IR 05000285/1985022
| ML20203G635 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/28/1986 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 8608010340 | |
| Download: ML20203G635 (22) | |
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July 28, 1986 Docket No. 50-285 MEMORANDUM FOR:
Eric H. Johnson, Director Division of Reactor Safety and Projects, RIV FROM:
James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement SUBJECT:
FORT CALHOUN SAFETY SYSTEMS OUTAGE MODIFICATIONS INSPECTION (SSOM')
This memorandum identifies anc' iorwards Potential Enforcement Findings (PEFs)
identified during the design portion of the Fort Calhoun Safety Systems Outage Modifications Inspection (Enclosure 1) and our evaluations of the licensee's April 15 and May 22 responses to our design and installation / test inspection reports (Enclosures 2 and 3, respectively).
We have conducted an in-office review of the PEFs tabulated in the enclosure to make a preliminary determination'of an appropriate enforcement classification for each.
Our determination is that the appropriate enforcement classification for each of the items considered individually is Category IV (Supplement I to 10 CFR 2, Appendix C).
Additional information relating to these findings is contained in the inspection report dated January 21, 1986 and in the licensee's response dated April 15, 1986.
The Potential Enforcement Findings were identi-fied as either deficiencies or unresolved items in the inspection report.
Deficiency D3.-2-7, regarding unstable valve operator supports in the auxiliary feedwater system steam supply lines, was not evaluated for enforcement action by this office because we were aware of an investigation being conducted relative to this item and will defer an enforcement decision until the investi-gation is completed.
However, we do consider the licensee's actions to be technically non-responsive for this item.
Enclosure 2, our evaluation of the licensee's response to inspection report 50-285/85-22, was prepared for transmittal to the licensee.
As discussed in our meeting with your staff on July 9,1986, it was agreed that Region IV should coordinate the response to the licensee, in view of the various inspec-tion reports that comprise the SS0MI.
Therefore we are forwarding this docu-ment to you to provide you with our thoughts regarding, 1) the items we con-sider to be closed based on the licensee's April 15, 1986 response, 2) our concerns regarding the items to which we feel the licensee's response is not adequate and 3) items that, in our opinion, need to be closed out by additional inspection.
In addition to Enclosure 2, your staff has been provided with the design inspection team members' individual evaluations of the responses, which should be useful in your future evaluation and closecut of the report findings.
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8608010340 860728 PDR ADOCK 05000285 G
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July 28, 1986 Eric H. Johnson-2-c'
Our evaluation of the licer.see's response to inspection report 50-285/85-29 is provided in Enclosure 3.
Although the general programmatic corrective actions, both long term and short term, were discussed in the July 10, 1986 enforcement conference held in Region IV, specific details of the respor:se were not discussed.
As we discussed by telephone, our evaluations, and any additional concerns or questions you have, should be transmitted to the licensee prior to meeting with the licensee to discuss the specific concerns. We recommend a Dallas location for such a meeting.
A draft transmittal letter is provided in Enclosure 4.
As noted above, our review indicates a need for followup inspection for many of the items in the design inspection report and the installation / test inspection report. We suggest that you consider using the original team members for the design aspects of the reinspection.
We will determine their availability to assist in the followup inspections.
If you have any questions, please contact me or James E. Konklin (492-9656).
- W7 James G.
artlow, Director Division of Inspection Programs Office of Inspection and Enforcement Enclosures:
1.
Potential Enforcement Findings, Design Inspection 2.
Evaluation of Licensee's Response, Design Inspection Report 50-285/85-22 3.
Evaluation of Licensee's Response, Installation and Testing Inspection Report 50-285/85-29 4.
Proposed Letter to Licensee l
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ENCLOSURE 1
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POTENTIAL ENFORCEMENT ACTIONS FORT CALHOUN INSPECTION 1.
Contrary to 10 CFR 50, Appendix B, Criterion III, design control has not been maintained.
The licensee had:
a.
Failed to assure that a design change affecting the post-accident heat loading of the component cooling water system was subject to design control measures commensurate with those applied to the original design (Deficiency D2.2-6).
b.
Failed to assure that design specifications used for plant piping and equipment were subject to design control measures commensurate with those applied to the original design (Deficiency D3.1-1).
c.
Failed to assure that operating and accident temperatures developed as design input fo-piping analyses pursuant to IE Bulletin 79-14 were subject to design control measures commensurate with those applied to the original design, including provisions for necessary control of design interfaces (Deficiency D3.1-2).
d.
Failed to assure that the support for modified junction box JB-432A, which supplies power for auxiliary feedwater turbine steam adMssior.
valve 1045B, was subject to design control measures commensurate with those applied to the original design (Deficiency D3.2-4).
e.
Failed to provide for verifying or checking the adequacy of the design inputs, such as load tables used and reliance on earlier unverified calculations, during the design of replacement station batteries (Deficiency 05.1-1).
2.
Contrary to 10 CFR 50, Appendix B, Criterion XI, test control was not established.
The licensee had:
a.
Failed to establish written test procedures which demonstrate that the accumulators installed to close the auxiliary feedwater steam admission valves would perform satisfactorily in service in accordance with requirements and acceptance criteria contained in applicable design documents (Deficiency D2.1-7).
