate that the lead shielding was installed under DCR 74A-4.
Gibbs, Hill, Durham and Richardson Inc. (GHDR), designed the piping support system.
l OPPD has evidence that the piping support system was analyzed by GHDR and that a safety evaluation was performed. OPPD is reviewing the files to locate the calculations and as-built documentation for this installa-tion to verify that an auditable trail of the installation is available.
Locations where lead shielding was removed were physically inspected and it has been concluded that no degradation was caused because of the temporary lead shielding installation.
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D2.2 Deficiency - Lack of documented safety evaluation for installation of a penetration fitting through a fire barrier.
During inspection of MR 84-179 (addition of HCV-1105/1106 to SG isolation signal) a swagelok fitting was found to be installed through the fire barrier at the entrance to room 57 between the Class I switchgear room and the pene-tration room. The fitting had been installed for several years and was apparently used for calibration of instruments in the switchgear room. This was an apparent unapproved / unauthorized design change to the plant since no documentation could be found to indicate that it had received appropriate engineering review and approval, and that an appropriate safety evaluation had been accomplished.
OPPD'S RESPONSE No documented evidence could be found pertaining to the installation of this 3/8" stainless steel tubing. The penetration was probably installed between the years 1980-1982.
The tubing was installed to facilitate I&C calibrations by providing a means to supply instrument air across the barrier. The tubing allowed air to be supplied without requiring the integrity of the barrier to be degraded by leaving the fire-rated door open during the calibration process.
The stainless steel tubing penetration appears to have been installed prior to the rigid controls OPPD has established pertaining to Fire Barrier Penetrations.
The subject penetration is a small (3/8") stainless steel tube which penetrates the fire barrier transom above door 1013-1. Door 1013-1 is a 3-hour fire rated i
door between the switchgear room and the upper electrical penetration room.
The tubing connects the west switchgear room and the upper electrical penetra-tion room when the tube is uncapped and fire door 1013-1 is closed. When not in use, the penetration is capped on both ends immediately adjacent to the door.
OPPD has examined and evaluated the subject penetration. A safety evaluation in accordance with 10 CFR 50.59 has been completed and concluded that the pene-tration did not involve an unreviewed safety question.
The penetration is a bulk-head type fitting and its presence does not degrade the rating of the fire barrier. As a separate but related action, fire door 1013-1 is scheduled to be replaced and a maintenance order for this has been prepared. The subject pene-tration will be relocated and this action will be properly documented. The relocation will be performed in conjunction with replacement of the door. Upon completion of the relocation of the penetration, the penetration will fully com-ply with the provisions of SO G-58.
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D2.2-2 Deficiencu - Continued j
OPPD'S Response (Continued) i i
The following-facts supports OPPD's determination that the penetration does not degrade the fire barrier or create a safety concern.
- 1. OPPD is committed to Branch Technical Position 9.5-1 regarding pene-trations through fire barriers, which states: " Openings through fire n
barriers for pipe, conduit and cable trays which separate fire areas
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should be sealed or closed to provide a fire resistance rating at least i
j equal to that required of the barrier itself." The stainless steel Swagelok fittings are noncombustible and provide __ a fire resistance i
rating at least equal to that of the barrier itself, t
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- 2. The size of the penetration is less that 1" in diameter, which is the i
. plant criterion for the minimum penetration size that does not have to be sealed per NRC Appendix R interpretations and complies with SO G-58.
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- 3. There are no combustible materials located directly opposite the fit-
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tings on either side of the door.
Procedures to control Fire Barrier Penetrations have been in effect at Fort Calhoun Station for a long period of time. However, in September, 1985, S0 i
G-58 was issued to provide additional controls.
SO G-58, specifically addres-l ses the concerns of this finding. The purpose of the Standing Order is:
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- 1. To identify Fire Barrier Penetrations in safety related areas of Fort l
Calhoun Station.
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- 2. To define the various approved methods of Fire Barrier Penetration seal-i ing and their applications.
- 3. To. delineate the inspection requirements of sealed Fire Barrier Penetrations.
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- 4. To provide instructio's for maintaining an updated list of Fire Barrier-n Penetrations.
l S. To provide requirements for personnel qualifications and training.
The procedure that has been established provides effective control of the condi-
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tion identified by this finding. OPPD believes that current controls will prevent recurrence.
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D2.2 Deficiency - Lack of documented safety evaluations for electrical jumpers installed for extended time periods.
A review of the temporary modification log revealed that safety-related elec-trical jumpers had been installed for as long as 18 months without any safety evaluations being accomplished.
Electrical jumpers installed for long periods of time and not associated with direct maintenance are considered design changes.
10 CFR 50.59 requires safety evaluations for temporary or permanent l
design changes.
In 1982 INPO identified that a number of jumpers had been in use at Fort Calhoun for extended periods.
INP0 recommended that a review of all jumpers be done and the appropriate ones be processed as permanent design changes. This inspection found that the situation still exists.
In addition, it was noted that shift supervisors did not review the temporary modification log.
Instead, the mechanical or electrical supervisor reviewed and signed the log once per month. When a shift supervisor was asked about a specific temp-orary modification, he was unaware of it.
OPPD'S RESPONSE The finding was due to a lack of specific documentation which recorded safety evaluations pertaining to the installation of electrical jumpers.
Electrical and mechanical jumpers and blocks are controlled at Fort Calhoun Station by Standing Order 0-25.
This procedure relied on formal approval by members of the Plant Review Committee to provide the safety evaluation for the installation of electrical jumpers. This method of assuring safe use of electrical jumpers has been in affect at Fort Calhoun Station for many years.
During this time, numerous electrical jumpers have been installed and removed using the PRC members safety assessments. This has been accomplished without any adverse safety effects. The jumper log is periodically reviewed by the Plant Engineer and the Supervisor, I&C and Electrical. Jumpers that have been in place for 18 months or longer are identified. Jumpers that are so identified are evaluated to determine if they should be made a permanent change. These reviews and evaluations have not been formally documented.
Prior to revision No. 17, dited March 21, 1986, Fort Calhoun Standing Order 0-25, Electrical and Mechanical Jumpers and Block Control, specifically re-quired that "if the jumper or. block affects safety related equipment, PRC (Plant Review Committee) approval must be obtained prior to installation" and such approval was documented on Form FC-66.
PRC approval consisted of approval by three (3) PRC members (a. cognizant PRC member, a cognizant member with a Senior Reactor license and the Plant Manager). Determination of whether or not the jumper or block affected. safety related equipment was made by the Shift Supervisor.
This approval procedure assured that a safety evaluation was made for each jumper prior to installation to ensure that plant safety was not compromised. A monthly review of the plant jumper log by the Supervisor, I&C i
and Electrical Maintenance, and the Plant Engineer was prescribed. Jumpers which remained in place for a period greater than 18 months were submitted to the Technical Support Group to determine if the electrical jumper should be considered a design change.
Numerous jumpers have been installed successfully following the procedure summarized above. Many are still in place. The procedures have been effective in assuring that safety standards have been met.
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a D2.2-3 Deficiency - Continued OPPD'S Response (Continued)
OPPD has reviewed the electrical jumper log. The review has justified the continued use of each jumper; determined if the jumper should be made permanent and appropriate design documentation prepared; and formal documentation in accordance with 10 CFR 50.59 of safety related electrical jumpers left in place has been completed.
Standing Order 0-25 was revised on March 21, 1986 to require that a technical assessment and a safety evaluation be performed and documented prior to approval for installing electrical safety related jumpers or blocks. This revision also includes guidance for the person performing the technical assessment and safety evaluation.
Safety evaluations will be performed in accordance with 10 CFR 50.59. The OPPD procedure was revised using INP0 Good Practice, OP-202; " Temporary Bypass, Jumper, and Lifted Lead Control". OPPD will revise 50 0-25 to prescribe documentation requirements for review of this jumper log and initiating Engineering Evaluation Assistance Requests for resolution of permanent jumpers. A tracking method will be developed to ensure that EEARs, requesting jumper or block evaluations, are resolved in a timely manner.
OPPD has always maintained a jumper logging system since the control room became operational.
Procedures to deal with the use of jumpers have been improved through a number of revisions to reflect industry standards and operating experience. The procedure addressed the safety concerns of using jumpers by requiring prior approval of the most experienced and knowledgeable people in plant operations.
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D2.3 Deficiency - Inadequate control of construction package drawings and drawing lists.
A review of drawings and drawing lists for seven construction packages indi-cated that drawings were not always adequately controlled. The results of the review are provided in Table III. Three of the seven construction packages had the following concerns:
MR 85-009 (replace penetration subassemblies) and MR 84-119 (replace instru-ment inverters) had extra drawings which were marked "for construction" but were not on the drawing list.
MR 84-119 had incorrect drawing revision numbers, a wrong drawing number in the drawing list, and two drawings which had the same revision number and date but had different information on them.
MR 83-158 (addition of air accumulators) had no P & ids in the construction package when reviewed by the team.
These discrepancies were not in accordance with the requirements of SO G-21,
" Station Modification Control", or Generating Station Engineering (GSE) Proce-dure B-3, " Drawing Production". The major concern in cases such as these was that installations could be accomplished to incorrect or outdated design requirements.
OPPD'S RESPONSE The first two items in Table III, B. of the inspection report concern drawings marked "For Construction" but not included on the drawing list.
Drawings included in construction packages and stamped "For information Only" are ad-ditionally stamped "For Construction". The "For Construction" stamp is placed on "For Information Only" drawings to comply with Standing Order C-5, 5.2.,
Construction Package Prints.
Paragraph 8.2.1 is interperted to require the "For Construction" stamp on any drawing that is included in the Construction Package. The information drawings are not required for installation, but provide additional information to the construction package reviewers and con-tractors. These drawings are available from the satellite drawing files and have not been altered for the modification. Therefore, these drawings were not always included on the drawing list.
The next three items are errors that resulted from typographical errors not detected in the checking process.
The last item concerns two P&ID drawings indicated on the drawing list but not in the construction package. Sufficient information could not be obtained to identify the precise cause of this finding. Several explanations are possible.
The drawings could have been lost or misplaced and not reported as such to the field supervisor or planner. The P& ids could have been removed after instal-lation, but prior to System Acceptance, to facilitate markup of a second set of drawings for submittal to drafting.
(P& ids must be updated prior to System Acceptance Committee review). The inclusion of P& ids in the construction pack-age is to enhance the review process of the proposed modification, however, they are not used for detailed installation.
P& ids are representations of the l
system.
Isometric drawings, detailed instructions in the procedure, or detail-ed direction from the planners as allowed by the procedures, are followed for installation.
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D2.3 Deficiency - (Continued)
OPPDS RESPONSE (Continued)
GSE procedures will be reviewed to clarify when "For Information" drawings should be part of the construction package and if they are to be included how they should be referenced on the drawing list. The need to strengthen control of construction drawings in the field will be reviewed as part of the Design Change / Modification Program discussed in Reference (4).
Request for prints and drawings to be included in the construction package are now prepared by the Engineering Services Department personnel. The stamped prints are double checked against the drawing list prepared by the design engineer.
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D2.3 Deficiency - Unapproved changes to installation procedures Installation procedures for MR 84-96 (replace HFA relays), MR 84-51 (replace Dresser-Hancock valves), MR 83-158 (addition of air accumulators) and MR 84-61 (union installation on SIT relief valves) had pen and ink changes and additions without approved field changes or procedure changes as required by SO G-30, "Setpoint/ Procedure Changes". Also, the procedure for MR 84-61 was signifi-cantly revised by an on-the-spot change, which was also not in accordance with S0 G-30.
In other cases it could not be determined what was changed by proce-dure or field changes because of nondescriptive explanations on the change cover sheet or annotations in margins of the procedures.
OPPD'S RESPONSE After extensive review, OPPD was unable to find any basis for this deficiency.
