ML20038C338

Forwards IE Performance Appraisal Insp Rept 50-285/81-24 on 810817-28 & 0908-11.No Noncompliance Noted

ML20038C338
Person / Time
Site:	Fort Calhoun
Issue date:	10/16/1981
From:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	William Jones OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20038C339	List: ML20038C338 ML20038C350
References
NUDOCS 8112100447
Download: ML20038C338 (7)

See also: IR 05000285/1981024

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Docket No. 50-285

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Omaha Public Power District

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ATTN:

Mr. W. C. Jones, Division Manager

Production Operations

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1623 Harney Street

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Omaha, NB 68102

Gentlemen:

Subject:

Performance Appraisal Inspection 50-285/81-24

This refers to the Performance Appraisal Inspection conducted by

Mr. D. R. Hunter and members of the Performance Appraisal Section, Of fice

of Inspection and Enforcement, on August 17-28 and September 8-11, 1981,

of activities authorized by NRC Operating License DPR-40 for the

Fort Calhoun Nuclear Station.

This also cefers to the observations

discussed with you and other members of your staff on August 21, and

September 11, 1981 at the Fort Calhoun Nuclear Station and the Omaha Public

Power District Offices.

This inspection is one of a series of performance appraisal inspections

being conducted by the Office of Inspection and Enforcement.

The results

of these inspections are used to evaluate, from a national perspective,

the performance of your management control programs in support of nuclear

safety.

The enclosed report 50-285/81-24 identifies the areas examined during the

inspection.

Within these areas, the inspection consisted of a corrprehensive

examination of your management controls over licensed activities, including

an examination of procedures and records, observations of work activities,

and interviews with management and other personnel.

While the enclosed report includes observations which may result in enforce-

ment actions, these matters will be followed by the IE Regional Office.

The

enclosed appraisal report also addresses other observations and the

conclusions made by the team for this inspection.

Section 1 of the report

provides further informatinn regarding the observations end how they will be

utilized.

Apperdix A to this letter is an Executive Surrmary of the

conclusions drawn for the seven functional areas inspected.

The management controls for four of the seven areas and '.he licensed operator

portion of the training area were considered average.

The remaining areas

were rated as below average:

Design Changes and Modifications, Quality

Assurance Audi: , and Non-licensed Training.

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As a result of the significant weaknesses identified in the three areas

considered below average, you are requested to inform this office within

30 days of receipt of this letter of the actions you have taken or plan

to take to improve the management controls in these areas.

Your response

to this office concerning the areas identified as below average will be

followed by the NRC Regional Office.

In accordance ,<ith 10 CFR 2.790 of the Commission's regulations, a copy of

this letter, its enclosures and your response, will be placed in the NRC's

Public Document Room.

If this report contains any information that you

(or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone

within seven (7) days from the date of this letter of your intention to

file a request for withholding; and (b) submit within twenty-five (25)

days from the date of this letter a written application to this office

to withhold such information.

If your receipt of this letter has been

delayed so that less than seven (7) days art available for your review,

please notify this office promptly so that a new date may be established.

Consistent with Section 2.790(b)(1), any such application must be accom-

panied by an affidavit executed by the owner of the information which

identifies the document or part sought to be withheld, and which contains

a full statement identifying the basis upon which it is claimed that the

information should be withheld from public disclosuce.

This section

further requires the statement to address with specificity the consideration

listed in 10 CFR 2.790(b)(4).

The information sought to be withheld shall

be incorporated as far as possible into a separate part of the affidavit.

If we do not hear from you in this regard within the specified periods

noted above, the report will be placed in the Public Document Room.

Should you have any questions concernir.g this inspection, we will be

pleased to discuss them vith you.