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Failed to establish written test procedures which demonstrate that the accumulators installed to close the component cooling water RCP supply and return containment isolation valves would perform satisfactorily in service in accordance with requirements and acceptance criteria contained in applicable design documents (Deficiencies D2.2-1 and D2.2-3).
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ENCLOSURE 1 3.
Contrary to 10 CFR 50, Appendix B, Criterion VI, document control measures were not established.
The licensee failed to control the issuance and
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accuracy of system descriptions, nor provided alternate design criteria necessary to establish design control (Deficiency D2.1-9).
4.
Contrary to 10 CFR 50, Appendix B, Criterion IV, procurement document control measures were not established.
The licensee failed to:
a.
Assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality were suitably referenced or included in documents for procurement of services associeted with seismic analysis of valves HCV-4388 and HCV-4380 (Deficiency D2.2-2).
b.
Establish procurement documents which contained provisions to assure the steam generator nozzle dams were qualified to their governing seismic requirements (Deficiency D3.2-6).
5.
Contrary to 10 CFR 50.59, changes to the facility as described by the safety analysis report have been made without the required evaluation to determine the existence of an unreviewed safety question (Deficiencies D6.1-1 and D6.2-2 and Unresolved item U6.1-2).
6.
Contrary to 10 CFR 50, Appendix B, Criterion V, documented instructions, procedures, or drawings were not provided for the installation of seismic
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tubing associated with accumulators for the auxiliary feedwater turbine steam admission valves (Deficiency D3.2-2).
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ENCLOSURE 2
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Evaluation of Licensee Response to Fort Calhoun Safety Systems Outage Modifications Inspection (Design), Inspection Report 50-285/85-22)
D2.1-1 (Deficiency) Lack of Design Analysis to Support Sizing of Air Accumulators for Valves YCV 1045 A/B.
The licensee's response addresses the concerns identified in the deficiency.
However, this deficiency should remain open pending followup inspection of functional testing performed by the licensee.
D2.1-6 (Deficiency) Failure to Follow Procedural Requirements for A Normal Modification Resulting In Lack of Required Design Verification Review.
The license 9's response is considered acceptable with reservation and with one correction.
From a safety point of view, the design verification can occur at any time including just prior to system acceptance.
As stated by the licensee, many times the final installed design may differ significantly from the original proposed design.
Normal engineering practice is to use field change requests, red-line drawings, etc., to modify the design. These documents are design verified as part of the change request approval cycle such that at any one time the design released for construction is design verified.
If OPPD chooses to do verification at the end of installation and testing, and if the verification is done properly, then from a safety point of view there is no problem.
However, the NRC's reservation is that this is not good engineering practice because it may cause design verifications at the end of a refueling cycle or major outage to be rushed through without sufficient thought or proper consid-eration of safety implications.
In addition, there will be greater emphasis on rationalizing why the installed work is adequate, rather than seeking the optimum design solution.
The licensee's proposed actions detailed in the July 10, 1986 enforcement con-ference seemed responsive to this issue; however, they have not been formally transmitted to the NRC as commitments.
The licensee incorrectly stated that ANSI N45.2.11 allows design verification to be done by testing.
Qualification testing of a prototype or initial production unit is described in ANSI N45.2.11 subsection 6.3.3.
The discussion in this subsection is clearly related to design of components.
Qualification testing _ associated with equipment qualification is a good example of the intent of this subsection.
Typically a production unit or prototype is subjected to seismic and harsh environments (pressure, temperature, humidity, and radiation)
so that other components can be qualified by reference.
The post-modification testing of a system is not the intent of this subsection.
During the inspec-tion, the team noted the licensee's apparent reliance on testing in lieu of design calculations or analysis to confirm design details.
Post-modification tests cannot test system performance under all of the adverse design conditions that the system may be required to experience.
It is clear that post-modifica-tion testing / functional testing is not routinely performed under the most adverse conditions (see OPPD Appendix B Item 3).
Post-modification testing demonstrates that the modifications or changes reasonably produce expected-1-
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ENCLOSURE 2
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results and the change does not reduce safety of operations.
It does not guarantee that the modified system or component will function under the most
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adverse conditions for which the design was based.
This item should remain open pending further evaluation of the licensee's use of testing for design verification purposes.
D2.1.7 (Deficiency) Incor.plete Installation / Testing Procedure in Construction Package for MR-FC-83-158.
This deficiency should remain open pending followup inspection of functional testing performed by the licensee.
D2.1-9 (Deficiency) Incorrect System Description Statements.
In the short-term the licensea's action is considered acceptable (i.e.. to warn potential users that the published volumes of system descriptions may not accurately reflect the as-installed design).
OPPD has deferred a decision regarding long-term corrective action pending a generic review of the design change / modification program.
The NRC considers that the longer term action should be to maintain these documents, or generate similar docu.nents containing system design criteria, as sources of design input data concerning the system.
This is especially important in view of the fact that design calculations, if performed, are stored by modification even though the files are " controlled."
Although the licensee states that design information is available in other controlled documents, a significant void exists in design basis documentation (as acknowledged in the licensee's letter).
