_ _ __-_ . _ - ___

!

U.S. NUCLEAR REGULATORY COMMISSIONs

0FFICE OF INSPECTION AND ENFORCEMENT;

REGION IV!<

Report: 50-285/81-16

Docket: 50-285 License: DPR-40

Licensee: Omaha Public Power District1623 Harney Street

{Omaha, Nebraska 68102 '

Facility Name: Fort Calhoun Station, Unit 1

Inspection at: Fort Calhoun Station, Blair, Nebraska

Inspection conducted: July 6-10, 1981

W' 7[.5 ?/Inspector: f

y.jR. Boardman,ReactorInspector,SystemsandTechnical DateL5ection

d# 7/&Approved: M -

'R. E. Hall, Chief, Systems and Technical Section D6te';

j Inspection Summary

Inspection Conducted July 6-10,1981 (Report 50-285/81-16)Areas Inspected: Routine, unannounced inspection including licensee recordsprogram, licensee on-site review conmittee, QA program annual review, andfollow up on licensee actions on previous inspection findings. The inspectioninvolved 31 inspector-hours by one NRC inspector.Results: In the four areas inspected, two violations were. found in one area(violation - failure to meet record retention requirements and violation -failure to retain records required by Technical Specifications - paragraph 3).

I

1

l

!

.

8108250462 8,

! PDR ADOCK 05O DR

t

DETAILS

1. Persons Contacted

Omaha Public Power District

*R. L. Andrews, Sectit: runager, OperationsW. G. Gates, Supervisor, Gperations

*J. M. Gloshen, QA Engineer*W. C. Jones, Division Manager, Production Operations*K. J. Morris, Section Manager, Administrative ServicesG. R. Peterson, Supervisor, Maintenance

*S. C. Stevens, Manager Fort Calhoun Station*P. M. Surber, Acting Section Manager, Generating Station Engineering*F. A. Thurtell, D"ision Manager, Environmental and Regulatory Affairs

The NRC inspector also contacted other plant personnel, including healthphysics, clerical, and administrative personnel.

* Denotes those attending the exit interview.

2. Licensee Action on Previous Inspection Findings

(Closed) Unresolved Item (8111-03): Reactor Coolant pump 3/4" spiralwound (metal asbestA gaskets on licensee Purchase Order 47921 was notordered requiring, ano did not have, certification of acceptable lowlimits of sulphur and chlorides. Subsequently, the licensee has per-fonr.ed chemical analysis of representative gaskets utilizing RegulatoryGuide 1.36, dated February 23,1973, " Nonmetallic Therral Insulationfor Austenitic Stainless Steel," as a guideline. The results of thechemical analysis of chloride, 81 ppm; silicate, 800 ppm; and sodium,34,200 ppm is considered nondeleterious as is the possible maximucsulphur content of <300 ppm for the 304 stainless gasket material aad<200 ppm sulphur for the asbestos portion of the gaskets. (See OPPDinteroffice memorandum File: TS-FC-81-36, dated May 21, 1981, Subject:Use of Spiral Wound Flexitallic Gaskets (CG-15C) for RC Pumps at FortCalhoun.

This item is closed.

(0 pen) Violation (8107-01): Failure to Maintain Sufficient Recordsto Furnish Evidence of Activities Affecting Quality. Example 1 wasthe licensee's failere to mcintain records of supplier performanceused by the licensee as the basis of initial supplier approval atthe inception of thc licensee's supplier approval program. Licenseeresponse to this violation included requalificatior:, or deletion, ofall iritial suppliers. As a result of this requalification program,32 initial suppliers were deleted for various reasons. Two reasonsappear to have significant quality implications as follows: (1) "noauditable QA program" and (2) "no authorized distributor documenta-tion."

-2-

. - - _ ._- .-

,

il

Based on discussions with licensee personnel, the NRC inspector deter-mined on July 8,1981, that no review of hardware documentation had

i been accomplished for hardware provided by suppliers deleted for thei two above listed reasons. Licensee personnel when questioned indicated

that such a review would be performed to assure that quality assurancedocumentation provided by deleted suppliers was in fact adequate andsatisfactory in those cases where the supplier was deleted for nothaving an auditable QA program cr where there was no authorized distrib-utor documentation.,

This itea will remain open pending completion of this review by thelicensee.

