IR 05000285/1990008
| ML20012D061 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/16/1990 |
| From: | Barnes I, Garrison D, Gilbert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20012D057 | List: |
| References | |
| 50-285-90-08, 50-285-90-8, NUDOCS 9003260410 | |
| Download: ML20012D061 (8) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION l~
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REGION IV
of NRC Inspection Report:
50-285/90-08 Operating License: DPR-40 Docket: 50-285 s
Licensee: OmahaPublicPowerDistrict(OPPD)
1623 Harney Street
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Omaha, Nebraska 68102 Facility Name: FortCalhounStation(FCS)
Inspection At: FCS, Blair, Nebraska inspection Conducted: February 12-15, 1990 Inspectors:
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9d c L. D. G Ubert, Reactor Inspector, Materials 5 ate
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and Quality Programs Section Division of Reactor Safety (h&
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D. L. Garrison, Reactor Inspector Materials Date andQualityProgramsSection,DIvisionof Reactor Safety Approved:
8e 3 - /6 - 70 I. Barnes, Chief, Materials and Quality Date Programs Section, Division of Reactor Safety Q inspection Summary Inspection Conducted February 12-15, 1990 (Report 50-285/90-08)
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Routine, unannounced inspection of the corrective action g o@ Areas Inspected:
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- O Results: The inspection identified that a corrective action program has been g
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established which appropriately provides for identification, tracking, vg correction, and trending of safety-related problems. Procedures were found to L
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Sq be satisfactory in content and methods; sufficient staff had been provided to M
support program activities, and site staff showed familiarity with program
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occ requirements. An inspection followup item was identified regarding management
$$c actions taken in response to trend information showing an increasing incidence
- of' procedures not being followed. Within the area inspected, no violations or deviations were identified.
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L DETAILS L
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PERSONS CONTACTED
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- R. L. Andrews, Division Manager. Quality & Environmental Affairs
- G. R. Peterson, Plant Manager, FCS
- J. W. Tills, Manager FCS
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- C. J. Brunnert, Supervisor, Operations QA r
- *G. Krieser, Supervisor, Corporate QA
- B. Blome, Acting Supervisor, Corporate QA
- S. W111 rett, Manager, Administrative Services
- D. J. Matthews, Supervisor, Station Licensing i
- C. F. Simmons, Station Licensing Engineer
- H. J. Sefick, Manager, Security Services
- J. K. Gasper, Manager Training
- L. T. Kusek, Manager, Nuclear Safety Review
- R. J. Sexton, Acting Supervisor, Radiation Protection
- D. R. Taylor, QA Engineer
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J. D. Kecy Supervisor Systems Engineering
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- P. Harrell, Senior Resident Inspector
- T. Reis, Resident inspector
The inspectors also interviewed other licensee employees during the~ inspection.
- Denotes attendance at exit interview conducted on February 15, 1990.
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CORRECTIVE ACTION PROGRAM (92720)
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The purpose of the inspection was to assess whether the licensee had developed
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a comprehensive corrective action program to. identify, follow, and correct L
safety-related problems - The inspectors reviewed the corrective action program l
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- as delineated in the FCS QA Plan, QA Manual, and plant procedures.
A. list of
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the documents reviewed is contained in Attachment I to this report. The i
program was reviewed in-regard to provisions made for identification of J
nonconforming conditions, evaluations, and recommendations for correcting the nonconforming condition, timeliness of corrective action, and trending of
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nonconforming items for management attention and action. The problem reports identified in Attachment 2 were selected for review, in order to assess the j
i adequacy of program implementation.
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p 2.1 0'perational Events
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Operational events are reported initially by the use of a station incident c
report, which states the problem or potential problem. The station incident
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report is then used to track the immediate, short-term, and long-) term actions
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required to resolve the situation. Licensee Event Reports (LERs are prepared L
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and issued for those events meeting the requirements of reportability to
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10 CFR 50.73, " Licensee Event Report System." Actions specified in LERs are.
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followed using the station action tracking system. The inspector reviewed five l
LERs for conformance to procedures for timeliness, content, NRC reporting
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2.2 _ Identification of Problems by General plant Staff l
The inspectors reviewed the provisions made in the corrective action program i
for reporting of problems by plant personnel who were not usually involved in i
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reporting as a matter of.their job classifications. A limited review was also
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g performed on reports of problems reported by general plant staff.
l 2.2.1 Procedures
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The inspectors noted that procedures (i.e., N00-QP-11, N00-QP-20, and QAM-20)
provided for reportino of conditions adverse to quality by all OPPD employees, contractors, and ven e s.