In addition, many of the systems have been so altered by past modifications it would be practically an impossible task to review all of those modifications to establish the current design arrangement if system descriptions (or design criteria) did not exist.
This item remains open pending inspection of the licensee's short-term correc-tive actions and definition of long-term actions.
The long-term actions detailed in the July 10, 1986 enforcement conference appeared responsive to this concern.
02.2-1 (Deficiency) Incorrect Design Input in Calculation Associated with MR-FC-81-218.
A new calculation which is checked, verified, and approved will resolve the team's concerns regarding accumulator volume, minimum air pressure, and docu-mentation by the checker.
However, the licensee has not performed functional testing to demonstrate that the valves in question will remain shut for a pre-determined period of time under worst case conditions.
The team is concerned that, due to air leakage through fittings and joints and through check valves which do not seat properly, a margin of 40% may not be sufficient.
The team noted that the air accumulator installation was not properly tested after modi-l fication (See Deficiency D2.3-3) and that surveillance testing is not performed to demonstrate the capability of the Critical Quality Element portion of the instrument air system to close these valves and maintain them closed for a pre-determined period of time without loss of function.
The NRC acknowledges the licensee's statements regarding the desire not to introduce unwanted transients during facility operations, but does not consider this objective and adequate functional testing to be mutually exclusive.
For example, the functional ade-quacy of this modification could be tested when the plant was otherwise shut down.
This item will be reinspected.
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ENCLOSURE 2
D2.2-2 (Deficiency) Incomplete Consideration of CQE and Seismic Class I
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Requirements for Portions of MR-FC-81-218.
The licensee's response addresses the concerns identified in the deficiency.
This item should remain open pending completion of OPPD's evaluation associated with IE Information Notice 85-84 and subsequent inspector followup.
D2.2-3 (Deficiency) Incomplete Installation / Testing Procedure Performed for MR-FC-81-218.
l The licensee's response is acceptable, in part.
The licensee's lack of commit-ment to functionally test that portion of the instrument air system associated
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with HCV-438B and HCV-4380 remains a concern.
Because these are containment iso-
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lation valves, the ability of the instrument air system to function should be
demonstrated by testing.
These concerns are heightened by the shift supervisor's and design engineer's concerns regarding the possibility that valve cycling during system operation
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would cause unacceptable transients in the system.
If the system design is such
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that this is the case, a significant safety concern exists and should be promptly i
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during the course of an accident when the safety feature is relied upon to
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function.
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D2.2-5 (Deficiency) Incorrect Information on Instrument Air Diagram.
The licensee's response is considered in conflict with good engineering practice.
The NRC is concerned with the licensee's position that if an item is not safety-related it does not need to be shown on a design document. The P&ID is a principal design document.
Information should be accurately recorded because this drawing is the basis for design and operation decisions.
This item should remain open pending further NRC review of the licensee's practice
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of not maintaining P&ID's consistent with the installed physical arrangement.
D2.2-6 (Deficiency) 10 CFR 50.59 Safety Evaluation Based upon an Incorrect
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Assumption and Analysis Methodology.
The licensee's response is considered inadequate.
First, the Fort Calhoun USAR is not adequately enough controlled to be used as a source of design input for design analyses.
The USAR is only updated yearly and no means exist to inform
design personnel which items in the USAR are incorrect.
If the USAR is to be used as a design document, a system must exist and be available to all 0 PPD design personnel to ensure that errors in the USAR are documented between i
revisions. The changes to the USAR must also be controlled in a manner similar to that of design drawing and calculations.
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The technical specification basis states the heat removal capacity available
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from the CCW system.
It is recognized that the added heat load was small, but 10 CFR 50.59 does not specify the threshold of significance.
However, the safety evaluation should have recognized that the modification decreased the margin of safety compared to the basis on a technical specification. Although
the safety evaluation recommendation regarding securing safety-related equipment was not implemented, the team noted that other " recommendations" made by design engineers are critical to preclude the introduction of unreviewed safety-3-
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ENCLOSURE 2
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questions.
For example, the vital ac inverter modification safety evaluation assumed inoperability of an inverter if the bus was powered by interruptable
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ac power.
If such an assumption is incorporated into the cperating procedures and the operators are thus precluded from powering more than one inverter supplied bus,at a time from interruptible ac power, then an unreviewed safety question is not introduced.
It is not clear that engineering assumptions and recommendations in safety evaluations are adequately controlled, and that, for example, guidance would have been provided to caution operators from powering more than one bus from interruptible ac power.
The lack of access to original design analyses or the failure to prepare com-parable design analyses in the absence of such design analyses was the major concern of this finding.
The licensee did not provide specifics as to corrective measures and has instead offered to study the problem.
It should be noted that the lack of access to OPPD calculations as well as original design calculations was a concern of the team.
The licensee's actions regarding short-and long-term use of the FSAR and design input information, and regarding enhancement of the safety evaluation process, appear responsive.
These were not provided in their response but presented at the enforcement conference.
This item should remain open pending implementation of these corrective actions.
D3.1-1 (Deficiency) Plant Design Specifications.
OPPD resolution of deficiency 3.1-1 is contingent on the results of OPPD's review of the Design Change / Modification program which includes a review of the control and use of design inputs, and the maintenance and use of design basis information.