.

3. Licensee Records Program

The NRC inspector reviewed the licensee's program and implementingprocedures for records for compliance with Appendix B to Part 50 ofTitle 10, N de of Federal Regulations; ANSI N45.2.9-1974; and licenseeTechnical Sp'cifications Section 5.10.

a. 10 CFR Part 50, Appendix B, Criterion XVII states that recordsshall be ider.tifiable and retrievable, and that, consistent with

;- applicable regulatory requirements, the applicant shall establish

requirements concerning record retention such as duration,location, and assigned rf.sponsibility.

1

The licensee Quality Assurance Manual, Section 1.2 states that theOmaha Public Power District commits itself to and complies withthe mandatory Quality Assurance program guidelines contained inWASH-1283, Revisic 1, " Guidance on Quality Assurance RequirementsDuring Design and Procurement Phase of Nuclear Power Plants";WASH-1309, " Guidance on Quality Assurance Requirements During theConstruction Phases of Nuclear Power Plants"; and WASH-1284," Guidance on Quality Assurance Requirements During the Operation

; Phases of Nuclear Power Plants."

WASH-1284 in Section B invokes ANSI N45.2.9-1974, " Requirementsfor Collection, Storage, and Maintenance of Quality AssuranceRecords for Nuclear Power Plants."

The followiig are examples of an apparent violation of the records.

requirements of 10 CFR Part 50, Appendix B, Criterion XVII andANSI N45.2.9-1974:

(1) 10 CFR Part 50, Appendix B, Criterion XVII requires recordsto be retrievable. ANSI N45.2.9-1974, Section 6.2 requires" accurate retrieval of infe mation without undue delay."ANSI N45.2.9-1974, Appendix A delineates records to beretained. Licensee Quality Assurance Procedure No. 7 (QAPNo. 7), Revision 1, approved August 9, 1978, " Storage andRetention of QA Records," contains in Appendix A the tabula-tion of Quality Assurance (QA) records included in thelicensee's QA records retention program.

-3-

~

On July 7 and 8, 1981, licensee personnel were unable toretrieve the following categories of permanent recordslisted in QAP No. 7, Appendix A:

Fonn FC-261, RM057 Monthly Tech. Spec. Calc. Sheet-GE-LIfor the year 1973

Form FC-263, RM062 Quarterly Tech. Spec. Calc. Sheet GE-LIfor years 1973, 1974, and 1978

(2) ANSI N45.2.9-1974, Section 5.6 sets forth design criteria forpennanent record storage vaults for protection of records from -

destruction by such causes as fire, and from deterioration.Basically, the requirements are that the facility be a 4-hourfire rated facility equivalent to National Fire ProtectionAssociation Class A. NRC will accept a 2-hour fire rating.

On July 7 and 8,1981, the licensee's Quality Assurance recordsvault did not meet the design criteria of ANSI N45.2.9-1974,Section 5.6 or the optional criteria of National Fire ProtectionAssociation Code 232-1975 permitted by ANSI N45.2.9-1974 (e.g. ,the roof of the vault was not concrete, the vault door appearedto be a joiner door and not fire rated, and a self-containedair conditioning unit penetrated the wall).

The failure of the licensee's Quality Assurance records vaultto meet design requirements was first identified as a deviationin NRC Inspection Report 75-09. This topic was discussed inthe NRC management meeting reported in NRC Report 7S.03..-- -- -

Licensee Internal Audit Report No. 4-80, dated Janaury 30, 1980," Handling and Storage of QA Records Fort Calhoun Station UnitNo.1," Section 5.1.1 states, "The condition of the vault hasnot changed. It is still not an acceptable single record storac e

facility under the requirements established in ANSI N45.2.9."