Existing procedures for control of pen and ink changes to modification control drawings are considered adequate. However, the following additional information is provided for clarification.
i The Modification Control Documents for MR-FC-84-96, MR-FC-84-51, MR-FC-83-158 and MR-FC-84-61 have been reviewed by Quality Control, Quality Assurance and the System Acceptance Committee for adherence to the requirements of standing orders including Standing Order G-30 and found to be satisfactory. The pro-cedure changes and field changes prepared for the subject modifications have i
been reviewed and approved by the PRC. The use of an on-the-spot change for MR-FC-84-61 was found to be appropriate and the descriptions or markups pro-j vided with the field changes were found to be adequate.
OPPD procedures do permit three types of pen and ink annotations to l
modification control documents without preparing a field change or procedure change. One type of change is made to incorporate PRC comments prior to PRC approval. The second type of change is one made during PRC approval. This l
type of change is re-initialed and dated.
Changes made prior to PRC approval are initialed and dated. The third is to annotate remarks or comments added as additional information during the modification installation process.
The use of an "on the spot p'ghizant PRC members can invoke full PRC reviewfo l
scope of the change. The co i
prior to implementation if it is felt to be necessary.
PRC approval of an on-the-spot procedure change is.. required within 14 days of initial approval. The j-inability to fully describe field changes on FC-1033 is recognized in Standing Order G-30 and the use of markups is suggested where appropriate. Verbal I
clarification can be obtained if required. OPPD does not believe this is a i
deficiency and request that this finding be reclassified as an observation because our review indicates that the annotations were made in accordance with procedures.
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D2.3 Deficiency - Procedure change implemented prior to PRC approval Procedure change 13494 to Operating Instruction 01-FW-3 for Steam Generator Level Control was not reviewed by a quorum of the Plant Review Committee (PRC) prior to implementation of the change. The PRC met on this procedure change six days after implementation. This was in violation of Technical Specifica-
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i tions, Section 5.8.2, which required PRC approval prior to implementation of procedure changes.
OPPD'S RESPONSE Fort Calhoun Station Technical Specification 5.8.2 requires that each procedure (as specified in sections 5.1 and 5.3 of ANSI N18 7-1972 and Appendix A of USNRC Regulatory Guide 1.33) and changes thereto, shall be reviewed by the Plant Review Committee (PRC) and approved by the Manager-Fort Calhoun Station prior to implementation. Technical Specification 5.5.1.6a further specifies that the PRC shall be responsible for review of all procedures required by Specification 5.8 and changes thereto. Standing Order No. G-30, Setpoint/ Procedure Changes, has been implemented to ensure that Setpoint/ Procedure Changes are correctly approved and documented to satisfy the requirements of the above referenced Technical Specifications. Section 3.6 of the referenced Standing Order provides the procedure _to be followed for the approval of proposed procedure changes and the proper use of Section III of Form FC-68, Setpoint/ Procedure Change Form.
Specifically, the left-hand portion of Section III is utilized by a cognizant PRC member with the most knowledge of the proposed change to determine the following:
If any other members of the PRC (or others) are involved in this change, and if any PRC member would like to review the change in detail.
If a detailed review is requested, the PRC member must document his detailed review in the space provided in the right-hand portion of Section III.
If the procedure change is to be permanently incorporated.
If the change requires SARC review in accordance with Standing Order G-5, Appendix A.
If training is required before the change can be approved.
If training is required, a representative from training will verify training has been completed by his signature in the space provided in the right-hand portion of Section III.
PRC members, as specified in Technical Specification 5.5.1.7a, have review authority with regard to prop'osed procedure changes and shall recommend in writing to the Manager-Fort,Calhoun Station approval or disapproval. The Manager-Fort Calhoun Station approves proposed procedure changes prior to implementation as required by Technical Specification 5.8.2.
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D2.3 Deficiency (Continued)
OPPD'S RESPONSE (Continued)
PRC quorum requirements established in Technical Specification 5.5.2.5 apply to the minimum number of PRC members required to legally transact business when duly assembled (convened for a meeting).
Quorum requirements are not applicable to the conduct of the detailed review activities assigned and documented in Section III_of Form FC-68.
ProcedureChange13494t6.i!0perating Instruction OI-FW-3 was initiated on i
October 31, 1984. The Plant Engineer, Reactor Engineer, and Training were designated to perform the detailed review. The Plant Engineer and Reactor Engineer, both members of the PRC, reviewed the proposed procedure change on November 1, 1984. Training department review was documented on November 2, 1984. Procedure Change 13494 was approved by the Manager-Fort Calhoun Station on November 2, 1984. The revised procedure was implemented (placed in the Control Room and Administrative Office copies of the Operating Manual) on November 6, 1984. The above synopsis of the review, approval and implementation process for Procedure Change 13494 is in conformance with Technical Specification 5.8.2.
'PRC members provided a detailed review of the proposed change and the Manager-Fort Calhoun Station approved the change on November 2, 1984 prior to implementation on November 6, 1984.
OPPD personnel properly dnplemented the requirements of Standing Order G-30 and as a result no violation of OPPD procedures or Technical Specifications occurred.
OPPD personnel will continue to follow the procedure approval guidelines of Standing Order G-30 to ensure full compliance with Technical Specification 5.8.2.
In addition, Procedure Change 13494 as approved by the Manager-Fort Calhoun Station on November 2, 1984 was submitted and reviewed a second time at the PRC meeting on November 8, 1984. No adverse or other corrective comments resulted. A quorum of PRC members and the Chairman (Manager-Fort Calhoun Station) were present.
In view of the foregoing discussion, OPPD requests that the NRC reconsider and dismiss this finding as a deficiency.
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D2.3 Deficiency - Training not accomplished prior to approval of procedure change The training representative signed procedure change 13494 to 01-FW-3 prior to
-completion of training. This was contrary to SO G-30 requirements to complete training associated with.a procedure change prior to signing the change.
The i
signature on the procedure change was dated November 2, 1984 but training sheets were not issued to operators until November 5, 1984.
OPPD'S RESPONSE The exact cause of this finding is not known.
It is OPPD's policy and procedure to ensure that required training is completed prior to implementing a procedure change.
OPPD believes this finding to be an isolated occurrence. There are no other known circumstances in which a procedure change was approved prior to required training.
Procedures in force at Fort Calhoun Station are adequate to control-the occurrence of conditions similar to this finding.
The specific condition cited was corrected by completing the training. Train-ing department personnel who are authorized to document that training has been completed have been required to review SO G-30.
OPPD will emphasize the importance of ensuring that necessary training is accomplished prior to implementing a procedure change in accordance with SO G-30.
This subject is already controlled by the Plant Review Committee.
It should be noted that Procedure Change 13494 was not implemented until November 6, 1984. Therefore, even though there appears to be a discrepancy with the date recorded for the signature when training was completed, the training was accomplished prior to implementating the procedure change.
(See discussion of D2.3-3) 12
U2.3 Unresolved Item - On-the-spot changes not approved by PRC within 4
l Technical Specification time constraints A review of the procedure change log for on-the-spot changes -revealed the following concerns:
Calibration Procedure change 14765 to CP-ICAM, Calibration. Procedure change i
14766 to CP-APGM, and Surveillance Test procedure change 15259 to ST-CONT-7 J
were not returned to the clerk with PRC approval within 14 days. SO G-30 and section 5.8.3 of the Technical Specifications require PRC approval of on-the-spot changes within 14 days of issue of.the change. At the time of l
the inspection these changes could not be located to determine if they had been signed by PRC or not. This was considered to be an apparent violation of Technical Specifications. Changes 14765 and 14766 were dated May 31, 1985 and change 15259 was dated October 19, 1985.
]
Four clerical log errors were noted in that on-the-spot changes 15920, 15443, 14961, 14937 were not marked in the log as returned but in fact had i
been returned for processing. These were dated November 85, November 85, l
July 85, and July 85 respectively, i
The significance of these findings was that a full PRC review of on-the-spot changes may not be occurring in a timely manner and that the log was apparently i
I not being reviewed to check for such problems as identified above.
OPPD'S RESPONSE l
A brief summary of the requirement for implementation 'and approval of temporary (on-the-spot) changes is provided to assist in the review of this unresolved item.
Fort Calhoun Station Technical Specification 5.8.3 specifies that temporary changes to procedures may be made provided:
The intent of the original procedure is not altered.
l The change is approved by two members of the plant supervisory staff, at least one of whom holds a Senior Reactor Operators License on the unit affected.
The change is documented, reviewed by the Plant Review Committee and approved by the Manager-Fort Calhoun Station within 14 days of implementation.
Standing Order No. G-30, Setpoint/ Procedure Changes has been implemented to
}
ensure that temporary (on-the-spot) changes are documented, reviewed and approved to satisfy the requirements of the above referenced Technical Specifi-cation. Section 3.3 of the referenced Standing Order prescribes the procedure i
to be followed for the initiation, review and approval of temporary (on-the-1 spot) procedure changes and the proper use of Section II of Form FC-68, i
Setpoint/ Procedure Change Form. Specifically,Section II is utilized to document the review of the proposed temporary (on-the-spot) change by:
13
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U2.3 Unresolved Item (Continued)
OPPD'S RESPONSE (Continued)
A cognizant PRC member who will verify whether or not the change is needed immediately (on-the-spot).
NRC Senior Licensed PRC member Shift Supervisor The change is considered on-the-spot after all three signatures are obtained.
4 Temporary (on-the-spot) changes are submitted to office personnel who perform the following:
'Index each Setpoint/ Procedure Change Form.(FC-68) by numerical sequence in the Procedure Change Log i
Forward change to PRC for approval as prescribed in Section 3.6 of Standing Order G-30.
The Manager-Fort Calhoun Station must approve the temporary (on-the-spot) change within 14 days of implementation.
On-the-spot changes included in this unresolved item were reviewed to determine the timeliness of the approval process. The following is the result of this
)
review presented in tabular form:
i On-the-spot Date Date
_ Change No.
Subject Implemented Approved 14765 CP-ICAM 5/17/85 2/4/86 (Note 1) 14766 CP-APGM 5/17/85 2/4/86 (Note 1) 14937 ST-FH-1 6/28/85 7/2/85 14961 ST-CHEM-1 7/17/85 7/18/85 15259 ST-CONT-7 10/6/85 10/19/85 15443 MP-N0ZDAM-1 10/19/86 11/6/85 (Note 2) 15920 CP-SP-1 11/2/85 11/11/85 4
l NOTE 1:
On-the-spot procedure changes 14765 and 14766 were reviewed at the i
Plant Review Committee Meeting convened on May 21, 1985.
No adverse or corrective comments relating to these on-the-spot procedure t
changes were recorded in the PRC meeting minutes.
NOTE 2:
On-the-spot Procedure Change 15443 was reviewed at the Plant Review Committee meeting convened on October 21, 1985. No adverse or cor-i rective comments relating to this on-the-spot procedure change were j
recorded in the PRC meeting minutes.
l 14 4
l U2.3 Unresolved Item - (Continued)
OPPOS RESPONSE (Continued)
A review of the above information indicates that approval of the temporary 4
(on-the-spot) changes 14937, 14961, 15259, and 15920 was timely and within 14 days of the implementation. Temporary (on-the-spot) Procedure Changes 14765, i
14766, and 15443 were reviewed promptly by the Plant Review Committee.
No adverse or corrective comments relating to these temporary (on-the-spot) Pro-cedure Changes were recorded in the PRC meeting minutes.
Each of the procedure changes resulted in revisions to their respective procedures. Although the Manager - Fort Calhoun Station (or his designated alternate) did not sign off (approval signature) these procedure changes within 14 days of implementation, no adverse impact on plant safety was created. Operations Incident No. 2323 was initiated to further investigate and evaluate the failure to approve Proce-dure Changes 14765 and 14766 within 14 days of implementation.