Attachment B, item 2 of OPPD's response, Lack of Design Basis Records, indicates tnat OPPD has factored the concern of design basis records into the overall review of the Design Change Modification program.
At the con-clusion of this review, OPPD should provide evidence to confirm that contract 763 has either been withdrawn from use by design personnel, or revised and issued to design personnel as a controlled document.
The licensee stated in their response that the information contained in the con-tract specification is contained in other, controlled documents.
This information was not made available to the team during the inspection.
Regardless of this, a long-term action detailed by the licensee at the enforcement conference was reconstitution of necessary design basis information.
Reinspection should be performed to verify the existence of controlled documents which contain the comprehensive piping specification information used by design engineers.
D3.1-2 (Deficiency) DesignTemperaturesiorSafety-RelatedPiping.
OPPD's specific resolution of this item is contingent upon the review of the Design Change / Modification program which OPPD is currently conducting.
At the conclusion of this review, OPPD should provide evidence to confirm that the marked up piping and instrumentation diagrams containing operating and accident temperatures have been withdrawn from use by design personnel, and replaced by a controlled documer:.
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ENCLOSURE 2
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U3.1-3 (Unresolved Item) Small Bore Pipe Support Spacing.
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OPPD's response to this item does not formally reconcile the discrepancy between the support spacing criteria specified by the contractor performing the field routing and USAR Appendix F, subsection F.2.5, for piping runs which penetrate the containment shall or are otherwise connected to it.
OPPD should provide the specific actions taken or planned to resolve this issue.
The NRC understood (during preliminary review of the licensee's corrective action discussed in the response letter) that this issue was to be formally reconciled during a complete review for Unresolved Safety Issue A-46.
No such commitment was made in the licensee's response.
U3.2-1 (Unresolved Item) MR-FC-84-61 Design Input Source and Use.
This item should remain open pending reinspection to confirm that modification request FC-84-61 has been revised to properly document engineering judgment and to document and reconcile design basis information.
D3.2-3 (Deficiency) MR-FC-84-162 Calculation.
This item should remain open pending OPPD's preparation or identification of a controlled document for use by design personnel which specifies shop and field surface preparation of Seismic Category 1 materials.
03.2-6 (Deficiency) Steam Generator Nozzle Dams.
This item should remain open pending review of the procedure that Nuclear Production Division is developing to provide guidelines for the purchase of critical quality element (CQE) materials and services.
D3.2-7 (Deficiency) YCV 1045B Valve Restraint.
The NRC considers OPPD's response to this item to be unacceptable.
The team notes that (Item 1 of OPPD response) the valve operator strut is attached to a stair post, in apparent violation of the seismic requirements which USAR Appendix F Subsection F.1.3 imposes on supports associated with Seismic Class I equipment.
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OPPD noted that they obtain valve weights and dimensions directly from the vendor, instead of retrieving the appropriate valve vendor drawing from a con-
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trolled data base.
However, OPPD did not provide any documentation to sub-stantiate the weight and center of gravity dimension for valve operator YCV 1045B which OPPD used to stress analyze portions of the auxiliary feedwater system.
The team reiterates that the supports adjacent to valve YCV 1045B were overloaded with respect to specific OPPD support loading criteria.
However, OPPD did not address this team concern in Item 6 of the OPPD response.
This item should also remain open pending NRC inspection of controlled instruc-tions for use by 0 PPD piping analysts and designer which incorporate the recommendations of OPPD's review of the Design Change / Modification program.
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ENCLOSURE 2 U4.3-2 (Unresolved Item) ESF Bypass Switch Keylock Provision.
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In modification MR-FC-81-102, three engineered safety feature bypass switches were to be added in each of two locked, metal enclosures.
The unresolved aspect of this concern was whether the technical description and design evalua-tion of the modification contained all of the equipment requirements necessary to establish an unambiguous design configuration that would help assure that only one engineered safety feature channel could be bypassed at any given time.
Omaha Public Power District's response states that the design modification met the administrative control requirements of section 4.14 of IEEE Standard 279-1968, and that use of different key combinations was not considered necessary to comply with applicable requirements.
While bypass annunciation was provided to alert the operator, the response does not address whether the design modification would prevent concurrent bypass of redundant engineered safety feature channels.
Section 4.11 of IEEE Standard 279-1968 requires system level compliance with the single failure criterion
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when one channel is bypassed or removed from operation.
Omaha Public Power District should be requested to provide confirmation that the present design of the modification conforms with the single failure criterion by preventing con-current bypass or removal from operation of redundant engineered safety feature channels.
U4.4-1 (Unresolved Item) Design Basis Physical Separation Within Panels.
Additional information is still needed to resolve these separation questions.
In 1978, modification MR-FC-77-40 added redundant engineered safety feature undervoltage protection components in separate enclosures within panel CB-4.
Physical separation of redundant safety-related metallic-shielded wiring external to these enclosures was not provided since no commitment had been made with respect to IEEE Standard 384-1974 or Regulatory Guide 1.75; however, Omaha Public Power District stated that this modification was installed in accordance with the original construction criteria derived from IEEE Standard 279-1968.
