IR 05000285/1987013

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/87-13
ML20236P384
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 08/07/1987
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Andrews R
OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8708120328
Preceding documents:
Download: ML20236P384 (2)


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LAUG 7 1987

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. Docket: 50-285/87-13 j

In Reply Refer To:

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Omaha Public Power District ATTN:

.R. L. Andrews, Division Manager-Nuclear Production 1623 Harney Street.

Omaha, Nebraska 68102'

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I Gentlemen:

Thanklyou for your letter of July 30,' '1987 in response.to our letter-and Notice of Violation dated June 30,11987.. We-have reviewed your reply and.

find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective ' actions during a. future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, Orignal G1gned By '

J. E. Gagilcrdo J. E. Gagliardo, Chief Reactor Projects Branch cc:

. 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 Washington, DC 20036 Kansas. Radiation Control Program Director

. Nebraska Radiation Control Program' Director i

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(see next page)

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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102-2247 hI July 30, 1987 LIC-87-543 i

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J. E. Gagliardo, Chief Reactor Projects Branch

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V. S. Nuclear Regulatory Commission Region IV 611 Ryan Plsza Drive, Suite 1000 Arlington, Tx. 76011 Reference:

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Docket No. 50-285 2.

Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews)

dated June 30, 1987

Dear Mr. Gagliardo:

SUBJECT:

Inspection Report 50-285/87-13 Omaha Public Power District (0 PPD) received the subject inspection report dated June 30, 1987. One violation was identified concerning failure to control special processes during installation of seism' wall supports.

Accordingly, pursuant to 10 CFR 2.201, Attachment A contains OPPD's response to

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this violation.

Attachment B contains a r,esponse to the three previously identified unresolved items related to the operator training program.

If you need any further information, please let us know.

Sincerely, i

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R. L. Andrews Division Manager Nuclear Production RLA/me

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Attachment cc: LeBoeuf, Lamb, Leiby & MacRae

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1333 New Hampshire Ave., N. W.

Washington, DC 20036 J. A. Calvo, NRC Project Director A. Bournia, NRC Project Manager

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P. H. Harrell, NRC Senior Resident Inspector D

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f Attachment A

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D * ng an NRC inspection conaucted on May 1-31, 1987, a violation of NRC

requirements was identified. The violation involved a failure to qualify a j

butt weld procedure prior to use for installation of seismic wall supports.

In

accordance with the " General Statement of Policy and Procedure for NRC l

Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed.

Criterion IX of Appendix B to 10 CFR Part 50 states, in part, that measures shall be established to ensure that special processes, including welding, are controlled and accomplished using qualified procedures in accordance with applicable codes and standards.

Paragraph 4.2.2 of Section 6.6 of the licensee's Quality Assurance Manual states, in part, that special processes shall be performed in accordance with written, qualified procedures.

These procedures are to be qualified

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in accordance with applicable codes and standards.

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Contrary to the above, the licensee used, during the 1985 refueling outage, welding procedure for installation of seismic wall supports with square butt welds; however, the square butt weld procedure was not qualified to AWS D1.1-8;. The design instruction (MR-FC-81-180) issued for installation of the wall seismic supports stated that all weld procedures shall be qualified in accordance with AWS D1.1-83.

This is a Severity Level IV violation.

(Supplement I) (285/8713-01)

OPPD's Response Reasons for the Violation if Admitted OPPD admits the violation.

The design of the welds for the modification were

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based on AWS D1.1-83. The existing plant weld procedures referenced ASME Boiler and Pressure Vessel Code Section IX: Rather than develop a new weld procedure, one of the existing weld procedures was used.

Corrective Steos That Have Been Taken and Results Achieved Calculations based on the as-built weld size and configuration were completed,

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and an evaluation of the results show that, with very conservative assumptions, the welds are adequate to bear the design. loads.

In April of 1987, a review of

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the welding program was begun.

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Corrective Steps Which Will be Taken to Avoid Further Violations A review and upgrade of the we] ding program will be completed this year. The ASME Boiler & Pressure Vessei Code,Section IX weld procedures will be updated, new weld procedures for AWS D1.1 will be put into effect, and an engineering guide will be issued. The engineering guide will address preparation of weld procedures, including procedure review. Training of the affected staff will

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ensure that design engincers are cognizant of the applicable code requirements.

Date When Full Compliance Will be Achieved OPPD is currently in compliance. The programmatic changes to increase the number of weld procedures and the review of the documentation requirements associated with the welding program will be completed by January 1988.

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Attachment B

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Pursuant to a request in Inspection Report 87-13, three previously identified l

unresolved. items related to the operator training program are noted below.

