ML20211D204
| ML20211D204 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/12/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8702200353 | |
| Download: ML20211D204 (33) | |
Text
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FEB 121987 In Reply Refer To:
Docket: 50-285 Omaha Public Power District
. ATTN:
R. L. Andrews, Division Manager-Nuclear Production 1623 Harney Street Omaha, Nebraska 68102 Gentlemen:
This refers to the Enforcement Conference conducted in the NRC Region IV office on July 10, 1986, with you and other members of your staff and NRC staff representatives and the supplemental meeting held on August 7, 1986, at the Region IV office with members of your staff to further discuss the details of the (SS0MI) findings and 15, 1986 (LIC-86-106) and May 22, 1986 (LIC-86-192)your responses dated April The subjects discussed at the July 10, 1986, enforcement conference and the August 7, 1986, working meeting are described in the attached meeting sunsnaries. A discussion by telephone was conducted on February 11, 1987, to provide further understanding of the status of overall corrective actions, planned or taken by OPPD, and the final disposition of the SS0MI findings, including the potential enforcement items.
The enforcement conference, working meeting, and supplemental discussions proved to be extremely beneficial and provided a better understanding of the areas of concern identified during the SS0MI to ensure your completion of adequate and comprehensive corrective actions.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Should you have any questions concerning this matter, we will be pleased to discuss them.
Sincerely, Odginal Signed Dy J. E. Gor!!ardo J.E.Gagiiardo, Chief Reactor Projects Branch Enclosurer.
(see next page) k C/RPB V /
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Omaha Public Power District
Enclosures:
1.
Attachnent A - July 10, 1986, Meeting Summary 2.
Attachment B - August 7,1986, Meeting Summary cc w/ enclosures:
W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Port Calhoun, Nebraska 68023 Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, D.C.
20036 Kansas Radiation Control Program Directory Nebraska Radiation Control Program Directory bcc:
bec distrib. by RIV:
RPB RRI R. D. Martin, RA R&SPB SectionChief(RPB/B)
MIS System RIV File DRSP RSTS Operator RSB Project Inspector J. Partlow, IE R. Heishman, IE E. Imbro, IE J. Konklin, IE R. Lloyd, IE R. Architzel, IE G. Sjoblom, IE i
ATTACHMENT A July 10, MEETING
SUMMARY
Licensee: Omaha Public Power District (OPPD)
Facility:
FortCalhounStation(FCS)
License No: DPR-40 Docket No: 50-285
Subject:
Enforcement Conference Concernin Modification Inspections (SSOMI)g the NRC Safety Systems Outage Findings (NRC Inspection Report No. 50-285/85-22 and Inspection Report No. 50-285/85-29)
On July 10, 1986, representatives from 0 PPD met in Arlington, Texas, with NRC personnel (IE HQ and Region IV) to discuss the SSOMI report findings. The attendance list is attached'as Enclosure A-1 to this summary.
The NRC discussed the concerns in general resulting from the SS0MI, including the adequacy of safety evaluations, procedural controls, design change control, procurement document control, document control, control of special processes, material storage, and corrective actions. The licensee discussed a number of the issues, including improvements taken and planned regarding the design change control and implementation programs. These improvements included prompt, short term, and long term actions. The outline of the licensee presentation is attached as Enclosure A-2 to this summary.
Enclosures:
1.
Attendance List 2.