For MR-FC-77-40, Omaha Public Power District is requested to provide an analysis to demonstrate that a USAR commitment in section 7.3.1.b for separation of
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engineered safeguard controls has been satisfied.
More recently, modification MR-FC-81-102 was prepared to add engineered safety feature bypass switches, and separation details were based on criteria stated in IEEE Standard 384-1981 to the extent practicable within the constraints of the existing panels.
Omaha Public Power District's response is based on IEEE Standard 384-1981 section 7.2.2.2 in that a control switch may be justified as an acceptable isolation device provided that section 7.2.2.1 requirements have been satisfied.
In this particular modification, the control switch has been assumed to be an acceptable isolat. ion device, but this assumption has not been demonstrated by analysis and qualification test as required by the IEEE Standard.
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For MR-FC-81-102, Omaha Public Power District is requested to provide the analysis of Class 1E circuits and qualification test results for the control switch to demonstrate the justification for not meeting a minimum separation distance.
To the extent that current and future modifications assume credit for metallic-braided wiring as a separation barrier in lieu of physical separation, qualifi-cation analysis and test results should be provided.
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ENCLOSURE 2 05.1-1 (Deficiency) Battery Sizing Calculation.
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The NRC should review the latest and 1985 revised load profile calculations and documentation to substantiate the new load profiles.
The NRC should also inspect the test procedures and the results of these battery discharge tests which demonstrate the acceptability of the modified battery.
D5.2-1 (Deficiency) Fire Wrap Protection for Cable Raceways.
The NRC should inspect the loading calculations for the MCC feeder cables and the formal and revised de-rated ampacity calculations for fire wrapped cables.
Cable routing and raceway details should also be reviewed.
The NRC also reviewed the licensee's response to the following deficiencies
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and unresolved items and considers the responses acceptable. Confirmatory inspection of the licensee's corrective actions may be conducted.
D2.1-2 (Deficiency) Seismic Requirements Not Specified in MR-83-158 Procurement Documents.
D2.1-8 (Deficiency) Incorrect Information on Flow Diagram For Main Steam System.
U2.1-10 (Unresolved Item) Use of Fluorocarbon-Elastomer Material in High l
Radiation Environments.
D3.2-2 (Deficiency) MR-FC-83-158 Installation Procedure.
D3.2-4 (Deficiency) Junction Box Supports.
04.3-1 (Deficiency) Limit Switch Circuit Protection by Fusing, MR-FC-84-74A.
D4.5-1 (Deficiency) Drawing Changes by Procedure A-9, MR-FC-82-178.
U4.5-3 (Unresolved) Battery Room Fire Hazard Analysis.
U5.1-2 (Unresolved) Battery Chargar/DC Bus Coordination.
D6.1-1 (Deficiency) Safety Evaluations for Non-Safety-P. elated Systems Described in the USAR.
U6.1-2 (Unresolved) Safety Analysis for Emergency Modifications.
D6.2-2 (Deficiency) Modifications to AFW Turbine Steam Supply Valves.
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ENCLOSURE 3
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Evaluation of Licensee Response to Fort Calhoun Safety Systems Outage Modifications Inspection (Installation / Testing)
Inspection Report 50-285/85-29 02.3-2 (Deficiency) Unapproved changes to installation procedures OPPD did not believe that D2.3-2 was a deficiency and requested that the finding be reclassified as an observation because the annotations were made in accordance with procedures.
The inspection team was not aware of OPPD procedures which control the use of " pen and ink" changes and indicate a threshold point at which S.0. G-30 is/is not applicable.
Review of procedures which control pen and ink changes should be accomplished prior to closecut of the deficiency.
On-the-Spot procedure change #15500 was essentially a complete re-write of the previous revision and deleted the depressurization verification requirement, l
which the inspection team considered to be a safety issue.
02.3-3 (Deficiency) Procedure change implemented prior to PRC approval The licensee's response is inadequate.
One purpose of the Plant Review Committee (PRC) is to meet as a committee (quorum) to discuss procedure changes including possible interactive effects of those changes.
These requirements cannot be satisfied by individual reviews.
OPPD's response clearly indi-cated that implementation of the procedure change took place two days prior to PRC quorum review of the proposed procedure change.
S.0. G-30 as written or interpreted should be revised to be in compliance with section 5.8.2 of the Technical Specifications.
D2.3-5 (Deficiency) Construction package drawing changes without an approved field change The licensee's response is inadequate.
The location of the weld was not clear on the drawing and an individual took the initiative to clarify or interpret the. welding instructions shown on the drawing without following the change process outlined in S.0. G-30.
The inspection team considered the weld clarification and subsequent welding a possible design deviation from the intent of Westinghouse which may affect the seismic qualification of the trans-former.
D2.4-1 (Deficiency) Installation procedures were not in accordance with S.0.
G-21, GSEE-0517 and GSEE-0512 OPPD's response is inadequate. The corrective action specified by the licensee was limited to reviewing the personnel qualification program to ensure only qualified people were allowed to perform the tasks assigned.
No mention was made concerning possible corrective action to improve procedures in either detail or quality.
The following is in response to OPPD's specific comments:
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ENCLOSURE 3 MR-FC-83-158 - OPPD indicated that tubing was field routed by verbal communi-
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cation between the design engineer / planner and craft, and that this was in accordance with ANSI N18.7-1976.