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each item, actions OPPD intends to take are provided, along with the dates when

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completion is anticipated.

l Unresolved Item (URI) 285/8624-01 related to establishing an effective training records program to document completion of training activities. A discussion of the follow-up performed on URI 285/86242-01 was provided in paragraph 2 of the NRC Inspection Report 50-285/87-10. The followup inspection indicated that the licensee had just recently initiated actions to establish an auditable record system.

Response: OPPD recognized the need for an improved training records system prior to the August 1986 inspection and was in the process of purchasing a new computerized training records system at that time. A purchase order was placed

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for the computerized training records system, OPTIM, in September 1986. The

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software design for OPTIM was approved by 0 PPD in December 1986. OPTIM was delivered for testing in March 1987 and is currently installed and running in the " Test CICS" mode on the OPPD Main Frame Computer System. OPTIM is functional and producing training records for the following programs:

1987/88 Licensed Operator Requal Training a

.1987 Licensed Operator Simulator Training a

Licensed 0'ty (Operator Watchstanding)

a Reports can be generated which indicate the training each individutl has completed.

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In January 1987, OPPD retained the services of a training records consultant who had previously corrected deficiencies in the training records system at another nuclear facility. This individual redesigned a portion of the OPPD training records system and is currently implementing the training records system on OPTIM.

In addition to the above records, up-to-date data for the following additional records will be available on OPTIM by January 1,1988:

R0 Initial Training Program a

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SRO Up grade Training Program m

Initial Simulator Training a

Accelerated Requalification Training e

During the completion of OPTIM software design and data loading, a manual training records system has been implemented which assures 1987 training records are maintained in accordance with 10 CFR Part 55. This system will be

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added to OPTIM by January 1, 1988. Utilization of OPTIM will greatly increase the speed and efficiency of conducting record searches.

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Attachment B (Continued)

Unresolved Item 285/8624-02 related to not providing on-the-job training for all aspects of plant operations by failing to give classroom lectures for the loss of instrument air and the loss of shutdown cooling. A discussion of this item was provided in Paragraph 2 of NRC Inspection Report 50-285/87-10.

The follow-up inspection indicated that no corrective actions had been initiated in providing these classroom lectures since the problem was initially identified in August 1986.

Resoonse: Training on the abnormal operating procedures for loss of instrument air and loss of shutdown cooling was conducted during the second and third requalification rotations of 1987, respectively. All licensed operators, and some licensed staff members, have completed this training.

Licensed staff members who have not received training are required to review these abnormal operating procedures and pass a quiz by August 28, 1987.

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Unresolved Item 285/8624-03 related to providing a preplanned lecture series on E0Ps. This item was. discussed in paragraph 2 of NRC Inspection Report 50-285/87-13. The follow-up inspection indicated that some E0Ps were discussed during simulator training given in the early part of 1987, but training on all l

E0Ps had not been provided.

Response: This item related to a lack of objective evidence that 15 of the R0's and-SR0's had attended preplanned lectures on emergency procedures during 1984 and 1985.

It is OPPD's belief that these 15 licensed individuals did attend proplanned lectures on emergency procedures prior to the implementation of the revised E0Ps in January 1986, but that this training was not documented.

In addition, E0P training was also conducted during simulator l

training in July and August of 1986. OPPD believes this unresolved item is due to inadequate training records rather than a failure to provide E0P training.

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Therefore, OPPD believes adequate E0P training was provided.

During 1986, the OPPD Training Organization received feedback from licensed operators that additional E0P training on the simulator was needed rather than additional preplanned lectures. Therefore, the training organization scheduled E0P simulator training for the first quarter of 1987.

All Licensed individuals received training on at least six of the seven E0P's during simulator training the first quarter of 1987.

This training consisted of classroom sessions and/or practical sessions on the simulator floor. All but ten licensed individuals have received training on all E0Ps during 1987.

Ten Licensed individuals (seven operators and 3 staff members) have not yet received training on E0P-02, " Electrical Emergency." during 1987. Training on E0P-02 will be conducted during the next requal rotation scheduled to start August 24, 1987 and end Octobef 9, 1987.

It is OPPD's belief that practicing the execution of E0Ps on the simulator is the most important aspect of E0P training. Therefore, execution of the E0Ps was emphasized during the 1987 requalification training on the CE simulator..

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A review of the lectures given during the 1987 simulator training identified certain licensed individuals who have not received " preplanned lectures" on certain F9Ps. Therefore, additional preplanned lectures on E0Ps will be incorporated into the requalification schedule during the 1987-1988 requalification interval. This will most likely be done during simulator training in 1988.

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