ML20149F414
| ML20149F414 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/11/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8802170143 | |
| Download: ML20149F414 (2) | |
See also: IR 05000285/1987025
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FEB l i 1988
In Reply Refer To:
Docket: 50-285/87-25
Omaha Public Power District
ATTN:
R. L. Andrews, Division Manager-
Nuclear Production
1623 Harney Street
Omaha, Nebraska 68102
Gentlemen:
Thank you for your letter of January 11, 1988, in response to our
letter and Notice of Violation dated December 4,1987. We have reviewed your
reply and find it responsive to the concerns raised in our Notice of
Violation. We will review the implementation of your corrective actions
during a future inspection to determine that full compliance has been
achieved and will be maintained.
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Sincerely,
Original Pe.ned By
A 3. li.u h
L. J. Callan, Director
Division of Reactor Projects
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W. G. Gates, Manager
Fort Calhoun Station
P. O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NW
Washington, DC 20036
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Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
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January 11, 1988
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U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
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Washington, DC 20555
References:
1.
Docket No. 50-285
2.
Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated
December 4, 1987.
Gentlemen:
SUBJECT:
Reply to a Notice of Violation - Inspection Report 50-285/87-25
The subject inspection report identified one violation involving the failure to
properly correct deficiencies involving the ability of fire doors to function
as designed.
Pursuant to the provisions of 10 CFR Part 2.201, please find
attached the Omaha Public Power District's response to this violation.
A one
week extension to the submittal date was discussed with Mr. T. Westerman of
Region IV and Mr. J. Fisicaro of my staff.
If you have any questions, please
contact us.
Sincerely,
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R. L. Andrews
Division Manager
Nuclear Production
RLA/me
cc: LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Ave., N.W.
Washington, DC 20036
R. D. Martin, NRC Regional Administrator
A. Bournia, NRC Project Manager
P. H. Harrell, NRC Senior Resident Inspector
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ATTACHMENT
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Response to Notice of Violation 285/8725-01
During an NRC inspection conducted on October 1 through October 31, 1987, a
violation of NRC requirements was identified. The violation involved the
failure of licensee management to implement a corrective action program for
correction of deficiencies related to nonfunctional fire doors.
In accordance
with the "General Statement of Policy and Procedure for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below.
Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, thn
measures shall be established to assure that conditions adverse to quality,
such as deficiencies, are promptly corrected.
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Paragraph 4.1.1 of Section 10.4 of the licensee's Quality Assurance Plan
states, in part, that conditions adverse to quality, such as deficiencies,
shall be corrected as soon as practicable.
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Contrary to the above, the NRC inspector identified 12 deficiencies
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involving seven fire doors that did not properly latch, thus making the
Technical Specification fire barrier non-functional, during inspections
performed from March 1 througl October 31, 1987.
Licensee management
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failed to properly correct deficiencies identified with fire doors in that
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the deficiencies continued to occur over an 8-month period of time and
resulted in the identification of an additional deficiency with Fire Door
989-9 on October 20, 1987.
This is a Severity level IV violation.
(Supplement I) (285/8725-01)
OpPD'S RESPONSE
THE REASON FOR THE VIOLATION IF ADMITTED
The violation is admitted as stated.
ELSCUSSION
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A review of the existing maintenance and surveillance records for the period in
question was conducted, and it was noted that the deficiencies discovered
during the monthly surveillance test ST-FP-1 were repaired as required.
The
deficiencies identified by the NRC inspector were investigated, and maintenance
orders were written if appropriate.
In some instances, the deficiency reported
by the NRC Inspector was not "repeatable", (i.e., maintenance craftspeople
investigating the concern often could not make the door repeat the condition
cited by the NRC inspector.)
If incorrect operation of the door was found, the
door was repaired.
It was found that certain door designs are more prone to failure from misalign-
ment than others.
It was believed that the best way to prevent these recur-
rences and to provide a long term solution was to initiate a door replacement
program, standardize door hardware to minimize delays associated with spare
parts inventory and the lead time associated with parts procurement, and
dedicato personnel to perform a preventative inspection and maintenance
program.
It was, however, decidd to postpone the door changeout program until
the necessary manpower resources could be made available.
In the interim, the
existing corrective maintenance program on the doors was continued, but did not
adequately ansure fire barrier integrity.
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OPPD'S RESPONSE (Continued)
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
A program for the replacement of doors and standardization of hardware has been
initiated.
Vendors have been contacted for quotations on the cost and the
scope of this work has been finalized.
Interim corrective actions to provide
increased compliance during the procurement, delivery, and installation have
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been taken as follows:
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1.
Maintenance Order 874860 was written to repair the latch for fire door
989-9 and was completed on 10-26-87.
However, since the door it of a
misalignment-prone design, and has warped, it must be re9 laced .o
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ensure that it will consistently latch when it is closed'.
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2.
Changes to the security foot patrol procedure, SCP-14, were made an
10-1-87 to heighten guard awareness of fire door problems and to
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require that any deficiencies found be fromptly reported to the Sh;ft
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Supervisor so that corrective actions ca1 be taken.