ANSI N18.7-1976 requires that modifications be performed in accordance with written procedures, documented instructions or drawings as appropriate.
Considerations are given to craft capabilities when determining the required level of detail of the procedures.
The use of verbal instructions (procedures) to install safety related equipment o* to relate design criteria, acceptance criteria, or material requirements, does not satisfy the requirements of S.0. G-26A or Appendix A of the Quality Assurance Program.
MR-FC-85-62 - OPPD indicated that a pre-job meeting was held to ensure that cleanliness of the system was maintained, however, verification of cleanliness after drilling through the 16 inch pipe was not accomplished.
The meeting also discussed bolt tightening requirements and fitup requirements, however, the flange faces were found to be out of parallel by approximately.030 inch (using a caliper) and the joint was leaking.
OPPD indicated that the loss of the existing flow element was not part of the modification since it was not known at the time of design, and that a safety analysis was performed to ensure that the loss of the flow element did not introduce an unresolved safety question.
Information made known to the inspec-tion team during the inspection indicated that the flow element was lost in the Fall of 1984, while the modification to replace the element was initiated in 1985, which appears to contradict the above statement.
Also, the analysis to determine whether an unreviewed safety questicn existed regarding the lost flow element was not performed until questions were raised by the inspection team.
Over a year had elapsed from the time that the element was lost to the point when the analysis was actually performed.
MR-FC-84-61 - OPPD stated that craftsman knowledgeable in the requirements to safely w Fd in the vicinity of the valve were available.
OPPD does not indi-cate that these welders were actually used to perform the welds, that the vendor recommended prerequisites for the welding were known by the welders, or that the vendor's welding procedure was used.
5.0. G-21 indicates that the planner is responsible for specifying any special tools, skills, processes, and suitable environmental conditions for accomplishing the activity, and the prerequisites to be satisfied for a given activity.
Reliance upon memories of welders to establish vendor-recommended welding prerequisites (rather than planner generated procedures) is inadequate.
MR-FC-84-74A - OPPD indicated that " random inspection" means random selection of a minimum of 10% of the specified splices including appropriate hold points for QC.
Procedure GSEE-0512 step 4.2 states:
" Notify QC prior to beginning splice procedure.
NOTE:
Plant QC shall inspect a minimum random sample of 10%
of the conductor splices for conformance with these procedures."
It is clear from reading GSEE-0512 that QC shall be notified prior to beginning a splice procedure (i.e. 100% of splices).
The procedure is also clear that QC is to randomly select 10% of those splices, and to perform an inspection.
If OPPD does not intend to have QC notified prior to each splice activity and to have QC perform a 10% random (unbiased) inspection, then procedure GSEE-0512 should be revised.
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ENCLOSURE 3 D2.4-2 (Deficiency) Failure to follow procedure requirements
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The following is in response to OPPD's specific comments:
MR 81-80 - OPPD did not believe that the finding associated with MR 81-80 regarding QC (QA) hold points for material verification prior to installation was a deficiency and requested that the finding be reclassified as an observa-tion.
It was the understanding of the inspection team that QC (QA) verifica-tion of material acceptability was required by the procedure prior to installa-tion and not at some later date.
This particular finding should remain open until additional information can be reviewed.
MR 85-105 - The modification procedure ord not control or provide status of the Halon fire suppression system as required.
A continuous fire watch was not established as required.
Technical Specifications also require that backup fire suppression equipment must be provided when the Halon system is inoper-able. OPPD did not adequately respond to the concerns noted, in either expla-nation or corrective action.
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MR 84-119 - 5.0. G-20 requires a shift supervisor signature for tagging'out of equipment.
Tags were hung and work was in progress without the shift superviscr's review and approval.
OPPD did not adequately respond to this concern and did not recommend corrective action.
OPPD's review of D2.4-2 indicated that each of the findings cited was an isolated case. The SSOMI revealed that over 50% of the modifications reviewed during the outage exhibited concerns in which procedures were not being fol-lowed.
Individual specific situations involving a procedure deviation may be considered isolated occurrences,'however, the generic concern of inadequate procedure observance should be a concern to OPPD and warrant corrective action.
D2.5-1 (Deficiency) Inadequate welding, end preparation, and inspection associated with the replacement of valve MS-100 It was the understanding of the NRC inspectors that none of the deficiencies associated with the installation of value MS-100 was identified by 0 PPD's QC inspectors prior to their being notified of the concerns by the S50MI inspection team.
Regarding the concern involving violation of minimum wall, OPPD indicated that an OPPD QC inspector had also observed and reported this condition.
The 550MI inspection team was not informed of that during the inspection.
The effectiveness of OPPD's corrective action should be reviewed during followup inspections.
02.5-2 (Deficiency) St.i mic instrumentation tubing span violations between supports OPPD did not believe that a deficiency existed and that D2.5-2 should be reclassified as an observation because the tubing was installed in accordance with applicable requirements and procedures.
OPPD stated that the tubing supports were not installed in accordance with the Stone and Webster guideline, that the planner was aware of the deviation and that calculations were requested to be performed to justify the support spacings that were used.
