LIC-90-0839, Forwards Quarterly Status Rept for Safety Enhancement Program

Forwards Quarterly Status Rept for Safety Enhancement Program

ML20058C009
Person / Time
Site:	Fort Calhoun
Issue date:	10/22/1990
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
LIC-90-0839, LIC-90-839, NUDOCS 9010310193
Download: ML20058C009 (12)

Text

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Omaha Public Power District

["[ @ [P pV/ Pif 444 South 16th Street Mall d' %

Omaha, Nebraska 68102-2247 4

402/636-2000 d ',

OCT 2 41990 October 22, 1990 LIC-90-0839 gj Mr. Robert D. Martin.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

References:

1.

Docket No. 50-285 2.

Letter from NRC (V. Stello) to OPPD (F. M. Petersen) dated July 8, 1988 3.

Letter from OPPD (W. C. Jones) to NRC (R. D. Martin) dated l

December 9, 1988 (LIC-88-1094) l 4.

Letter from OPPD (W. G.. Gates) to NRC (R. D. Martin) dated March 30, 1990 (LIC-90-0222) l 5.

Letter from OPPD (W. G. Gates).to NRC (R. D. Martin) dated l

May 4, 1990 (LIC-90-0330) l 6.

Letter-from OPPD (W. G, Gates) to NRC (R. D. Martin) dated L

June 5, 1990 (LIC-90-0242)

L 7.

Letter from OPPD (W. G. Gates) to NRC (R. D. Martin) dated July 20, 1990 (LIC-90-0590)

SUBJECT:

Safety Enhancement Program - Quarterly Status Report l

l This letter provides the Omaha Public Power District's (OPPD)^ quarterly report on the completion status of items in OPPD's Safety Enhancement-Program (SEP),

developed to integrate nuclear commitments, projects, and programs to ensure the resolution of managerial, organizational,' and operational concerns. This report describes the completion status of each individual SEP item and any-significant progress or problems related to Priority I items.

l As of September 30, 1990, OPPD has completed 66 of the 72 corrective. action-activities, twenty two of which are Priority I items.

Information on 63-completed items has been submitted through official correspondence to your office.

There was one item schedaed for completion in the third quarter of 1990, SEP 72 " Surveillance Test Performance Needs Improvement", and this item was completed on time.

A total of 38 items have been closed by-0 PPD.

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U.. S. Nuclear Regulatory Commission LIC-90-0839 i

Page 2 During this reporting period, a Verification & Validation (V&V) process continued to ensure that all activities contained in each completed SEP item had been accomplished.

Presently, 11 nonsignificant weaknesses remain open and I

these are currently in the process of being resolved. Thirteen other weaknesses identified during V&V activities have been classified as significant. Ten of these were identified to you in previous submittals, and the other three are described in the summaries for-items 55 ana 59.

Quality Assurance Corrective Actions Reports (CAR) have been written.to assure timely resolution of these significant weaknesses.

i The Quality Assurance and Quality Control Department has incorporated.the SEP' items into their audit and surveillance program and-are-now conducting these audits and surveillances as part of their scheduled. activities.

If you should have any questions, please contact me.

Since# rely, 9

+y1 W. G. Gates Division Mafager Nuclear Operations WGG/sel c:

LeBoeuf, Lamb, Leiby & MacRae T. E. Murley, NRC Director, Nuclear Reactor Regulation S. J. Collins, NRC Director, Reactor Projects, Region IV T. R. Quay, NRC Project Director l

A. Bournia, NRC Project Manager R. P. Mullikin, NRC Senior Resident Inspector Document Control Desk l

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Omaha Public: Power District-Safety Enhancement = Program Quarterly Status Report' i.

1 l.

Improve communications-via training, team b'uilding,. eliminating organizational barriers, monthly managers meetings, newsletter.

CLOSED - Closeout letter has been submitted to the NRC.

Verification &

Validation process complete.

This item is closed 2.

Initiate training to encourage problem reporting b/: coaching and counseling, use of performance indicators,- feedback and tracking.

CLOSED - Closeout letter has been submitted to the NRC.

Verification &

Validation process is complete.

Identified V&V weaknesses have been resolved. This item is closed.

3.