The inspectors also noted that the fitness for duty
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and general employee training programs instructed personnel on the importance
of reporting problems.
2.2.2 Implementation
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The inspectors reviewed two cases in which problems were identified by the general staff. These were:
Corrective Action Report (CAR) No.90-012 was written by a contract
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procurement engineer on January 9,1990, evaluated on January 16-19, and replaced by CAR No.90-056, which was issued on February 7, 1990. This CAR concerned improper purchasing practices whereby material could arr_ive on ' site before a purchase order was complete; also, certificates of conformance could be received before a purchase order was issued. :In the initial description (Part 1) of CAR No.90-056, a re omendation stated,
"QC will write a CAR for each future occurrence.
It is recommended that CQE material not be shipped prior to approval of the purchase orders." At
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the time of the inspection, the proposed corrective action had not been added to the CAR, thus, precluding assessment of the effectiveness of proposed measures to preclude recurrence. The inspector discussed the recommendations on the CAR with the QA supervisor and was assured that appropriate actions to preclude recurrence would be required before QA acceptance.
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-4-DeficiencyReport(DR)FC1-88-232, which was identified by a warehouseman
on November 16, 1988, dealt with warehousemen or inspectors needlessly opening sealed packages containing parts with delicate surfaces; thereby, increasing the risk of degrading the product during handling. The resolution was the initiation of a revision to Procedure QAPD-12 to i
require determination of specific receipt inspection requirement prior to opening such packages. The corrective action was indicated complete on l
December 26, 1988, for this DR.
2.3 Concerns Brought by External Persons or Organizations identified concerns, which are not within the scope of established programs and procedures, ere handled by the corporate licensing group. The licensing group
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also administratively har.dles NRC inspection report responses, information notices, and responses to bulletins, and generic letters. These areas were discussed with the OPPD licensing) manager who indicated that the items
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(including substantiated concerns are tracked in the open items tracking j
system, with licensing maintaining the responsibility for closure.
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2.4 OA Audits /Special Reports The inspectors reviewed QA and safety audit and review committee (SARC) yearly schedule of audits for 1989 and reviewed each of the 13 audit reports. The audits were performed in accordance with Procedure QAM 12, "QA Audits Scheduling."
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The-subjects of the audits were as follows:
J Audit Number Subject Deficiencies Generated
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SARC 1-89 QA Program 9 DRs j
QA/QC 2 Electrical EQ 6 DRs SARC 3-89 Emergency Response 8 DRs SARC 2-89 Fire Protection 13 DRs QA/QC 29 Shift Operations 6 DRs QA/QC 30 Material Control 10 DRs j
QA/QC 35 Inservice Inspection 10 DRs j
QA/QC 38 Design Engineering 16 DRs i
SARC 45 Corrective Action 13 DRs SARC 4-89 Facility Operations 9 DRs QA/QC 58 Radiation Protection 3 DRs
SARC 62 Training 7 DRs Eight DRs were selected for review in the above audit reports. The DRs were reviewed for clarity of description, short-term and long-term corrective action, review comments, and completed corrective action. The DRs reviewed
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were:
FC1-89-082 FC1-89-153 FCl-89-187 FC1-89-101 FC1-89-275 FC1-89-223 FC1-89-363 FC1-89-217
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The audit reports and the samples of DRs that were examined were found to be
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clear, concise, and professionally written. The recommendations were clear and appropriate. The corrective actions were detailed and included references and
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criteria. Completed corrective action was verified before fir.a1 sign-off except in one case.
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A disparity was noted on the completed DR FC1-89-217 which concerned lost
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hardware. Licensee personnel had signed off the corrective action as complete,
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although the root cause analysis required by procedure had not been performed.
r The tracking system, however, carried the item as open. The corporate QA supervisor indicated that the DR was being held in an open status on the
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tracking system until the root cause analysis was received.
