ML20151R113
| ML20151R113 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/27/1988 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-493, NUDOCS 8808120056 | |
| Download: ML20151R113 (3) | |
Text
l
. f..
.g
(..
4 v
Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000 July 27, 1988 LIC-88-493 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated January 25, 1988 3.
Letter from OPPD (R. L. Andrews) to NRC (Document Control Desk) dated February 24, 1988 (LIC-88-120) 4.
Letter from 0 PPD (R. L. Andrews) to NRC (Document Control P.sk) dated March 4, 1988 (LIC-88-159) 5, Letter from NRC (L. J. Callan) to 0 PPD (R. L. Andrews) dated March 23, 1988 Gentlemen:
SUBJECT:
Updated Response to NRC Inspection Report 50-285/87-24 Omaha Public Power District (OPPD) received Reference 5 requesting additional information regarding the Response to Notice of Violation, NRC Inspection Report 50-285/87-24, Reference 3.
This letter addresses the questions presented in Reference 5, including completion dates for the action items.
Should you have any further questions concerning this matter, please contact me.
Sincerely,
's
/
J.
lorris Division Manager i
l Nuclear Operations 1
KJM/me c:
LeBoeuf, Lamb, Leiby & MacRae l
1333 New Hampshire Ave., N.W.
j Washington, DC 20036 R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector l
8808120056 880727
{DR ADOCK0500g5
[/[O/
/f/
d55:24 Empiovmen w n opponunau m'
ATTACHMENT
^
Question 1 The response to Deviation 285/8724-01 states in the "Corrective Steps That Have Been Taken and Results Achieved" section that you have taken two mecsures to ensure more timely follow-up on commitments. The first measure states that the plant manager has established a formal weekly staff meeting that focuses on open commitments and provides a forum for ensuring management awareness of problems associated with completing these tasks.
It is requested that you address the following with respect to these measures.
a.
How are commitments that are in areas that are not under the direct supervision of the plant manager to be addressed?
b.
The establishment of the staff meeting appears to presume that a list of open commitments will be used as a basis for the meeting discus-sion.
How will you ens,ure that the open commitment list will be complete and up-to-date?
OPPD'S RESPONSE TO OVESTION #1 a.
The Nuclear Licensing & Industry Affairs (NL&IA) Department tracks and updates the status of commitments contained in written submittals by utilizing Policy / Procedure G-2 Intearated Reaulatory Reauirements Loa, (IRRL). These include commitments under the supervision of the Plant Manager and commitments which are not. Commitments are classified according to completion dates, with "A" items having dates documented in the submittal, and "B" items having commitments that do not have a date assigned in the submittal.
The NL&lA Department assigns these log items and for those that do not have a date assigned, requests the individual to supply the completion date.
The IRRL is distributed to the Senior Vice President, the Division Manager - Nuclear Operations, and various departments including those which are not under direct supervision of the Plant Manager.
This process ensures that the status information is available to groups responsible for completion of various actions.
b.
The IRRL which contains commitment items in a report format is updated and distributed by the NL&IA Department on a periodic basis (generally biweekly) to reflect the current status of commitments.
This, as well as other informal tracking processes, form the basis of the plant manager's staff meeting discussion on commitments.
As noted previously, OPPD has also established monthly meetings between the resident inspectors and the Manager - N!.&IA for a regular review of NRC commitment status.
It is intended that these meetings update longer term items such as submittals being reviewed by NRR and the status / effectiveness of OPPD longer term corrective actions.
In our previous response, several actions were provided to describe ongoing activities relating to the management process and the communications process at OPPD. While we believe these to be an extremely important aspect of our business, it is also difficult to define something as intricate as human communication in a one paragraph response to an NRC letter.
We recognize the desire to develop and implement effective actions and programs, but maintain that a degree of informality must be used with this process.
Attachment (Continued)
Qpe'stion 2 The response to Violation 285/8724-05 failed to provide a date for issuance of a plant procedure for control of the erection of scaffolding in safety-related areas.
It is requested that you provide a date when the procedure will be issued and when the requirements of the procedure will be implemented.
OPPD'S RESPONSE TO OVESTION #1 To control its use, scaffolding is be defined as a temporary mechanical jumper controlled by Standing Order 0-25 "Electrical and Mechanical Jumpers and Block Controls." Standing Order 0-25 was revised to define safety-related areas, require a safety evaluation prior to the construction of scaffolding, and provide for pre-approval prior to the erection of scaffolding.
Standing Order G-17, "Maintenance Orders," was revised to reference Standing Order 0-25 for the control of scaffolding. Also, Stand-ing Order G-21, "Station Modification Control," was reviewed to determine if revisions were necessary to reference the control of scaffolding.
No change to Standing Order G-21 was deemed necessary. Also, scaffolding was discussed at several morning and afternoon maintenance meetings to ensure that plant personnel are aware of scaffolding controls.
The standing order change was issued and implemented June 30, 1988.
In addition, a hotline was issued for this change, indicating that the topic would be covered during the next training rotation.
Question 3 The response to Violation 285/8724-06 failed to provide a date for issuance of a new procedure regarding posting of NRC-required documents.
It is requested that you provide a date when the procedure will be issued and when the require-ments of the procedure will be implemented.
OPPD'S RESPONSE TO OVESTION #3 OPPD issued a new procedure, NPD Quality Procedure QP-17, regarding the posting of NRC required documents; 10 CFR Part 21, Section 206 of Energy Reorganization Act of 1974, Quality Procedure QP-12,10 CFR Part 19 required documents, and Form NRC-3.
This procedure requires a periodic review to assure that required documents are posted with the latest revision.
The reviev: will be documented by a signed off transmittal sheet that lists the latest revision of the documents and how to obtain a copy if any are found not to be in compliance.
Procedure QP-17 was issued and implemented in May 1988.
_ _ _ _ _ _ _ _ _ _ _