ML20212K143
| ML20212K143 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/05/1986 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Reznicek B OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8608190193 | |
| Download: ML20212K143 (17) | |
See also: IR 05000285/1985022
Text
AUG 5 1986
Docket No. 50-285
Gmaha Public Power District
ATTH: Mr. Bernard E Reznicek
President and Chief Executive Officer
1623 Karney Street
Omaha, Nebraska 68102
Centlerer.:
SUBJECT: SAFETY SYSTEMS OUTAGE 110DIFICATION 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
cur letters dated January 21, and March 19, 1986, which respectively forwarded
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the des 15n 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 oppcrtunity to discuss your
short and long term ccrrective actions in the conference at our office on
July 10, 1985.
Certain of the i. Is 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 plar.ned 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.
Fonnal enforceraent action relating to the subject report will be sent to you
folicwing the meeting on August 7, 1986.
Resolution and followup inspection for the items in the enclosure will be
har.dled 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 cf the design change / modification program and your increased
emphasis on completion of design work as part of pre-outage planning.
C/RP
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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. D. R. Hunter (817-860-8103) of this office.
Sincerely,
Original signed by
T. F. Westerrnan
E. H. Johnson, Director
Division of Reactor Safety
dnd Projects
Enclosures:
1.
Fort Calhoun Safety Systems Outage Modifications Inspection (Design),
Inspection Report 50-285/85-22
2.
Fort Calhoun Safety Systems Outage Modifications Inspection
(Installation / Testing) Inspection Report 50285/85-29
cc w/ enclosures:
W. G. Gates, Manager
Fort Calhoun Station
P. O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NW
20036
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
bcc to DMB (IE01)
bcc distrib. by RIV:
RP8
Resident Inspector
R. D. Martin, RA
R&SPB
Section Chief (RPB/B)
MIS System
RIV File
DRSP
RSTS Operator
RSB
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ENCLOSURE 1
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 licensee'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 NPC'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
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production unit is described in ANSI N45.2.11 subsection 6.3.3.
The discussion
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in this subsection is clearly related to design of components. Qualification
testing associated with equipment qualification is a good example of the intent
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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
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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
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adverse conditions (see OPPD Appendix B Item 3). Post-modification testing
demonstrates that the modifications or changes reasonably produce expected
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results and the change does not reduce safety of operations.
It does not
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guarantee that the modified system or component will function under the trost
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adverse conditions for which the design was based. This item should remain
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open pending further evaluation of the licensee's use of testing for design
verification purposes.
D2.1.7 (Deficiency)
Incomplete Installation / Testing Procedure in. Construction
Package for MR-FC-83-158.
This deficiency should remain open pending followup inspection of functional
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testing performed by the licensee.
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D2.1-9 (Deficiency)
Incorrect System Description Statements.
In the short-term the licensee'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
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. regarding long-term corrective action pending a generic review of the design
change / modification program. The NRC considers that the longer term action
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should _ be to maintain these documents, or generate simi.lar documents containing
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system design criteria, as sources of design input data concerning the systen.
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This is especially important in view of the fact that design calculations, if'
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performed, are stored by modification even though the files are " controlled."
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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
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have been so altered by past modifications it would be practically an
impossible task to review all of those modifications to establish the current
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design arrangement if system descriptions (or design criteria) did not exist.
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This item remains open pending inspection of the licensee's short-term correc-
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tive actions and definition of long-term actions.
The long-term actions detailed in the July 10, 1986, enforcement conference
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appeared responsive to this concern.
D2.2-1(Deficiency)
Incorrect Design Input in Calculation Associated with
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MR-FC-81-218.
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A new calculation which is checked, verified, and approved will resolve the
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team's concerns regarding accumulator volume, minimum air pressure, and docu-
mentation by the checker. However, the licensee has not performed functional
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testing to demonstrate that the valves in question will remain shut for alpre'-
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determined period of time under worst case conditions. The team is concerned
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that, due to air leakage through fittings and joints and through check valves
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which do not seat properly, a margin of 40% may not be sufficient. The team
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noted that the air accumulator installation was not properly tested after modi-
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fication (See Deficiency D2.3-3) and that surveillance testing is not performed
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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-
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. quacy of this modification could be tested when the plant was otherwise shut down.
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This item will be reinspected.
D2.2-2 (Deficiency)
Incomplete Consideration of CQE and Seismic Class I
Requirements for Portions of MR-FC-81-218.
The licensee's response addresses the concerns identified in the deficiency.
This-item should remain opan 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.
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
with HCV-438B and HCV-438D remains a concern. Because these are containment iso-
latico 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
corrected, rather than subject the plant to an unacceptable (unexpected) promptly
that this is the case, a significant safety concern exists and should be
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during the course of an accident when the safety feature is relied upon to
function.