Licensee Internal Audit Report No. 4-81, dated February 9,1981," Handling and Storage of QA Records Fort Calhoun Station,"Section 5.1.1 states, " Lack of records microfilming sincemid-1979 makes those records stored since that time fall underthe requirements for a single storage facility. It is question-

able whether or not the vault meets all the requirements ofANSI N45.2.9, Paragraph 5.6.1 for a single storage facility.For some documents, such as the radiographs, a single storagefacility is the only solution, but they should not be storedin cardboard or wooden boxes which contribute to the firehazard in the vault."

(No known work was done to upgrade the vault between the1980 and 1981 licensee audits.)

-4-

1|

(3) As an alternative to records storage in a fire rated vault,ANSI N45.2.9-1974 permits equivalent protection such as afire rated file container. NRC accepts a 2-hour rated firecontainer meeting NFPA No. 232 (Class B) without additionalNFPA provisions. QAP No. 7, however, requires essentiallyall permanent records to be stored in the QA records vault.

On July 7 and 8, licensee permanent records " Fuel InventoryReports" and " Records of Transient or Operational Cyclingfor Those Plant Components That Have Been Designated toOperate Safely for a Limited Number of Cycles" were foundnot to be permanently stored in the Quality Assurance recordsvault. The latter record is known at Fort Calhoun as thePlant Useage Data Book and was kept in the Control Room.The " Fuel Inventory Reports" were permanently stored in thecorporate Quality Assurance offices. Not only were theserecords not permanently stored as required by QAP No. 7,but the " Fuel Inventory Reports" were stored in a standardnonfire rated file cabinet and the Plant Useage Data Bookwas located on a desk top in the Control Room.

(4) Another alternative record storage method permitted by ANSI- N45.2.9-1974 is the maintenance of duplicate records stored

in separate remote locations. The licensee committed to"~

this method in response to NRC Inspection Report 77-05 asdocumented in licensee letter dated May 24, 1977, as modifiedby licensee letter dated October 7, 1977. The licensee stated,"The system for transferring records to the vault, inspectingthem, and indexing them has been performing satisfactorily formore recent records; however, it is unknown if all the earlyplant records are available in the vault. The records storagewill soon be reorganized, with microfilming to start in July1977. When completed, January 1,1978, the records shouldmeet all raquirements and be much more accessible, and thatfull compliance would be achieved by January 1,1978."

On July 7, 8, and 9,1981, NRC discussions with licensee per-sonnel, review of vault inventory and the records program,and review of Internal Audit Reports 4-80 and 4-81 coveringhandling and storage of QA Records Fort Calhoun Stationshowed that microfilming was not complete. On factor may bethe licensee's apparent failure to enforce the requirementof QAP No. 7 and Standing Orders C-2, Revision 6, datedSeptember 30,1980, " Fort Calhoun Station Quality Assurance(QA) Records," and C-3, Revision 6, dated March 2, 1978," Fort Calhoun Station Quality Assurance (QA) Records (Chemistryand Radiation Protection ONLY)," that permanent storage willbe in the vault and that records will be transferred to thevault in a timely manner. Another factor may be that thespecific person, organization or function responsible for

-5-

transferring records to permanent storage is not designated.In some cases, such as the monthly TLD data processing status,there are apparently multiple copies of records. For the yearssince 1974, the monthly TLD data processing status has not beensent to the vault. The 1974 monthly TLD records were sent tothe health physics organization, but when questioned, healthphysics personnel stated that their record was actually only acopy and the original was retained by another organization.It is noted that licensee Procedure QAP No. 7 does not discussor authorize the use of the duplicate records and microfilmingin lieu of permanent storage in the Quality Assurant a recordsvault. ,

(5) ANSI N45.2.9-1974, Appendix A identifies records to be retainedand included in the licensee's Quality Assurance Records Programincluding records for design, procurement, manufacturing,installation-construction, preoperational and startup testingand cperation phase.

On July 9,1981, licensee Procedure QAP No. 7 ir cluded in itsrecord retention program, as delineated in its Appendix A, onlyoperation phase records.

(6) ANSI N45.2.9-1974 requires single copy records to be protectedfrom destruction by such cause as fire when in permanent storagewith a storage method equivalent to a 4-hour fire rating. TheNRC will accept a 2-hour fire rating.