In summary the PRC did perform a timely review at a convened PRC meeting of the subject proce.
dure changes, however, the approval signature of the Manager - Fort Calhoun Station was not secured within 14 days of implementation primarily because of inefficiency in the conduct of administrative duties and functions.
0 PPD recognizes the importance of timely documentation and will continue to i
l emphasize this recognition in traininq personnel.
In addition, the Procedure Change Log was reviewed to determine if the required l
data had been entered for Procedure Changes 14937, 14961, 15443 and 15920.
The j
procedure changes were not checked as having been returned to the office, however, information was recorded in the log showing the disposition of the sub-ject procedure changes after they had been returned. This information includes the new revision number of the procedure and the procedure in which the change i
was incorporated. This information is ample evidence that the procedure change had indeed been processed by the office personnel.
1 i
.I l
15 4
. ~
A i
t D2.3 Deficiency - Construction package drawing changes without an approved field change Drawing file number 39881 for MR 84-105 (replacement of 4160/480 volt trans--
formers) was marked up in ink and a name was signed next to the changes to indicate a clarification in the weld symbology. No field change number was entered, and the planner responsible did not consider a field change necessary.
This violated SO G-30 since changes to installation instructions require an approved change.
OPPD'S RESPONSE The clarifying additions to this drawing were discussed at' length by the plan-ner, design engineer, and the QC inspector at the time of construction.
It was i
determined that the information was added merely to clarify the weld location.
This was not a change to the information previously shown on the Krawing nor was it a change to the installation instructions, therefore, the planner per-ceived no requirement for a field change.
J t
l The Field Change and Procedure Change forms are required to document changes to modification control documents. Occasionally additional comments or informa-tion may be noted in the margins of procedures or on drawings. This practice is useful in transmitting information to craftsmen, planners and QC inspectors on other shifts. Adequate controls exist during the modification acceptance process to assure that Field Changes and Procedure Changes are written where appropriate. These controls include review of the modification control docu-j ments by QC, QA for safety related design change orders and the System Acceptance Committee (SAC).
i No special actions are required to correct this condition; the existing ad-ministrative controls provide adequate control of changes to modification documents. However, the programmatic review of the modification process may i
recommend improvements in the Design Change / Modification process discussed in Reference (4).
l The pen and ink notations on the drawings which are the subject of this finding i
l were not considered by the cognizant Engineer to constitute a change to either l
the design or procedures contained in the modification documents. Therefore, j
in the Engineer's opinion, the annotations were not within the domain of S0 i
G-30.
Our review of this finding supports the decision of the Engineer.
1 Communication between planner and craft is an important part of a properly executed modification program.
In this case, OPPD believes that the communi-cation process was accomplished properly and within the provisions of the governing procedures. Therefore, OPPD does not believe this is a deficiency and request that this finding be reclassified as an observation.
l i-16 i
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i D2.3 Deficiency - Calibration procedure changes without approved field changes In reviewing MR 85-009 (replacement of penetration subassemblies), loop cali-bration procedures for CP-X/905 and CP-X/902,.seven instances were found where procedure revisions were not made in accordance with SO G-30.
The changes on the calibration sheets involved inconsistencies in entering the revisions as well as not attaching the correct forms.
OPPD'S RESPONSE Lack of proper documentation according to SO G-30 was determined to be the cause of this deficiency. The procedure changes associated with the reference calibration procedures were properly reviewed and performed in the course of the procedure. However, the procedure changes to the procedure were not anno-tated to refer to attachments and the procedure change number.
The records pertaining to the subject calibration procedures were reviewed, are i
now properly annotated, and are in conformance with SO G-30.
l Additional training will be given to technicians responsible for procedure changes emphasizing plant standing order and other relevant procedures and the importance of proper documentation for auditability.
i l
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4 17
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U2.3 Unresolved Item - Lack of calibration record for a pressure source used for safety-related channel calibration While reviewing MR 85-009, it was noted in the loop calibration procedure for CP-D/102-2 (pressurizer pressure) that several cross-outs were made for the pressure source (i.e., dead weight tester with pressure gage) such that it was not obvious which source was actually used.
Procedure M-26 required that the pressure source used be calibrated before and after use, or calibrated previous-ly within a set number of days. The calibration record for the pressure source used to calibrate the safety-related channel could not be found. Apparently, no record existed of the device's calibration.
OPPD'S RESPONSE Pressure Test Gauge #238 was originally selected, calibrated, and QC verified to perform Pressurizer Pressure loop calibration procedures CP-A/102, CP-B/102, CP-C/102, and CP-D/102. However, the technicians found that after the test instrument had been calibrated, they were unable to perform the calibration procedures because the loops were not available for calibration due to modifica-tion work being performed. When the systems became available for calibration, Test Gaune #246 was used to complete the calibration procedures CP-A/102, CP-B/102, 'P-C/102, and CP-D/102. Although it is somewhat unclear by the
" cross-out>
or. the record copy of the calibration procedures, Pressure Source
- 246 was us Records have been located to document that this Pressure Source l
was indeed c..
- bra ed and verified by QC within the allowable time limits both before and ai.
erformance of the Pressurizer Pressure loop calibration.
Therefore, the ret 'rements of Standing Order M-26 were met. The fact that Test Gauge #246 wt used is documented in Operating Incident Report 2225.
To ensure that records are clearly documented, I&C technicians have been notified to make sure that test equipment has been calibrated and QC verified, both before and after performance of a calibration procedure, and to record the test equipment ID number on the calibration procedure form at the time that the procedure is performed, i
Since OPPD has identified the test device used and can produce records that it was calibrated within a time frame to meet specified requirements, OPPD feels this should resolve the concern raised about lack of calibration records for the subject test equipment.
l 18
D2.4 Deficiency - Installation procedures were not in accordance with SO G-21, GSEE-0517 and GSEE-0512 Review of installation procedures in detail revealed the following concerns:
Procedures were, in general, too simplified or, in some cases, no procedure steps were provided at all.
Examples were:
MR 83-158 (addition of air accumulators) did not provide tubing configura-tion and accumulator tank location instructions in the procedure. Tank location was considered significant by the team since the engineering calculation accomplished prior to work start was based on floor mounting.
Apparently all these instructions were verbal.
MR 85-42 (replace MS-100) provided limited craft direction for valve remo-val and reinstallation of the replacement valve. The instructions amounted to basically, remove the valve and install the new valve, with no reference to precautionary statements regarding internal cleanliness control, end prepping and valve nozzle minimum wall thicknesses, QC requirements, and so on. These items were not covered in the procedure nor were they specified in supporting documentation. This modification had several installation problems identified by the team that are discussed in Section 2.5.1.
MR 83-158 did not reference the Stone and Webster prepared tubing seismic support guideline, " Guidelines for the Installation of Tubing and Tubing Supports for Seismic Instrument Systems," in the procedure.
Important installation criteria such as need for axial restraints and additional supports at concentrated loads were likewise not specified. As discussed in Section 2.5.2 several concerns were identified by the team with the seismic supports.
MR 85-62 (replacement of CCW flow element) did not provide instructions for proper flange makeup which may have eliminated a flange leak identified by the team.
Items such as bolt torque, even gasket compression, flange paral-1elism, bolt elongation, and so on, were not discussed in the procedure or in any supporting documentation. As discussed in Section 2.5.4, concerns were identified by the team with the flange installation. Also, in-structions were not provided for a cleanliness inspection following pipe drilling for boss installations on the 16" line. The original flow ele-ment, approximately 15" long, was lost in the Component Cooling Water (CCW) system in the fall of 1984 and was never recovered.
No attempt was ever made to locate the missing element. This problem is discussed further in Section 2.7.
MR 84-61 (union installation of SIT relief valves) did not provide a cau-tion statement or a hold point for verification of protection of valve 0-rings during welding. A vendor prepared procedure for installation of l
the relief valves included the use of a spacer to hold the 0-ring off the valve seat while welding.
Installation problems were also noted with this modification.
19
D2.4 Deficiency (Continued) i Description (Continued)
MR 84-61 (replacement of 4160/480 volt transformers) required welding to the transformer base in accordance with Generating Station Engineering Electrical (GSEE)-0517, " Installation of Seismic Supports for CQE and Limited CQE Electrical Equipment". GSEE-0517 required QC to be notified when work started so visual inspections could be completed. The installa-tion procedure had no hold points or objective evidence to assure visual inspections would be accomplished by QC. As discussed in Section 2.5.6 the inspections were not performed prior to this review. When interviewed, the design engineer expressed no knowledge of these requirements.
MR 84-74A (fuse protection for limit switches) identified specific splice numbers for QC inspection which was contrary to GSEE-0512, " Cabling Splic-ing Procedure", requirements. GSEE-0512, which was referenced in the procedure, required a 10% random inspection.
The installation instruction did specify inspection of 10% of the total splices but specific splice numbers were identified to the craft and QC for inspection instead of re-quiring QC to conduct a 10% random inspection of splices.
This problem was also noted in MRs85-009 and 84-179.
All of the above examples were not in accordance with SO G-21, GSEE-0517 and GSEE-0512 requirements respectively.
OPPD'S RESPONSE Standing Order G-21 does require preparation of detailed installation and testing procedures. However, ANSI N18.7-1976 states " skills normally possessed by qualified maintenance personnel may not require detailed step by step de-lineations in a written procedure." Procedures are written with the assumption that they will be installed by personnel who are qualified in their respective craft and knowledgeable of plant requirements delineated in the Standing Orders.
The procedures are reviewed by Quality Control personnel prior to PRC review.
The following paragraphs of Standing Order G-26A demonstrate adequate control of procedures and personnel:
3.2.4 Check that the procedure is sufficiently detailed for the task to be performed. Detailed procedures are required for extens've or com-plex jobs where reliance or, memory cannot be trusted and for tasks that must be performed in a specified sequence.
Skills normally possessed by qualified maintenance personnel may not, however, re-quire detailed step-by-step delineations in a written procedure.
3.3.4 Check that personnel performing the task are qualified to perform that task.
Pay particular attention to the craftsman in direct charge of the job and any personnel actually making tests, measure-ments or examinations.
20
l c
\\
l D2.4 Deficiency (Continued)
OPPD'S RESPONSE (Continued)
The quality of the modification installation is assured by adequate nondestruc-tive testing and performance testing.
A brief discussion of each example referenced in this deficiency is as follows:
MR-FC-83-158 - Because the accumulator had to be seismically mounted, its location is dependent on obtaining a specific hole pattern for the Hilti anchor bolts.
Since the calculation must assure the accumulator and tubing supports are adequate, the design engineer was assigned as the planner for the modification.
Field routing of the tubing from the valve to the accumu-lator was accomplished by the design engineer / planner and craft. This was verbally communicated and is within the guidance of ANSI N18.7-1976 and OPPD procedures.
MR-FC-85 The installation and testing procedure for this modification was reviewed and approved per OPPD's procedure. The level of detail should have been sufficient for a craftsman to perform the installation. Addition-l ally, see the response to Deficiency 2.5-1.
MR-FC-83-158 - See the response for Deficiency 2.5-2.
MR-FC-85 The installation and testing procedure for this modification was reviewed and approved per OPPD's procedure. During a prejob meeting between the craft, design engineer / planner and quality control, the pro-cedure was discussed as were methods to ensure that cleanliness of the system was maintained, bolt tightening requirements, fit up requirements, types of gaskets to be used, etc. The requirement to have a prejob meeting is included in the procedure. The loss of the existing element was not part of the modification since it was not known at the time of design, 1
i Prior to plant startup a safety analysis was performed by plant personnel i
to ensure that this condition did not introduce an unresolved safety question.
MR-FC-84 The modification to install the unions was performed because i
the previous practice was to cut and reweld the relief valves when they i
needed to be sent for testing. Therefore, craftsmen knowledgeable in the requirements to safely weld in the vicinity of the valve were available.
Refer also to the response to Deficiency D2.5-4.