OPPD Documentation Outline
ENCLOSURE A-1 OPPD ENFORCEMENT CONFERENCE JULY 10, 1986 ATTENDEES OMAHA PUBLIC POWER DISTRICT (OPPD)
R. L. Andrews, Division Manager, Nuclear Production K. J. Morris, Division Manager, Quality Assurance and Regulatory Affairs R. C. Liebentritt, Division Manager, Engineering S. K. Gambhir, Section Manager, Generating Station Engineering M. E. Eidem, Department Manager, Generating Station Engineering, Mechanical and Nuclear R. L. Jaworski, Section Manager, Technical Services T. J. McIvor, Supervisor, Technical, FCS J. J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs NUCLEAR REGULATORY COMMISSION J. G. Partlow, Director, Division of Inspection Programs R. E. Hall, Deputy Director, Division of Reactor Safety and Projects, RIV R. F. Heishman, Chief, Vendor Program Branch, IE E. V. Imbro, Chief, Engineering Section, IE J. E. Konk11n, Acting Chief, Reactor Construction Programs Branch, IE R. L. Lloyd, Chief, Reactor Construction Program Branch, IE G. L. Sjoblom, Special Assistant to Director, IE D. R. Hunter, Chief, Reactor Projects Section B, RIV R. E. Architzel, Senior Inspection Specialist, IE J. M. Sharkey, Inspection Specialist, IE M. E. Murphy, Project Inspector, RIV D. A. Powers, Enforcement Officer, RIV l
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ENCLOSURE A-2 4
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NRC ENFORCEMENT CONFERENCE t
JULY 10, 1986-i LICENSEE HANDOUT u
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NRC ENFORCEMENT CONFERENCE July 10, 1986 OPENING COMMENTS R. L. ANDREWS OVERVIEW OF OPPD RESPONSES TO R. L. ANDREWS 50-285/85-22 50-285/85-29 INTERIM CORRECTIVE ACTIONS R. L. ANDREWS
- PRE-STARTUP ACTIONS
- EXECUTIVE ORDER
- PRE-OUTAGE PLANNING OVERVIEW OF DESIGN CHANGE MODIFICATION PROGRAM REVIEW R.
L. ANDREWS
SUMMARY
OF REPORT J. J. FISICARO 1.
DESIGN BASIS AND CONSTRUCTION S. K. GAMBHIR QA RECORDS j
2.
UPDATED SAFETY ANALYSIS REPORT (USAR)
J. J.
FISICARO l
3.
DOCUMENTATION OF DESIGN ASSUMPTIONS, S. K. GAMBHIR DESIGN INPUTS, AND ENGINEERING JUDGEMENTS 4.
COMMITMENT TRACKING J. J.
FISICARO 5.
DESIGN CHANGE PROGRAM S. K. GAMBHIR 6.
PROCUREMENT S. K. GAMBHIR 7.
SAFETY EVALUATIONS J. J.
FISICARO 8.
REVIEWS AND APPROVALS S. K. GAMBHIR 9.
QUALITY ASSURANCE PROGRAM S. K. GAMBHIR F
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NRC ENFORCEMENT CONFERENCE Page 2 10.
QUALITY CONTROL T. J. McIVOR 11.
POST-MODIFICATION TESTING T. J. McIVOR 12.
INSTALLATION PROCEDURES AND FIELD S. K. GAMBHIR CHANGES 13.
SYSTEM ACCEPTANCE T. J. McIVOR 14.
EMERGENCY MODIFICATIONS S. K. GAMBHIR 15.
MINOR MODIFICATIONS S. K. GAMBHIR 16.
PRE-OUTAGE PLANNING J. J. FISICARO (INTEGRATED LIVING SCHEDULE) 17.
TRAINING R.
L. JAWORSKI 18.
SYSTEM ENGINEER R. L. JAWORSKI
SUMMARY
STATUS OF RECOMMENDATIONS RELATIVE TO R.
L. ANDREWS DESIGN CHANGE MODIFICATION PROGRAM REVIEW FUTURE PLANS 6
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Inputs Design Basis and Construction QA Records
. Updated Safety Analysis Report (USAR)
Documentation of Design Assumptions, Design Inputs and Engineering Judgements Commitment Tracking Process Design Change Program
~*
Procurement Safety Evaluations Reviews and Approvals Quality Assurance Program Quality Control Post-Modification Testing Installation Procedures and Field Changes System Acceptance Emergency Modifications Minor Modifications Plannina Pre-Outage Planning (Integrated Living Schedule) i Trainina and ExDerience j
Training
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1.
