ML20024C256

Responds to NRC 830506 Ltr Re Violations Noted in IE Insp Rept 50-285/83-08.Corrective Actions:Qa Procedure 19 Replaced by Dept Manual Procedure,Establishing Requirement for Individual Training Files

ML20024C256
Person / Time
Site:	Fort Calhoun
Issue date:	06/03/1983
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20024C251	List: ML20024C256
References
LIC-83-133, NUDOCS 8307120454
Download: ML20024C256 (4)

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Omaha Public Power District 1623 Hamey Omaha, Nebraska 68102 402/536-4000 June 3, 1983 LIC-83-133 Mr. W. C. Seidle, Chief Reactor Project Branch 2 ~

9 U. S. Nuclear Regulatory Commission Region IV i 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 1 M-

Reference:

Docke t No. 50-285 h L_

Dear Mr. Seidle:

IE Inspection Report 83-08 The subject inspection report dated May 6, 1983 identified two (2) deviations regarding the Omaha Public Power Dis-trict's quality assurance program. Please find attached the District's response to these two (2) deviations.

Sincerely,

/. ones I #44'

d. .

Division Manager Production Operations WCJ/TLP:jmm Actachment cc: Le Boe u f , Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 Mr. L. A. Yandell, Senior Resident Inspector i

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l 8307120454 830701 PDR ADOCK 05000285 O PDR 455 24 Emntoyment with Equal Opportunity Male / Female  ;

Attachment OMAHA PUBLIC POWER DISTRICT'S RESPONSE TO IE INSPECTION REPORT 83-08 Deviation reem 1 Documentation of Continuing Training of Licensee Quality Assurance Personnel By letter dated June 16, 1981, the licensee forwarded a re-sponse to violation 50-285/8107-01. This violation cited <

the licensee for failure to maintain sufficient records to furnish evidence of activities affecting quality.

The response stated, in part, that:

'b. Corrective-steps which will be taken to avoid further violations:

QAP No.19 Revision 1, requires that QA forms

1. 18, #28, -and #29 be completed and signed to document all continuing training of quality assurance personnel.

c. The date when full compliance will be achieved:

The use of the documentation forms commenced on June 3, 1981, and the research of the files to validate past training was initiated on May 11, 1981. Updated files will be complete by September 1, 1981, and the District will be in full compliance."

l In deviation from the above, it was found that QA form #18 l

is not required by QAP No. 19 and is not being used, QA form 628 was missing from one QA inspectors training file, QA form #29 was being used but had not been filed in the indi-i vidual training folders, and documentation to validate past l training was filed separately from the individual training

. files.

Response

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(1) Corrective steps which have been taken and the results achieved.

The District's QAP #19 has been replaced by a QA De-j partment Manual (QADM) procedure as a part of the l District's Quality Assurance Program rewrite effort.

l The QADM establishes the requirement for individual l training files which will contain the same types of

l information required by the old QAP #19. The old QA forms $18 and #29 have been replaced with a new type of forn in the QADN. The elements of the forms have '

been retained such that the same information is pro-vided. A form similar to the old QA form #28 will be incorporated into the QADM at a later date. In the meantime, the old QA form #28 or a form containing the same elements will be nsed. At the time of the NRC inspection, the individual files required by the new i- QADM were being established and information from several other sources to complete the files was being consolidated. The formation of these individual train-ing files has been completed and any missing document-ation has been identified.

(2) Corrective steps which will be taken to avoid future i

deviation from commitments made to the Commission.

The intent of the original commitment by the District was to assure that training and certification records were retained on each Quality Assurance Department individual requiring qualification, training, or certi-fication. This intent, and the elements of the origi-nal documents used by the District, has been retained 4

in the new QADM, but not necessarily the exact format or forms of the original commitment. In the future, the individual training files for Quality Assurance Department personnel will be retained in accordance with the QADM and will contain documentation of train-ing received, applicable certifications of capability (such as Lead Auditor certification or inspector certi-fications).

( 3') The date when full compliance will be achieved.

The District will be in full compliance with the QADM and'the intent of our original commitment as described in paragraph (2) above by July 1, 1983.

4 Deviation Item 2 Failure to Accomplish Activities Affecting Quality In the licensee response to NRC Inspection Report 50-285/81-07, a commitment was made to achieve compliance with the licensee Quality Assurance Program 17, Revision 1, requirement to respond to QA audit reported discrepancies in writing within 30 days from receipt of an audit report. The licensee committed to be in compliance by the end of August

-1981.

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• - . In deviation from the above, the licensee did not achieve compliance with the requirements of QAP-17 to respond, in writing, to audit reported discrepancies within 30 days.

This is evidenced by numerous failures to meet this require-ment both before August 1981 and subsequently through the time of this inspection.

Response

(1)' Corrective steps which have been taken and the results achieved.

As was noted in the inspection report, there'has been a considerable reduction in the number of late re-ports, but the frequency of occurrence is still not acceptable. In order to obtain compliance with our commitment, additional attention is being given to this area to ensure that the required 30-day responses are provided in a timely manner.

The District's continued failure to meet the 30-day reporting requirements for open items was traced to the methods being used to track the open items.

Quality Assurance' has established a Quality / Deficiency Report-Status Report which is issued on a monthly basis. However, while the monthly report and informal j follow-up by QA is sufficient to track correctlye acticn progress and completion, it is inadequate for tracking the initial 30-day response.

Therefore, to provide more responsive short-term tracking of 30-day responses, each division involved l in the report process has established an internal short-term tickle system. This will provide improved assurance that initial corrective action responses are accomplished within 30 days.

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(2) Corrective steps which will be taken to avoid future deviations from commitments made to the Commission.

l The actions outlined in paragraph (1) will prevent future deviation from this commitment.

, (3) The date when full compliance will be achieved.

The District will be in full compliance with the 30-day initial response requirements for deficiency

and quality reports by July 1, 1983.

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