ML20087P645
| ML20087P645 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/10/1984 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| LIC-84-011, LIC-84-11, NUDOCS 8404090238 | |
| Download: ML20087P645 (11) | |
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Omaha Public Power District MY/E N ~S 1623 Harney Omaha. Nebraska 68102 402/536-4000 January 10, 1984 LIC-84-011
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l Mr. J. E. Gagliardo, Acting Chief L
Reactor Project Branch 2 U. S. Nuclear Regulatory Commission ji qg Region IV j
611 Ryan Plaza Drive, Suite 1000 b--
Arlington, Texas 76011
Reference:
Docket No. 50-285
Dear Mr. Gagliardo:
Subject:
Systematic Assessment of Licensee Performance (SALP)
Omaha Public Power District management met with the SALP Board on December 20, 1983 to review the results of the SALP program as detailed in Inspection Report 50-285/83-28 dated December 14, 1983. The SALP review covered 16 functional areas related to the Fort Calhoun Station operation and design.
Inspection Report 83-28 details the findings and performance ratings of each functional area. Additionally, for each functional area, the SALP team has provided recommendations for up-grading District performance in each area. Enclosed is the District's response to each recommendation. The enclosure also addresses specific weaknesses detailed in the report or discussed during the December 20, 1983 meeting.
Si ncerely, bW W. C. Jo es Division Manager Production Operations WCJ/JJF/lp Enclosure cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 8404090230 840110 DR ADOCK 05000285
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Attachment OMAHA _PUBLIC-POWER DISTRICT'S RESPONSE TO SALP FINDINGS AND RECOMMENDATIONS (BY. FUNCTIONAL AREA)
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1 PLANT OPERATIONS Recommendation Licensee management should continue its active involvement in the Port Calhoun-Station operation.
Efforts should be continued to license additional plant supervisors not pre-sently holding an' SRO license on the plant.
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Response
The District's management intends to continue its active in-
-volvement-in. Fort Calhoun. Station operations and plans to
. continue-its practice of licensing additional plant staff supervisors.
.B.
RADIOLOGICAL CONTROLS 1(
-Radiation Protection
-Recommendation Attention should continue to ensure that NRC-identified ini-tiatives'are closed-in a timely manner.
Management a t-tention is needed to' ensure that a comprehensive ALARA pro-
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-gram 11s implemented.
Response
The District is actively pursuing closing out all open items as discussed in the July, 1983 meeting at Region IV head-quarters.
The present status of open items indicates that 22 are closed,: out of a total of.49, and the remaining items are' progressing satisfactorily.
The District is' presently studying ways to strengthen the management' structure of the chemistry / radiation protection organization, including establishment of ALARA Coordinator
.and Radvaste' Coordinator positions.
The ALARA program is presently being reviewed to improve its effectiveness.
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. B.
RADIOLOGICAL CONTROLS (Continued)
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Radwaste Systems, Effluent Treatment and Releases, and Effluent Monitoring Recommendation Attention should be given to the completion of existing open items.
Response
Included in B.l.,
Radiation Protection.
3.
Transportation / Solid Radwaste Recommendation Increased management oversight of transportation activities and the development of procedures are necessary to provide adequate guidance to ensure compliance with applicable regu-lations..Take necessary action to close the nine NRC con-cerns addressed as open items in NRC Inspection' Report 285/82-26.
Review the existing transportation and solid waste program to ensure that new regulations appearing in 10 CPR 71, 10 CFR 61, and 10 CPR 20.311 have been included in appropriate procedures.
Response
As_part of the reorganization of the Chemical & Radiation Protection Department, a Radwaste. Coordinator position will' be created.
In addition, the District has developed and implemented procedures to assure compliance with applicable radwaste transportation regulations.
The~ internal audit program has been strengthened in.this and other selected audit. areas through the addition of a techni-cal specialist-to the audit team conducting these audits.
The District believes these improvenents.will greatly strengthen the-effectiveness of.the internal audit program.
4.
Confirmatory' Measurements, Chemistry / Radiochemistry Recommendation Continued effort is necessary to. resolve the high number of disagreements associated with gaseous sample analyses.
Re-view of' existing calibration procedures and the gaseous sample system is necessary.
The licensee should consider obtaining the services of. contractor expertise to evaluate their present program.
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g RADIOLOGICAL CONTROLS (Continued) 4.