MR-FC-84-105 - Refer to the response to Deficiency D2.5-7.
a MR-FC-84-74A - The cause of this finding is apparently a misinterpretation of the phrase " random inspection." OPPD's cable splicing procedure, GSEE-0512, required Quality Control (QC) to inspect, "...a minimum random sample of 10% of the conductor splices..." for conformance to the procedures. Dur-ing the preconstruction review of the installation procedures, QC did, in 4
21
)
D2.4 Deficiency (Continued)
OPPD'S RESPONSE (Continued) i fact randomly, select a minimum of 10% of the specified splices and marked a QC holdpoint in the procedures to ensure that QC would be contacted to witness the splica procedure. The intent of this random selection is to assure that a representative sample is inspected.
OPPD will review the personnel qualification program to ensure only qualified people are allowed to perform the tasks assigned.
1 6
I 22
'4 02.4 Deficiency - Failure to follow procedure requirements -
Review of the selected work packages identified the following examples of failure to follow procedures:
During accomplishment of MR 81-80 (seismic supports on masonry wall), work proceeded without verification of material adequacy in a QC hold point and the shift supervisor was not notified prior to proceeding with drilling holes through the battery room wall for HILTI through wall studs.
Both of these items were required by the installation procedure.
Nonlevel III inspectors were noted to have been reviewing and approving i
procedures for adequacy of QC hold points. This violated S0 G-21 and S0 4
G-26A, " Quality Control Program", which required level III certification to review and approve QC hold points.
It was also noted that the engineers writing the procedures were not Level III certified.
MR 85-105 (replacement of 4160/480 volt transformers) called for the fire suppression part of the Halon system to be disabled so that welding could l
take place without setting off the fire suppression system. A step in the l
installation procedure had been signed to disable the Halon fire suppres-sion systems in Zones five and six (switchgear room).
Later, in the same 2
procedure, the step to disable the Halon fire suppression systems was signed again.
Steps in the procedure had not been signed for restoration of the disabled Halon systems. At no time was there evidence that the Halon systems were, in fact, in service during the period of December 6-10, 1985.
Technical Specifications 2.19 part (8) required that when the Halon systems were inoperable, a continuous fire watch must be posted and backup fire suppression equipment must be provided.
The Shift Supervisor could not demonstrate that he had directed that a continuous fire watch be estab-lished.
It was also noted that the Halon system had an inoperable power fail light which would have made it difficult to detect problems with the fire detection part of the system.
During performance of work for MR 84-119 (replacement of instrument inver-ters) Bkr CB-5 and Ckt-33 were required to be tagged out. Tag numbers 85-1078-1 & 2 were issued to perform this work. No shift supervisor appro-val was found on the sheet as required by Standing Order 0-20, " Station Tagging".
The tag had been hung and the work was in progress without Shift Supervisor documented review.
The original modification design for MR 84-61 (union installation on SIT relief valves) specified the " nut" portion of the new unions to be welded to the new pipe stubs which connect to the relief valves.
Instead, the unions were installed upside down with respect to the installation sketch provided in the construction package. The installed orientation was later determined to be technically acceptable and a field change was prepared to document the change. However, failure to install the unions as originally designed indicated the craft did not follow the original installation procedure.
The above examples were contrary to the requirements of installation proce-dures, Standing Orders and Technical Specifications.
23 1
e D2.4-2 -, Deficiency OPPD'S RESPONSE MR 81-180 - The procedure step cited was for QA, not QC, review of material certification. Material used in the modification work was QA receipt inspected and had green tags attached. The purchase order numbers were listed in the modification documents as the material was received and inspected. However, the procedure step was not signed off as completed because the material was being received in stages throughout the project.
The procedure allowed for steps to be performed out of order to facilitate the work. Additionally, on QA's final review before Systems Acceptance, material used for the modification was verified. OPPD does not believe that this is a deficiency and request that this finding be reclassified as an observation because QA requirements were met and procedures were followed.
The Shift Supervisor was verbally notified prior to start of drilling, however, a signature was not secured until the situation was identified. The elapsed time was approximately 30 minutes. Upon identification of the missing signa-ture, the Shift Supervisor was immediately contacted and his signature secured while the NRC inspector was at hand and witnessed same.
The intent of SO G-26A was to have Level III certification for personnel review-ing and approving NDE and welding procedures and Level II certification for per-sonnel reviewing and approving all other procedures subject to QC redew.
However, the S0 as it is now written does not make this distinction. ' Current procedures do not require certification for engineers preparing draft procedures that specify QC hold points.
These procedures are reviewed for adequacy of hold points and identified in the procedures other hold points that may need to be added by a properly certified QC Inspector. A procedure change has been implemented to S0 G-26A to clarify the intent of the classification levels for QC personnel especially the qualification level required (Level III) to review and approve NDE procedures and the level (Level II) required to review and approve other procedures.
During the period cited from December 6 through December 10, 1985, while installing modification MR 85-105, the control room logs indicate that the switchgear Halon Fire Suppression System was alternately taken out of service and returned to service five (5) times during the 5 day period. Although the logs did not specifically indicate that a fire watch was established, the flame cutting / welding permit under which the job was being worked specified desig-nated personnel by name to perform the duties of firewatch. Operators have been instructed by interoffice memo FC-1692-85 dated 12/11/85, to ensure that continuous fire watches are established per TS 2.19(8) and to make special notations in the log books whenever firewatches are instituted to provide accountability to the required procedures.
During performance of work for MR 84-119, tag sheet 85-1078 was issued and did not have Shift Supervisor signoff. The signature of the Shift Supervisor, while not present, does nat represent a situation where operations was unaware 24
I D2.4 Deficiency (Continued)
OPPD'S RESPONSE (Continued) of the situation. While the specific Shift Supervisor might have been unaware, the R0 and AR0 were aware. Two other cognizant operators performed the tagging procedure and signed the sheet. The tagging log sheet 85-1078 has been sub-sequently reviewed, independently verified and signed by the Shift Supervisor present at the time of the tagging event.
MR 84 The union on the SIT relief valve in question was in fact installed contrary to the procedure and drawings. The fitter installed the unions in a manner which he considered standard. This departure from design was discussed with the responsible engineer, was determined to be of no consequence, and a field change was issued. The procedures and drawings were revised after-the-fact to agree with the as-built configuration.
Upon review of applicable modification documentation, it appears that each of the situations cited is an isolated case.
l 25
I f
D2.5 Deficiency - Inadequate welding, end preparation, and inspection associated with replacement of valve MS-100
~
MR 85-042 (replace MS-100): This 1" non-isolable steam header equalizer valve had been installed, welded, inspected (which included dye penetrant (PT) exam-ination of the weids) and accepted by OPPD. At the request of the team, based on a visual inspection, the lower (non-isolable) weld was reinspected by PT and found to be unacceptable. The weld was ground out, the pipe end prepped, and the joint rewelded and accepted again. When reinspected by the team, it was noticably tapered, although the weld was visually acceptable.
The tapered pipe raised concern for violation' of minimum pipe wall thickness. Subsequent rein-spection by 0 PPD revealed that minimum pipe wall thickness for schedule 80 pipe had been violated. After engineering review, the pipe wall thickness was deter-mined to be acceptable for the application since the remaining wall thickness exceeded schedule 40 pipe wall requirements.
OPPD'S RESPONSE Acceptance of the wcld on MS-100 was based on the successful examination by dye-penetrant (PT). The crater pit did_not show on the PT examination because the crater was filled with tightly adhered slag that was missed by both the welder and the QC inspe: tor.
The weld in question was a socket weld. Repair entailed grinding out the defective weld and replacing it with an acceptable weld.
During the grinding process, the craftsman btcame overly aggressive when reinoving the defective wel d.
This caused the @ served thinning of the pipe wall. An OPPD QC inspec-tor had also observed and reported this condition.
The inspector that missed the crater pit is a highly qualified contract inspec-tor that has shown competence as a QC inspector during three different plant outages. The contract that is used to procure contract inspectors specifies that inspectors must be experienced and fully qualified in applicable codes and procedures. All inspectors are certified. The certifications of the contract QC inspectors were reviewed by OPPD QA prior to the outage. OPPD provides an indoctrination course for contract inspectors prior to beginning work.
During this outage the contractor QC program was audited by OPPD QA. Therefore, OPPD believes that this finding represents an isolated event.
The defective weld was removed and replaced. The new weld was inspected by PT examination and found acceptable. The condition caused by grinding out the old weld and reducing the pipe thickness was evaluated by 0 PPD engineering and found to be acceptable for the design conditions.
The existing wall thickness was measured and calculations prepared using design temperatures, pressures and mechanical and seismic loadings.
The calculations verified that the remaining wall thickness conservatively complied with all code requirements.
Inspectors were notified of this occurrence and instructed to exercise vigilance to ensure that similar conditions did not reoccur.
26
D2.5 Deficiency (Continued)
OPPD'S RESPONSE (Continued)
OPPD had already noted a need for improvement of the welding program through internal QA audits. A programmatic review of the welding program and proce-dures is in progress by Plant Engineering and QC. A draft of a new Standing Order is currently under review.
Implementation of the revised Standing Order will further strengthen the welding program at Fort Calhoun Station.
The qualification of the craft personnel that were responsible for this condi-tion will be reviewed to identify the need for retraining and recertification.
OPPD has an aggressive program for training of QC inspectors at Fort Calhoun Station. Applicable portions of the maintenance training program, instruction by plant specialists, outside corporations specializing in NDE, refresher courses from local colleges, and two weeks of intensive training and recertifi-I cation by Combustion Engineering are examples of the training programs employed to ensure the qualifications of our QC inspectors.
27
e
- F D2.5-2 --Deficiency - Seismic instrumentation tubing span. violations-between supports Four examples were found in which the maximum unsupported span requirement of 4'-6" specified in section 4.2.2 of the Stone & Webster guideline for seismic tubing was violated.
The guideline limited cumulative distance between sup-ports on either side of tubing bends to the defined maximum, and it did not specifically permit any span without restraint regardless of length. The fol-l, lowing anomalies were noted:
Adjacent to valve YCV-1045A there was a distance totalling 5'-6" of un-supported tubing including bends.
I, In the branch to instrument air for YCV-1045A, there was a distance total-ling 5'-8" of unsupported tubing including bends.
I' Adjacent to valve YCV-1045B there was a distance totalling 5'-10" of unsup-j ported tubing including bends.
Adjacent to valve YCV-1045B accumulator there was a distance totallinc 4'-7" of unsupported tubing including bends.
OPPD'S RESPONSE l!
OPPD relies on its engineers to perform calculations in accordance with ap-i proved procedures and ensure that criteria such as adequate safety factors on anchors and stress of tubing or support components are within allowable ranges.
i The engineer can use the guidelines or perform his own calculations.
In this i
case, the as-built configuration of the tubing supports did not conform with the spacing criteria of the tubing support guidelines. The concern of this finding had already been identified by the Planner. He requested that cal-i, culations be performed to justify the support spacings that were used. These i
calculations were not available for review at the time of the inspection be-cause they were undergoing independent review at the time.
II Modifications requiring the installation of seismically suppcrted tubing per-formed prior to the development of the current tubing support guidelines relied i,
upon design and installation similar to that used in the original plant design, 4
The use of the guidelines provides additional assurance that CQE tubing requir-j ed for subsequent modifications is appropriately installed.
4 !
Since field conditions required the movement of the accumulator farther from i
the valve than originally intended, the standard support design became appli-
{,
cable and was utilized (added to the procedure via procedure change).
It was necessary to alter the standard spacing criteria. This was justified by alter-l-
nate calculations.
These calculations were completed and verified, and they
}!
confirmed that the installed tubing is seismically supported.
i l
0 PPD is developing a special training session for the applicable design groups to enhance their knowledge of the design of instrument tubing and re-emphasize the importance of using the Fort Calhoun criteria for routing and support of l-seismic instrument tubing.
l, 28 l.
a 02.5 Deficiency (Continued)
OPPDS RESPONSE (Continued)
OPPD believes this is not a deficiency and should be reclassified to an-observation because the tubing was installed in accordance with applicable requirements and procedures.