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s EECLOSURE 3
The NRC inspection team was not informed of any 0 PPD initiated action being
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taken to resolve problems associated with MR-83-158 prior to the time that NRC concerns were voiced to 0 PPD.
Despite the level of attention given MR-83-158 during the design inspection part of the SS0MI, the installation was not in accordance with design requirements and additional engineering reviews had to be performed to accept the as-built configuration.
Documentation that supports OPPD's corrective action, including engineering calculations and reviews, should be reviewed by the NRC.
D2.5-4 (Deficiency) Installation discrepancies found in installation of safety injection tank relief valves OPPD did not believe that D2.5-4 was a deficiency and requested that the deficiency be reclassified as an observation since an engineering analysis was performed on the surface discontinuities and that the weld was PT'd and found to be acceptable.
During the SSOMI, the inspection team requested several welds which were previously PT accepted to be re-PT'd for evaluation.
The inspection team requested the weld associated with SI tank 6B to be reinspected.
A written response from a QC inspector stated that the indication was filed on but not totally removed, however, it passed PT.
There appears to be some confusion as
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to whether the PT was ever accomplished as requested.
OPPD should be able to produce the NDE results for the inspection performed on 12-16-85. The engi-neering analysis which accepted the surface discontinuities should also be reviewed for adequacy.
D2.5-5 (Deficiency) Inadequate flow element flange installation OPPD stated that at the time the craft signed off the step in the installation procedure the flange wasn't leaking and that OPPD uses leakage as the primary criterion when installing flanges.
OPPD also stated that the flange faces were visually determined to be parallel by the modification planner.
Upon walkdown of MR 85-62 the inspection team noticed that the flange was leaking and that the flange faces were visually out of parallel and assumed this to be the cause for the leakage.
Measurements were later taken using a caliper and the flange faces were determined to be out of parallel by approxi-mately.030 inch.
It is requested that documentation be reviewed which would verify that the CCW system was at normal operating pressure at the time of craft sign-off for nonleakage.
D2.5-7 (Deficiency) Weld inspections not accomplished for transformer base welds to the imbedments OPPD stated that the procedure for MR-FC-105 did not have a signoff in the procedure body itself to document QC notification prior to performing work.
However, QC was notified prior to the start of work and did perform the required visual inspection.
Clarification of the actual events surrounding the QC inspection should be provided by OPPD.
The inspector who reported the concern recalls the follow-ing:
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ENCLOSURE 3
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- An NRC inspector wat present during the welding A QC inspector was not present during the welding
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The welder did not know whether the weld was to be inspected, and asked the NRC inspector whether he knew
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Several times during the inspection, the inspection team requested that the inspection records be produced, however, the records could not be found The planner / engineer was not aware of the inspection requirements specified in GSEE-0517 section 5.2.2 There appears to be inadequate control and documentation o, the inspection effort.
Corrective action regarding this deficiency was not addressed by OPPD.
D2.6-1 (Deficiency) Inadequate welding and nondestructive test inspection OPPD accepted the overall deficiency but rejected the individual finding involving MR 84-061.
OPPD contended that QC inspected the weld and determined that the crater pit was not sufficient to reject the weld, and that testing verified the acceptability of the welds.
It appears that OPPD is relying upon the original PT results, which were accepted as satisfactory, and that the re-PT inspection requested by the NRC may not have been accomplished.
See response to D2.5-4.
Additional followup will be required to better determine the sequence of events and which inspections were actually performed.
D2.8-1 (Deficiency) Inadequate requirements for recording of data resulted in an indeterminate battery charger load test OPPD did not believe that D2.8-1 was a deficiency and requested that the finding be reclassified as an observation because the test was accomplished according to procedures.
In response to the above, the inspection team notes that the test procedure required that data be obtained to document that the inverter and battery combinavion was capable of performing for at least one hour at the proper voltages. The. test performed did not specifically record data to verify acceptance.
The test data should have included:
starting time of test initial float and equalizing voltages voltage values recorded at regular intervals (e.g., eve'ry five minutes) during conduct of the test final float and equalizing voltages at the completion of the test
- completion time of test.
No data was taken to demonstrate that the system performed adequately during the test or that the duration of the test was controlled and documented.
It is also not clear whether the modification test performed met the requirements of ANSI N18.7.
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ENCLOSURE 3
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D2.8-2 (Deficiency) Test procedure did not verify design concept under accident conditions
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OPPD accepted the deficiency but did not believe that a generic concern existed and therefore did not specify any corrective action.
The inspection team, however, believes that corrective action is required as evidenced by concerns involving MR 84-119, MR 83-158 and MR 84-74A.
Modifications to plant compo-
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nents or systems should be adequately tested to verify acceptability of the l
intent of the modification and to ensure that modifications do not adversely l
affect the design basis or the safety of operations.
D2.9-2 (Deficiency) Inadequate warehouse storage of safety-related material 0 PPD indicated that the items identified by the inspection team were improperly stored, however, OPPD had implemented a project to verify the adequacy of CQE material and storage.
OPPD also indicated that QA had previously identified the concerns of D2.9-2 and was in the process of taking corrective action.
Because of the action taken OPPD requested that the deficiency be reclassified as an observation.