Desian Basis and Construction O.A. Records Page 1 of 2 Short Term Continue to recreate design basis documents on as-needed basis and conduct appropriate training.
Use the Fort Calhoun USAR and Safety Evaluation Reports referenced in the Technical Specifications as the basis for future modifications and for performing safety evaluations.
Index Safety Evaluation Reports (SER's) referenced in the Technical Specifications.
Index existing calculations and analyses which are being developed in support of modifications.
Transfer Jones Street records to GSE/ Records Management for safekeeping.
Evaluate OPPD's document retrieval program (RMS) for improving the ease of retrieval of design basis information.
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Page 2 of 2 Long Term Develop an organization to complete the following long term actions:
Review, retrieve, and organize existing records.
Evaluate missing records that are identified when performing the above action.
Recreate, where required, missing records that were identi-fled above.
Develop the necessary system-based design documents to sup-port FC operation, modification and operating license exten-sion effort.
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2.
Updated Safety Analysis ReDort (USAR)
Short Term 4
Finalize the USAR evaluation.
Issue guidance on USAR purpose and level of detail.
Compile and index SER's.
Develop an OPPD USAR policy document.
Develop USAR update guidance procedure.
Long Term Proceduralize the USAR update process.
Implement training on USAR updates.
Compara Technical Specifications to USAR to verify USAR accuracy and consistency.
In'itiate a program to correct USAR data.
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Documentation of Desian Assumotions, Desian Inputs and Engineerina Judaements Short Term Develop a training program on the necessity for documentation.
Develop a program outline resulting in a plan and schedule for updating / improving existing procedures in the area of require-ments and guidance for documentation.
Long Term Update and revise procedures and prepare new guidance documents to ensure proper documentation.
Implement a training program on a continuing basis.
Establish design basis documentation utilizing construction QA records, where available, supplemented by additional analyses as required.
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Commitment Trackina Short Term Improve the existing tracking system to include available histor-ical information.
Long Term Create Licensing Review Packages from available data and incorpo-rate them into the data base.
Create Packages based on commitments contained in various design based and operational documents.
Review, in detail, commitments made which may not be reflected in the various, more formal forms of regulatory correspondence.
Verify selected items to ensure commitments are completed.
Develop and/or procure an application software _ program to per-form commitment tracking.
5.
Desian Chance Procram Short Term Revise Fort Calhoun Standing Order G-21 to eliminate Technical Services review of EEARs which are determined to be obvious modi-fications by FC plant engineering.
Encourage the continuation of planning meetings between Techni-cal Services, GSE, and Plant Staff.
Develop a guidance document to define the scope of and provide guidance for review of EEARs by Nuclear Production Division.
Long Term Develop a corporate procedure for control of modifications to Fort Calhoun Station.
s Purge Fort Calhoun Standing Order G-21 of design-type require-ments which should be included in the implementing procedures.
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Procurement Short Term Review all procedures that define OPPD methods for specifying equipment and vendors with an objective of defining areas where additional guidance is necessary for implementation.of proce-dures and requirements.
Develop an interface document between the procuring organiza-tions and QA regarding receipt inspections.
Develop a plan for receipt, temporary storage and tracking of-materials.
1 Develop a guidance document for the procurement and dedication of commercial grade equipment.
Long Term Develop training modules for specifications.
Develop standard technical criteria and specification documents.
Develop, specific guidance criteria for receipt inspection.
l Provide training on procurement and dedication of commercial r
grade equipment.
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Revise existing and develop new procedures for specifications i
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where necessary.
Implement a tracking program to ensure that receipt inspection packages are available to QA prior to delivery of equipment and f
that receipt inspections are done in a timely manner.
Provide for CQE storage in the new warehouse.
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Safety Evaluations Short Term Adopt definitions of key words and phrases pertaining to the con-duct of safety evaluations.
Develop and implement a single OPPD procedure for the prepara-tion of safety evaluations.
This procedure will also allow for an applicability check, and separate detailed safety evaluations will not be required for every change.
Develop and implement training / instruction in the requirements of the above procedure and the adopted definitions.
