IR 05000285/1989037

Insp Rept 50-285/89-37 on 891011-20.Seven Open Items Noted. Major Areas Inspected:Safety Enhancement Program

ML19324B712
Person / Time
Site:	Fort Calhoun
Issue date:	10/31/1989
From:	Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19324B707	List: IR 05000285/1989037 ML19324B706
References
50-285-89-37, NUDOCS 8911080059
Download: ML19324B712 (7)

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,. APPENDIX-

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U.S. NUCLEAR REGULATORY CO, MISSION j

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REGION IV

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"i F-NRC'.Assessmant Report:~ 50-285/"I-37 Operating License: DPR-40 j

I Docket:,50-285 l

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Licensee: OmahaPublicPowerDistrict-(0 PPD)

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444 South 16th Street Mall.

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$ if, l0maha, Nebreska 68102-2247

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. Facility Name:

Fort,CalhounStation(FCS)

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le'l p Assessment At:

FCS, Blair, Nebraska

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October 11-20."1989

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[ ' Assestment conducted

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. inspector:

.i y P. Harrell,' Senior Pesident Inspector 0-1J

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Appro'ed:

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' T F. Westerman,' CMef, Project Sect 1on B-lc.y

, Division of Reactor Projects-j

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Assessment Sanmary -

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y,,, 4 fAssessment Conducted October 11-20,1989 (Repert 50-285/89-37)

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I$sults:1 Baded on the" assessment: performed byL the l inspector, it appeared that

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the dicensee was implenenting an adequate'verificationsund validation process'

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fortthe items containedlin the Safety Enhancement Prcgrani. tiowever, seven open i"

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ittms were ' identified during this assessment'that indicated that the licensee

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4'%' ne,eded to provide greater oversight of the verification and validition process.

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u Of the seven open. items identified by the inspector..the NRC.is'most concerned '

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'about the.relatively large number sf weaknestes that were classified by the fi n

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slicensee as significant.- ' Other areas identified'during this assessment' that

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"p 'are of concern to the NRC include the lack of a procedural 12ed:progrtm to

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" address the verification and validation process, the failure to take a proactive.

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' role in informing the'NRC or the status of the weaknesr.es, the failure to

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establish acceptance criteria for an accepttble method for institutionclizatlon

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jot items in the Safety'Enhanc? ment Program, and the failure to establish a

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Kg program for revalidation of 1dentified weaknesses.

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DETAILS vp-

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Persons Contacted'

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• R.-Andrews,; Division Manager, Quality and Environmental Affairs

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• B. Blome, Quality Assurance Engineer

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• J. Chase, Acting Manager, Nuclear Licensing and Industry Affairs F

• D. Matthews, Supervisor, Station Licensing

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• S. Gambhir, Division Man 6ger, Production Engineering g

• M. Lazar,' Supervisor, Opetations: and Technical Training j

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. *T. McIvor, Manager, Nuclear Projects l

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• K. Morris, Division Manager, Nuclear Operations'

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• W..Orr; Manager, Quality Assurance and Quality Control

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• G. Potet son, Manager, Fort Calhoun' Station

• A. Spencer, Licensing Contractor

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• Denotes attenaance at the' assessment exit interview.

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LAssessment of the Verification and Validation Process (92702)<

k This' assessment was performed to verify that the licensee had established

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contained in the Safety Enhancement Program (SEP). The intent of the V&V

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process initiated by the licensee was to provide' assurance that each item

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The

,i,,f implementation was performed by the licansee to ensure.that the items

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would become institutionalized (i.e., a commitment placed into'a document

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such that the' licensee ~ would continue to perform the actions specified in

each item once the SEP was closed)..

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To perform this assessment, the inspector selected's sampling of Priority

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Level I and II items that h'ad been statused to the NRC ar. complete by the'

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licensee.'>The focus of this assessment was directed toward the V&V process only'and did not verify the actual. implementation of the item. 'An L " f,

ndepth review'of selected iters' will be_ performed.dur.ing a future

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f' i i assessment.'

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During performance of the assessment, the following elements werc

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The V&V process had been adequately' defined.

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item had been made

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Treaining in the V&V process had been provided for each assigred

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'The institutionalization proccsr, for the inclusion of requirements

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A tracking system had been established to address any implementation-

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weaknesses identified during validation'of the SEP item.

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Aprocessfor'revalidaticnoftheactionstakenon'ideni,1fied

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. eaknesses had been established.

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The state * -provided to the; NRC for each SEP item was accurate.

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o The inspector. identified the fo;1owing items during as'sessnient ofL the V&V

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process.

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The V&V, process had not been formally reviewed,dpproved, and-

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proceduralized.

In 1.ieu of a formalized, documented proce' lure;.the-J ManagerE Nuclear i.icibsing and Industry Affairs, issued a memorandume i

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~ on May,16, 1989, to dstablish and, implement'the V&V proc 9ss.