D2.2-5 (Deficiency)
Incorrect Information on Instrument Air Diagram.
The licensee's response is considered in conflict with good engineering practice.
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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
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
Assumption and Analysis Methodology.
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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
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design analyses. The USAR is only updated yearly and no means exist to inform
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design personnel which items in the USAR are incorrect.
If the USAR is to be
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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
revisions. The changes to the USAR must also be controlled in a manner similar
to that of design drawing and calculations.
The technical specification basis states the heat removal capacity available
.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.
questions. For example, the vital ac invertei modification' safety evaluation
assumed inoperability of an inverter if the bus was powered by interruptable
ac power.
If such an assumption is incorporated into the operating 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
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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 that 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,
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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) Design Temperatures for Safety-Related Piping.
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 document.
U3.1-3 (Unresolved Item) Small Bore Pipe Support Spacing.
OPPD's response to this item does not formally reconcile the discrepancy between
the support spacing criteria specified by the contractor performing the field
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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.
D3.2-6 (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-
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 tnis team concern in Item 6 of the OPPD response.
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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.
U4.3-2 (Unresolved Item) ESF Bypass Switch Keylock Provision.
In modification MR-FC-81-102, three engineered safety feature bypass switches
were to be added in each of two lccked, 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
when one channel is bypassed or removed from operation. Omaha Public Poeer
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.
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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 comitment in section 7.3.1.b for separation of
engineered safeguard controls has been satisfied.
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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 sutisfied.
In this particular modification, the control switch has been
assumed to be an acceptable isolation device, but this assumption has not been
demonstrated by analysis and qualification test as required by the IEEE Standard.
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.
D5.1-1 (Deficiency) Battery Sizing Calculation.
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
and unresolved items and considers the responses acceptable. Confirmatory
inspection of the licensee's corrective actions may be conducted.
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D2.1-2 (Deficiency) Seismic Requirements Not Specified in MR-83-158 Procurement
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Documents.
D2.1-8 (Deficiency)
Incorrect Infonnation on Flow Diagram For Main Steam System.
U2.1-10 (Unresolved Item) Use of Fluorocarbon-Elastomer Material in High
Radiation Environments.
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D3.2-2 (Deficiency) MR-FC-83-158 Installation Procedure.
D3.2-4 (Deficiency) Junction Box Supports.
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D4.3-1 (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.
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U4.5-3 (Unresolved) Battery Room Fire Hazard Analysis.
US.1-2 (Unresolved) Battery Charger /DC Bus Coordination.
D6.1-1 (Deficiency) Safety Evaluations for Non-Safety-Related 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 2
Evaluation of Licensee Response to Fort Calhoun
Safety Systems Outage Modifications Inspection (Installation / Testing)
Inspection Report 50-285/85-29
D2.3-2 (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 closeout 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,
which the inspection team considered to be a safety issue.
D2.3-3 (Deficiency) Procedure change implemented prior to PRC approval
The licensee's response is inadequate. One purpose of the Plant Review
Comittee (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.O. 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
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field change
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The licensee's response is inadequate. The location of the weld was not
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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
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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
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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.
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The following is in response to OPPD's specific comments:
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MR-FC-83-158 - OPPD indicated that tubing was field routed by verbal communi-
cation between the design engineer / planner and craft, and that this was in
accordance with ANSI N18.7-1976. ANSI N18.7-1976 requires that modifications
be performed in accordance with written procedures, documented instructions or
drawings as appropriate. Considerations are given to craft capabilities when
determining the required level of detail of the procedures. The use of verbal
instructions (procedures) to install safety-related equipment or 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 question 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 weld 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.
S.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
welders to establish vendor-recommended welding prerequisites (pon memories of
prerequisites to be satisfied for a given activity. Reiiance u
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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%
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of the conductor splices for conformance with these
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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
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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.
D2.4-2 (Deficiency) Failure to follow procedure requirements
The following is in response to OPPD's specific comments:
MR 81-80 - OPPD did not believe that the finding associated with MR 81-80
regarding QC (QA) hold points for material verification prior to installation
was a deficiency and requested that the finding be reclassified as an observa-
tion.
It was the understanding of the inspection team that QC (QA) verifica-
tion of material acceptability was required by the procedure prior to installa-
tion and not at some later date. This particular finding should remain open
until additional information can be reviewed.
MR 85-105 - The modification procedure did not control or provide status of
the Halon fire suppression system as required. A continuous fire watch was not
established as required. Technical Specifications also require that backup
fire suppression equipment must be provided when the Halon system is inoper-
able. OPPD did not adequately respond to the concerns noted, in either expla-
nation or corrective action.