Sincerely,

J

Norman C. 'toseley, Director,

Division of Program Development

and Appraisal

Office of Inspection and Enforcement

Enclosures:

1. Appendix A, Executive Summary

2. IE llanagement Appraisal Report

No. 50-285/81-24

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Distribution: (W/ Appendix A)

SECY

OPE

OCA (3)

W. J. Dircks, EDO (10)

V. Stello, DEDO

H. R. Denton, NRR

W. P. Haass, NRR

C. Michelson, AE00

S. H. Hanauer, NRR

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H. Boulden, OIA

D. L. Kelley, SRI, IE

R. C. DeYoung, IE

J. H. Sniezek,IE

H. D. Thornburg, IE

N. C. Moseley, IE

J. M. Taylor, IE

C. M. Trammell, NRR

SALP Staff

Regional Directors

RIV Reading Room

All Licensees

E. P. Wilkinson, INPO

D. Goddard, Oregon Dept. of Energy

State of Nebraska

IE Files

PAS Files

'AS Regional Coordinators

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Distribution: (Letter and Appendix A w/o Report)

S. W. Reznicek, OPPD

W. E. Miller, OPPD

G. P. Bahle, OPPD

Distribution (w/o Report)

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Appendix A-

EXECUTIVE SUMMARY

A team of six Inspection Specialists from the Performance Appraisal Section

conducted an announced inspection at'the' Fort Calhoun Station and the Omaha

Public Power District offices during the period August 17 through

September 11,.1981. Management controls in seven areas were evaluated; four

of the seven areas and the licensed operator port;on of the training area

were_ rated.as " average." The remaining areas were rated "below average" and ~

included Design Changes and Modifications, Quality Assurance Audits, and

Non-licensed Training.

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Underlying several significant weaknesses was the lack of management support

for and commitment to the Quality Assurance (QA) Program.

This was evidenced

by: (1) the absence of a policy statement from the General Manager endorsing

the QA Program and directing adherence ; (2) failure to update.the QA Manual-

since 1975; (3) vacancies in key positions in the OPPD organization -

particularly the lack of.a full time QA Manager during the previous four

years; and (4) the lack of effective QA training and retraining programs

for all persons performing quality related activities.

Additional weaknesses in management controls were identified, particularly.

in areas rated below average.

These included failure to maintain cu'rrent-

plant drawings and an accurate list of quality related systems and equipment,

failure to conduct design reviews, a lack of coordination in the non-licensed

training program, and a lack of independence of the site Quality Control (QC)

group (the Supervisor-Maintenance was also the supervisor of the QC group).

Several weaknesses were also observed in the QA audit program,. including

failure to audit a number of safety-related activities.

The qualifications and experience of the plant and district office staffs

permitted completion of key functions even though many of these

activities were not clearly described in the licensee's administrative

control program.

As an example, key individuals, including non-exempt

employees, were in some cases accomplishing safety related activities in

the absence of administrative controls defining the methods to be used. An

increase in staff turnover without more effective administrative controls

could lead to conditions adverse to quality.

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Observed strengths and weaknesses in the licensee's management controls

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are further discussed in the following summary of inspection results for

the individual areas.

Plant Operations: Average (Se: tion 2).

The licensee had an established

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program to ensure safe plant operation

Personnel involved in plant

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operations appeared to be qualified ard knowledgeable of their specific

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responsibilities.

Except as noted be a , the licensee had adequately

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implemented-the program requirements; o

er, excessive reliance was placed

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on key hourly personnel to informally accomplish specific tasks instead of

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identifying these tasks in the written program.

The most significant weak-

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nesses identified were the failure to assign responsibilities for the

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Appendix-A

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fire protection program, lack of management overview of.the jumper control

program, limited independent verification of safety system lineups, and

management's failure to implement design changes and not quickly completing

maintenance orders affecting control room annunciators.

Strengths in the

licensee's_ program were the backshift and weekend visits conducted by

district management and the surveillance test program management control

~ techniques.

Committee Activities: Average (Section 3).

With minor exceptions, the

licensee had established an effective program and organization for con-

trolling review functions.

The licensee conducted committee meetings more

frequently than required, with attendance considered mandatory.

General job

descriptions were provided.