Long Term Develop and implement a task / performance based-training program.
Review and evaluate the effectiveness of the procedures devel-oped above.
Consider further the assignment of qualified personnel who are dedicated to the review of safety evaluations within each work group.
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Desian Review and ADDrovals Page 1 of 2 l
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Short Term Require that Independent reviews be done prior to PRC acceptance of Construction Packages.
I Consider performing multi-disciplinary independent reviews in lieu of the present practice of one-person reviews.
Consider using INPO Good Practice Checklist as a guid.
t Implement training for the GSE checking and approval 1 process.
~
Conduct plant reviews in two parts, i.e., Technical reviews and y
Procedural reviews.
Limit plant technical reviews to plant safety, operability and maintainability aspects only.
Assign the PRC subcommittee and Operations Engineers within 30 days of a job being assigned an " Active Status".
Suggest that Design Engineers meet with the PRC subcommittees and/or operations engineer during various stages of design.
Perform system walkdowns with one or more subcommittee members.
i Continue to send packages to Technical Services for review and and ask reviewers to participate in plant subcommittee discus-sions.
Review and revise the Corporate QA Department checklist'for design packages to be consistent with the requirements.
Ask plant QC to review both Final Design and Construction pack-ages and assign a QC representative to the PRC Subcommittee.
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Quality Assurance Procram Short Term Develop more specific procedural guidance for QA reviews of Final Design and Construction packages.
Revise design review procedures to include the resolution of QA review comments.
Follow up to verify that commitments made to the NRC in the SSOMI team responses are being planned or implemented.
Long Term Conduct a review of ANSI Standards applicable to the design change program and identify areas where procedures could be improved.
Prepare an audit plan based on the lessons learned from the SSOMI team findings.
Use technical experts to assist with QA audits on design activ-ities where needed.
Expand QA surveillances to cover the various types of modifica-tions (Civil, Electrical, Mechanical and Nuclear).
i Review implementing procedures against Appendix A of the USAR and QA Plan.
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- 10. Quality Control Short Term Consider qualification of the dye penetrant (PT) NDE procedure to a lower temperature.
Revise the PT report form to document the temperature at which the examination was performed.
Review other NDE procedures to determine if similar changes are necessary.
Complete implementation of the revised welding program.
Develop a documented set of criteria for the indoctrination of contractor inspectors.
Develop a trial program of Quality of Work Life Groups within selected craft groups.
Long Term Implement improved training programs for craft personnel.
Strengthen the procedural requirements regarding the assignment of qualified personnel.
Increase the staff in the Quality Control Group to at least six persons.
Evaluate the success of the Quality of Work Life Groups.
- 11. Post-Modification Testing Short Term Modify Standing Order G-21 to define testing program.
Revise Standing Order G-19, " Test Control" to be consistent with regulatory commitments.
Long Term Establish a group within the Nuclear Production Division which would have responsibility for post-maintenance and post-modifica-tion plant testing.
The present practice of design engineer involvement in the testing process should also be continued.
Establish a program for evaluating and qualifying test personnel.
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- 12. Installation Procedures and Field Chances Short Term Develop a formal numbering system to identify field changes.
Designate a GSE person responsible for tracking field changes to normal modifications during outages.
Require QC and/or QA review of field changes prior to SAC.
Revise the FC-1033 Form to require prior to SAC, GSE-Department Manager approval of. field changes which may change the design basis or design intent of the modification.
Provide training to modification Design Engineers, Operation Engineers, and Planners which addresses the proper preparation of installation procedures and field changes.
Delete the requirement for PRC review of fiald changes to DCOs which were not originally PRC approved.
4 Long Term Prepare a new Standing Order which would govern field changes.
Prepare future installation packages such that work instructions are separate documents from installation procedures and test pro-1 cedures.
Investigate the use of a computerized tracking system for field p
changes.
Develop standard installation specifications and detailed work instructions.
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- 13. System Acceptance Short Term Revise Standing Order G-21 as follows:
Add an acceptance category for testing / trial operation.