MR 84-119 - S.0. G-20 requires a shift supervisor signature for tagging out of
equipment. Tags were hung and work was in progress without the shift supervisor'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.
02.5-1 (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 OPPD's
QC inspectors prior to their being notified of the concerns by the SSOMI
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 SSOMI inspection team was not informed of that during the
inspection. The effectiveness of OPPD's corrective action should be reviewed
during followup inspections.
D2.5-2 (Deficiency) Seismic instrumentation tubing span violations
between supports
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,.
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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.
The NRC inspection team was not informed of any 0 PPD initiated action being
taken to resolve problems associated with MR-83-158 prior to the time that NRC
concerns were voiced to OPPD. 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 C2.5-4 was a deficiency and requested that the
deficiency be reclassified as an observation since an engineering analysis was
performed on the surface discontinuities and that the weld was PT'd and found
to be acceptable.
During the SSOMI, the inspection team requested several welds which were
previously PT accepted to be re-PT'd for evaluation.
The inspection team
requested the weld associated with SI tank 6B to be reinspected. A written
response from a QC inspector stated that the indication was filed on but not
totally removed, however, it passed PT. There appears to be some confusion as
to whether the PT was ever accomplished as requested. OPPD should be able to
produce the NDE results for the inspection performed on 12-16-85. The engi-
neering analysis which accepted the surface discontinuities should also be
reviewed for adequacy.
D2.5-5 (Deficiency) Inadequate flow element flange installation
OPPD stated that at the time the craft signed off the step in the installation
procedure the flange wasn't leaking and that OPPD uses leakage as the primary
criterion when installing flanges. OPPD also stated that the flange faces
were visually determined to be parallel by the modification planner.
Upon walkdown of MR 85-62 the inspection team noticed that the flange was
leaking and that the flange faces were visually out of parallel and assumed
this to be the cause for the leakage. Measurements were later taken using a
caliper and the flange faces were determined to be out of parallel by approxi-
mately .030 inch.
It is requested that
documentation be reviewed which would
verify that the CCW system was at normal operating pressure at the time of
craft sign-off for nonleakage.
D2.5-7 (Deficiency) Weld inspections not accomplished for transformer base
welds to the imbedments
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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 0 PPD. The inspector who reported the concern recalls the follow-
ing:
An NRC inspector was present during the welding
A QC inspector was not present during the welding
The welder did not know whether the weld was to be inspected, and
asked the NRC inspector whether he knew
Several times during the inspection, the inspection team requested
that the inspection records be produced, however, the records
4
i
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 of 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
combination was capable of perfoming for at least one ilour 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
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,
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,
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,
- voltage values recorded at regular intervals (e.g., every
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
D2.8-2 (Deficiency) Test procedure did not verify design concept-
under accident conditions
OPPD accepted the deficiency but did not believe that a generic concern existed
and therefore did not specify any corrective action. The inspection team,
however, believes that corrective action is required as evidenced by concerns
involving MR 84-119, MR 83-158 and MR 84-74A. Modifications to plant compo-
nents or systems should be adequotely tested to verify acceptability of the
intent of the modification and to ensure that modifications do not adversely
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 temporary
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.0. 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
coninonly understood to be a period of time of approximately 30 days. Based
upon the records available this interpretation 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.
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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.
D2.3-1(Deficiency)
Inadequate control of construction package drawings and
drawing lists.
D2.3-4 (Deficiency) Training not accomplished prior to approval of procedure
change.
U2.3-1(Unresolved
On-the-spot changes not approved by PRC within Technical
Item)
Specification time constraints.
D2.3-6(Deficiency) Calibration procedures changes without approved field
changes.
U2.3-2(Unresolved
Lack of calibration record for a pressure source used
Item)
for safety-related channel calibration
D2.5-3 (Deficiency)
Inadequate support of seismic instrumentation tubing
near air regulators
D2.5-6 (Deficiency)
Installation discrepancies found in installation of new
delta T power process loop instrumentation
U2.5-1(Unresolved
Questionable installation practices relative to installa-
Item)
tion of delta T power process loops cables and panels.
U2.5-2 (Unresolved
Foxboro transmitter 0-ring replacement not documented to
Item)
maintain environmental qualification
D2.6-2(Deficiency) Plant welding accomplished to nonapplicable weld procedures
D2.9-1 (Deficiency)
Inadequate temporary storage of safety-related material
D2.10-1 (Deficiency) Inadequate corrective action for control of installation
of lead shielding
D2-10-2 (Deficiency) Inadequate corrective action for resolving System
Acceptance Consnittee discrepancies identified to systems
accepted for operation