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D2.5 Deficiency - Inadequate support of seismic instrumentation tubing near air regulators Seismic supports to the instrument support frame were not installed adjacent to the " air sets" for valves YCV-1045 A&B. Section 4.2.2 of the Tubing Guideline required support to be located "as close as possible" to instrument connections and required attachment of that support to the instrument support frame. Such support was not provided in the vicinity of the tubing connections to the reg-ulators at either valve YCV-1045A or B.
In both cases, the first support upstream of the regulators was located at a distance from these connections which exceeded the standard allowable span for the subject tubing.
OPPD'S RESPONSE Although the tubing support guidelines were used as a basis of support design and support spacing, the guidance for locating the support "as close as pos-sible" to the instrument connection was not followed. Based upon observation and knowledge of the relative thermal expansion between the valves and the accumulators, the supports were not located near the air sets. Calculations performed verified the adequacy of the support spacing and design.
Modifications requiring the installation of seismically supported tubing per-formed prior to the development of the tubing support guidelines relied upon designs and installations similar to that used in the original plant design.
The use of the current guidelines provides additional assurance that CQE tubing required for subsequent modifications is appropriately installed.
OPPD is developing a special training session for the applicable design groups to re-emphasize the importance of using the Fort Calhoun criteria for routing and support of seismic instrument tubing.
1 30
D2.5 Deficiency - Installation discrepancies found in installation of safety injection tank relief valves l
MR 84-61 (union installation on SIT relief valves): The following discrepancies l
were identified by the team:
The relief valve for SI tank 6B had the wrong relief valve installed on it according to the manufacturer's label plate (i.e., label plate was stamped SI 221 instead of SI 217).
The valve label plate for SI 221 conflicted with the valve number on the brass identification tag attached to the valve.
The union on SI tank 6B had a large crater pit in the lower pipe weld which appeared to be visually unacceptable.
This weld was previously PT examined and accepted by QC personnel.
See Section 2.6.1 for further discussion on this defect.
The union tail piece pipe for SI tank 68 had a large flat surface discon-tinuity (3/8" x 3/4") as well as other surface discontinuities of less size and depth. The large surface discontinuity raised concern for violation of minimum pipe wall thickness.
The union tail piece pipe for SI tank 6D was also covered with surface dis-continuities apparently caused by a pipe wrench.
OPP 0'S RESPONSE Valves SI-217 and SI-221 are identical components both functionally and mater-ially. At some unknown time the valves were switched during installation.
The i
brass identification tag for SI-217 attached to valve SI-221 was the plant installed identification. Tag SI-217 was the correct identification for the valve location. Documentation applicable to Valves SI-217 and SI-221 will be corrected to show as built location of the valves As a result of the inspectors comments, an OPPD QC inspector looked at the installation. The pit in question was a small indentation caused by tungsten lift-off. The original PT examination was found to be acceptable. Therefore, examination of this weld did not substantiate the inspectors concern that the crater pit was evidence that the weld was unacceptable. As was the case in this finding, welds are accepted only after appropriate QC examination. See response to D2.6-1 for further discussion of this finding.
1 i
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31
D2.5 Deficiency -(Continued)
OPPD'S Response (Continued)
The discontinuities observed on the union tail piece pipe for SI tank 6D were verified and examined by an OPPD QC inspector.
The discontinuities were appar-ently caused by wrench marks from the fit-up process.
Engineering analysis has been performed on these discontinuities. The discontinuities did not affect the integrity of the pipe to perform its design function. There are no known discontinuities in the unreviewed portion of the design that would affect the integrity of the piping.
A programmatic review of the welding program and procedures is in progress by Plant Engineering and QC to enhance welding at Fort Calhoun Station.
Most of the observations identified in this finding were examined and found to be acceptable in the condition that existed at the time of the inspection. The valve identification was admittedly incorrect.
This condition is mitigated by the fact that the two relief valves are identical components and the condition did not present a safety concern. OPPD does not believe that this is a defic-iency and request that this finding be reclassified as an observation because the installation was acceptable by QC inspection.
l 32
g I
D2.5 Deficienc,y
' Inadequate flow element flange installation MR 85-62 (replace of CCW flow element): The installation procedure had a sign-off to verify that the flange was not leaking. However, the joint was found to be leaking during this inspection.
It was also noted that the flange faces were out of parallel by approximately ;.030".
Other problems are discussed in Section 2.6.1.
OPPD'S RESPONSE The flange was not leaking at the time that the craft signed off the step in the installation procedure. The leakage identified by the inspection team was apparently detectable at some later time.
The flange gasket was a Flexitallic Gasket, style CG.
Flexitallic Bulletin '171 recommends 0.050" - 0.055" compres-sion of the gasket with a tolerance of i 0.010".
Therefore, an out of parallel condition of approximately 0.020" could be tolerated ar:d.still be within manu-facturer's recommendations. The flange faces were -visually determined to be parallel by the modification planner.
1 Flange leakage in the unreviewed portion of the design has not been identified by OPPD as being abnormally trouble.some. As in all similar installations, occasionally leakage is observed. When these isolated occurrences are ident-ified, appropriate action is taken to resolve this issue.
The planner prepared maintenance order'No. 857887 to tight'en the flange bolts.
Completion of this M.0. corrected the leakage condition. Subsequently, mea-surements taken verified that the out of parallel condition was within the allowable 10.010" tolerance.
OPPD will review the installation procedures used to install flanges to develop better instruction to craft personnel.
OPPD uses leakage as the primary criterion when installing flanges. Occasion-ally, leakage is not immediately detectable but will show up some time after the system has been pressurized. The flange in question is located.in an area that is accessible during plant operation and the leakage would not have gone unnoticed. OPPD performs periodic walkdown inspections of the CCW system in accordance with IST-CC-4-F.1 to identify leakage. This condition did not intro-duce a situation that was likely to cause the CCW system to become inoperable.
33
l 1:
D2.5-6 ' Deficiency - Installation discrepancies' found in installation of new delta T power process loop instrumentation l
l MR 84-140 (delta T power process loops): The following discrepancies were identified by the team:
Safety-related cable EC10483 (Channel C)' was tie-wrapped to nonsafety-re-lated cables 1152A and 1152B in panel AI-216, which was not in accordance with the Updated Safety Analysis Report (USAR), Section 8.5.1.1.
Safety-related cable ED10484 (Channel D) was tie-wrapped to nonsafety-re-lated cable 1152A in panel AI-217, which was not in accordance with the USAR, Section 8.5.1.1.
Welds on conduit supports FC-84-140-006, -008, and.-009 were accepted by QC personnel but did not conform to the configurations specified by the design details. The design called for a unistrut to be fillet welded to a beam-but, in fact, the unistrut had been moved to the edge of the beam and seal-i welded instead.
Conduit installations had been accepted by QC personnel-even though defic-iencies existed and, in many cases, construction activities were not.yet complete. An example of this condition was a 11" ~ diameter conduit contain-i ing cables EC11504, EC11505, EC11506, and EC11507 which was accepted with the following conditions present:
- All required supports were not yet installed (the design details for one support were not yet issued by engineering).
- Conduit was not strapped to one installed support.
Nuts on concrete wedge anchors did not exhibit adequate thread engagement.
J
- A required square washer on a concrete wedge anchor was missing.
- Condulet covers were missing.
- Due to unavailability of approved safety-related material, temporary 1
nuts were installed.
OPPD'S RESPONSE USAR Section 8.5.1 does not address separation between safety related and non-safety related cables in panels. Section 8.5.1' addressed only cables in raceways. At the time of FCS construction, no separation criteria existed
'beyond the general guidance criteria in IEEE 279-1968 and FSAR, Appendix G, Cri-1 terion 20, 22, and 25. The craftsmen responsible for this modification were not aware that more stringent separation criteria than that given in IEEE 279 wo61d be applied to the new AI-216 and AI-217 panels.
The subject cables were relocated prior to plant operation.
34
D2.5 Deficiency (Continued)
OPPD'S RESPONSE (Continued)
Justification for the cable separation criteria utilized at Fort Calhoun Sta-tion was provided to the NRC in Reference (4). That response concluded that no generic safety concern existed.
OPPD has nearly completed the development of a separation criteria for safety-related circuits. Upon approval, this standard will be distributed to appropriate design, maintenance, and inspection personnel. These groups will also receive appropriate training on application of the standard.
The seismic conduit support design and installation process was extensively revised by 0 PPD prior to the 1985 outage.
The QC inspection criteria for seis-mic supports and conduit were not well developed as a part of that process.
A complete analysis and inspection of new seismic conduit supports was per-formed by the GSE-Civil department prior to completion of the 1985 Outage.
This information was included in the modification file. This inspection includ-ed verification of support details, support spacing and conduit configuration.
This extensive review was necessary to assure the adequacy of the conduit support and was in addition to the inspections performed by QC.
This review addressed any generic concerns which may have developed due to lack of effec-tive QC inspection criteria.
OPPD is presently reviewing the seismic conduit support design and installation process.
Experiences during the 1985 Outage will be factored into appropriate modification control documents for safety-related modifications.
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's U2.5 l'nresolved Item - Questionable installation practices relative to installation of delta T power process loops cables and panels.
l The following questionable installation practices were observed, although
. specific counter requirements in the licensee's procedures were not identified i:
in all cases.
3 Cables EC10483 and EC10484 (locations above) were bent severely back' upon themselves. This was not consistent with manufacturer's recommendations and standard 1 dustry practices with regard to cable bend radius.
?
The procedure step for torquing of the wedge anchors in panels AI-214 and i
AI-215 was signed off by QC but the " Seismic Support Data Sheets" required by GSEE-0517 were not filled out to include the required data and accep-tance signatures.
The procedure step for welding of the support frames for panels AI-214 and AI-215 was signed by QC but the applicable sections of the " Seismic Support Data Sheets" required by GSEE-0517 had not been filled out by QC personnel.
The anchorage of panels AI-216 and AI-217-was accepted by QC, but panel bases were not flush with the concrete mounting surfaces. Washers were used as shims without being noted or reported to engineering for review and j
resolution. Subsequent design review indicated that corrective measures l
were needed, and have'been accomplished.
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OPPD'S RESPONSE OPPD's response to each of the four cases cited above is as follows:
(1) Cables EC10483 and EC10484:
The GSEE-0516 cable installation specification did not provide guidance on cable bend radius.
The experience and training of the craftsmen was gen-erally relied upon to maintain good cable installation practices.
The craftsmen performing modification work at Fort Calhoun Station general-1 ly have extensive experience in power plant construction.
In addition, the District's QA department has recently addressed and resolved the issue of cable installation practices (DR85-098).. Therefore, it is felt that this issue is not of generic safety concern.
The cables in question were reconfigured and reterminated prior to plant startup.
1 GSEE-0516 has been revised to incorporate cable installation criteria.
4 Craftsmen and QC inspectors involved in future modification work will be
)
given training on the cable installation requirements.
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.U2.5 Unresolved (Continued) 1 OPPD'S RESPONSE (Continued) 1 (2)
Wedge Anchors:
The craftsmen responsible for installation of panels AI-214 and AI-215 and QC inspectors apparently were not aware of the requirement for comple-tion of the Seismic Support Data Sheet.
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Installation of wedge-type anchors is verified by FCS QC personnel. The inspection criteria applicable to these anchors are available in plant procedure MP-Seismic-1 in addition to GSEE-0517. The ultimate
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requirement is correct installation of the anchor and a documented QC verification. Therefore, lack of the Seismic Support Data Sheet is not a
. generic safety concern.
The Seismic Support Data Sheets were subsequently completed based on j
written daily log records of the QC inspector and reinspection of the i
anchors.