Confirmatory Measurements, Chemistry / Radiochemistry (Continued)
Response.
The Di' strict has had a contract chemist onsite working on analytical methods and a split sample program which has freed experienced chemistry workers to deal with the con-firmatory measurements open item, including calibration and
' representative sampling.
A recalibration of counting equip-ment has been performed and will be retested in February, 1984 on receipt: of fresh gaseous sources.
A consultant with the ability to perform onsite confirmatory measurements is being sought.
A technician training program was initiated in the fall of L1982.
Five trainees completed the academic portion of the 3-year program-in the_ fall of 1983.
Four trainees were as-signed to chemistry / radiochemistry and one to health physics to gain the 2-year technician experience required by ANSI N18.1-1971.
Each has completed shift technician qualifi-cations in the applicable area and is currently working on shift.with a fully qualified individual.
Full qualification for the 5 trainees will be achieved by the fall of 1985.
5.
Environmental Surveillance Recommendation Initiate action to close identified open items.
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Response
Base'd on the results of NRC Inspection Report 83-27, these items-have been closed.
The internal audit program has been strengthened in this and other selected audit areas through the addition of a techni-i-
cal specialist to the audit team conducting these audits.
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The-District believes these improvements will greatly strengthen the effectiveness of the internal audit program.
C.
MAINTENANCE Recommendation The board recommends that the licensee continue to focus management attention on the update team and the timely completion of this work.
Implementation of the maintenance order tracking-system should continue.
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C.
'KAINTENANCE (Continued)
Response
Management is currently' involved in reviewing the progress of the drawing. update team.
The November 19, 1982 commit-ment to the NRC in the area of drawing update was to update by December 31, 1983 safe ty related, fire protection, an'd radwaste DCR and MR design packages completed prior to January 1, 1981.
This commitment has been met.
Currently, 23 non-safety related packages are all that remain to be reviewed to complete the modification package portion of the drawing update. task.
In addition, the drawing update team will continue to review maintenance orders and will complete this portion of the task by the committed completion date which is 2 months after the end of the 1984 refueling outage (approximately July 1, 1984).
With'regar'd to testing'of older design changes that are pre-sented to the plant staff for close-out, the System Ac-ceptance Committee includes in their review of the system the identification of whether the modification has performed satisfactorily in service or whether additional testing is warranted.
The District is actively pursuing-the full implementation of a computerized history and maintenance order tracking system.
Significant progress has already been made on development of this system and is expected to be completed
.within the next SALP period.
D.
SURVEILLANCE Recommendation
.The board recommends that the-licensee continue to exercise strong management control of the surveillance program.
Response
Present efforts in this area will ensure continued strong-management control of the surveillance program.
E.
FIRE PROTECTION Recommendation The licensee management should ensure that fire protection
. measures required by Appendix R are fully implemented or that the appropriate exemptions be obtained for those areas acceptable to the NRC.
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. E. w -FIRE PROTECTION (Continued)
Response
The District has-filed for exemption which will close out all Appendix R items.
Upon resolution of the requested exemptions, the District believes it will be in full com-pliance with Appendix R.
F.
EMERGENCY PREPAREDNESS Recommendation The' licensee should complete a thorough generic training program evaluation with careful review by management.
Emphasis should be placed on improving the efficacy of practical factors training.
An offsite post accident sampling analysis procedure, meeting the 3-hour limit, should be fully implemented.
The licensee should complete the evaluation of the TSC op9 ration and management and should demonstrate the proper implementation of needed corrective measures during the 1983 emergency preparedness exercise.
Response
During this SALP period, the District has spent a signifi-cant amount of time training personnel in their emergency assignments.
Part of this training included a study done on practical factors performance of ' employees to ensure the Dis-trict that not only did personnel receive training but that they could perform.all functions in a proficient manner.
This study was completed and the improved performance of
-individuals was-reflected in'our recent emergency exercise in December 1983.
.The District is actively pursuing the completion of our PASS.'
Mechanical portions of the system, with the exception
.of the ion chromatograph, have been installed and the re-solution of the problems with the analytical equipment is underway..
The operation and management of the TSC was reviewed and administrative measures adopted to provide better interface with the OSC.
The effectiveness of the changes made were demonstrated during the successful 1983 emergency exercise.