The inspection team was not informed that OPPD had identified the same concerns as those of D2.9-2 and had implemented corrective action.
OPPD should provide documentation (nonconformance reports, audits, surveillances and corrective actions) to support the above remarks.
D2.9-3 (Deficiency) Inadequate QC surveillance of '.emporary safety-related storage areas OPPD stated that QC inspections were not missed nor late according to procedures and requested that D2.9-3 be reclassified as an observation.
S.O. G-22 clearly indicates that a periodic inspection of all temporary CQE storage areas should take place at least once each month.
The term " month" is commonly understood to be a period of time of approximately 30 days.
Based upon the records available this interpretatior; would indicate inspection problems with seven of the 13 temporary storage areas.
OPPD should produce documentation to clarify when the areas were opened and closed, or other auditable records that to indicate that control of CQE areas was being main-tained.
It appears that S.0. G-22 is either inadequate or is not being fol-lowed.
The NRC also reviewed the licensee's responses to the following deficiencies and unresolved items and considers the responses to be acceptable.
Confirmatory inspection of the licensee's corrective actions may be conducted.
D2.2-1 (Deficiency)
Lack of documented safety evaluations for installation of lead shielding on safety-related piping and components.
D2.2-2 (Deficiency) Lack of documented safety evaluation for installation of a penetration fitting through a fire barrier.
D2.2-3 (Deficiency) Lack of documented safety evaluations for electrical jumpers installed for extended time periods.
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ENCLOSURE 3 D2.3-1 (Deficiency) Inadequate control of construction package drawings and
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drawing lists.
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D2.3-4 (Deficiency) Training not accomplished prior to approval of procedure change.
U2.3-1 (Unresolved On-the-spot changes not approved by PRC within Technical Item)
Specification time constraints.
D2.3-6 (Deficiency) Calibration procedures changes without approved field changes.
U2.3-2 (Unresolved Lack of calibration record for a pressure source used Item)
for safety-related channel calibration D2.5-3 (Deficiency) Inadequate support of seismic instrumentation tubing near air regulators D2.5-6 (Deficiency) Installation discrepancies found in installation of new delta T power process loop instrumentation U2.5-1 (Unresolved Questionable installation practices relative to installa-Item)
tion of delta T power process loops cables and panels.
U2.5-2 (Unresolved Foxboro transmitter 0-ring replacement not documented to Item)
maintain environmental qualification D2.6-2 (Deficiency) Plant welding accomplished to nonapplicable weld procedures D2.9-1 (Deficiency) Inadequate temporary storage of safety-related material D2.10-1 (Deficiency) Inadequate corrective action for control of installation of lead shielding
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D2-10-2 (Deficiency) Inadequate corrective action for resolving System Acceptance Committee discrepancies identified to systems
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accepted for operation i
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ENCLOSURE 4
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k UNITED STATES
,[ \\ g (' i NUCLEAR REGULATORY COMMISSION g..
f. j WASHINGTON, D. C. 20555 k.u /
....
Docket No. 50-285 Omaha Public Power District ATTN: Mr. Bernard W. Reznicek President and Chief Executive Officer 1623 Harney Street Omaha, Nebraska 68102 Gentlemen:
SUBJECT:
SAFETY SYSTEMS OUTAGE MODIFICATION INSPECTION; REPORTS 50-285/85-22 AND 50-285/85-29 This refers to your letters, dated April 15, and May 22, 1986, in response to our letters dated January 21, and March 19, 1986 which respectively forwarded the design portion and installation / test portion of the Fort Calhoun Station Safety Systems Outage Modification Inspection conducted by the NRC's Office of Inspection and Enforcement.
These inspections were part of a trial NRC program being implemented to examine the adequacy of licensee management and control of modifications performed during major plant outages.
Thank you for informing us of the corrective and preventive actions documented in your letter.
In addition, we appreciated the opportunity to discuss your short and long term corrective actions in the conference at our office on July 10, 1986.
Certain of the items require additional information, review and/or reinspection
)
to assess their acceptability.
The enclosure to this letter describes these items, including specific concerns regarding individual responses.
A meeting on August 7, 1986 has been planned to discuss the particular inspec-tion findings and remaining specific concerns regarding your responses.
The enclosed evaluation of your responses is provided to assist in your preparation for this meeting.
Formal enforcement action relating to the subject report will be sent to you following the meeting on August 7, 1986.
Resolution and followup inspection for the items in the enclosure will be handled by the Region IV Office.
The NRC may perform confirmatory inspections of certain items addressed in the subject inspection reports.
In addition the NRC will monitor your short and long term corrective actions described in your letters, including the results and conclusions of the system-atic review of the design change / modification program and your increased emphasis on completion of design work as part of pre-outage planning.
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ENCLOSURE 4 Omaha Public Power District
,
In accordance with 10 CFR 2.790 (a), a copy of this letter, the enclosures, and your letters dated April 15, and May 22, 1986 will be placed in the NRC's Public Document Room.
Should you have any questions concerning this letter, please contact me or Mr. Dorwin A. Hunter (817-860-8103) of this office.
Sincerely, SIGNATURE Enclosures:
1.
Fort Calhoun Inspection Items Requiring Reinspection and/or Additional Information cc w/ enclosures:
See next page
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