ML20080S817
| ML20080S817 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/19/1983 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20080S794 | List: |
| References | |
| LIC-83-238, NUDOCS 8310180506 | |
| Download: ML20080S817 (6) | |
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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536 4000 September 19, 1983 LIC-83-238 .
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h Mr. W. C. Seidle, Chief SEp 2 2 G83 Reactor Project Branch 2 U. S. Nuclear Regulatory Commission Region IV . J hA
- 611 Ryan "laza Drive, Suite 1000 Arlington, Texas 76011 i
Reference:
Docket No. 50-285 1
Dear Mr. Seidle:
Notice of Violation Inspection Report 83-17 The subject Inspection Report, dated August 19, 1983, ident?.fied a violatica of 10 CFR 50, Appendix B, Criterion XVI, regarding the District's Quality Assurance records file room and construction records. This letter also requested 2n enforcement conference to discuss the District's proposed actions in response to this notice of violation. According-ly, on September 9, 1983, representatives from the District attended a meeting in your office to discuss proposed actions. The attached response is in accordance with the discussions held during that meeting.
Sincerely,
/V l W. C.. Jones Divisfon Manager Production Operationc WCJ/KJM:jmm Attachment l cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C. 20036 Mr. E. G. Tourigny, Project Manager Mr. L. A. Yandell, Senior Resident l Inspector 8310180506 831013 Employment with Equal Opportunity PDR ADOCK 05000285 Male / Female G PDR
OMAHA PUBLIC POWER DISTRICT'S RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 83-17 Violation Failure to Take Prompt Corrective Action 10 CFR Part 50, Appendix B, Criterion XVI, states that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, though deficiencies have been identified to the Aicensee by Region IV since 1975 (NRC Inspection Reports 75-09, 77-05, and 81-16), licensee records vault and records pro-gram for construction records (including design and manufacturing records) are not in compliance with licensee commitments.
This is a Severity IV Violation. (Supplement I.E.) (285/8317-01)
Response (Quality Assurance Records File Room)
(1) The corrective steps which have been taken and the results achieved Construction modifications to correct deficiencies regarding the Quality Assurance records file room were completed July 23, 1982 and final halon system testing was completed August 16, 1982. These modifications were completed in ac-cordance with NUREG-0800, Standard Review Plan, Part 17.1, Acceptance Criteria 17.4, and identified as follows: a l
2-hour rated fire resistant file room meeting NFPA No. 232 with the following provisions:
(a) Early warning fire detection and automatic fire sup-pression systems with electronic supervision.
l Records stored in fully enclosed metal cabinets. No (b) open steel shelving or records storage on the floor and adequate access and aisle ways.
(c) Work not directly associated with records storage or retrieval shall be prohibited within the records storage facility.
(d) Smoking and eating / drinking shall be prohibited throughout the records storage facility.
(e) Ventilation, temperature, and humidity control equip-ment shall be protected inside with standard fire door dampers where they penetrate fire barriers bounding
- the storage facility.
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This design was also in accordance with ANSI N45.2.9-1979 which requires a 2-hour fire rated structure. NUREG-0800, Part 17.1, paragraph 17.4, endorses N45.2.9 but does not identify either the 1974 or 1979 edition.
These modif' ations result in providing a 2-hour fire rated records file room, as discussed above.
(2) Corrective steps which will be taken to avoid further vio-
_1a.tions The District will submit to the NRC Quality Assurance Branch, Division of Quality Assurance, Safeguards and In-spection Programs, a letter requesting approval of the de-sign of the existing Quality Assurance records file room.
This request will include approval to operate a recorda storage facility meeting the requirements of Standard Review Plan 17.1,Section II.17.4, with site specific deviations from the requirements of NFPA 232, which will be detailed in the District's letter. Specifically, this request will ad-dress the design of the existing file room ceiling and sup-port of the ceiling at the preexisting walls. This request 1983 and, if approved, the will be submitted by October 1, District's existing file room will satisfy.NRC requirements.
If not approved, appropriate corrective actions will be taken.
As identified in Inspection Report 83-17, "On one corner of the file room roof a preexisting I-beam for an overhead walk-way required elimination of the concrete roof in that area.
Licensee drawings did not show this interference or the modi-fication to the roof."
The District has completed an inspection of this I-beam and has identified that the beam was not encased with aA minimum work of 4 inches of concrete as originally intended.
order has been initiated to have this exposed I-beam encased with 4 inches of concrete on the inside of the file room and to encase the corner on the outside with concrete. This work will be completed by October 15, 1983 and will assure compliance with NFPA 232, paragraph 3234(c).
Also identified in Inspection Report 83-17, "NFPA Standard 232 requires the filo room light switch to be located on the outside of the file room so that no energized wiring (ig-nition source) will be located in the unoccupied file rooe..
The light switch for the licensee's file room was located in the file room."
A work order has been initiated to have the file room light switch located outside the file room. This work will be com-pleted by October 15, 1983 and will assure compliance with NFPA 232, paragraph 3313.