During the SALP period,-the District also completed con-struction of a new EOF and officially began operation of this facility on February 1, 1983.
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,4M,ERGENCY PREPAREDNESS.- (Continued)
~ Response (Continued)~
- The District has devoted {much' effort to provide offsite emer-
, gency analytical capability.
The CNS radiochemistry labor-
.atory'is being tested as a back-up to the Port Calhoun Station radiochemistry laboratory.
G..
SECURITYJAND SAFEGUARDS-
-Recommendation
- The, licensee's quality' assurance department should give in-creased attention to-the federal regulations applicable to security. -Quality assurance attention should be more
- thorough, complete, 'and ef fective in uncovering weaknesses in_-the security system, procedures, and practices to ensure that a.high' level of performance is achieved.
Response
.The newly established Captain position, created to assist in the: overalli coordination of the sec.urity force, has shown
-favorable results.- The District expects to continue with-its present. efforts to improve performance of the security t
force and related groups.
Upgraded training has been 1successfullyfcompleted this fall for.the security' guards.
.The-QualityfAssurance Department-has thoroughly researched
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the. Federal. Regulations applicable to security and has re-
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vised and-strengthened the audit' checklist in this area.
In Laddition, a technical specialist in the' security area has
^been addedMto.the audit team to enhance the department's
-ability,to become1more thorough, complete, and effective in
, uncovering weaknesses in thefsecurity system procedures and
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.pract' ices and t'o assure that a-high level of' performance is
' achieved.
.H.-
REFUELING-
-Recommendation
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Licensee management is encouraged'to continue its involve-ment in the planning 1of refueling outages, the observation 2
ofErefueling' activities, and the-: emphasis on adherence to iprocedures.
Response
The DistrictJplans to continue its efforts in maintaining a
-high' degree 7of-effect'iveness and management involvement'in the ; refueling operations ;ati the -Fort Calhoun Station.
. I.
L5 CENSING ACTIVITIES Recommendation OPPD should be more aggressive in resolving licensing issues that have been unresolved for a number of years.
This will entail more management and technical attention.
OPPD should improve the training of licensed oper'ators.
Response
The District intends to continue aggressively pursuing the resolution of the remaining unresolved licensing issues.
The resolution of 27 issues during the rating period re-quired extensive management involvement by the District and by the NRC dealing with many difficult and complex issues.
The remaining 39 unresolved licensing issues also involve matters which will require a significant effort by the NRC staff and the District.
Several of the 39 unresolved issues are scheduled for completion in accordance with information previously provided to the NRC.
The remaining issues are awaiting NRC review, approval, or guidance to licensees.
The District will continue to provide timely responses to NRC requests in order.to expedite the review and resolution of these issues.
Arriving _at a resolution of the RETS issue has consumed a considerable amount of personnel resources and the District is anxious to close out this issue in a manner consistent with the resolution of similar items in other areas.
The District intends to cor.tinue efforts to resolve this issue.
We are confident that thece efforts, coupled with extensive participation by the NRC staff, will result in a resolution which will ensure that-resources are indeed effectively utilized to assure safe and efficient operation of the Port Calhoun Station and thereby enhance the protection of the health and safety of the public.
'The improvement of the licensed operator training program has recently received considerable attention within the Dis-trict at the plant staff and management levels.
The Dis-trict's plans.for' assuring improvements in this area are discussed in Section J of this report.
J.
TRAINING
' Recommendation Licensee management should implement strong measures to reverse the trend that has been exhibited this evaluation period.
Of primary importance is the need to expand the training staf f in order to upgrade lesson outlines and
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. J.
%R.AINING (Continued)
Recommendation (Continued) material, to share the classroom / lecture responsibilities, and to provide more individualized attention to trainees with regard to screening, testing, and licensee examination preparation.
The poor examination success rate indicates the.need for-a more careful screening program for license candidates and the capability to evaluate each trainee's
' progress throughout.the process.
Response
The Omaha Public Power District recognizes the need to strengthen the Fort Calhoun Station training program and is
. committed to developing a strong training organization and programs.
This recognition has resulted in a comprehensive review of the existing training organization and the development of a plan to strengthen the existing organization.
The recently developed plan is designed to provide additional resources to the onsite training department and includes provisions to establish an.offsite training support group.
This plan is currently being reviewed by District management.