(3)
Support Frames:
j GSEE-0517 is an optional procedure which may be used by the planner to document installation and fabrication of seismic supports. Alternate methods of verification may be used.
For the AI-214 and AI-215 support j
frames, the weld inspection was documented on the Welding and Test Con-l trol Record, Form FC-145. No seismic Support Data Sheet was required.
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Other documentation is acceptable for verification of QC weld inspec-l tions, therefore, no generic safety concern exists.
The seismic supports for electrical conduit and equipment installed dur-i ing the 1985 Outage were reviewed by the GSE-Civil department to provide as-built documentation and analysis. This review addressed any safety concerns caused by lack of effective QC inspection criteria.
(4)
Anchorage of Panels:
1 The craftsmen and QC inspectors involved with installation of panels 4
AI-216 and AI-217 failed to recognize the seismic significance of the jl shims which were installed. No specific inspection criteria were avail-able to the QC inspector beyond the normal weld inspection criteria.
- li The seismic supports for electrical conduit and equipment installed dur-ing the 1985 Outage were reviewed by the GSE-Civil department to provide as-built documentation and analysis.
This review addressed any safety l
concerns caused by lack of effective QC inspection criteria.
j Corrective measures were installed on the supports in question prior to plant startup.
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The above information should resolve all concerns regarding this unresolved j
item.
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D2.5 Deficiency - Weld inspections not accomplished for transformer base welds to the imbedments MR 84-105 (replacement of 4160/480 volt transformers): Weld inspections were not accomplished by QC as required by GSEE-0517 for the transformer base welds to the embedments. Section 5.2.2 of GSEE-0517 required that QC be notified when work was starting and that visual inspections be accomplished by QC. No weld inspection sheets were in the procedure when reviewed by the team. Appar-ently QC had not been notified of work starting other than by their initial concurrence on the procedure.
OPPD'S RESPONSE The procedure for MR-FC-84-105 did not have a sign off in the procedure body i
itself to document QC notification prior to performing the work.
However, QC was notified prior to the start of work and did perform the required visual inspection.
GSEE-0517 requires all welding material (including weld rod) to be CQE.
Fort j
Calhoun Standing Order G-12 governs the use of CQE weld rod, which must be ob-tained from the QC department.
Issuance, receipt, and disposition of the weld rod is documented on Form FC-145. Verification of QC inspection is provided on Attachment "A" to GSEE-0517. Documentary evidence of both the notification and inspection of each of these welds exists on the FC-145 form and the Attachment "A" forms which are included with the construction package. Apparently, the j
welds in question had not been inspected at the time of review and thus, the documentation was not available to the NRC.
Notification of QC prior to starting work is a standard practice at Fort Cal-houn Station.
The primary goal of this practice is to establish QC require-ments before work is performed, thus reducing the possibility of not involving QC personnel appropriately.
i Review of the modification records indicate that QC performed the required j
visual inspection and the modification was completed in accordance with OPPD procedures.
The weld inspections were performed by QC and these inspections were properly 4
documented on Forn FC-145.
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U2.5 Unresolved Item - Foxboro transmitter 0-ring replacement not docu-mented to maintain environmental qualification Several instruments were being recalibrated because their connections had passed through the penetrations being replaced by MR 85-009.
Review of calibration procedure CP-A/102-3 for pressurizer pressure transmitter, 102A, revealed that the safety-related transmitters were opened to make adjustments but 0-rings may not have been replaced as required by the transmitter manufact-urer (FOXBOR0) to maintain environmental qualification of the transmitters.
The calibration procedures contained statements regarding the requirement to replace the 0-rings if the transmitters were disassembled, but no objective evidence existed to document 0-ring replacement.
This concern involved about 74 transmitters.
OPPD'S RESPONSE The 0-rings in question were replaced prior to plant operation to provide positive assurance that this step of the procedures was not missed during calibration. Subsequent to returning to operation a thorough review of records verified that the 0-rings were properly replaced as part of the calibration process.
The 0-ring for the Pressure Transmitter PT102A was replaced upon completion of the calibration procedure in accordance with the requirements specified in Calibration Procedure CP-A/102-3. At the time this calibration was performed, the calibration procedure contained statements specifying the need to replace the gasket if transmitters were opened, but provided no sign-offs to document that the 0-ring was replaced or record of the material P.O. for the replacement gasket. The fact that the gasket was replaced is documented on Form FC-198, Electrical Equipment Qualification / Qualified Life Program-Information Sheet, which was completed in conjunction with performance of the calibration proce-dure. The signed-off FC-198, which was completed at the time calibration was performed, is on file with OPPD. Standing Order G-17A requires that this FC-198 form be completed to document replacement parts to all EEQ (environment-ally qualified) equipment resulting from calibration procedures. OPPD has identified only sixty-two (62) Foxboro transmitters which were calibrated during the 1985 outage. The basis for the seventy-four (74) transmitters identified by the NRC inspector cannot be determined.
Completed FC-198 forms are on file to document 0-ring replacement for all sixty-two (62) Foxboro transmitters which were calibrated per Calibration Procedures during the 1985 refueling outage.
To ensure that the 0-ring replacement for Foxboro transmitters is documented on the Calibration Procedure forms as well as the FC-198 forms, Setpoint/ Procedure changes have been prepared in accordance with Standing Order G-30 to amend the calibration procedures to provide for this documentation. The procedure change updating CP-A/102 was incorporated January 11, 1986.
Based on the documentation provided on the completed FC-198 forms, which are attached to and filed with the original signed-off calibration procedures, OPPD feels that this should resolve the concern that the 0-rings may not have been replaced as required when the Foxboro transmitters were calibrated.
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E.
l D2.6 Deficiency - Inadequate welding and' nondestructive test inspection Three modifications were examined which involved ASME Code welding and NDE.
i The following welding and NDE control concerns were noted:
MR 85-42 (MS-100 replacement): A previously QC accepted socket weld (via PT examination) was rejected based on information from a visual inspection by the team and reaccomplishment of the PT examination. During repair of the rejected weld joint, the connecting pipe nipple was ground to the point at which the pipe no longer met minimum wall criteria.
This problem was also not realized by OPPD until a second visual inspection by the team.
MR 84-061 (union installation on SIT relief valves): A large pit was noticed in a previously QC accepted weld (via PT examination) associated with valve SI 217. The team requested a re-examination of the weld. OPPD QC personnel examined the weld, noted the pit, filed on the pit to fair in or remove the defect and then re-PT inspected the weld. The weld was found to be acceptable after the minor repair actions.
MR 85-062 (replacement of CCW flow element): The temperature of the CCW system was between 47* and 51*F at the time that initial pts were accomp-lished and accepted on welds associated with this modification. This was in violation of the PT procedure found in 50 G-26A, Appendix F which re-quired a minimum temperature of 60*F.
The pts were reaccomplished at the request of the team which resulted in two of the four welds being rejected because of linear indications.
OPPD'S RESPONSE The response to this finding is given in the order of the concerns listed in the description. OPPD's response to the concern pertaining to MR 85-42 (MS-100 replacement) is fully addressed in OPPD's Response to D.2.5-1.
MR 84-061 (union installation of SIT relief valves) - OPPD's response to D2.5-3 is also applicable to this item. The significance of the crater pit identified was based on the NRC inspector's opinion. OPPD QC inspected the weld and determined that the crater pit was not sufficient to reject the l
weld. The original PT examination supported this position. No rework of the weld such as filing is known to have been completed. However, testing verified the acceptability of the welds.
Therefore, OPPD does not believe that this is a deficiency and request that this finding be reclassified as an observation because the weld passed NDE.
MR 85-062 (replacement of CCW flow element) - OPPD failed to check the temp-erature of the welds prior to performing PT examination to ensure that the criterion of the procedure was satisfied. OPPD believes that the failure of the re-examination of the welds in question was not due to a deficient condition of the welds or the temperature of the welds during PT examina-tion. Before the welds were reexamined, OPPD's QC inspector informed the NRC inspector that reexamination of the welds would probably result in 40
D2.6 Deficiency (Continued)
OPPD'S RESPONSE (Continued) discontinuities. The discontinuities were predicted on the basis that corrosion had formed on the weld material.
Experience has shown that cleaning would not be effective in removing the corrosion. Minor dressing of the welds with a file was sufficient to clean the welds so that reexamination was acceptable. The NDE procedure used can be qualified to a temperature of i
approximately 40*F.
The 60*F temperature used in OPPD procedures was selected so that the criterion would be conservative.
OPPD exercises an effective QC program that monitors the modification and main-tenance program. OPPD also fully conforms to Inservice Inspection programs that comply with applicable codes and regulations. The Inservice Inspection program verifies OPPD's confidence that conditions identified in this finding are isolated occurrences and are not expected to exist in the unreviewed por-tion of the design.
Corrective action taken for the finding pertaining to MS-100 is discussed in OPPD's response to D.2.5-1.
Corrective action taken for the findings pertaining to the SI tank unions are discussed in OPPD's response to D.2.5.3.
The concerns pertaining to the CCW flow element were resolved by minor surface dressing of the welds and reexamination at a temperature above 60*F.
1 1
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D2.6 Deficiency - Plant welding accomplished to nonapplicable weld procedures Inadequate and nonexistent weld procedures were noted during review of the construction packages. OPPD had only nine basic weld procedures to accomplish all nuclear welding in the plant. These are listed in Table IV.
From the limited sample of modifications reviewed involving welding, the following concerns were noted.
A skewed fillet weld was installed using a 90* fillet weld procedure in MR 84-162 (containment HVAC supports).
A misdrilled hole in a support baseplate was plug welded using a 90' fillet weld procedure in MR 84-162 (containment HVAC supports).
Partial penetration pipe boss welds to CCW 16" piping were accomplished using a 90' fillet weld procedure in MR 85-62 (replacement of CCW flow element).
A fillet weld procedure was used to accomplish a seal weld in MR 85-62 (replacement of CCW element).
OPPD'S RESPONSE MR 84-162 - The knee brace of containment ventilation duct support B was attach-ed to the base plate using Weld Procedure No. 1-B.
The principal axis of this support is not perpendicular to the wall on which it is mounted, rather it is skewed 15* counterclockwise from the perpendicular. Weld Procedure No.1-B is designated as applicable to fillet welds in general, however, the term "90' Fillet" is used in the space on the form where other types of joints for which the procedure is applicable can be listed. This procedure does lack any in-structions relative to proper end preparation for a skew T-joint. OPPD has completed an engineering evaluation of the welds in question and has verified that the two supports, A and B, are satisfactor.y as installed.
A misdrilled hole in the base plate for the knee brace of support A was repair-ed using Weld Procedure No. 1-B.
This work was done as Field Change F-6 and was designated on the field mark-up of Drawing No. A-4875, Sheet 2 of 3, as a plug weld on both sides. OPPD has no procedure specifically designated for plug welds.
MR 85 The Welding and Test Control Record sheets show that all welds on this modification used Welding Procedures No. I and No. 6, not No. 1-B, which was implied by the statement of the deficiency.
The only indication that 90' fillet welds might have been used is the statements in the notes on Drawing No.
SK-FC-85-62. Weld procedures No. I and No. 6 apply to groove welds and were properly applied in this modification. A drawing revision notice has been pre-pared to correct the notes on Drawing No. SK-FC-85-62 to remove the reference to fillet welds.
42
D2.6 Deficiency (Continued)
OPPD'S RESPONSE (Continued)
OPPD will evaluate the extent to which inappropriate welding procedures may have been used in other modifications installed during the 1985 outage. OPPD has a programmatic review of welding and welding procedures for Fort Calhoun Station in progress.
Prior to this NRC inspection, OPPD QA identified a deficiency relating to the lack of a working system to identify traceability of welders to welded joints.
As corrective action, Fort Calhoun Station committed to a programmatic review of all welding and welding procedures. A proposed Welding Standing Order has been drafted and is currently under review. This new Standing Order will in-clude a new Weld Design Data Form which will explicitly detail all relevant data for each weld.
