ML20134M267

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Responds to NRC Re Violations Noted in Insp Rept 50-285/85-11.Corrective Actions:Investigations Conducted to Determine Locations of Six Missing Surveillance Tests. Four Tests Located
ML20134M267
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 07/26/1985
From: Andrews R
OMAHA PUBLIC POWER DISTRICT
To: Hunter D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20134M266 List:
References
LIC-85-350, NUDOCS 8509040051
Download: ML20134M267 (3)


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Omaha Pubilr. Power District 1623 Harney Omaha. Nebraska 68102 402/536 4000 July 26,1985 ' $ $ & Q\\!/ 2 L IC-85-350 '

JA. 2 919E L '

. a:J Mr. Dorwin R. Hunter, Chief L Reactor Project Branch #2 U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000

  • Arlington, TX 76011

Reference:

Docket No. 50-285

Dear Mr. Hunter:

IE Inspection Report 85-11 Notice of Violation The Omaha Public Power District received the stbject inspection report dated June 26,1985. This report forwarded a notice of violation for " Failure to Follow Procedures." Pursuant to 10 CFR 2.201, please find attached the Dis-trict's response to this violation.

Sincerely, Aw R. L. Andrews Division Manager Nuclear Production RLA/DJM/rh Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, DC 20036 l

Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Inspector 8509040051 e50828

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ATTACHMENT i

Based on the results of an NRC inspection conducted during the period of May

1-31, 1985, and in accordance with the NRC Enforcenent Policy (10 CFR Part 2, 1 Appendix C), 49 FR 8583, dated March 8,1984, the following violation was j identified:

I Failure to Follow Procedures Technical Specification 5.8.1 requires that " written procedures . . . be estab-lished, implemented, and maintained that meet or exceed the minimum require-ments of Sections 5.1 and 5.3 of ANSI 18.7-1972, and Appendix A of USNRC Regu-latory Guide 1.33 . . . ."

i Standing' Order G-23, " Surveillance Test Program," has been established in i

accordance with Technical Specification 5.8.1.

Section 6.5 of Standing Order G-23 requires that controls be established "to ensure that completed surveillance tests are accounted for in the files."

! Contrary to the above, six surveillance tests perfomed during the refueling outage ending in July 1984, could not be accounted for in the files.

This is a Severity Level V violation (Supplement 1.E) (285/8511-01).

l

Response

(1) The corrective steps which have been taken and the results achieved.
  • An immediate investigation was conducted to determine locations of the

, missing six surveillance tests. Four of the missing six surveillance

tests were located, found to be adequately completed / reviewed, and re-filed in accordance with Standing Order G-23. For those two surveil-lance tests which were not located, steps were taken to ensure the tests

! were indeed performed by referencing documentation of results and/or en-tries in other procedures and the Control Room Log. In addition, Opera-tions Incident Report 2101 was initiated to ensure these missing surveil-lance tests provided no safety impact on the Fort Calhoun Station and to

, ensure continuity of documentation as far as the missing surveillance i test files were concerned. These actions have been completed.-

(2) Corrective steps which will be taken to avoid further violations

i i The following actions will aid in ensuring accountability of surveil-

!' lance tests during review and to ensure timely and prampt corrective actions will be implemented should surveillance tests be " unaccounted for" or became lost.

Each month the surveillance test clerk will issue a list of ST's that l are due but not filed and those due but not completed. Each supervisor

! will be required to respond to this list by indicating the status of each test. This status list will then be compiled and presented to the

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Plant Review Committee (PRC) by the Supervisor-Technical indicating those tests not completed /not filed and the action taken to assure com- i pletion/ filing by the end of the next monthly review period. This prac- .

tice will provide immediate accountability of each test and assurance I that action is taken, to document performance of a lost test, in a time-ly manner. This action is presently being implemented.

To aid. in ensuring refueling surveillance tests are filed correctly, a letter will be issued with the refueling surveillance test schedule.

This letter will stress the importance of filing all outage surveillance tests, performed or not, with appropriate wording in the remarks section to indicate how the requirenents for perfonnance of the test were satis-fied.

In addition, a review of a list of "not filed" tests will be conducted in order to account for these tests. If located, documentation of their completion and review will be filed for future reference. If a test cannot be located, an Operations Incident Report will be initiated to ensure the missing test has no safety impact on Fort Calhoun Station.

(3) The date when full compliance will be achieved:

OPPD believes the aforementioned actions, when fully implemented, will ensure that no further violations relating to missing surveillance tests will occur. All actions committed to above either have already been implemented or will be implemented by September 30, 1985.

., . . , .