Detailed responsibilities were c'elineated in the

Safety Audit and Review Committee (SARC) implen,enting procedures; however,

the Plant Review Committee (PRC) procedure did not include adequate detail.

Program implementation weaknesses were noted in the areas of SARC review of

safety evaluations, the PRC ballot review technique, and the indoctrination

and training for new committee members.

Design Changes and Modifications:

Below Average (Section 4).

There were

significant problems regarding the sizeable backlog of engineering work

and drawing revisions, as previously identified by the NRC Regional

Office.

Significant weaknesses were also observed in timely completion of

modification control forms, measures to provide interim drawing revisions,

completion of design verification, the scope of written safety

evaluations, and failure to maintain a current Critical Quality Element

(CQE) list.

Maintenance:

Average (Section 5).

The licensee had an established

program to control corrective and preventive safety-related maintenance

activities.

Personnel interviewed appeared to be. knowledgeable and

capable of performing their responsibilities

The most significant

weaknesses in the maintenance program were the apparent lack of management

support for the QA and QC functions and the licensee's failure to provide

timely corrective actions or interim measures to reduce the impact of

significant program problems.

These problems indicated a lack of emphasis

on compliance with QA and QC requirements and on effective corrective

action measures when these requirements were violated.

Additional

weaknesses identified were in administrative control of maintenance

documents; storage of hazardous materials near c,uality items; poor control

of quality materials after removal from the storeroom; and use of

uncontrolled CQE lists by maintenance personnel.

Quality Assurance Audits:

Below Average (Section 6).

The licensee had

established and implemented a QA audit program.

The conduct of a separate

schedule of audits by the SARC was perceived as a strength in the

licensee's program.

Several significant weaknesses in the QA program were

identified, including failure to update the QA Manual, the absence of a

full time QA Manager during the past four years, and the lack of an

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Appendix A

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effective policy statement from the General Manager endorsing the QA Program.

A number of CQE activities were not included in the audit prograre, some

auditors had audited activities for which they had responsibility, and some

audit findings were not documented in the prescribed manner to provide formal

response and followup.

Weaknesses were also observed in the certification

of audit personnel and in the periodic evaluation of audit program

effectiveness.

The degree of management commitment to the QA Program was also questioned

based upon apparently inadequate staffing of the QA Department and the

continued existence of previously identified weaknesses in the program.

Corrective Action System:

Average (Section 7).

The licensee had estab-

lished corrective action systems which were effective in tracking the

ccmpletion of corrective actions and commitments.

Weaknesses were

identified in implementation of the Operating Incident report system, in

the trending of plant parcmeters and .ctivities, and in the awareness of

senior management regarding quality activities.

The nature and extent of

review given at the Production Operations Division level to plaret

activities and corrective actions represented a strength in the

licensee's program.

Training:

(Section 8)

a.

Non-Licensed:

Below Average

The lack of centralized management of training within OPPD caused a

number of significant weaknesses.

Training and retraining in quality

assurance program requirements was limited.

Preplanned, organized

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initial training for non-licensed personnel had been conducted within

some elements of OPPD, but not in others.

There was a widespread

lack of systematic retrainirig for non-licensed personnel.

A

long-standing problem with an understaffed Training Department at the

Fort Calhoun Station had

tributed to a number of problems with

implementation and documentation of training program requirements.

OPPD's plans to strengthen the Training Department staff should

result in enhanced program implementatior and in the development of

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needed program improvements.

Strengths in the program included

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incentives to encourage the pursuit of advanced degrees and a

computerized tracking system to monitor training activities at the

Fort Calhoun Station,

b.

Licensed Training:

Average

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Fort Calhoun maintained a six shift rotation for operators with one

of these shifts devoted full time to training.

This availability of

a full-time training shift was considered a strength.

%e lack of

sufficient Training Department staffing contributed to problems with

training documentation and with the late administration of annual

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requalification examinations.

The Operations Department had

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Appendix A

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experienced relatively little turnover, but there was no formal

program to involve the Shift Supervisor in managing and monitoring

the qualification progress of junior personnel on shift.

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