ML20217D447

Notice of Violation from Insp on 980209-13 W/In Ofc Insp Until 980302.Violation Noted:Since Aug 1994 QA Lead Auditor Had Not Satisfied or Completed QA Qualification Manual Requirements Prior to Conducting Lead Auditor Functions

ML20217D447
Person / Time
Site:	Fort Calhoun
Issue date:	03/25/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217D423	List: IR 05000285/1998002 ML20217D420 ML20217D447
References
50-285-98-02, 50-285-98-2, NUDOCS 9803300021
Download: ML20217D447 (2)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION Omaha Public Power District Docket No.: 50-285 Fort Calhoun Station License No.: DPR-40 During an NRC inspection conducted on February 9-13, with in office inspection continuing until March 2,1998, two violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

Technical Specification 5.8.1 states, in part, that written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the minimum requirements of Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, recommends, in part, that procedures should be written covering administrative procedures for safe operations.

A. Quality Assurance Manual QAM-13. Revision 3, and ANSI N45.2.23-1978 specify the training required to qualify and certify quality assurance auditors and lead auditors.

Quality Assurance Manual QAM-13, Step 3.1.1 states, in part, that auditors shall have, or be given, appropriate training or orientation to develop their competence for performing required audits. The quality assurance / quality control training program master plan provides a structured srogram to ensure these training requirements are met it ensures a candidate (who has not been previously certified as a quality assurance auditor) completes or otherwise satisfies initial training and qualification manual requirements prior to independently performing auditor or lead auditor functions. The satisfaction of j these requirements are reflected in the quality assurance qualification manual.

Contrary to the above, since August 1994 a quality assurance lead auditor had not satisfied or completed the quality assurance qualification manual requirements prior to conducting independent auditor and lead auditor functions. Specifically, the manual 4 could not be located. l 1

This is a Severity Level IV violation (Supplement I) (50-285/9802-01).

B. Standing Order SO-R-2, " Corrective Action Program," Revision 3, Step 5.2.2, states, in part, that a condition report shall be initiated immediately upon determining that documentation deficiencies exist, and events identified which are, or suspected of being, adverse to quality. Initiation of a condition report shall not be delayed pending investigation or review of possible options for resolving the condition.

Contrary to the above, condition reports were not initiated immediately for the following situations that were adverse to qualitv: i 9903300021 930325 PDR ADOCK 05000285 O PDR _,

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1. When it was identified in June 1997 that a lead quality assurance auditor did not meet the minimum training requirements of the quality assurance training program master plan.

2. When it was identified in September 1997 that quality assurance Surveillance Report H12-96-1 had not been issued.

This is a Severity Level IV violation (Supplement l} (50-285/9802-02).

Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of ,

the letter transmitting this Notice of Violation (Notice). This reply r,hould be clearly marked as a

Reply to a Notice of Violation" and should include for each vie ' in: (1) the reason for the violation, or, if contested, the basis for disputing the violation verity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlington, Texas this 25th day of March 1998

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