Develop a system to reduce control room traffic for maintenance work control activities - modification FC-81-051.

CLOSED - Closeout letter has been submitted to the NRC.

Verification &

Validation process is complete.

Identified V&V weaknesses have been resolved. This item is closed.

4.

Develop plant and system. level Design Basis Documents for safety systems and other selected systems.

COMPLETE - A closeout letter has been : submitted to the NRC'. ' Verification and Validation process is ongoing..

5.

Verify that ops, E0Ps, A0Ps and Technical Data' Book (TDB) conform to the design bases when complete.

COMPLETE - A closeout letter has been submitted to the NRC

-Verification and Validation process is ongoing.

l 6.

Verify that safety systems and other selected syst'ms perform their e

intended functions on completion of design basis documentation.

In accordance with letter-LIC-90-022 from 0 PPD (W. G. Gates) to NRC-(R. D.

Martin) dated March 30, 1990, the completion date was extended.for this item from April 1, 1990 to December 31', 1990. This extension was requested because issuance of the last Design Basis Document (DBD's) was required under SEP 4 before the actions of SEP 6 could be ' completed.-.

SEP 6 involves verification that safety systems and other selected systems can perform their intended functions.

Significant progress toward completion of the verification task has been made-to date. Overall, SEP 6 is apprcximately 75% complete.. Functional verification has been completed for the DBDs written by Stone & Webster. Engineering. Work is continuing for the DBDs' written by Combustion Engineering. The modification review for potential unreviewed safety questions was initiated in May.

This task involves the review of approximately 1200 modifications against the new DBD's -to insure that potential unreviewed safety questions do not-exist, and this effort has been completed.

Safety Enhancement Program Quarterly Status Report Page 2

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7.

Determine which records must be recreated and provide a schedule for recreating the records.

I COMPLETE - Close out letter has been submitted to the NRC Verification and Validation process is ongoing.

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8.

Establish and train Safety Review Group, COMPLETE - A closeout letter has been submitted to NRC. Verification &

Validation process is ongoing. One significant weakness has been previously identified to the NRC.

9.

Improve effectiveness of PRC by reducing procedure review, revising membership, training, upgrading minutes and action tracking.

CLOSE0 - Closecut letter has been submitted to the NRC.

Verification &

I Validation process is complete.

Identified V&V weaknesses are resolved.

This item is closed.

10. Complete implementation of Trending and Root Cause analysis program by completing policies and procedures and training.

CLOSED - Closecut letter has been submitted to the NRC.

Verification &

Validation process is complete.

Identified V&V weaknesses have been resolved.

This item is closed,

11. Long term PRC procedure program.

l CLOSED - Closecut letter has been submitted to the NRC. Ver.ification &

Validation process is complete.

Identified V&V weaknesses have been l

resolved.

This item is closed.

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12. Increase EP staffing.

CLOSED - Closeout letter has been submitted to NRC. Verification &

Validation process is complete.

No V&V weaknesses were identified.

This item is closed.

13. Improve emergency plans and procedures.

Following PRC subcommittee review of revised procedures, they were given to the Training Department for Emergency Response Organization.(ERO) training. After full PRC approval of revised procedures and completion of training on them, the procedures will be implemented. This SEP item has been extended to D ; ember 31, 1990 in accordance with Reference 6.

Safety Enhancement Program Quarterly Status Report.

Page 3

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14. Implement improved training program by small. scale drills, improved exercise scenarios and performance based instruction.

This item is on schedule.

It.was previously extended to December 31, 1990 in accordance with Reference 6.

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15. Increase HPES & IR accountability through use of performance indicators i

including performance of subordinates as an accountability in supervisory I

performance appraisals.

j CLOSED - Closecut letter has been submitted to NRC.. Verification &

Validation process is complete.

Identified V&V weaknesses have been 1

resolved. This item is closed.

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16. Identification of career paths, supervisor training, employee training.

CLOSED - Closeout letter has been submitted to the NRC. Verification &-

Validation process is complete.

Identified V&V weaknesses have been resolved.. This item is closed

17. Develop and implement succession program.

COMPLETE - Closeout letter has been submitted to the NRC. Verification &

Validation process is complete.