In addition to the above prescribed corrective actions, the work order being initiated will also provide for replacing the existing caulk with a non-flammable caulk and replacing the caulk around the halon pipe penetration with cement grout. This work will be completed by October 15, 1983 and will assure compliance with NFPA 232, paragraph 3233.
(3) The date when full compliance will be achieved As indicated above, modifications regarding the non-encased I-beam, the relocation of the light switch, and replacement of caulking will be completed by October 15, 1983, at which time the District will be in compliance with these items.
The date for compliance with the remaining item will be determined by the actions of the NRC Quality Assurance Branch, Division of Quality Assurance, Safeguards and In-spection Programs.
Response (Construction Records)
(1) The corrective steps which have been taken and the results achieved The District has implemented Records Management Systems (RMS) for Quality Assurance records relating to the Fort Calhoun Station. These programs are presently intendedSince to includc design and construction records and drawings.
initiating these systems, beginning in 1980, well over one The develop-million records have been entered into the RMS.
ment and implementation of these systems has provided the District with the capability to more ef fectively store, The file, index, and retrieve Quality Assurance records.
Certified Material Test Reports (CMTR) from constructionthe that were retained by site QA have been transferred to records file room and are, at present, being entered into the RMS.
(2) Corrective steps which will be taken to acold further vio-lations As reported in the District's June 29, 1982 and November 19, 1982 letters, a major effort is currently underway to pro-cess Quality Assurance records and drawings into the Dis-trict's RMS. It is the District's intention to continue this effort, in addition to the following tasks:
(a) The Fort Calhoun Station's Preliminary Safety Analysis Report (PSAR), including supplements, will be reviewed in order to identify specific types of records which the District committed to maintain. Codes and standards referenced in the PSAR will be considered in this review.
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(b) The District will submit a plan and a schedule to Region IV by. October 14, 1983 for the review of those documents recently received from Gibbs & Hill, Inc.
(stored on the sixth floor at the Jones Street Station) and those documents stored in the Jones Street Station storeroom.
(c) The District will contact those organizations which provided major portions of the construction work on the Fort Calhoun Station in an effort to obtain any construction records they possess or assure that any such records are properly controlled in their facili-ties. These contractors are Combustion Engineering, Inc.; Gibbs & Hill, Inc.; Commonwealth Electric Corporation; and Peter Kiewit & Sons.
(d) The results of the reviews completed in part (2)(a) above will be compared to the available records re-sulting from efforts in (2)(b) and (2)(c) to assure that the specific types of records which the District committed to retain, as stated in the PSAR, are avail-able. In the event any types of records are identi-fied which are not available, then an evaluation will be performed in order to determine the safety signi-ficance of such omissions. If this evaluation indi-cates that no significant hazards considerations are involved, then the record will be closed. In the event it is determined tnat significant hazards con-siderations do exist, the appropriate action (s) will be taken.
-(3) The date when f"ll compliance will be achieved Specific schedules relating to the District's efforts to improve recordkeeping capabilities are as follows. The completion of these tasks will assure full compliance.
l (a) The present effort of entering records into the RMS is i
scheduled to be completed by December 31, 1983, as committed in our letter dated June 29, 1982.
f -(b) Updating of drawings, as committed in our letter dated l November 19, 1982 will be completsd by approximately
( July 1, 1984.
I (c) The schedule for the review of the PSAR will be sub-mitted by October 14, 1983.
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(d) A schedule and plan for reviewing the documents on the sixth floor at the Jones Street Station and in the Jones Street Station storeroom will be submitted by October 14, 1983.
(e) The District will contact those contractors discussed in (2)(c) above by October 1, 1983. In the event re-cords are identified which must be transferred to the District, a schedule for transferring and processing these records will be submitted by December 1, 1983.
(f) The schedule for task (2)(d) above will be greatly in-fluenced by the degree to which the available records satisfy the PSAR records commitments. The District presently anticipates that comparisons discussed in (2)(d) above will be completed by August 1, 1984, at which time full compliance should be_ achieved, as-suming that large discrepancies are not identified.
In the event large discrepancies are identified, a re-port will be submitted to Region IV.
Response (Protection of Single Copy Records Not Stored in the Licensee's Site QA File Room)
(1) The corrective steps which have been taken and the results achieved The existing requirements for single copy records not stored in the file room provide for their protection by periodi-cally copying these records and transferring either the original or a copy to the records file room.
(2) Corrective steps which will be taken to avoid further vio-lations l
The District has recently initiated action to improve the
! Quality Assurance RMS. This action involves a review of the District's RMS by a consultant (Stone & Webster). This review will include the present methods of processing and u
l handling records prior to final disposition. The records I referenced in Inspection Report 83-17, paragraph 2.c. will be included in this review.
(3) The date when full compliance will be achieved l
A duplicate copy of the Plan,t Usage Data Book is being main-tained and, therefore, the District is presently in com-pliance regarding the handling of these Plant Usage Data Book records. As discussed above, improvements in pro-cessing single copy records are anticipated as part of the District's RMS upgrade effort.
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