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{{Adams | |||
| number = ML20154R374 | |||
| issue date = 09/21/1988 | |||
| title = Ack Receipt of 880727 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/88-21 | |||
| author name = Callan L | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = Morris K | |||
| addressee affiliation = OMAHA PUBLIC POWER DISTRICT | |||
| docket = 05000285 | |||
| license number = | |||
| contact person = | |||
| document report number = NUDOCS 8810040237 | |||
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE | |||
| page count = 2 | |||
}} | |||
See also: [[see also::IR 05000285/1988021]] | |||
=Text= | |||
{{#Wiki_filter:3 | |||
* | |||
A | |||
^ ~ ' | |||
- | |||
. SEP 2 l 1988 | |||
In Reply Refer To: | |||
Docket: 50-285/88-21 | |||
Omaha Public Power District | |||
ATTN: Kenneth J. Morris, Division Manager | |||
Nuclear Operations | |||
1623 Harney Street | |||
Omaha, Nebraska 68102 | |||
Gentlemen: | |||
Thank you for your letter numbered LIC-88-760, in response ~ to our letter | |||
and Notice of Violation dated July 27, 1988. We have reviewed your reply and | |||
find it responsive to the concerns raised in our Notice of Violation. We will | |||
review the implementation of your corrective actions during a ^;ture | |||
inspection to determine that full compliance has been achieved and will be | |||
maintained. | |||
Sincerely, | |||
'rigual , | |||
, ,, | |||
. | |||
a D. IQ | |||
L. J. Callan, Director | |||
Division of Reactor Projects | |||
CC: | |||
Fort Calhoun Station | |||
ATTN: W. G. Gates, Manager | |||
P.O. Box 399 | |||
Fort Calhoun, Nebraska 68023 | |||
Harry H. Voigt. Esq. | |||
LeBoeuf. Lamb Leiby & MacRae | |||
1333 New Hampshire Avenue, NW | |||
Washington, D. C. 20036 | |||
Nebraska Radiation Control Program Director | |||
RIV:MQPS M C:MQPS M S fd 0:DRP4 Ejl | |||
WMcNeill/cjg IBarnes JLN hoan LJCalltn | |||
9/$ 4/88 7/w/88 9/J.0/88 i / 21 / 8 8 | |||
LO | |||
8G10040237 880921 h \\ | |||
gaa noccxosoopgg5 | |||
, | |||
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . | |||
' | |||
. | |||
.- . | |||
(haha Public Power District -2- | |||
bec to DMB (IE01) | |||
bec distrib. by RIV: | |||
R.D. Martin, RA RPB-DRSS | |||
Section Chief (DRP/P) MIS System | |||
RIV File DRP | |||
RSTS Operator Project Engineer DRP/B | |||
Lisa Shea, RM/ALF P. Milano, NRR Project Manager | |||
W. McNeill I. Barnes | |||
DRS | |||
. | |||
b | |||
5 | |||
i | |||
P | |||
--w . - - - _ . _ , , . -_ --, _ - , _ __ , _ . _ _- _ , _ _ ._ ____ __ ,_, | |||
- | |||
. | |||
.'. | |||
. _m S _= '= = - -4 : .-. m. - y - -- | |||
4-s : . = - - = = - ----:------: | |||
. . . _. _ . . . - _ _ . _. . _ . _ _ _. _ _ _ | |||
Om;ha Public Power District | |||
1623 Harney Omaha. Nebraska 68102 2247 | |||
3[lKC)[h[lW/D 1 | |||
402/536 4000 - ,! | |||
0 | |||
' | |||
' | |||
i | |||
SEP I ? te | |||
. -- t | |||
LIC-88-760 - _ _ | |||
l | |||
U. S. Nuclear Regulatory Commission | |||
Attn: Document Control Desk i | |||
Mail Station PI-137 l | |||
Washington, DC 20555 ; | |||
i | |||
References: 1. Docket No. 50-285 | |||
2. Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated | |||
July 27, 1988 | |||
Gentlemen: | |||
t | |||
SUBJECT: Response to Notice of Violation - NRC Inspection Report | |||
50-285/88-21 l | |||
1 | |||
Omaha Public Power District (OPPD) 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 submittal date of September 6, 1988 was | |||
! | |||
discussed between Mr. R. Mullikin of Region IV and Mr. J. J. Fisicaro of my ! | |||
l | |||
staff. l | |||
. | |||
1 If you have any questions concerning this matter, please contact us. I | |||
' | |||
! | |||
( Sincerely, , | |||
/n .- | |||
// . /f N' | |||
I k.J. Morris ! | |||
l Division Manager | |||
l | |||
Nuclear Operations l | |||
! | |||
KJM/mc l | |||
Attachment j | |||
c: LeBoeuf, Lamb, Leiby & MacRae ! | |||
R. D. Martin, NRC Regional Administrator | |||
P. D. Milano, NRC Project Manager | |||