Revalidation is being conducted or, this item.

18. Develop mission statement / functional job descriptions.

CLOSED - Closeout letter has been submitted to NRC. One significant weakness has been identified and closed.

Identified V&V weaknesses have i

been resolved.

This item is closed.

19. Develop interpersonal skills using positive reinforcement techniques via the management / supervisory development program.

CLOSED - Closeout letter.has been submitted to the NRC. Verification &

Validation process is complete.

Identified V&V weaknesses.have been resolved. This item is closed.

20. Evaluate, improve depth and strengthen quality audit and surveillance i

programs.

CLOSED - Closecut letter has been submitted to NRC.

Verification &

Validation process is complete. -Identified V&V weaknesses have been resolved. This item is closed.

21. Develop and conduct a'SSFI.

CLOSED - A closeout letter has been submitted to NRC.

Verification &

Validation process is complete. This item is closed.

Safety _ Enhancement Program Quarterly Status Report' Page 4

22. Initiate periodic observations of work in progress and provide timely feedback to craftsmen and supervisors.

COMPLETE - Closeout letter has been submitted to NRC.

Verification &.

Validation process is complete.

Four identified V&V weaknesses have been-resolved.

Revalidation will. be conducted on this item based on closure of weaknesses.

23. Perform audits to verify that commitments made to the NRC in the-SSOMI team responses are planned / implemented.

COMPLETE - A closeout letter has been submitted to the NRC.

Verification and Validation process is ongoing.

24. Complete staffing studies.

Hire additional experienced personnel on an expedited basis.

CLOSED - Closecut letter has been submitted to 'NRC.

Verification &

Validation process is complete.

This item is closed.

25. Training program for managers and supervisors implemented.

COMPLETE - Closeout letter has been submitted to NRC. ~ Verification &'

Validation process ongoing.

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26. Evaluate and implement station standards for safe work practices requirements.

CLOSED - Closeout letter has been submitted to NRC. Verification &

Validation process is complete.

Identified V&V weaknesses have been resolved. This item is closed.

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27. Implement supervisory enforcement of industrial safety standards.

CLOSED - Completed prior to SEP submittal.

Verification & Validation process is complete.

Identified V&V weaknesses have been resolved.- This item is closed.

28. Complete required instrument air program corrective actions' for 1988 refueling.

CLOSED - Closecut letter hc. been-submitted to NRC.

Verification &

Validation process is complete.. Identified V&V weaknesses have been resolved. This item is closed.

29. Incorporate the instrument air system / accumulators into the surveillance test program.

CLOSED - Closecut letter has been submitted to NRC.

Verification &.

Validation process is complete.

Identified V&V weaknesses have been resolved. This item is closed.

Safety Enhancerent Program Ouarterly _ Status Report Page 5

30. Complete long term corrective action on Instrument Air System.

COMPLETE - Closeout letter has been submitted to the NRC. Verification and Validation process is ongoing.

31. Develop outage & maintenance planning manual and conduct project' management

training, COMPLETE - Closeout letter has been submitted to NRC. Verification &

Validation process is complete.

Closure of five identified V&V weaknesses is in progress. Revalidation will be conducted based on closeout of weaknesses.

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32. Perform post outage critique.

CLOSED -- Closeout letter has been submitted to NRC.

Verification &

Validation process is complete.

Identified V&V weaknesses have been resolved.

This item is closed.

33. Develop on-line maintenance and modification schedule.

COMPLETE - closeout letter has been submitted to NRC. Verification &

Validation process is ongoing.

34. Create and staff central planning group.

COMPLETE - Closeout letter has been submitted to NRC.

Identified V&V weakness have been resolved. Revalidation will be conducted based on l

closecut of identified weakness.

35. Establish criteria for identifying post-maintenance testing requirements and track, completion, and retesting.

COMPLETE - Closecut letter has been submitted to NRC. Verification &-

Validation process is complete. One V&V identified weakness is being i

tracked by the Nuclear Licensing & Industry Affairs Department. A i

significant weakness was previously identified to the'NRC.

36. Reduce corrective non-outage maintenance backlog.

1 Verification &-

COMPLETE - Closecut letter has been submitted to NRC.

Validation process is ongoing.