In addition, OPPD retained a welding consultant to review welding procedures and as a result, some modifications to existing welding pro-cedures were accomplished.
T 43
l D2.8 Deficiency - Inadequate requirements for recording of data resulted in an indeterminate battery charger load test MR 84-119 (replacement of instrument inverters):
Battery charger #3 load test procedure did not identify logging of data to verify acceptance criteria (float and equalizing voltage) which resulted in indeterminate test results. The test procedure required that the charger output should be stable and within values specified after operating under rated load conditions for one hour. No data was taken (nor was any required to be taken) to document that the charger had performed for one hour within the values specified in the acceptance criteria.
In addition, the acceptance criteria, which was listed separately in the back of the procedures, was not identified to the procedure steps to which it ap-plied. Upon review of the completed procedure, it was not obvious which procedure step accomplished which portion of the test requirements to satisfy the acceptance criteria.
OPPD'S RESPONSE The battery charger acceptance tests were designed to supplement the factory acceptance tests performed by the vendor.
In addition, the recommendations of IEEE 415-1976 were followed. The tests were not intended to duplicate the extensive design tests used by the vendor to verify performance under all postulated design conditions. The design engineer selected appropriate tests which would provide reasonable assurance that the battery chargers were prop-erly installed and calibrated.
Consequently, the one Sour local test was performed only at the float voltage.
The ability of the charger to operate at maximum load without overheating was established.
Further data taken at varying loads, input voltage, input fre-quency and output voltage were not necessary because of this type of testing had already been performed by the vendor.
The acceptance criteria was prepared as guidance for the Planner and Supervisor I&C/ Electrical to review the results of the test. The criteria were suffic-iently detailed for a knowledgeable Electrical Engineer to perform the required evaluation.
Specific co relation between procedure steps and acceptance cri-teria was not deemed necessary because of the technical review which was specified and accomslished. OPPD does not believe that this is a deficiency and requests that t11s finding be reclassified as an observation because the test was accomplished according to procedures.
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D2.8 Deficiency - Test procedure did not verify design concept under accident conditions MR 84-74A (fuse protection for limit switches): The test procedure required only stroking of the valves, which would not verify the design concept of the circuit modification. The test did not consider proving the circuit changes by also testing for operability with the fuses removed, which could be a more real-istic accident condition. OPPD agreed to test procedure enhancements which would fully verify operability of the modification.
OPPD'S RESPONSE The test procedure originally prepared for this modification was considered adequate by the design engineer, the electrical department manager and the independent design reviewer. Design calculations in conjunction with an operability verification were considered to provide an adequate test of the system. This modification involved the installation of one additional fuse in certain valve control circuits and it would be difficult to simulate the actual conditions under which the protective fuses would operate.
The normal wiring check plus the operability test should have detected any errors in the instal-lation. Design calculations verified the ability of the fuse to clear the postulated ground.
Adequate procedures exist in the design review process to assure that in gen-eral, post modification functional testing is performed.
Isolated cases have been identified where functional testing could have provided additional assur-ance that the modification would function as designed, however, this is not considered to be a generic problem.
After consultation with the inspector, the design engineer agreed that a par-tial functional test would provide additional assurance that the modification would function as designed. This testing was completed prior to startup from the 1985 outage.
45
=
D2.9 Deficiency - Inadequate temporary storage of safety-related material Three' temporary Critical Quality Element (CQE) storage areas were inspected.
The following concerns were noted:
Temporary CQE Storage Area #4:
Loose electrical cable identified by CQE card as Item W-71, STK #611-1850 Reel #C-1093 & P0 #42148 was being crushed l
by a large reel of electrical cable.
Temporary CQE Storage Area #17: Two electrical components were found 3
4 stored in Area #17 without any CQE cards attached which was not in accor-3 dance with SO G-22 requirements.. It was later discovered that these two components were non-CQE and were improperly stored in a CQE area which also violated SO G-22, " Storage of Critical Element and Radioactive Material Packaging, Fire Protection Material, and Calibration Equipment". Label plate identification for the components was as follows:
a.
GE switchgear i
GV-4.16-250 l
413-36507 j
836C138 G21 1/75 l
I b.
GE switchgear GV-4.16-250-1200A I
836C138 G20 2/75 1
413-38986-1 4
Temporary Storage Area #14: Three electrical penetration subassemblies were found stored in Area #14 without any CQE cards attached which was in violation of SO G-22.
Identification for the components was as follows:
i a.
PN7M56-12000-03 Pen #E9-13 P.O. 07233 i
WO 7-M5600 b.
PN7M56-12000-03 Pen #E2-6 j
PO 7233 WO 7-M5600 4
c.
PN7M56-12000-03 Pen #E2-11 PO 7233 l
WO 7-M5600 i
All of the concerns identified above were contrary to ANSI Standard N45.2.2 requirements for nuclear material storage and handling.
It was also noted during this inspection that no procedure existed for placement, control and removal of material in temporary CQE storage areas.
In view of the signif-icance of maintaining proper condition of quality material until installed, a procedure with detailed requirements appeared to be warranted.
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I D2.9 Deficiency (Continued)
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OPPD'S RESPONSE j
Inadequate control of materials stored in temporary CQE Storage areas is identified as the cause of this finding.
Because of the period of high act-ivity (85 outage) where materials were being placed in and being taken out of the Temporary. Storage areas, controls proved to be insufficient.
Because temporary CQE storage areas are utilized throughout the plant to facilitate use of CQE materials without repeated trips to the warehouse, it appears that the subject of this finding could be related to other CQE storage
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areas to some extent.
Those items identified as being in violation of the ANSI Standards and SO G-22 were corrected by Craft personnel.
4 OPPD is in the process of upgrading procedure SO G-22 to ensure that tighter controls are placed on CQE material placed in Temporary Storage areas. The i
upgrade will include more frequent surveillances during times of increased activity such as outages and delineation of persons in direct charge of such j
Temporary Storage areas. The procedure will also be expanded to include specific instructions relative to placement, control, and removal of material i
q in Temporary CQE Storage areas.
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l D2.9 Deficiency - Inadequate warehouse storage of safety-related material The following concerns were noted involving storage of CQE material in the Fort Calhoun warehouse:
Three examples of materials that had tags that did not agree with material markings and other documentation were noted as follows:
a.
Relays - MR 78-56 (quantity - four)
Doc #45240 Model 7022PB 125VDC SER #80082367 b.
Relays - MR 78-56 (quantity - four)
Doc #45240 Model 7012 PF 125VDC SER #80082373 c.
ASCO Solenoid Valve (quantity - two)
Code #NP8320A185V Doc #54884 MR-84-77 Four examples of CQE material that was required to be stored in Level B areas but were incorrectly stored in Level C areas for 10 months,17 months, 18 months and 19 months, respectively, were noted as follows:
a.
Relay lockout (quantity - see note)
Code #12HEA610243 PO 536881 b.
Sleeve (quantity - see note)
STK #13.3728 Lot N3275 Code #WCSF 115-40N PO 5496 c.
Byron Jackson 0-ring (quantity - see note)
STK #606.9010 P/N 11-28 Doc #534817 d.
Foxboro Power Supply (quantity - see note)
Code # Device Tag #725C/ Unit Tag #8/LQ-904 P0 05105 One example of incomplete material certifications was noted wherein the required hardness and mechanical properties were not listed on the Certi-fled Material Test Record.
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D2.9 Deficiency (Continued) j 1 3/8" x 8 Nuts (quantity - see note)
STK #621.4501 Code #2H ASTMA194 Doc #49041 NOTE: The actual quantities for the above five groups of material were not recorded due to the large numbers of each item.
In some cases sev-
)
eral pallets or boxes or material were involved.
All of the examples identified above were not in accordance with ANSI N45.2.2 requirements.
OPPD'S RESPONSE OPPD had undertaken an extensive effort to rearrange and reorganize the ware-house inventory. During this program the items identified by the inspection team were improperly stored.
That equipment which could not be supported by necessary documentation to establish the CQE classification was reclassified as non-CQE.
OPPD has implemented a project to verify CQE inventory for proper identifica-tion, certification records, tagging and storage.
Storage areas in the Fort Calhoun Station warehouse are subject to a homogen-eous environment that satisfies the requirements for Level 8 storage. The general nonconformance identified by the inspection team had been previously identified by OPPD's QA organization. At the time that the warehouse was in-spected by the inspection team, work was in progress to remedy this condition.
A space utilization study for Fort Calhoun Station had been completed. This study addressed the warehouse and storage requirements for CQE components.
Since OPPD had already identified the concerns of this finding and was in the process of taking corrective action, it is requested that this finding be reclassified as an observation.
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D2.9 Deficiency - Inadequate QC surveillance of temporary safety-related storage areas Review of the log for surveillance of temporary CQE storage areas by QC re-vealed that surveillances were generally not meeting the monthly requirement of SO G-22.
Table V provides a listing of each temporary storage area and their respective surveillance date(s).
From Table V it was apparent that temporary storage areas 1,3,4,5,14, and 15 were overdue for surveillance as required by SO G-22.
Also the July 1985 sur-veillance for area 3 was three months late and for area 15 the July 1985 surveillance was two months late. This was also not in accordance with SO G-22.
OPPD'S RESPONSE Temporary CQE storage areas are established at Fort Calhoun Station to provide controlled short term storage of CQE components to facilitate availability during installation.
Surveillance inspection of a temporary CQE storage area is not required if the area is not active.
Lack of an entry in the surveil-lance log does not necessarily mean that an inspection was not performed in a timely manner. The temporary storage area may not have existed during the time period in question.
OPPD agrees that the temporary storage areas identified in the report were due for surveillance inspection; however, the inspections were not overdue in accor-dance with the governing procedures of Standing Order G-22; paragraph 4.7. This paragraph states:
"QC will perform a periodic inspection on all Temporary CQE Storage Areas using the Fort Calhoun Temporary CQE Storage Area Approval form as a guide.
QC may perform as frequent an inspection as they deem necessary, but should inspect each area at least once each month."
0 PPD does not interpret this statement to require inspection in a 30 day period although it is our objective to schedule inspections as closely as possible to a regular monthly time interval.
Area 3 did not exist during the several months when no QC inspections were performed for this area.
Temporary CQE storage areas are transitory and are established and dissolved as required to satisfy the temporary storage needs.
There is not a one to one correspondence of a storage area identification number with a specific plant location. Area identification exists only when the storage area is active.
Thus, over a period of time, one identification number may be used for many storage locations.
Surveillance of temporary CQE storage areas is performed in accordance with existing procedures.
Therefore, the extent to which this condition may apply to the unreviewed portion of design is not applicable.
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'e D2.9 Deficiency OPPD'S RESPONSE (Continued)
Surveillance inspections of temporary storage areas have continued to be per-formed in accordance with plant procedure. Additional measures will be taken to record dates when an area is activated and deactivated to improve the audit-ability of the surveillance activity.
Record forms and procedures will be revised to provide an auditable trail that shows the dates that each temporary storage area is active. This, in conjunc-tion with the surveillance log, will clearly record that all appropriate surveillance inspections are completed in a timely manner.
The inspection comments reveal a lack of auditable records for surveillance inspections of temporary CQE storage areas.
This will be corrected. However, OPPD does not believe that this is a deficiency and request that this finding be reclassified as an observation because QC inspections were not missed nor late according to procedures.
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D2.10 Deficiency - Inadequate corrective action for control of installation of lead shielding In 1982 INP0 identified that Fort Calhoun had no program for lead shielding installations and that engineering evaluations should be performed for those installations in place and a program developed for future installations. A reevaluation by INP0 in 1983 indicated that " design and safety reviews are not documented" for lead shielding installations.
In addition, Information Notice 83-64 and IE Circular 80-18 provided clarification of the requirements of 10 CFR 50.59 with regard to lead shielding and system design changes.
