ML20246M849
| ML20246M849 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/11/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8907190235 | |
| Download: ML20246M849 (2) | |
See also: IR 05000285/1988037
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In Reply Refer To:
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Docket: 50-285/88-37
Omaha Public Power District-
ATTN:- Kenneth J. Morris, Division Manager
Nuclear Operations
444 South 16th Street Mall
Omaha, Nebraska 68102-2247
Gentlemen:
This responds to your letter of June 15, 1989, which provided additional
information clarifying your response to Notice of Violation 285/8837-01.
Previous correspondence on this subject was our Inspection Report and Notice
of Violation, dated November 7,1988; your response dated December 9,1988;
our response and request for additional information, dated January 12,'1989;
your supplemental' responses, dated February 13 and May 1,1989; and our
responses dated February 24 and May 17, 1989.
Your additional, unsolicited response was appropriate, and we shall factor the
information provided into our review of your actions during a future
inspection.-
Sincerely /
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OQ lS
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James-L. Milhoan Director
Division of Reactor Projects
cc:
Fort Calhoun Station
ATTN:
G. R. Peterson, Manager
P.O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
1333 New Hampshire Avenue, NW
Washington, DC 20036
Nebraska Radiation Control Program trector
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June 15, 1989
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LIC-89-590
.JUN 2 7 !E
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U. S. Nuclear Regulatory Commission
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Attn: Document Control Desk
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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
November 7, 1988
3.
Letter from OPPD (K. J. Morris) to NRC (Document Control
Desk) dated December 9, 1988 (LIC-88-1089)
4.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated
January 12, 1989
5.
Letter from OPPD (K. J. Morris) to NRC (Document Control
Desk) dated February 13, 1989 (LIC-89-179)
6.
Letter from OPPD (K. J. Morris) to NRC (Document Control
Desk) dated May 1, 1989 (LIC-89-433)
Gentlemen:
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SUBJECT:
Request for Additional Information Concerning Clarification of
Response to Notice of Violation 285/80-37-01
Omaha Public Power District (0 PPD) responded to Notice of Violation
285/83-37-01, Failure to Maintain Traceability of Measuring and Test Equipment
(M&TE) in Reference 3.
Reference 4 requested additional information needed to
clarify our response. As stated in Reference 3, our initial response, OPPD
based the conclusion that the conditions identified by the inspector were
isolated events.
This conclusion was based on prior reviews and interviews
with individuals involved in use of M&TE. OPPD had no evidence to the contrary
at that time.
In Reference 5, OPPD committed to the review of 50 Surveillance
Tests (STs) conducted between January 1988 and October 1988 to verify that test
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equipment used was properly calibrated and recorded in the Instrument and
Control (I&C) shop logs, and to confirm that the cases identified were
isolated.
As stated in Reference 6, OPPD completed its initial review of Surveillance
Test (STs) and determined that contrary to our initial indications, this was
not an isolated case and additional measures were needed to ensure traceability
of M&TE.
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Reference.6 outlined a review plan to determine the scope of the problem and
stated that it would be used as a basis for defining permanent corrective
actions to prevent recurrence. This plan consisted of:
A.
Review additional STs
B.
. Review M&TE calibration records
C.
Review M&TE Deficiency Reports
D.
Review M&TE Procedures
E.
Conduct interviews with Technicians from the I&C group
A comparative review of I&C STs against the M&TE usage leg for the period
between January 1, 1988 and October 31, 1988 has been completed.
The results
indicate that the M&TE usage log has not been routinely completed as directed
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by Standing Order M-28 " Calibration of Test Equipment." Further, the
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calibration records and deficiency reports have been compared against the M&TE
usage log to identify STs which may have been performed with questionable
M&TE. Of the comparisons made, there have been no instances identified where
deficient M&TE was used on STs; therefore, the STs were measured in an
acceptable method.
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The'M&TE calibration procedures have been reviewed and other than stated above,
there were no technical deficiencies identified.
Interviews conducted with the
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I&C Technicians indicated that personnel were aware of the procedural
requirements. However, due to the lack of rigid enforcement of M&TE procedural
controls, personnel failed to comply with the requirement outlined in the M&TE
calibration procedure. This was addressed by establishing a fulltime position
responsible for issuing M&TE as discussed in Reference 6 and will be further
strengthened by accomplishment of permanent corrective actions identified
below.
Additional corrective actions which OPPD wil' implement to prevent recurrence
are
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1.
Revise Standing Order M-28 " Calibration of Test Equipment" to include:
a.
Clarification of the requirements for issuance and control of
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M&TE.
This will include the requirement to have all M&TE
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equipment used for critical measurements checked out from the
M&TE lab.
b.
Establish a procedural requirement to have M&TE deficiency
reports reviewed within 30 days to expedite the identification of
instruments which were tested or calibrated by M&TE which
required calibration adjustments.
c.
Require that M&TE equipment used for critical measurements for a
particular work activity at Fort Calhoun Station be logged in the
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" usage log" maintained by personnel assigned to the M&TE issue
area.
If the M&TE is to be used on a different job then it will
be required to be reentered in the " usage log."
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QC-89-590
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d.
Establish controls for immediate corrective action when M&TE is
identified as defective. This will be accomplished by placing
the defective equipment in a holding area separate from the issue
area and placing a reject tag on the defective equipment.
e.
Define critical measurements and incorporate into Standing Order
M-28.
2.
Establish a finite M&TE issue area.
3.
Recall M&TE, which is maintained by the Instrument and Control and
Electrical / Maintenance Craft / departments, to the central issue area.
4.
Train personnel who utilize M&TE in the requirements of the revised
Standing Order M-28 " Calibration of Test Equipment", the requirement
for adherence to procedures, and the reason for maintenance of an M&TE
p rog ram ,
5.
Current outstanding deficiency reports dealing with M&TE will be
reviewed by October 15, 1989. This completion date was established
based on the length of time these reports have been outstandirJ.
Reference 6 also addressed compensatory action OPPD had instituted prtding the
outcome of this review. These compensatory actions have been imp 112..ented and
will remain in place pending implementation of additional correttive action.
Additional corrective action will be completed by August 15, 1989.
The items committed to in Reference 5 are on schedule for implementation by
July 31, 1989. These items are:
1.
An individual will be designated to control issuance of Measure and
Test Equipment (M&TE). This individual will be responsible for
maintaining the I&C shop log to document the release and return of
test equipment, as well as maintaining equipment calibration records
and associated documentation.
2.
Controlled access to calibrated test equipment will be established by
July 31, 1989.
This will restrict access to ensure that each piece of
equipment is properly released to service and returned from service.
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This has been administratively established by the Supervisor -
Instrument and Control and will be proceduralized by the date noted
above.
3.
An improved system for recording test equipment used for M&TE
functions will be developed and implemented by July 31, 1989. This
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will aid in maintaining traceability of test equipment.
Item 3 has been revised to specify test equipment used for M&TE functions not
just surveillance tests which was what had been committed to in Reference 6.
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In conclusion, OPPD has determined that the action taken in Reference ~6 in
conjunction with the additional corrective actions included in this letter,
will correct the conditions reported in Notice of. Violation 285/88-37-01.
'If you should have any' questions, please'do not hesitate to contact me.
Sincerely,
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K
J. Morris
. Division Manager
_ Nuclear Operations
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LeBoeufs Lamb, Leiby & MacRae
RM D:I Mart i n E NRC T Re'g i on al'!Admi n i sti atort
A. Bournia, NRC Project Manager
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P. H. Harrell, NRC Senior Resident Inspector
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