37. Review and upgrade, as required, scope and content of the MOV operating, maintenance, spare parts, and testing' programs and procedures.

CLOSED - Closeout letter has been submitted to NRC.

Verification &

Validation process is complete.

Identified V&V~ weaknesses.have been resolved.

This item is closed.

Safety Enhancement Program l

Quarterly Status Report Page 6

38. Major technicC issues monitoring /statusing.

3rd AFW pump modification is complete.

In accordance with letter OPPD (W. G. Gates) to NRC (R. D. Martin)' dated r

08/22/90 (LIC-90-0665), the PRA effort was removed.from the scope of' SEP-38.

Seismic walk-downs and related activities will be delayed.as reported in previous NRC correspondence.

A new date will be established after receipt of the generic implementation program (GIP) final SER..

39. Establish and communicate clear standards of expected plant cleanliness, and appearance and follow-up.

CLOSED.- Closeout letter has been submitted to NRC.

Verification &

Validation process is complete.

Identified V&V weakness has been resolved. This item is closed.

40. Construct and occupy Training Center.

CLOSED - Closeout letter has been submitted to NRC.

Verification &

Validation process complete. This item is closed.

41. Develop and implement a preventive maintenance program.

COMPLETE - Closecut letter has been submitted to NRC.. Verification &

Validation process is complete. Two V&V identified weaknesses have been resolved. A significant weakness was identified-and closed during the 1st quarter of 1990.

Item has been revalidated, and closure of one weakness is pending.

42. Evaluate need for a roliability centered maintenance program.

l Project is on schedule.

43. Implement the check valve test program.

I CLOSED - Closecut letter has been submitted to-NRC

. Verification &

l Validation process is complete.

Identified V&V weaknesses have been resolved.

This item is closed..

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44. Compliance with and use of procedures.

COMPLETE - Closeout letter has been submitted to NRC.

Verification &

Validation process is ongoing.

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L Safet'y Enhancement Program Quarterly Status Report Page 7

45. Revise'and conduct training on Emergency Operating Procedures.

COMPLETE - Closeout letter has been submitted to NRC.

Verification &

Validation process is ongoing.

46. Design a procedures control and administration program..

COMPLETE - Completed prior to original.SEP submittal. Verificatioi; &

Validation process is ongoing. One identified V&V weakness is being.

tracked by OPPD Nuclear Licensing and Industry Affairs Department;

47. Conduct Operations' memo review and incorporate procedural guidance as appropriate.

CLOSED - Closeout letter has been submitted to NRC. Verification &.

Validation process is complete.

Identified V&V' weakness has been resolved. This item is closed..

48. Safety related procedures upgrade project.

As of September 30, 1356 safety related procedures have been revised,,1210 l

have been verified,1129 validated, 955 to.PRC, and 940 approved.

Management attention is being provided to this item to ensure timely completion, l

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.49. Revise and conduct training on emergency and abnormal operating procedures.

I COMPLETE - A closeout letter has been submitted to NRC. Verification.&.

Validation process is ongoing.

50. Perform appraisals and develop Radiological Improvement Program.

CLOSED - Completed prior to SEP submittal.

Verification & Validation process is complete. This item is closed.

51. Complete. revision of Radiation Protection Manual and radiological procedures of operation manual.

CLOSED - Closeout letter has been submitted to NRC. Verification &

Validation process is complete. One V&V. identified weakness has'been-resolved. This item is closed.

52. Establish supervisory accountability for workers radiological practices.

CLOSED - Completed prior to SEP submittal. Verification & Validation process is complete.

Identified &V& weakness has been resolved. 'This. item is closed.

53. Acquire new TLD-processing equipment and upgrade dosimetry program.

CLOSED - Closeout letter has been submitted to NRC. Verification &

Validation process is complete. OneLidentified weakness has'been resolved.

This item is closed.

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Safety Enhancement Program-Quarterly Status Report Page 8

54. Complete implementation of radiological enhancement plan.

CLOSED - Closeout letter has been submitted to NRC.

Verification &

l Validation process is complete. Three V&V identified weaknesses have.been.

resolved.

This-item is closed.