P. H. Harrell. NRC Senior Resident inspector | |||
TCh 'lb) | |||
~ 2807/3 o f, | |||
--- -_ | |||
~~g:mym | |||
- _ - _ _ - - - -- | |||
t | |||
---__ --_ _ _ - ___ __ ____ - - _ -_________ - _. ______ | |||
. | |||
* | |||
. ; | |||
* -O' ' | |||
. | |||
r | |||
i | |||
, ATTACHMENT | |||
! | |||
' | |||
! During an NRC inspection conducted on June 27 through July 1,1988, a violation | |||
of NRC requirements was identified. The violation involved failure to estab- | |||
, lish procedural controls in regard to conditional release of nonconforming , | |||
! items. In accordance with the "General Statement of Policy and Procedure for ' | |||
i NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1988), the violation is i | |||
' | |||
listed below: l | |||
4 | |||
l | |||
l Criterion XV of Appendix B to 10 CFR Part 50 and the licensee's approved j | |||
f quality assurance program description requires that measures be established ' | |||
) to control materials, parts, or components which do not conform to require- l | |||
ments, in order to prevent their inadvertent use or installation. The Qual- l | |||
ity Assurance Plan for Fort Calhoun Station, Unit No. 1. Section 7.4, para- t | |||
graph 4.2.3 provides for a "conditional release basis", for use of noncon- ; | |||
.1 forming items which can be corrected if a statement documenting the author- [ | |||
4 | |||
ity and technical justification is prepared. Paragraph 4.3.1 of the same ! | |||
' | |||
I plan also requires that procedures for the control of nonconforming items | |||
; shall be contained in the Quality Assurance Department Manual. [ | |||
; Contrary to the above, the Quality Assurance Department Manual procedures ! | |||
: for control of nonconforming items did not address a "conditional release ' | |||
j basis" although the process was being implemented, f | |||
i | |||
3 | |||
j This is a Severity Level IV Violation (Supplement I.D.) (285/8821-21) l | |||
. | |||
5 | |||
! | |||
OPPD RESPONSE j | |||
l | |||
I | |||
i | |||
The Reason for the Violation if Admitted l | |||
t | |||
OPPD admits the violation as stated. As described in Section 7.4 of the Qual- ! | |||
l ity Assurance Plan for Fort Calhoun Station, OPPD has the ability to provide a ! | |||
; "Conditional Release Basis" for nonconforming material. The procedures that ! | |||
, | |||
implement this provision center on nonconforming material at the point of re- , | |||
1 ceipt inspection. Items that were in operation 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 , | |||
OPPD has admitted that this method is a procedurally inadequate control mechan- i | |||
i ism. Therefore, OPPD has retained a consultant to restructure the Fort Calhoun ! | |||
Nonconformance Program. This project was initiated in July 1988. The major ; | |||
j) 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 ! | |||
j Plan, j | |||
: | |||
i | |||
' | |||
Technical justifications for use of nonconforming items were documented to en- ! | |||
! sure safe plant operation. Although the justiff:ations are adequate, the cited { | |||
4 NRs are still open, pending long term follow up on these itens. This will en- l | |||
sure proper corrective actions on the root causes are accomplished, and will ! | |||
. ensure 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 j | |||
; technical justifications, j | |||
! Any new NRs initiated for items already in operation (e.g., not receipt inspec- f | |||
j tion identified) will remain open until the revised procedures are in place. | |||
} l | |||
1 | |||
1 ! | |||
-- | |||
_ _ _ _ _ _ _ _ _ ____ _ | |||
. | |||
. * | |||
, , | |||
. s . | |||
' | |||
' | |||
, | |||
Aktachment(Continued) | |||
' | |||
The Corrective Stoos Which Will Be Taken | |||
I Each of the six cited NRs will be closed as expeditiously as possible over the | |||
, | |||
next 90 days, | |||
i | |||
! OPPD is undertaking a general programmatic upgrade of procurement and storage | |||