In the development of the revised training organization, the District considered the recommendations of the Institute of Nuclear Power Operations (INPO) in the areas of self-evalu-ations, job and task analyses, training program development, instructor qualification, and other steps ultimately leading to accreditation by INPO.
The District is presently com-pleting the self-evaluations for the initial training pro-grams for selected operator. positions.
Meetings are scheduled with INPO training peruonnel during the week of January 16, 1984 for a-training assistance visit andfto re-view the District's progress and plans for achieving INPO accreditation.
During the past few months, the District has also been in-volved in reviewing and following the development of NRC regulations related to the selection and training of nuclear
. power plant personnel.
These proposed regulations are being considered in the Distri'ct's current planning for improve-ments to training for nuclear plant personnel.
The efforts discussed above involve activities which-will ultimately result in significant improvements in the Port
'Calhoun Station training programs; however, these improve-ments will'not be achieved immediately.
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_9 J.
' TRAINING (Continued)
Response (Contint3d) some immediate' improvements in the training programs for licensed operators, the District has 2 personnel from a training consultant organization who are assisting the onsite training department.
The availability of these personnel has resulted in substantial improvemeats to the licensed operator training program.
K.
-QUALITY ASSURANCE Recommendation The licensee management should become more involved with the resolution of these long term problems, and with the imple-mentation of the upgraded QA program.
The microfilming of records needs to be completed, with particular attention being given to construction QA records.
Response
LThe Omaha Public -Power District has implemented practices which assure that several levels of management, including senior management, _ will-become more involved with the re-solution of Quality Assurance problems and with the imple-mentation of the upgraded QA plan.
Senior management is conducting monthly meetings with QA management personnel to review the status of: QA related activities.
Major changes in procedures and practices have been insti-tuted in many.QA department activities including document-ation of training and conduct of internal audits, which the
. District believes will greatly enhance the department's per-formance.
The internal audit program, in particular, has been strengthened through the addition of technical special-ists - to selected audit teams and through improved audit practices and auditor training.
These improvements have already been implemented in the radiological controls and security _ areas.
An improved system is currently in effect to provide prompt corrective action response (30 days) and l
completion including monthly deficiency status reports for tracking purposes, intensified followup activities by re-sponsible departments,'and monthly corrective action status meetings.with senior management.
The District believes
-these improvements will~cause prompt'and effective cor-rective action to occur.
LThe District believes that new and revised procedures were implemented in a carefully planned, controlled, and prudent
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- QUALITY ASSURANCE (Continued)
Response-(Continued) manner, _ allowing for necessary. personnel training and in-doctrination.
Some ' implementation problems attributable to the establishment of major procedural and staffing changes in the QA department'over a short period of time, including
- a 30 percent increase in QA department staffing over the past 2' years, have. occurred.
QA department and other Dis-trict management havs~been extensively and actively involved in the' correction of these> problems and in the establishment of strengthened pro 6edur,es'and practices.
The District be-lieves that the problems-addressed within the SALP report have been effectively correcte7.
- hNse QA p'ogram revisioti wa s, '
Phase 1 of the District's r
completed in November:lE83., This, phase included the es "
tablishment of the' Quality Assurance Department Manual and the cancellation of the " superseded,Qu'ality Assurande PrL-cedures.
Planned iinpro~v'ement's a'ad' increases in QA pr6 gram
' scope have-been include,d-in,and1 implemented by these new-QA
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department procedures and in revisions to.the procedures and practices of'other District departments responsible-for acti-vities_affecting safety.
Phase-2 of-the QA program revision includes preparation of'a new activities based QA plan,.re-
- placing the cu,rren t QA ma nual, which will reflect the7im-provements and' changes in the QA program already implemented in.thejDistrict's procedures.
This, phase has.been sub-stantially completed and the District expects to issue thef Enew_QA plan by September 1,,1984.
It should be noted tha t ^
District management at all levels has been, and will con-tinue to be, extensively. involved 13 the development and im-plementation of the new QA program documents.
L.
MANAGEMENT CONTROL
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Recommendation
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Licensee ~ management is urge'd to increase their involvement in the areas and situadfons described above.
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Response ~
The' responses'to the preceeding sections of this report confirm the District'sLintention,tn increase management's involvement'in~several areas.
The-District'~is committed to assuring that performance isJimproved in the Quality As-surance, training, and radiological protection areas through strong _ management involvement.-
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