Develop a documentation summary sheet as part of the Form J.
Develop a tracking system for tracking progress on defi-ciencies.
Long Term None Required t
- 14. Emercency Modifications Short Term Call out GSE Design Engineer to provide designs for Emergency modifications.
Obtain independent reviews by telephone.
This should be done prior to putting systems in operation following Emergency modifi-cations.
Judiciously use the Emergency Modification classification.
Require SAC review within 14 days of completion of the modifica-tion.
Long Term Establish an Emergency Modification Form to facilitate the docu-mentation process.
Continue the call out system for GSE Engineers.
When a DCO or SRDCO is completed, enough information should be available to allow SAC to approve the modification.
- 15. Minor Modifications Short Term Review and revise the definition of " Minor Modification" to limit the use of this classification to "truly". minor modifica-tions only.
Coordinate outside engineering design services, if required, through GSE.
Include in the Form A requirements to document the following information:
Modification Design Basis, Technical Evaluation, Design Evaluation, and Plant Design Basis Safety Analysis.
Long Term None Required i
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- 16. Pre-Outace Planning Short Term Continue OPPD's involvement in the industry activities on Inte-grated Living Schedule Systems (ILS).
Increase the planning windows to at least two outages and 24 months for on-line work.
Make the modification packages available to the modification installation staff ahead of the scheduled construction.
Modify Executive Order 86-1 per the recommendations contained in Section 6.16.6.
Long Term Purchase, if necessary, software and implement an ILS for modifications at Fort Calhoun.
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- 17. Trainina and Experience Short Term Establish and maintain programs for personnel training and qualifications which suit the specific needs of each super-visor's work group.
Utilize established NPD Training Department materials and resources whenever possible.
Finalize and implement the GSE training program based upon INPO guidance and regulatory requirements.
Long Term Assign one individual, in each section or major work group, the responsibility for assembling and administering the training l
resources of the group.
Consider job analysis in the long term development of training programs.
- I Methods and programs for encouraging the retention of experi-enced personnel, including programs for advancement of personnel through a parallel technical ladder, must be evaluated by appro-priate Division Management, and appropriate steps taken to build l
the experience levels in GSE and NPD.
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- 18. Systems Encineers Short Term Continue the current practices within OPPD and give individuals with specialty assignments added training in their systems or specialties and responsibilities to enable them to perform more effectively.
Long Term NPD management should further explore this concept to more specifically quantify resource requirements, relocation of engineers, and operational advantages derived.
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i ATTACHMENT B August 7, 1986 MEETING
SUMMARY
4 Licensee: Omaha Public Power District (0 PPD)
Facility: FortCalhounStation(FCS)
License No: DPR-40 Docket No: 50-285
Subject:
Working Meeting Concerning the NRC Safety Systems Outage Modification Inspections (SS0MI) Findings (NRC Inspection Report No. 50-285/85-22 and NRC Inspection Report No. 50-285/85-29)and the licensee responses (April 15 and May 22,1986).
References:
NRC Inspection Report No. 50-285/85-22, dated January 27, 1986 NRC Inspection Report No. 50-285/85-29, dated March 19, 1986 OPPD to NRC, dated April 15, 1986 (LIC-86-106)
NRC Inspection Report No. 50-285/85-03, dated April 18, 1986 OPPD to NRC, dated May 22, 1986 (LIC-86-192)
NRC to OPPD, dated August 5, 1986 On August 7,1986, representatives from OPPD met in Arlington, Texas, with NRC porsonnel (IE HQ and Region IV) to discuss the specific OPPD responses to the SSOMI findings and the NRC comments, documented in the August 5, 1986, letter to OPPD. The attendance list is attached as Enclosure B-1 to this summary.
Selected SSOMI findings were discussed in detail to expedite disposition of the findings based on additional information presented by OPPD. The SS0MI findings were determined to be either acceptable; unacceptable requiring additional response; or unresolved requiring further inspection effort. A compilation of the items is attached to this meeting summary: Status of Unresolved Items - Enclosure B-2; and Status of Deficiencies - Enclosure B-3.