practices for safety related material and services to bring them into compli- | |||
ance with currently accepted NRC and INPO criteria, and to maintain the prac- | |||
i 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: | |||
1. Revise Standing Order G-18 to include a separate dedicated section for pro- | |||
, cessing nonconformances for operational "Conditional Release Basis" mater- | |||
; tal. | |||
l 2. Ensure Standing Order G 18 still clearly addresses the control of noncon- | |||
3 | |||
forming material discovered during receipt inspection. | |||
: | |||
3. Establish a new vehicle for the resolution of minor or questionable receipt | |||
inspection discrepancies. | |||
4. Provide proper "flagging" that the NR is a "Conditional Release Basis" NR | |||
on both the revised form and in the technical justification used for re- | |||
lease. | |||
5. Provide administrative controls to limit the scope of an NR such that if | |||
additional concerns are identified at a later date, they will become the | |||
subject of a separate NR. | |||
6. Provide clear authority as to who shall authorize the release of the mater- | |||
tal for use. | |||
7. Revise QADP 13 and Standing Order G 22 to include provisions for engineer- | |||
ing review. | |||
Date of Full Comoliance | |||
OPPD will be in full compilance by December 1. 1988. | |||
. | |||
}} |
Revision as of 15:25, 2 January 2021
ML20154R374 | |
Person / Time | |
---|---|
Site: | Fort Calhoun |
Issue date: | 09/21/1988 |
From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | Morris K OMAHA PUBLIC POWER DISTRICT |
References | |
NUDOCS 8810040237 | |
Download: ML20154R374 (2) | |
See also: IR 05000285/1988021
Text
3
A
^ ~ '
-
. SEP 2 l 1988
In Reply Refer To:
Docket: 50-285/88-21
Omaha Public Power District
ATTN: Kenneth J. Morris, Division Manager
Nuclear Operations
1623 Harney Street
Omaha, Nebraska 68102
Gentlemen:
Thank you for your letter numbered LIC-88-760, in response ~ to our letter
and Notice of Violation dated July 27, 1988. We have reviewed your reply and
find it responsive to the concerns raised in our Notice of Violation. We will
review the implementation of your corrective actions during a ^;ture
inspection to determine that full compliance has been achieved and will be
maintained.
Sincerely,
'rigual ,
, ,,
.
a D. IQ
L. J. Callan, Director
Division of Reactor Projects
CC:
Fort Calhoun Station
ATTN: W. G. Gates, Manager
P.O. Box 399
Fort Calhoun, Nebraska 68023
Harry H. Voigt. Esq.
LeBoeuf. Lamb Leiby & MacRae
1333 New Hampshire Avenue, NW
Washington, D. C. 20036
Nebraska Radiation Control Program Director
RIV:MQPS M C:MQPS M S fd 0:DRP4 Ejl
WMcNeill/cjg IBarnes JLN hoan LJCalltn
9/$ 4/88 7/w/88 9/J.0/88 i / 21 / 8 8
8G10040237 880921 h \\
gaa noccxosoopgg5
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
'
.
.- .
(haha Public Power District -2-
bec to DMB (IE01)
bec distrib. by RIV:
R.D. Martin, RA RPB-DRSS
Section Chief (DRP/P) MIS System
RIV File DRP
RSTS Operator Project Engineer DRP/B
Lisa Shea, RM/ALF P. Milano, NRR Project Manager
W. McNeill I. Barnes
.
b
5
i
P
--w . - - - _ . _ , , . -_ --, _ - , _ __ , _ . _ _- _ , _ _ ._ ____ __ ,_,
-
.
.'.
. _m S _= '= = - -4 : .-. m. - y - --
4-s : . = - - = = - ----:------:
. . . _. _ . . . - _ _ . _. . _ . _ _ _. _ _ _
Om;ha Public Power District
1623 Harney Omaha. Nebraska 68102 2247
3[lKC)[h[lW/D 1
402/536 4000 - ,!
0
'
'
i
SEP I ? te
. -- t
LIC-88-760 - _ _
l
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk i
Mail Station PI-137 l
Washington, DC 20555 ;
i
References: 1. Docket No. 50-285
2. Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated
July 27, 1988
Gentlemen:
t
SUBJECT: Response to Notice of Violation - NRC Inspection Report
50-285/88-21 l
1
Omaha Public Power District (OPPD) 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 submittal date of September 6, 1988 was
!
discussed between Mr. R. Mullikin of Region IV and Mr. J. J. Fisicaro of my !
l
staff. l
.