On July 7,1981, licensee radiographic film was stored in thevac.. in wooden boxes and records were stored in cardboardtransfer files. It is noted that the NRC position is that evenwhen a vault meets a 2-hour fire rating, records must be storedin fully enclosed metal cabinets and that even open steel shelv-ing is not permitted.

The problem of storage of radiographic film being a problem areawas identified in licensee Internal Audit Report 4-81, " Handlingand Storage of QA Records Fort Calhoun Station." This situationwas not made a deficiency and no corrective action was requiredby this licensee audit report.

(7) ANSI N45.2.9-1974 requires tempcrary record storage facilities,as well as permanent facilities, to provide protection frompossible destruction by causes such as fire and requires storageto provide protection equivalent to a 4-hour fire rating, whichNRC will allow to be reduced to a 2-hour fire rating.

On July 7, 8, and 9,1981, licensee Quality Assurance and healthphysics records were in temporary storage in file cabinets and-

metal drawers which were not fire rated. Licensee StandingOrders C-2 and C-3 do not require fire-rated protection forrecords in temporary storage.

-6-

-

Failure to have retrievable records and to meet the requirements ofANSI N45.2.9-1974 constitute an apparent violation of 10 CFR Part 50,Appendix B, Criterion XVII. (8116-01)

b. Licensee Technical Specifications, Section 5.10.2 lists records whichshall be retained for the duration of the Facilities Operating License.Included are (1) records of radiation exposure for all individualsentering radiation control areas and (2) records of gaseous radioactivematerial released to the environs.

On July 7, 8, and 9, licensee personnel were unable to retrieve(1) Forms FC-229 Pencil Dosimeter Logs for 1973, (2) Film Badge /TLD -reports prior to December 1973, and (3) Form FC-252 Waste Gas ReleasesQuarterly Technical Specifications requirements for 1974. It wasverified that licensee personnel received exposure in 1973 by reviewingthe record of an employee who received exposure in October 1973.

Failure to retain records of individual exposure and records of gaseousrelease to the environs is an apparent violation of Section 5.10.2 ofthe licensee Technical Specifications. (8116-02)

4. Annual Review of QA Program

The NRC inspector reviewed the following procedure changes since the last.nnual review to verify conformance with 10 CFR Part 50, Appendix B, andthe licensee's Quality Assurance Manual:

QAP 2, Revision 2, " Audit Plans," May 1,1981

QAP 4, Revision 1, " Approved Suppliers List," May 1,1981

QAP 5, Revision 2, " Supplier Surveillance," May 1,1981

QAP 6, Revision 1, "QA Surveillance," May 1,1981

QAP 9. Revision 1, " Surveillance of In-Service Inspection," January 25,1980

QAP 10, Revision 1, "Non-Destructive Evaluation (NDE) PersonnelAdministration," January 25, 1980

QAP 14, Revision 1, " Operational QA Mini-Audit Program," May 1,1981

QAP 15, Revision 2, " Adverse Condition Reporting and Correction,"May 1,1981

I QAP 16, Revision 3, " Internal Audit Cycle for QA Program," May 1,1981

QAP 19, Revision 1, " Indoctrination and Training of Quality Assurance1

Personnel," May 1,19811

-7-

I_ _ _ _

,

QAP 22, Revision 1, " Visual Examination Procedure," February 28, 1980

QAP 23, Revision 0, " Fire Protection," January 25, 1980

No violations or deviations were identified.

5. On-Site Review Committee

The NRC inspector performed a review of the licensee's Plant ReviewCommittee (PRC) to ascertain whether the on-site review functions wereconducted in accordance with Section 5.5.1 of the licensee's TechnicalSpecifications. The PRC meeting of July 7,1981, was attended andits minutes reviewed.

No violations or deviations were identified.

6. Exit Interview

An exit interview was conducted on July 10, 1981, with those OPPDpersonnel denoted in paragraph 1 of this report to summarize the scopeof the inspection and the findings.

:

|

,

i

-8-!

i