ML20079L504
| ML20079L504 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/30/1982 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20079L508 | List: |
| References | |
| LIC-82-142, NUDOCS 8302230349 | |
| Download: ML20079L504 (7) | |
Text
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o Omaha Public Power District 1623 HARNEY a OMAHA. NEBRASMA 68102 s TELEPHONE 536-4000 ARE A CODE 402 December 30, 1982 LIC-82-412 Mr. W. C. Seidle, Chief I
'P) l Reactor Project Branch 2 U. S. Nuclear Regulatory Commission
!O M i 0 l983 Region IV
\\\\r oh 611 Ryan Plaza Drive, Suite 1000 L Ol i
Arlington, Texas 76011
Reference:
Docket No. 50-285
Dear Mr. Seidle:
Systematic Assessment of Licensee Performance (SALP)
Omaha Public Power District management met with Region IV manage-ment on December 9, 1982 to review the results of the SALP program as detailed in Inspection Report 50-285/82-31 dated December 2, 1982. The SALP review covered twelve (12) functional areas related to the Fort Calhoun Station operation and design.
Inspection Rept rt 82-31 details th: findings and performance ratings in each functional area. Addi-tionally, for each functional area, the SALP team has provided recom-mendations for upgrad'ng District performance in each area.
Attached is the District's response to each recommendation.
The District has also attempted to address specific weaknesses detailed in the report or discussed during the December 9,1982 meeting.
Sincerely,
)
'h&
W. C. Jones Division 41anager Production Operations WCJ/TLP:jmm Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 r302230349 830127 PDR ADOCK 05000285 O
Attachment OMAHA PUBLIC POWER DISTRICT RESPONSE TO SALP FINDINGS AND RECOMf1ENDATIONS (BY FUNCTIONAL AREA)
A.
PLANT OPERATIONS Recommendation The licensee should continue its efforts to license additional personnel to meet minimum shift manning requirements of NUREG-0737 (Item I. A.1.2) and expand the training department staff to meet increased training requirements.
Licensee management should con-tinue its active involvement in the Fort Calhoun Station operation.
Response
The District's management will continue to maintain an active involvement in all facets of Fort Calhoun Station (FCS) operations.
Special emphasis will continue to be provided towards upgrading of shift and training staffing.
B.
RADIOLOGICAL CONTROLS Recommendation Licensee should vigorously pursue the resolution of identified open items in a timely manner.
Efforts should continue to add personnel to provide additional radiological controls expertise.
The SALP team's first recomendation is supported by these find-ings:
(1) Appraisals have not been closed out in a timely manner, (2) the licensee has failed to establish an ALARA program that satisfies the recomendations of Regulatory Guide 8.8, (3) there are problems with the RWP program, and (4) there is no procedure to provide uniform guidance in the evaluation of contractor health physics personnel.
Response
The District believes that significant progress has been made by the District in resolving the above concerrs.
For example, of the remaining HP audit open items, the majority require plant modifi-cations, and in all cases the District has initiated the necessary corrective measures. The District has also made significant progress in providing a long tenn solution to the staffing problems in the radiation controls area as detailed in our letter dated December 30, 1982.
During 1982, a formal ALARA program was es-tablished, improvements in the RWP centrols procedures were imple-mented, and formal evaluation criteria for contract HP were es-tablished.
Continued management attention to timely resolution of open items is a District comritment.
r C.
MAINTENANCE Recommendation The board recommends that the licensee implement a tracking system for maintenance orders to provide meaningful status information, and that management continue to involve itself in the maintenance activities at the site.
Response
The District has recently received bids on the computerized Work Force Maintenance Management System (WFMMS).
This system will be capable of providing priority and completion status data and is expected to be a valuable tool in upgrading the tracking of mainte-nance orders for the FCS.
The WFMMS is expected to be operational for the FCS during 1983.
D.
SURVEILLANCE Recommendation The licensee should continue to exercise strong managtment control of the surveillance program.
Response
It has long been a District philosophy that cne of the key elements in assuring plant safety is availability of plant safety systems.
High safety system availability is assured through a responsible and active surveillance program. Thus, the District's management involvement in the surveillance program will continue.
E.
FIRE PROTECTION Recommendation The licensee should assure that a vigorous training and drill schedule is conducted in fire protection and that the results are monitored by management to assure maximum effectiveness.
General employee training should cover the subject of fire barriers (temporary and permanent) and their importance to plant safety.
The role of the shift supervisor as the leader of the fire brigade is a matter of intere:t to the NRC and needs to be resolved in a timely manner.
Response
The District increased its fire brigade drill requirements to one drill for each shift per quarter, as of July 1,1982. General employee training presently covers the subject of fire barriers and th'eir importance to safety is emphasized.
The District will also continue to provide increased emphasis on fire brigade training in the future.
. =
l.
e 3-The District is re-evaluating the role of the shift supervisor as the fire brigade leader and concurs with the Commission's ccteern.
4 A reactor operator or qualified equipment operator is being con-4 sidered as the possible fire brigade team leader. This concern f ould be resolved sometime in the near future.
F.
EMERGENCY PREPAREDNESS Reconinendation The licensee should develop and test a plan for occupying and
-effectively utilizing the TSC during an emergency.
The board recommends strong management involvement in the activation of the new TSC-and Emergency Offsite Facility, and the resolution of those deficiencies identified during the emergency preparedness appraisal, l
the Emercency Plan evaluation, and the annual emergency exercise.
Response
The District will continue to aggressively pursue corrective actions of any weaknesses identified in emergency preparedness procrams.