This method of handling this type of discrepancy is not consistent with other l
licensee procedures, which require that the completed action signatures be voided and initialed and a revision to the DR be made or another DR be generated
with corrective action to preclude recurrence. The corporate QA supervisor informed the inspector that procedure QAM-2, " Control of Quality Assurance Documents and Records," would be revised to include instruction for voiding of signatures when errors are detected.
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2.5 Trending
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The trending analysis program was reviewed by the inspectors. The governing
document is QAM 21, " Deficiency, Tracking. Trending, and Reporting."
In the trending program, incident status reports are trended, and a monthly'
report generated to satisfy the performance measurement objectives for the
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safety enhancement program. A quarterly corrective action status report is
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also generated; this report provides trend analysis results for significant
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deficiencies, deficiencies, discrepancies, NRC violations, INPO findings,
incident reports, LERs, surveillance root cause analysis results, corrective actions, and nuclear safety review group findings.
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The trended items are separated into three categories as follows:
The first part, " Group Trending Categories" contains 46 subjects.
- The second part, functional areas, covers 19 discipline areas.
The third part, cause trending, covers 11 major and 33 subsets of categories.
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Threshold values have been established in certain categories for determination
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of when actions are required by the particular managers responsible for that
area. Once the report is issued to management there are no further procedural requirements for management to provide a response on the actions taken in t
L response to trend data showing threshold values have been exceeded. The
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inspectors noted that the fourth quarter of.1989 trend report identified that
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- the_ incidence of " procedures not followed" had more than doubled over the past three quarters. Review of management actions taken in response to this trend informationisconsideredaninspectorfollowupitem(285/9008-01).
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CONCLUSION
The inspectors verified that the licensee has developed a comprehensive corrective action program to identify, track, correct, and trend safety-related i
problems. The corrective action program was found to be consistent.with the
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policy statements and commitments expressed in the-Updated Safety Analysis Report, Technical Specifications, and plant-procedures.
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EXIT INTERVIEW
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I An exit interview was conducted on February 15, 1990, with those denoted in paragraph 1.
At this exit interview, the inspection findings were summarized.
The licensee did not-identify, as proprietary, any of the information provided
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to or reviewed by the inspectors.
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ATTACHMENT 1
- Standing Order No. G-18, "Nonconformance Control," Revision 15, issued July 1, 1989.
Quality Assurance Manual QAM-22. " Control of Nonconforming items and
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Material," Revision 0, issued September 18, 1989.
' Quality Assurance Plan Section 7.4, " Control of Nonconforming Items,"
Revision 2, issued October 6, 1989.
Quality Assurance Plan Section 10.4, " Deficiency Control and Corrective Action," Revision 2, issued January 10, 1990.
Quality Assurance Manual QAM-20, " Control of Internal Deficiencies and Corrective Action," Revision 1, issued January 2, 1990.
Quality Assurance Manual QAM-21. " Deficiency Tracking, Trending and Reporting," Revision 5, issued January 9.1990.
Standing Order No. R-3, " Reportable Occurrences," Revision 9, issued Harch 3, 1987.
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Standing Order No. R-4, " Station Incident Reports," Revision 24; issued January 25, 1990.
Standing Order No. R-11 " Notification for Significant Events," Revision 15, issued January 25, 1990.
Quality Procedure N0D-QP-23. " Commitment Tracking System (CTS) Action
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. Tracking," Revision 1, issued August 18, 1989, f
Quality Procedure N0D-QP-11. " Reporting and Corrective Action of Conditions
Adverse to Quality " Revision 1, issued October 3',1988.
Quality' Procedure NOD-QP-20. " Human Performance Evaluation System Program."
Revision 1, issued November 15, 1989.
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ATTACHMENT 2
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IncidentReports(irs).
Corrective Action Reports (CARS)
'IR Number 890508 CAR No.90-056 IR Number 900034 CAR No. 90-12 L
IR Number 890035
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IR Number 890075
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IR Humber 890062
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LicenseeEventReports(LERs)
Deficiency Reports (DRs)
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LER 89-007 DR No. FC1-89-082 LER 89-20 DR No. FC1-89-275 LER 89-02 DR No. FC1-09-153 LER 59-001 DR No. FC1-89-232 LER 89-016 Revision 2 DR No. FC1-89-223 DR No. FC1-89-187 DR No. FC1-89-363 DR No. FC1-89-101
' J DR No. FC1-89-217
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