ML20247G674
| ML20247G674 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/18/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-496, NUDOCS 8905310040 | |
| Download: ML20247G674 (2) | |
Text
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Omt.ha Public Power District 1623 Harney Omaha, Nebraska 68102-2247 1
402/536-4000 May 18, 1989 LIC-89-496 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 (K. J. Morris) dated March 3, 1989 3.
Letter from OPPD I
J. Morris) to NRC (Document Control Desk) dated Apri' 1989 (LIC-89-329) 4.
Letter from NRC g. J. Callan) to 0 PPD (K. J. Morris) dated April 18,1989 Centlemen:
SUBJECT:
Supplemental Information for Response to Notice of Violation (285/8905-01)
This letter provides the additional information requested in Reference 4.
Reference 2 transmitted the Notice of Violation (285/8905-01) which documented the use of an incorrect dimension for determination of a maximum moment within a pipe support design calculation.
Reference 3 transmitted Omaha Public Power District's (0 PPD) response to the violation.
It summarized the investigation of the violation which determined that adequate design control measures existed at the time the calculation was performed and that the use of an incorrect dimension was an isolated incident.
The response stated that OPPD would " continue to promote attention to detail and emphasize the importance of the design control process and procedures" to avoid further violations.
The following discussion provides more definitive details with respect to our actions to " promote attention to detail and emphasize the importance of the design control process and procedures" as requested in Reference 4.
Our actions, which promote the aforementioned values, fall into two categories:
explicit, such as formal training and inherent, such as in our system of design control as established by procedures responsive to our QA Plan and 10CFR50, Appendix 8.
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.LIC-89-496 Page 2 Examples of training which explicitly promotes the two values include, " General Employee Training", (GET), given to personnel badged for access to Fort Calhoun, and the "Cr.lculation Preparation" course, given to personnel involved in the performance of calculations. Within the " Calculation Preparation" course, attention to detail and the importance of calculations to the design process are stressed.
Both the basis in regulatory requirements and the productivity benefits which result from incorporation of these values are emphasized.
Verbatim procedural compliance and individual accountability are stressed in both the GET and " Calculation Preparation" courses.
Continuing training with respect to attention to detail in the design control process is provided under the Lessons Learned and Training Hotline programs.
The emphasis on the importance of design control is reinforced in our safety related procedures and checklists which require both checking and independent verification of calculations and design modifications.
Detailed procedures pertinent to the design process and calculation preparation provide guidance in the form of checklists for the checker and independent verifier. The quality of these procedures and checklists and their level of detail emphasize the importance o, the design control process and " attention to detail".
The assignment of senior, more experienced, engineers as checkers of work prepared by less experienced engineers inherently emphasizes attention to detail.
Engineers realize that the quality of their work and their productivity, which is a function of the " attention datail" required to do 3
things right the first time, are key factors in the a usment of their job performance.
OPPD believes that the emphasis that management has placed on the existing training programs and procedures has maintained our attention to detai'l and respect for the importance of the design control process.
Sincerely, t
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rris DTvision Manager Nuclear Operations KJM/jak c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector
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