ML20065Q699

Responds to NRC Re Violations Noted in Insp Rept 50-285/90-29.Corrective Actions:Position of Eop/Abnormal Operating Procedure Coordinator Created & Configuration Mgt Program Put in Place

ML20065Q699
Person / Time
Site:	Fort Calhoun
Issue date:	12/14/1990
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-90-0916, LIC-90-916, NUDOCS 9012180035
Download: ML20065Q699 (6)

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Omaha Public Power District 444 South 16tn Street Mall Omaha, Nebra',Ka 68102-2247 December 14, 1990 LIC-90-0916 402.'636-2000 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C. 20555

Reference:

(1) Docket No. 50-285 (2) Letter from NRC (S. J. Collins) to OPPD (W. G. Gates) dated October 31, 1990 Gentlemen:

SUBJECT:

Reply to Notice of Violation (Inspection Report 50-285/90-29)

Omaha Public Power District (OPPD) received the subject inspection report which identified one violation involving the failure to establish and maintain appropriate Emergency Operating Procedures and Abnormal Operating Procedures (EOPs and AOPs). OPPD is committed to improving the EOPs and AOPs, while remaining confident that the operators are capable of utilizing the currently approved procedures to perform the actions required to maintain the plant in a safe condition during a transient. This was demonstrated by the operator's ability to handle the recent loss of instrument air transient in November which involved entry into EOP-20. Please find attached OPPD's response to the Notice of Violation in accordance with 10 CFR Part 2.201.

In addition to the violation, several other weaknesses in the FOP program were identified. Our commitments as summarized in paragraphs 2.4 and 2.5 of the subject report are correct. Tnose deficiencies identified as safety significant were corrected immediately during the inspection.

OPPD's Quality Assurance (QA) Department conducted a scheduled audit of the EOP program in August of 1990. QA was assisted by an individual with experience in both evaluating adequacy of EOP programs at other utilities and actual implementation of EOPs.

Guidance of NUREG-0899 was used as a basis for the audit. QA found problems similar to those identified in the subject report but many corrective actions were not able to be implemented since the inspection was performed within a month of the QA audit. QA's t l

l schedule for the audit was based on the arrival of OPPD's plant  !

specific simulator (April 1990) so that the EOPs could be 45-5124 Empoyment w'th Egel Onxrtumty l

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U. S. Nuclear Regulatory-Commission-LIC-90-0916 Page 2 evaluated against.the Tort Calhoun simulator prior to-the audit.

This evaluation alPo identified problems similar to those identified in the itspection report.

Many of the concerns identified during the NRC inspection involved discrepancies with plant labels. OPPD's label upgrade program is scheduled for completion in December 1990. OPPD had assessed the discrepancies between the plant labels and EOPs/AOPs. It was determined that any rfains provided by continuous updates to these procedures to match labels were. offset by potential insertion of errors into the EO9s/AOPs and greater. confusion - due to multiple updates and were r.ot cost effective. Therefore, to prevent-the EOPs and AOPs fror. being in a constant state of change, a decision-was made to comp)ete the labeling program and then update the EOPs and AOPs to reflect the revised labels. 1 i

During the inspection, a concern was raised as to-entry into EOPs from off-power conditions. The guidance for entry into EOPs has been established by memo. This directs entry into EOP-00 for various plant conditions when- the plant is not critical nor on shutdown cooling. It will be formally incorporated into Standing Order 0-1 " Conduct of Operations" by January 31,-1991.

Another concern raised during the NRC inspection was execution of the EOPs with minimum staffing levels in the control room. It'is OPPD's understanding that the minimum staffing crew of licensed '

operators were able to maintain effective __ control- of safety functions but had difficulty in diagnosing the occurrence of complicating events. OPPD had been unable to provide training with minimum stafting in the control room due to the delivery of the

-simulator. Only two licensed _ operator requalification cycles had been conducted prior to the subject _ inspection. OPPD will evaluate the number of licensed operators _ normally in the control room (Fort Calhoun infrequently has less than three (3) licensed operators in-the control room at any given time) and the time required for a licensed operator to return to the control room from within the protected area. Based on this evaluation, OPPD will determine a statistically valid control room crew size and composition and the

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time required for a licensed operator to return to the control room, and will provide training using this crew configuration in 1931. The results of the operator response time study will be-incorporated into the simulator' training during the'1991 training cycle.

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U. S. Nuclear Regulatory Commission-LIC-90-0916 Page 3 As discussed in our response to the violation, responsibility and-ownership for the EOPs and AOPs was diffused.- Because-of this l diffusion of responsibility,'no focal point existed for management oversight of the EOP/AOP development process. To assure adequate oversight of'and support of the EOP/AOP rewrite program discussed in the violation response, a committee composed of the Manager:

Training, Manager: Nuclear Licensing &. Industry- Affairs, and-Manager: Nuclear Safety Review Group has been formed to assist the Manager: Fort Calhoun Station ~in overseeing this program, i

A two week extension for this response was approved on November '19, 1990 by J. Gagliardo.

If you should have any questions, please contact me.-

S.i ncerely ,

AV. 5 W. G. Gates 1 Division Manager Nuclear Operations WGG/jb Attachments c: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrat.or, Region IV W. C. Walker, NRC Project Manager R. P. Mullikin, NRC Senicr Residenu Inspector.