During the. September,1982 emergency exercise, both the District and the region's inspection team identified weaknesses in the i
utilization of the TSC. The District has implemented an. improved trainiag and evaluation program to resolve this concern. Manage-ment attention has been directed to this effort, as well.as the -
planning and implementation of the new E0F.
One -issue discussed during the SALP management meeting was related-to the District's use of Nebraska Public Power District for the backup analysis capability for RCS samples.
A concern was ex-l
- pressed that the Cooper Nuclear Station (CNS) analytical capabilities- [.
may not be adequate for FCS reactor coolant' activities. The Dis-trict has initiated dialogue with CNS on this ~ issue and it appears that there is a good match on analytical capabilities. The Dis-trict'is continuing to pursue this issue to ensure that there is sample size compatibility and that CNS can bandle pressurized samples.
G.
SECURITY AND SAFEGUARDS Pecemmendation It is recommended that the licensee review the current Physical Security Plan (PSP) and make revisions in accordance with changing regulations, per 10 CFR 50.54(p).
Current physical security pro-j cedures also need to be reviewed and adjusted to be in accordance i
with the approved PSP.
Both tasks are expected to be time-consuming and.an assistant to the Supervisor - Administrative Services would strengthen the Fort Calhoun Station security program.
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Response
The District's letter dated September 24, 1982 forwarded the latest revision to the FCS site security plan. This revision was made pursuant to 10 CFR 50.54(p) and incorporates suggestions of recent regional inspectors to upgrade and clarify the plan. The PSP and contingency plans receive an annual review to ensure compliance with 10 CFR 50.34(c), 10 CFR 50.5d(p) and 10 CFR 73. The FCS security procedures are presently under review to ensure compliance l
with the PSP, and all future changes to the PSP will be reflected in procedures.
The District recognizes the heavy burden carried by the Supervisor -
Administrative Services and Security and is presently evaluating what measures can be taken to relieve this burden. A qualified security assistant to the Supervisor - Administrative Services and Security is being considered.
Another area related to site security that was discussed during the r.ecember 9,1982 meeting concerned the scope and completeness of ty event reports submitted by the District. The District ensure that sufficient detail is provided on any future security event reports.
H.
REFUELINC Recomrendation Licensee management is encouraged tc continue its involvement in the planning of refueling outages, the observation of refueling activities, and assuring adherence to procedures.
Response
Management participation in all facets of the refueling process willscontinue to be a District process. District management is intimately involved in the refueling from initial planning through the day-to-day refueling activities and this level of involvement will continue.
I.
LICENSING A.CTIVITIES Recommendation The licensee should continue to remain extensively involved in licensing actions and maintain a responsive attitude toward licensing i s st,es.
In terms of licensing philosophy, it is reconrended that the licensee base future comitments more upon high standards for safety in lieu of ensuring that every requirement and position be based specifically en regulations which are not as prescriptive as OPPD would desire.
Response
The District plans to remain extensively involved in licensing actions and maintain a responsive attitude toward licensing issues.
The District's licensing philosophy has always been one of re-quiring compliance with regulatory requirements and maintaining high standards of safety.
Ncn-regulatory safety issues are care-fully evaluated and, when these evaluations indicate additional actions are appropriate, such actions are implemented.
These evaluations consider, inter alia, the basis for implementing additional actions. The District resists implementing additional actions in those cases where an inadequate basis exists for such actions and where there is a reasonably high probability of ad-versely impacting on the reliability, availability, and operating cost of the station.
During the SALP meeting on December 9,1982, concern was expressed regarding the generic issue of containment building hydrogen control and handling system. The District has recently installed a containment hydrogen monitoring system and upgraded the hydrogen purge system, as required by NUREG-0737.
These modifications comply with the appropriate provisions of 10 CFR 50.44.
In addi-tion, the District plans to evaluate the modifications required and resulting benefits in order to achieve capability for using a hydrogen recombiner so that a decision can be made on this issue.
J.
QUALITY ASSURANCE Recommendation OPPD management should become very involved with this functional area with particular attention given to continuing the upgrading of the QA organization and to completing the QA manual revision to define the new program. OPPD should proceed with microfilming of records in accordance with the revised schedule and implement the new Records Management System.
Response
The District is making steady progress in the development of a revised QA Manual which provides an improved definition of functional area responsibilities and requirements, thereby clarifying and i
emphasizing the need for, and the extent of, management involvement and management control in Quality Assurance activities. The QA Department organization has been tipgraded to include five addi-tional members and the QA Department's staffing and organizational needs are under continuous review by the newly appointed Manager -
Quality Assurance.
In addition to ongoing QA Program and QA organizational revisions, the District has established an aggressive program for the microfilming of QA records and for the establish-ment of a permanent Records Management System.
This effort is i
presently in progress and over 300,000 records have been micro-filmed and coded to date.
K.
DESIGt: CONTROL Recommendation The licensee should continue to maintain close management control of the update team effort in terms of providing adequate staffing i
and technical expertise to ensure scheduled completion of that effort.
Response _
The District's letter to your office dated November 19, 1982 provides a sumary of the cpdate team's progress and the schedule for completing this effort. The commitment of manpower and re-sources to this effort demonstrates the District's concern in resolving this problem.
L.
MANAGEi1ENT CONTROLS Recomendation The board recomrends that the licensee establish stronger manage-ment controls in the area of Quality Assurance and continue to emphasize management involvement in the remaining areas.
Response
The District believes that the steps currently being taken in revising the QA Program and the establishment of new QA Manual will, in itself, strengthen management controls in the Quality Assurance area, and will provide an improved framework from which District management at all levels can increase its involvement in, and contrcl of, Quality Assurance activities.
_,