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E memorandum'describedjan overview of the V&V process,;how the: process i

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was to be implemented, and assigned individual responsibilities for the verification of nach item.

In addition,- tht. memorandum stated n

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that the licensing or quality assurance (QA) organization would be-

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' responsible:ror validation of all items.

The specific group

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responsibic:for validation was identified for each item.

Based on n

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the reviews performed by the inspector, it appeared that the V&V -

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process had been adequately defined.

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tilthougn no significant problems were identified'wid the establishment of thfi V&V process, the licensee should consider formal

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npprov'al and issuance of the intitrottiont, for the V&V process.

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Formal institutionalization of proceduralized requirements for the i

SEPLitems was beingeaccomplished.by the licensee; % wever, the'

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,Ilicensee had not ' initiated action to. institutionalize the V&V process

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itself.

. Inclusion of the V&V profes's.into a formally issued '

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procedure,would' t:nsure that management? maintains control over the V&V-

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, process! so changes could not be,madetwithout, management approval.

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' It ist reguested that ethe licensee provide a response to the

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,ch inspector'pobservation regarding institutionalization of the V&V 4,

process.

Thisiiten will remain open pending receipt of the y

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licensee's< response and evaluation oftthe licensee's proposed action c

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by an'i,nspector.

(285/8937-01)

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As part of,the, validation process, the' individual assigned ~the task j

1m for validation of an SEP item was require'd.to ensure that the items e

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.had t,een fully institutionalized.

Durirg review.of conpleted SEP

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. items,1the' inspector noted that different individuals performing the

valiuation tetivities were applyiqg different criteria as to what

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constituted acceptable institutionalization.

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J-The inspector noted that the licensee had not provided any direction

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or acceptance criteria to the individuals perforaring validation fm

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activities as Mo what.constitutec acceptable instMtionalization.

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Due to the ab unce of specific criteria, each individeal was

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establishing his/her own set of ctandards; therefere,' inconsistent

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criteria were being applied.,

LThe licensee should establish and document the criteria for

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-acceptable institutionalization for use by the individuals during the

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validation process.

The licensee is requested to provide a respon;e i

as to what actions will De taken to define'the> criteria required to'

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' nstitutionalize an item.

This item remains-open pending issuance of

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the criteria by the licensee and a review of the criteria by an

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inspector.

(285/8937-02)

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U Once the institutionalization criteria have been established, the

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> licensee should revalidate ^all SEP-items that were previously

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completed to ensure t.dequate institutionalizatica n&d.been pe= formed.

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'As discussed in paragrapt. 2.e of this report,.the licensee f

estahlished a tracking system to ensure that all weaknesses-

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identified during the validation process were formally addressed by

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the individual responsible for implementation of the SEP itene.

However, the' inspector no'ted a problem,where an SEP-item had not been

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.~ properly institutionalized and no rction item was entered'into the

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- tra-king system.

For this reason, it appeared the' revalidation of

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the institutionalization of all completed SEP items is appropriate.

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~ The licensee is requested to pNvide a response as to what actions'

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will be.taken to revalidate the completed SEP items for l

institutionalization.

This, item remains open pending verification of L

the proper institutionalization of the SEP items by the licensee and lj

' review of the licensee's actions by an inspector.3 (285/8937-03)

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The inspector' reviewed the status of the V&V process for SEP Item 63,

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" Complete Safety-k A ted Vendor Manual Upgrade Project," and noted

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scope of work for this item contained a Phase I and Phase II/ work scope that identified 1pecific actions that would'be completed by the

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licensee.. During review of the item, the inspector.noted that

p Phase I'had been completed; however, it appeared that Phase'II had L+t'

not been completed.

Based on the documentation reviewed by the

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inspector, it appeared that'the scope.of work centained in Phase 11

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would not be completed until approximately 1991.

s It is requested that the licensee provide a response to this apparent inconsistency between reporting to the NRC that SEP Item 63 had been

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completed, and documentation indicating that the Phase II work scope

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The response should alsv contain a discussion of the licensee's review of other items to verify that the

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item status provided to the NRC is accurate.

This item remains cpen

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pending the'ireceipt of a response from the licensee and a review of the response by an inspector.

(285/8937-04)

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The inspector reviewed SEP Item 60, ")mprove Controls Over pa" Surveillance Test Program." and noted that the scope of work for the

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item. appeared to have been changed.

In response to an NRC

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'C Operational Safety Team Inspection, the licensee added to the scope

of work toJinclude~an action to. revise Procedure 50-G-7, " Operating

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Manual," to address. the requirements for verbatim compliance, i

The' inspector;noted. during review of this item, that the individual-

performing the verification and the' individual performing the

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validation'had not been informed of the change in;the work scope.

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t4nsequently, the portion of the : cop'e of work related to verbatim

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compliance was'not verified or validated.