Based on the results of this inspection, it is apparent that INP0 findings and the information provided in IE Information Notice 83-64 and IE Circular 80-18 have not been acted on by OPPD.
Lack of correction of identified discrepancies represents inadequate corrective actions on the part of the licensee.
OPPD'S RESPONSE Cause of the Deficiency 0 PPD initiated corrective action for the condition pertaining to the use of lead shielding identified by INPO in 1982 and information received from the NRC.
In response to the INPO finding in INP0 Evaluation 82-09-43, OPPD prepared a procedure to calculate acceptable lead shielding loads. These procedures were provided to the Plant Engineer on June 12, 1982.
AnEngineeringEvaluationandAssistanceRequest(EEAR)wasissuedinSeptember 1982. The EEAR requested that the lead shielding that was in place prior to the 1982 procedures be evaluated.
It also requested that procedures be devel-oped for installing temporary lead shielding. Standing Order G-17 was changed to require the Plant Engineer to review any Maintenance Order which included the installation of lead shielding.
When the IE Notice 83-64 was received, OPPD reviewed the lead shielding issue and the actions that had been taken to provide a program to control the con-I dition.
It was determined that the program which was in place at that time was sufficient to satisfy the concern expressed in the notice. OPPD had procedures in place that controlled installation of future lead shielding and procedures to evaluate the loads caused by lead shielding.
These procedures were 4
interpreted to comply with the provisions of 10 CFR 50.59 to ensure that an unresolved safety issue was not introduced by installing lead shielding, An active program to evaluate lead shielding that had been installed prior to the 1982 INP0 finding was in progress at the time of the inspection.
Subsequent to the findings of this inspection, lead shielding that had been identified in the shielding log was removed except for three locations (see D2.2-1).
Locations where lead shielding was installed and removed have had a safety evaluation performed for the current configuration.
It was concluded that no damage to piping, supports, or equipment occurred, j
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D2.10 Deficiency (Continued)
DPPDS RESPONSE (Continued)
Significant changes were made to Standing Order G-57, Installation of Temporary Lead Shielding, in March, 1986. The Standing Order has been rewritten using INP0 Good Practice TS-411, Temporary Lead Shielding, as a guideline. The new procedure outlines specific types of analyses which should be considered before installing temporary shielding and requires a safety evaluation be performed and attached to the Temporary Shielding Request Form. The Plant Engineer or his alternate must sign the Temporary Shielding Request Form, giving his con-currence for the shielding to be installed after ensuring the required analysis and safety evaluations are performed and attached.
Procedures have also been enacted to ensure that lead shielding that is approv-ed for installation in accordance with SO G-57 will be properly secured and supported in accordance with seismic and structural design requirements.
A walkdown of plant areas was completed to verify that temporary lead shielding has been identified. Health Physics, Maintenance, and Plant Engineering person-nel have been trained on the procedures to install temporary lead shielding.
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02.10 Deficiency - Inadequate corrective action for resolving System Acceptance Committee discrepancies identified to systems accepted for-operation Review of Systems Acceptance Committee (SAC) activities revealed that no correc-tive action system existed for clearing or re.colving discrepancies identified to systems that had been accepted for operation.
Specific review of SAC accepted modifications from January to June 1984 pro-duced 26 modifications that had been accepted with discrepancies as shown in Table VI. No documentation was available that had followed these discrepancies and assured that they were in fact resolved in a timely manner.
Identification of discrepancies with no system for assurance of completion and management re-view was considered to be inadequate corrective action on the part of the licensee.
The team accomplished a limited check of six of those modifications with SAC discrepancies in Table VI, and found that the discrepancies identified in the SAC meetings had been cleared with the exception of a missing valve identifi-cation tag on MS-338.
TABLE VI t
LIST OF MOOIFICATIONS WITH SAC DISCREPANCIES MR #
Subject Comments83-150 Reroute MSIV Leakoff Lines MS-338 tag not attached as required i
79-171B Pzr Safety Valve Loop Seal TS snubber list was updated 84-90 PORV Reset Demands OP-10 issued 83-116 VLPMS OP & CP issued 82-178 HEPA Carbon Filter Delta P. Indicator Action complete 83 159 SG Support Plate 83-49 HCV-884A Seat Material 76A 04 SG Feedwater Bypass Valve Controls O! Issued 83-32 Qual, of Foxboro Transmitters 82-91 SG Blowdown Rad Monitor 83 21 HCV 348 Shaft Change l
80 10 Install Drain Valve 84-74 Fuse Protection 84 004 Upgrade Limit Switches79-147 Trip Circuit Bypass for Aux. Bldg.
80-19 Wide Range Excore Detectors 70 66 Qual, of Backup Instrumentation r
83 50 Turbine Drain Valve Controls 82-95 Offsite Radwaste Processing l
03 73 Replace Waste Gas Release Valves 82 169 Nitrogen Blanket on EFWST 81 99 HJTC Pressure Boundary 83 56 Hydrogen Purge Valves 83 146 Relocation of PT 105 L
79 81 PORV Activation Setpoints 82 96 Ventilation Mod 54 f
02.10 Deficiency (Continued)
OPPD'S RESPONSE Standing Order G-21, Station Modification Control, outlines the conduct of the System Acceptance Committee (SAC). The SAC currently reviews modifications to determine if:
Applicable sign offs / dates are completed on the procedure The Start-up tests indicate that the equipment operates correctly according to Design Specifications.
Equipment manuals have been received by the Plant Engineer.
All documents such as the surveillance tests, System Descriptions, Operating Instructions and Procedures, Emergency Procedures, the Tech-nical Data Book, USAR, Site Security Plan and security procedures, etc., have been updated, or submitted to the PRC for approval, accordingly.
Applicable training has been completed or at least scheduled for the Operations Staff.
Marked up prints detailing all applicable changes have been included in the plant print files.
Updated P& ids and ems detailing all applicable changes have been pro-vided to the Control Room and the office area.
All Engineering Data Collection Forms have been revised or completed for changes made under this modification.
Equipment Qualification Data Forms have been completed for all new or modified EEQ components.
Preventative maintenance procedures have been written / updated for all new or modified EEQ components.
The Fort Calhoun Storeroom has been notified of changes in spare parts requirements due to equipment replacement, removal or installation.
Confirmation that all necessary Design Verification Reviews have been completed.
This SAC review is documented on a Station System Acceptance Form (Form J).
Form J becomes a permanent part of the modification completion report.
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,o D2.10 Deficiency (Continued)
OPPD'S RESPONSE (Continued)
Standing Order G-21 establishes the following minimum criteria for modification acceptance with outstanding discrepancies and/or deficiencies.
All the sign-offs in the modification procedure and successful startup testing must be completed.
Updated P&ID/EM drawings relating to the modification must be placed in the control room.
Training applicable to the modification must be scheduled or completed.
Operating instructions pertaining to the modification must be updated.
An independent (third party) review must be completed.
Applicable Surveillance Test Procedures (depending on frequency of performance) must be updated.
Standing Order G-21 further specifies that any modification accepted by the SAC with outstanding discrepancies / deficiencies will not be closed out until all listed discrepancies / deficiencies are corrected or satisfactorily disposi-tioned. An assignment is made on the Form J designating the position / person responsible for ensuring that any identified discrepancies / deficiencies are resolved in a timely manner.
Each Form J for the modifications listed in Table VI was reviewed to ensure the minimum criteria for acceptance with outstanding discrepancies / deficiencies had been met at the time of consideration by the SAC.
The results of this review indicate the SAC appropriately discharged its responsibilities with regard to accepting a modification with outstanding discrepancies and/or deficienties.
The Form J, dated March 16, 1984, for modification FC-83-150 entitled " Reroute of MSIV Leakoff Lines" recommended that the modification be accepted with out-standing discrepancies and/or deficiencies. The discrepancy reported on the Form J specified that brass valve tags should be provided for valves MS-338, MS-339, MS-341, and MS-342. On April 5,1984 another Form J for modification FC-83-150 was completed which indicated the valves had been tagged and recom-mended the modification be accepted. Recently,
)lant operations personnel have inspected each of the subject valves to ensure t1at the tagging has not degrad-ed during the period April 5, 1984 to the present.
The Form Js for those modifications listed in Table VI and which are not com-monted on by the NRC Inspection Team were reviewed to determine the timeliness of corrective actions.
The following is the result of this review presented in tabular form:
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D2.10 Deficiency (Continued)
OPPD'S RESPONSE (Continued)
Date Accepted Date MR No.
Subject with Deficiencies Accepted 83-159 SG Support Plate 5/2/84 5/4/84 83-49 HCV-884A Seat Material 2/3/84 (Note 1) 83-32 Qualifi:ations of Foxboro Transmitters 5/15/84 5/16/84 82-91 SG Blowdown Rad Monitor 5/12/84 6/12/84 83-31 HCV-348 Shaft Change 8/26/83 (Note 2) 80-10 Install Drain Valve 4/26/84 5/4/84 84-74 Fuse Protection 4/26/84 5/12/84 84-004 Upgrade Limit Switches 4/19/84 5/12/84 79-147 Trip Circuit Bypass for Aux. Bldg. fans 9/30/83 (Note 3) 80-19 Wide Range Excore Detectors 6/15/84 7/18/84 79-66 Qualification of Backup Inst.(Post LOCA) 5/14/84 6/15/84 83-50 Turbine Drain Valve Controls 4/19/84 6/15/84 82-95 Offsite Radwaste Processing 4/12/84 4/19/84 03-73 Replace Waste Gas Release Valves 1/20/84 (Note 4)82-169 Nitrogen Blanket on EFWST 4/19/84 7/18/84 81-99 HJTC Pressure Boundary 4/19/84 (Note 3) 83-56 Hydrogen Purge Valves 5/11/84 6/15/84 83-146 Relocation of PT-105 5/9/84 5/16/84 79-81 PORV Activation Setpoints 5/11/84 5/14/84 82-96 Aux. Bldg. Ventilation Mod 5/2/84 5/5/84 NOTE 1.
The outstanding discrepancy reported specified that the modification planner should notify the storeroom of new spare parts requirements.
NOTE 2.
The outstanding discreaancy reported specified that the modification planner should place tie marked u) print (other than P&lD and EM drawings) in the plant file. Mar (ed up print was filed on 6/5/84.
NOTE 3.
The outstanding discrepancy reported specified that the system description be updated.
NOTE 4.
The outstanding discrepancy reported specified that the system description be updated and that equipment manuals be provided.
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D2.10 Deficiency (Continued)
.0 PPD'S RESPONSE (Continued) i 1
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A review of the above data indicates that corrective actions by the Systems 1
Acceptance Committee are principally completed in a timely manner. The out-i
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standing discrepancies for which no documentation of corrective action has been j
found are not considered to have significant impact on the proper operation of
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the installed modifications.
4 In as much as our review of the modifications listed in Table VI has resulted
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in a determination that the minimum criteria for acceptance of the modification with outstanding discrepancies has been satisfied, it is concluded that appro-i priate measures have been taken by Fort Calhoun Station personnel to ensure that installed modifications will perform as required and that the necessary training is conducted.
In order to further enhance the Station Modification Control Program, GSE and c
Fort Calhoun Station personnel have developed computer programs to track all outstanding discrepancies identified by the SAC for modifications installed during the 1985 refueling outage. The computer programs track the outstanding discrepancies and the person (s) assigned to implement the corrective action.
l This action will ensure an even more timely response to reported discrepancies t
than has been observed in the past.
The outstanding discrepancies associated with those modifications identified in this response will be resolved. Upon the receipt of documentation of correc-tive action another Form J for the modification will be completed.
f The action already taken will enhance the timely manner in which discrepancies identified by the SAC are resolved.
It is anticipated, after further evalua-
- l tion, that a single computer program will be instituted which could be utilized by OPPD personnel to determine the status of outstanding discrepancies ident-i i
j ified by the SAC.
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