Enclosures:
1.
Attendance List 2.
Status of Unresolved Items 3.
Status of Deficiencies
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b ENCLOSURE B-1 WORKING MEETING AUGUST 7, 1986 ATTENDEES OMAHA PUBLIC POWER DISTRICT S. K. Gambhir Section Manager, Generating Station Engineering M. E. Eidem, Department Manager, Generating Station Engineering, Hechanical and Nuclear T. J. McIvor, Supervisor, Technical, FCS J. J. Fisicaro, Supervisor, Nuclear Regulatory and Industrial Affairs NUCLEAR REGULATORY COMMISSION J. E. Konklin, Chief, Reactor Construction Program Branch, IE E. V. Imbro, Chief. Engineering Section, IE D. R. Hunter, Chief, Reactor Project Section B, RIV
Enclosure B-2 Status of Unresolved Items Associated with SSOMI (NRC IR No. 50-285/85-22-and IR No. 50-205/85-29)
STATUS Closed 0 en Item No.
(Inspection as appro.)
( urt er inspection req.)
285/85-22,U2.1-10 X
285/85-22,U4.3-2 X
285/85-22,U4.5-3 X
' 285/85-22,US.1-2 X
285/85-29,U2.3-1 X
285/85-29,U2.3-2 X
285/85-29,U2.5-1 X
285/85-29,U2.5-2 X
285/85-22,U3.2-1 X
285/85-22,U4.4-1 X
285/85-22,U3.1-3 X(Deficiency) 285/85-22,U6.1-2 X (Deficiency)
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ENCLOSURE B-3 Status of Deficiencies - By Categories STATUS CLOSED OPEN Item No.
(Inspection followup)
(Add. info. needed) 285/85-22,D6.2-2 X
285/85-22,D6.1-1 X
285/85-29, D2.2-1 X
285/85-29,D2.2-2 X
285/85-29,D2.2-3 X
285/85-22,U6.1-2 X
285/85-29,D2.4-2 X
285/85-29,02.3-3 X
285/85-22,D2.2-1 X
285/85-22,D3.1-1 X
285/85-22,D3.2-3 X
285/85-22,D3.1-2 X
285/85-22,U3.1-3 X
285/85-22,D2.1-1 X
285/85-22,D3.2-4 X
285/85-22,D2.1-2 X
285/85-22,D2.2-6 X
285/85-22,D2.2-2 X
285/85-22,D3.2-6 X
285/85-22,D2.1-7 X
285/85-22,D2.2-3 X
285/85-22,D2.2-5 X
285/85-29,D2.8-1 X
285/85-29,D2.8-2 X
285/85-29,D2.5-2 X
285/85-29,D2.4-1 X
285/85-29,D2.5-5 X
285/85-29,D2.5-6 X
285/85-22,D2.1-8 X
285/85-22,D2.1-9 X
285/85-22,D3.2-7 X
285/85-29,D2.4-2 X
285/85-29,D2.5-2 X
- a. CLOSED (cont'd)
OPEN(cont'd) 285/85-29,D2.5-4 X
285/85-29,D2.3-4 X
285/85-22,D2.1-6 X
285/85-22 D5.1-1 X
285/85-22,D4.3-1 X
285/85-22,D4.5-1 X
285/85-22,D5.2-1 X
285/85-29,D2.5-3 X
285/85-29,D2.5-7 X
285/85-22,D3.2-2 X
285/85-29,D2.3-1 X
285/85-29,D2.3-5 X
285/85-29,D2.3-2 X
285/85-29,D2.3-6 X
285/85-29,D2.6-1 X
285/85-29,D2.5-1 X
285/85-29,D2.6-2 X
285/85-29,D2.5-6 X
285/85-29,D2.9-2 X
285/85-29,D2.9-3 X
285/85-29,D2.9-1 X
285/85-29,D2.10-1 X
285/85-29,D2.10-2 X