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It is requested that the licensee provide a response to this item I

discussing what actions will be taken to ensure that a proper verification and' validation is performed when the work scope of an a

fEP' item has been revised. The response should'also include a l

discussion of the' review performed by the licensee to identify other

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items where the work scope has changed, if any, and how the items j

will be properly verified and validated.

This is considered an open

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item pending receipt of 1.he licensee's response and review of the t

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response by an. inspector.

(285/8937-05)'

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The licensee's validation process was established'to provide an

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independent review of the verification performed by the designated

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responsible. individual.

The validation function provides the-licensee assurance that the individual has completed all'the action j

items co.ntained'in the work scope for the SEP item.

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a The validation:of the SEP items was performed by QA or the licensing I

organization. QA was c.ssigned the items that involved hardware

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issues and licensing was assigned the items that involved software l

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issues.. Since QA was. assigned responsibility for verification of j

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three items, licensing was designated as the appropriate. group to validate.the items.

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During the validation process, the individual performing the

validation. activities may identify weaknesses in the implementation

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of the work. scope actions.

If weaknesses are identified, the

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individual performing the validation is required to document the

weakness and enter the weakness in the licensee's action item

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tracking system.

Once the item has been entered into the system, the

h.g waakness is fo warded to the responsible individual for review.

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q The licensee has identified SS weaknesses in the tracking system for review by the responsible, indivictual.

During review of the iweaknesses, the inspector' identified the following:

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(1) The licensee has.not taken a proactive approach to keeping the

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NRC informed on the significance and types of weaknesses being identified during the validation process.

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(2)- The licensee has not' estab11shed a program to adarcss how the

weaknesses will be reva11 dated to ensure that the actions l

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required to be taken by the assigned individual have been

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properly completed.

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It.is requested that theilicensee provide a response to the concerns

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identified by the inspector, as discussed above. This is considered

an open. item pending receipt of the licensee's response and review by

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.an inspector.

(285/8937-06)

The licensee perfomed a review of all 96 weaknesses identified to

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, 1 date. The licensee initiated the review of the weakness due to

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concerns identified by the inspector of the relatively large number

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of weaknesses. The review indicated that the majority of the -

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weaknesses rolated to relatively minor problems such as the-individual ~ not signing Form FC-1077, " Certification of Accurac/," or

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the institutional 1 ration of the item not b31ng completed.

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Form FC-1077 was required to be signed by the individual assigned the

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verification of an item as a certification that the item had been fully completed.- The licensee identified 23 weaknesses that were

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significant. The weaknesses were classified'as significant because the SEP actions were not completed or the SEP work scope was not met.

The licensee stated that a QA deficiency report (DR) would be issued for each significant weakness identified. The DR process is being

used since the process had been fully procedurait ad.

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It is requested that the licensee provide i response that discusses

the significant weaknesses'that were identified and the actions that E

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item pending receipt of the licensee's response and a review of the

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l r proposed actions to be taken to. resolve the weaknesses by an inspector.

(285/8937-07)

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The inspector did note that the validation activities' performed by QA

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and the-licensing-organization were generally vey,ood.

It appeared

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1-that the validation review was performed in a professional manner.

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The inspector reviewed records to verify that the appropriate

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individuals had been provided training in the validation process.

The inspector also reviewed the lesson plans used for the training

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sessior.s for adequecy. The licensee stated that training had been given in the verification process, but the inspector did not '.tview L

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During review of this item, the inspector noted no problems other.

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than the problem discussed in paranraph 2.b related to establishing

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E acceptance criteria for institutionalization, end providing -

l instruction of the criteria to personnel involved in validation 1:

activities.

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Overall, it appear'ed, based on'the assessment performed by the inspector,

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that the licensee was implementing an adequate V&V process.

Based on the 3'

. limited' sample of items reviewed by-the inspector,-it appeared that the licensee needed to provide additional attention to the details of the V&V

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process to ensure that the types of concerns identified by the inspector

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are identified and. corrected by the licensee.

The licensee should take a

,more proactive role in informing the NRC on the status of the weaknesses.

being' identified dLring the validation process.

The lack of a

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proceduralizid program to address the V&V process, the failure to.

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establish acceptance criteria for an acceptable method for

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institutionalization, and the failure to establish an' appropriate method

for the validation of ider.tified weaknesses are of concern to. the'NRC.

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particular ~ concern to the NRC is the relatively large number of significant weaknesses that' were-identified by the licensee, f One notable aspect of the V&V process was the professional approach used by QA and the licensing organization during the performance of the validation process.

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Exit ~ Interview

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Thefinspector met with Mi K. J. Morris,'(Division Manager, Nuclear

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s Operations) and other: members of the licensee staff-on October 20,1989.

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l The meeting attendees are listed in paragraph 1 of this inspection report.

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lAt this meeting, the inspector summarized the scope of the assessment and E

i the-findings.

During the exit meeting, the licensee did not identify any

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l 'o proprietary information to the inspector.

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