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l l ATTACHMENT A REPLY TO A N0TICE OF VIOLATION During an NRC inspection conducted from August 20 through 31, 1990, a violation of NRC requirements was- identified. The violation involved the failure to establish and maintain plant procedures.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement," 10 CFR Part 2, Appendix C (1990) (Enforcement Policy), the violation is listed below:

Failure to Establish and Maintain Appropriate Plant Procedures Technical Specification 6.8.1 requires that, " written procedures be established, implemented, and maintained," for the activities described in Appendix A to Regulatory Guide 1.33, November 1972.

Procedures for combating emergencies and abnormal occurrences are included in this requirement.

By order, dated December 17, 1982, Item I.C.1 of NUREG-0737 and Supplement to NUREG-0737 regarding post-TMI action items were made requirements; these included the upgrade of emergency and abnormal operating procedures (EOPs and AOPs). The details of these requirements for upgrade of EOPs and AOPs were described in NUREG-0899 and included a verification and validation process to demonstrate procedural effectiveness.

Contrary to the above, the licensee failed to establish en adequate procedure to control development of the emergency operating procedures. Specifically, the licensee's verification and validation program was inadequate to ensure that the emergency operating procedures were correctly maintained. The failure to establish and maintain adequate EOPs and AOPs was illustrated by the following examples:

a. Validation and verification of EOPs and AOPs did not include adequate walkdowns outside the control room; therefore, multiple errors in nomenclature, direction, and labeling were not identified, thus leaving the procedures in an erroneous state,

b. The EOPs and AOPs contained examples of multiple use of "AND" and "OR" in the same statement, thus providing the potential for confusion in the execution of these procedures,

c. When changes affecting the EOPs or AOPs were made to other procedures, the changes were not always adequately reflected in the EOPs or AOPs, thus resulting in errors and inconsistencies among the procedures.

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d. The EOPs and.AOPs were not effectively verified against OPPD's writer's guide,:as delineated.in=NUREG 0899,..thus

,- resulting in numerous discrepancies and inconsistencies-in the procedures.

This is a Severity Level IV violation-(285/9020-01)(Supplement 1)  !

1. Reason for the Violation OPPD-admits that we failed to establish an adequate procedure to control the development of the EOPs and AOPs as -~ stated . in the violation. The verification and validation- (V&V): process was developed without fully utilizing existing-industry expertise which resulted ' in- failing to- provide detailed guidance to personnel-performing the V&V functions. The weaknesses in the V&v process included:

(1) the- failure. to perform complete walkdowns of the procedure which included actions outside the control room, (2) the resolution of validation comments or concerns by the same individual who originated the comment, and, (3) lack of a multidiscipline review, including human factor aspects of the revisions.

Additionally, OPPD did not assign ownership and responsibility for the EOP maintenance process to a specific individci or group. The-EOPs were assigned as additional duties to several individuals.

Although the EOPs/AOPs were initially issued-in 1986,-the writer's guide used' in the . maintenance of EOPs was developed without-applying Human Factor experience and was not'a controlled plant document until December 12, 1989. This may have resulted in changes . to the EOPs/AOPs which- were not in conformance to the written guide. These errors were not corrected during the rewrite process because an adequate -V&V was not' rigorously - performed against the writer's guide criteria.

2. Corrective Steps Which Hnve Been-Taken and Results Achieved

a. The position of EOP/AOP Coordinator was created, formally L approved and placed under-the direct supervision of the:

l Operations Supervisor. This placed ownership of the EOPs

and' AOPS - with one individual. who .has full-time i responsibility for.these procedures.

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b. A configuration management program'has been put in place to identify changes in hardware and procedures _which -

af fect EOPs and AOPs. This program allows a text. search' <

i of EOPs and AOPs to. identify other' areas of-procedures l where a change may apply. . This program will be expanded as outlined in tho' rewrite program below..

c. An EOP/AOP rewrite program has been initiated which' 'l includes an upgrade to the~ writers guide to includeEhuman-factors aspects of procedure ~ structure. The EOPs/AOPs '

will be rewritten to conform:to the writer's guide. The V&V process will be improved to include a multidiscipline review and_ complete _walkdowns of the procedures -as l appropriate. The results .of the V&V will be incorporated into the AOPs and.EOPs.- The rewrite program is_ outlined as follows:

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1. Appoint EOP. Coordinator under Operations

2. Upgrade / Control' Technical Basis Documents ,

3. _ Upgrade EOP Writer's' Guide.

4.. Upgrade V&V Process

5. Expand Configuration Management Program to Include other. Operating. Procedures

6. Conduct Human Factors Training Including Rewritten Writer's Guide Enhancements -

7. Rewrite EOPs/AOPs to Conform.with Writer's -

Guide, PGP and.to: Correct. Previous QA Audit / HRC Inspection' Findings

3. Corrective Steps Which Will- be Taken _to'- Avoid Further._

Violations completion of-corrective actions as outlined in the plan above will-

. avoid further violations. In addition to its'normally scheduled EOP audits, Quality Assurance will-conduct. periodic surveillances of the EOP rewrite program to ensure program-objectives are)being-met.

4. The Date When Full Compliance.Will Be-. Achieved-

- The EOPs and-AOPs, as. currently written, are adequate to mitigate-the consequences of an accident 1or transient although weaknesses

. exist and1 enhancements-~are being made. The expected completion date-for rewriting, verifying,_ validating, training.on and. issuing.

the EOPs and AOPs to the new writer's guide' criteria is June-30,_

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