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3.
Changes to Standing Order 0-38, Firewatches, were completed on
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December 14, 1987 to require that fire barrier deficiencies be
reported to the Shift Supervisor so that prompt corrective action can
be taken.
4.
Changes to the Fire Door Status Log, Form FC-37, were made on November
30, 1987 to require that the Shift Superviser be informed of any
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inoperable fire door within 30 minutes of discovery so that prompt
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corrective action can be taken.
5.
An interoffice memo FC-1878-87 was issued to plant operations person-
nel to inform them of their responsibilities in finding and reporting
inoperable fire doors so that prompt corrective action can be taken.
6.
Operations personnel have been informed that the appropriate cor-
rective action for fire protection deficiencies is to initiate a
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maintenance order.
Standing Order G-17, Maintenance Orders, states
that "maintenance orders on fire protection equipment should be com-
pleted within 7 days."
These corrective actions have increased personnel awareness concerning the
importance of fire door operability and the need to perform prompt corrective
action.
Additionally, interaction with the NRC resident inspetors was undertaken in a
full time manner in November 1986 when a licensing representative was assigned
full time to the site.
This move has helped facilitate communication with the
NRC Inspectors and has assisted in coordination of other inspection efforts at
Fort Calhoun Station.
CORRECTIVE STEPS WHICH Will BE TAKEN TO AVOIO FURTHER VIOLATIONS
Specific 1cng term corrective actions will consist of a fire door replacement
program aimed at eliminating the high maintenance door designs (HO 875822),a
door hardware standardization program to minimize delays associated with
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OPPD'S RESPONSE (Continued)
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CORRECTIVE STEPS WHICH Will BE TAKEN TO AVOID FURTHER VIOLATIO_NS (Continued)
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procurement and/or inventory problems associated with spare parts (M0 875823),
and a preventative testin5; and maintenance program to keep fire doors
The schedule for replacement is as follows:
1.
Procurement of doors and hardware is expected by February 1988.
2.
Issuance of a purchase order for outside labor support for door
installation is expected by May 1988.
3.
Doors and hardware are expected to be delivered 120 days after the pur-
chase order is issued, or approximately June 1988.
4.
Both of the maintenance orders should be completed for necessary doors
and hardware by September 1988 based upon meeting the milestones
established above.
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5.
In addition to those doors listed in Maintenance Order 875822, several
doors will be replaced under modification MR-FC-86-Il6C which remodels
existing plant areas for the Chemical and Radiation Protection build-
ing addition. Currently, six of these doors are fire doors.
This
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modification is scheduled for completion in October 1989.
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Additionally, in order to improve communications, each Nuclear Production
Division employee will participate in small group meetings with OPPD
management.
The purpose of the meetings is to detail the standards of
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performance expected of OPPD cmployees, and to elicit the employee's support of
these standards. The need for each employee's support in identifying,
reporting, and helping find solutions to recurring problems will be emphasized
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during these interviews.
This first series of meetings is scheduled to be
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completed by February 15, 1988.
This does not include shift personnel who will
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attend as their schedule allows.
After the first series of meetings, followup
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meetings will be held to allow for feedback from the employees.
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Furthermore, OPPD will continue to maintain a licensing person on site. A list
of requests made by the NRC Resident Inspectors will be compiled and
maintained.
This list will include Open Items, Unresolved Items, etc. in
addition to routine requests made by the Resident Inspectors. The list will
formalize the Resident requests, keep OPPD's management apprised of current
concerns, and will serve as a measure of OPPD's responsiveness to NRC
Concerns.
Additionally, the Supervisor - Nuclear Regulatory and Industry Affairs is estab-
lishing a periodic meeting (anticipated at this time to be monthly) with the
Senior Resident Inspector to improve communications in the realm of Licensing
activities. This independent meeting will preytde an additional forum for the
exchange of ideas between the NRC and OPPD. Additionally, feedback to assess
the effectiveness of OPPD's corrective actions, especially as perceived by the
NRC, can be gained.
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OPPD'S RESPONSE (Continued)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS (Continued)
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0 PPD is developing a plan and schedule for establishing a trending / root cause
program that will ensure that we appraoch future problems from a proactive
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rather than a reactive frame of reference.
OPPD is also developing a means to systematically prioritize day-to-day
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concerns. The Integrated Living Schedule is a useful concept, and will serve
to perform the necessary function for long term tasks.
A similar mechanism
more adaptable to small tasks will be established so that OPPD does not need to
rely primarily upon the judgment of individuals when establishing schedules.
Further contact with the NRC during the process will help keep the regulator
apprised of OPPD's criteria for prioritization.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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OPPD is currently in compliance with the Technical Specification requirements
in the area of fire protection.
OPPD recognizes the need for an improved corrective action program.
We believe
that the proposed initiatives in the areas of communication and interaction
with the NRC Resident Inspectors, will result in a significant improvement in
OPPD's corrective action program.
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