55. Procure hardware and replace locksets on VHRA doors and barriers' and implement improved key control program.

COMPLETE - Closeout letter has been submitted to NRC.

Verification &

Validation process is ongoing. One significant weakness has been identified for this11 tem: The scope of this SEP required'that a remote alarm be installed for VHRA doors to indicate when a " latch bolt not-engaged" condition occurs.

Contrary to this it was noted that this remote alarm has been replaced by a local alarm. A CAR has been written on this item to ensure timely resolution of the problem.

56. Evaluate and revise PASS system procedures.

CLOSED - Completed prior to SEP submittal. Verification & Validation process is complete.

Identified V&V weaknesses have been resolved. This item is closed.

57. Conduct in-depth physical security assessment and establish action plan.

CLOSED - Closeout letter has been submitted to NRC.

Verification &

Validation process is complete. This item is closed.

58. Revise physical security training and procedures program.

s CLOSED - Closeout letter has been submitted to NRC.. Verification &

I Validation process is complete.

Identified V&V weaknesses have been resolved.

This item is closed.

59. Complete security system hardware upgrades (MOD 85-049).

COMPLETE - Closecut letter will be submitted to NRC.1 Verification and Validation process is ongoing. Two significant weaknesses have been-identified for this item: 1) Two perimeter cameras and two microwave zones require modification to correct deficiencies.

2) Protected Area lighting deficiencies exist.

CAR's have been written against these two~ items to ensure timely resolution of these problems.

60. Improve controls over surveillance test program.

CLOSED - Closeout letter has been submitted to NRC. -Verification &

Validation process is complete. One identified V&V weakness has been resolved.

This item is closed

61. Modify computer program to correctly schedule surveillance tests.

l CLOSED - Closeout letter has been submitted to the NRC. ' Verification &

Validation process'is complete.- Identified V&V weaknesses are resolved, i

This item is closed.

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Safety Enhancement'Prograa Quarterly Status Report Page 9

62. Establish interim system engineers.

COMPLETE - Closeout letter has been submitted to NRC.

Verification &

Validation process is ongoing.

63. Complete safety related vendor _ manual upgrade project (760 manual scope)..

COMPLETE - Closeout letter has been submitted to NRC.

Verification &

Validation process is complete. One identified V&V weakness has been resolved.

One significant weakness was previously identified to the NRC.

64. Finalize 1990 outage modifications list,. and strength'en-management; controls.

COMPLETE - Closeout letter has been submitted to NRC.

Verification-&

Validation process is ongoing..

65. Revise FCS modification control procedures.

COMPLETE - Closeout letter has been submitted to NRC.- Verification &

Validation process is complete.

Revalidation will_be conducted on this item based on closure of identified weaknesses.

66. Respond to the eight open items listed on pages A-I through A-3 of the report regarding SSOMI items.

CLOSED - Completed prior to SEP submittal.

Verification & Validation process is complete.

Identified V&V-weaknesses have been resolved.

This item is closed.

67. Develop and implement a plan to assign _ more licensed operators and instructors.

COMPLETE - Closeout letter-has been submitted to NRC. One identified V&V weakness has been resolved.

Revalidation will be conducted on this item based on closure of weaknesses.

68. Assess root cause of poor operator training and establish means to monitor operator training.

CLOSED - Closeout letter has been submitted to NRC. Three identified V&V weaknesses have been resolved. Verification and. Validation process is complete. This item is closed.

69. Complete installation and start-up of simulator.

CLOSED - Closecut letter will be submitted to NRC._ Verification &

Validation process is complete. This item is closed.

70. Complete observation training for management: andLsupervisory personnel, and develop a field observation guideline-for good observation techniques.

COMPLETE - Closecut letter has been submitted to NRC.

Verification &

Validation process is ongoing. Two significant weaknesses have been previously identified to the NRC.

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Safety Enhancement Prograa Quarterly Status Report Page 10

71. Improve controls over the review and documentation of temporary modifications.

CLOSED Closeout letter has been submitted to NRC.

Ve"ification &

Validation process is complete.

Identified weaknesses have been resolved.

This item is closed.

72. Surveillance Test Performance needs improvement.

COMPLETE - Closeout letter will be submitted to NRC. Verification &

Validation process is ongoing, r

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