ML20154A589
| ML20154A589 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/13/1988 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-760, NUDOCS 8809130024 | |
| Download: ML20154A589 (3) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000 LIC-88-760 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated July 27, 1988 Gentlemen:
SUBJECT:
Response to Notice of Violation - NRC Inspection Report 50-285/88 21 Omaha Public Power District (0 PPD) received the subject inspection report on corrective action programs. The report identified one violation on failure to establish procedural controls in regard to conditional release of nonconforming items.
Please find attached OPPD's response to the Notice of Violation in accordance with 10 CFR Part 2.201.
The subm Rtal date of Feptember 6, 1988 was discussed between Mr. R. Mullikin of Region IV and Mr. J. J. Fisicaro of my staff.
If you have any questions concerning this matter, please contact us.
Sincerely, l/
sbO k)J.Horris
]k, Division Manager M
Nuclear Operations h
KJM/mc Z'd Attachment oo 80 LeBoeuf, Lamb, Leiby & MacRae g
R. D. Martin, NRC Regional Administrator 0 0:
P. D. Milano, NRC Project Manager
$$c P. H. Harrell, NRC Senior Resident inspector gol
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ATTACHMENT l
During an NRC inspection conducted on June 27 through July 1, 1988, a violation I
of NRC requirements was identified. The violation involved failure to estab-l lish procedural controls in regard to conditional release of nonconforming i
items.
In accordance with the "General Statement of Policy and Procedure for l
NRC Enforcement Actions",10 CFR Part 2, Appendix C (1988), the violation is l
listed below:
i Criterion XV of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program description requires that measures be established i
to control materials, parts, or components which do not conform to require-ments, in order to prevent their inadvertent use or installation.
The Qual-ity Assurance Plan for Fort Calhoun Station, Unit No.1, Section 7.4, para-graph 4.2.3 provides for a "conditional release basis", for use of noncon-forming items wnich can be corrected if a statement documenting the author-ity and technical justification is prepared.
Paragraph 4.3.1 of the same plan also r(quires that procedures for the control of nonconforming items i
shall be contained in the Quality Assurance Department Manual.
i Contrary to the above, the Quality Assurance Department Manual procedures l
for control of nonconforming items did not address a "conditional release l
basis" although the process was being implemented.
l This is a Severity Level IV Violation (Supplement I.D.) (285/8821-21) i OPPD RESPONSE The Reason for the Violation if Admitted OPPD admits the violation as stated. As described in Section 7.4 of the Qual-ity Assurance Plan for Fort Calhoun Station, OPPD has the ability to provide a l
"Conditional Release Basis" for nonconforming material.
The procedures that i
implement this provision center on nonconforming material at the point of re-ceipt inspection.
Items that were in operatien and then found to be nonconform-ing are not addressed in the implementation procedures in sufficient detail I
The Corrective Steos Which Have Been Taken and the Results Achieved j
OPPD has admitted that this method is a procedurally inadequato control mechan-ism. Therefore, OPPD has retained a consultant to restructure the Fort Calhoun Nonconformance Program.
This project was initiated in July 1988.
The major elements of this program include revisions to Quality Assurance Department Pro-cedure QADP 13. Standing Orders G 18 and G 22, along with revisions to the QA Plan.
Technical justifications for use of nonconforming items were documented to en-sure safe plant operation. Although the justifications are adequate, the cited i
NRs are still open, pending long term follow up on these items.
This will en-sure proper corrective actions on the root causes are accomplished, and will l
ensurc, tracking until the revised procedure is in place and in use. QA Plan, Section 7.4, Rev. 1, now provides clear authority concerning who may perform t
technical justifications.
1 Any new NRs initiated for items already in operation (e.g., not receipt inspec-l l
tion identified) will rem.in open until the revised procedures are in place.
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Attachment (Continued) i Ihe Corrective Steos Which Will Be Taken Each of the six cited NRs will be closed as expeditiously as possible over the next 90 days.
OPPD is undertaking a general programmatic upgrade of procurement and storage practices for safety related material and services to bring them into compli-i ance with currently accepted NRC and INPO criteria, and to maintain the prac-j tices and procedures at the required quality level on a continuing basis to support safe operation at Fort Calhoun Station.
The improvement program will incorporate the following major elements of the restructured NR program:
j 1.
Revise Standing Order G 18 to include a separate dedicated section for pro-cessing nonconformances for operational "Conditional Release Basis" mater-1 ial.
l 2.
Ensure Standing Order G 18 still clearly addresses the control of noncon-forming material discovered during receipt inspection.
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3.
Establish a new vehicle for the resolution of minor or questionable receipt inspection discrepancies.
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i 4.
Provide proper "flagging" that the NR is a "Conditional Release Basis" NR
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on both the revised form and in the technical justification used for re-i 1
lease.
5.
Prov de administrative controls to limit the scope of an NR such that if additional concerns are identified at a later date, they will become the j
subject of a separate NR.
j 6.
Provide clear authority as to who shall authorize the release of the mater-f ial for use.
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7.
Revise QADP 13 and Standing Order G 22 to include provisions for engineer-l ing review.
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Date of Full Comoliance OPPD will be in full compliance by December 1, 1988.
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