1 If you have any questions concerning this matter, please contact us. I
'
!
( Sincerely, ,
/n .-
// . /f N'
I k.J. Morris !
l Division Manager
l
Nuclear Operations l
!
KJM/mc l
Attachment j
c: LeBoeuf, Lamb, Leiby & MacRae !
R. D. Martin, NRC Regional Administrator
P. D. Milano, NRC Project Manager
P. H. Harrell. NRC Senior Resident inspector
TCh 'lb)
~ 2807/3 o f,
--- -_
~~g:mym
- _ - _ _ - - - --
t
---__ --_ _ _ - ___ __ ____ - - _ -_________ - _. ______
.
. ;
- -O' '
.
r
i
, ATTACHMENT
!
'
! During an NRC inspection conducted on June 27 through July 1,1988, a violation
of NRC requirements was identified. The violation involved failure to estab-
, lish procedural controls in regard to conditional release of nonconforming ,
! items. In accordance with the "General Statement of Policy and Procedure for '
i NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1988), the violation is i
'
listed below: l
4
l
l Criterion XV of Appendix B to 10 CFR Part 50 and the licensee's approved j
f quality assurance program description requires that measures be established '
) to control materials, parts, or components which do not conform to require- l
ments, in order to prevent their inadvertent use or installation. The Qual- l
ity Assurance Plan for Fort Calhoun Station, Unit No. 1. Section 7.4, para- t
graph 4.2.3 provides for a "conditional release basis", for use of noncon- ;
.1 forming items which can be corrected if a statement documenting the author- [
4
ity and technical justification is prepared. Paragraph 4.3.1 of the same !
'
I plan also requires that procedures for the control of nonconforming items
- shall be contained in the Quality Assurance Department Manual. [
- Contrary to the above, the Quality Assurance Department Manual procedures !
- for control of nonconforming items did not address a "conditional release '
j basis" although the process was being implemented, f
i
3
j This is a Severity Level IV Violation (Supplement I.D.) (285/8821-21) l
.
5
!
OPPD RESPONSE j
l
I
i
The Reason for the Violation if Admitted l
t
OPPD admits the violation as stated. As described in Section 7.4 of the Qual- !
l ity Assurance Plan for Fort Calhoun Station, OPPD has the ability to provide a !
- "Conditional Release Basis" for nonconforming material. The procedures that !
,
implement this provision center on nonconforming material at the point of re- ,
1 ceipt inspection. Items that were in operation 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 ,
OPPD has admitted that this method is a procedurally inadequate control mechan- i
i ism. Therefore, OPPD has retained a consultant to restructure the Fort Calhoun !
Nonconformance Program. This project was initiated in July 1988. The major ;
j) 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 !
j Plan, j
i
'
Technical justifications for use of nonconforming items were documented to en- !
! sure safe plant operation. Although the justiff:ations are adequate, the cited {
4 NRs are still open, pending long term follow up on these itens. This will en- l
sure proper corrective actions on the root causes are accomplished, and will !
. ensure 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 j
- technical justifications, j
! Any new NRs initiated for items already in operation (e.g., not receipt inspec- f
j tion identified) will remain open until the revised procedures are in place.
} l
1
1 !
--
_ _ _ _ _ _ _ _ _ ____ _
.
. *
, ,
. s .
'
'
,
Aktachment(Continued)
'
The Corrective Stoos Which Will Be Taken
I Each of the six cited NRs will be closed as expeditiously as possible over the
,
next 90 days,
i
! OPPD is undertaking a general programmatic upgrade of procurement and storage
practices for safety related material and services to bring them into compli-
ance with currently accepted NRC and INPO criteria, and to maintain the prac-
i 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:
1. Revise Standing Order G-18 to include a separate dedicated section for pro-
, cessing nonconformances for operational "Conditional Release Basis" mater-
- tal.
l 2. Ensure Standing Order G 18 still clearly addresses the control of noncon-
3
forming material discovered during receipt inspection.
3. Establish a new vehicle for the resolution of minor or questionable receipt
inspection discrepancies.
4. Provide proper "flagging" that the NR is a "Conditional Release Basis" NR
on both the revised form and in the technical justification used for re-
lease.
5. Provide administrative controls to limit the scope of an NR such that if
additional concerns are identified at a later date, they will become the
subject of a separate NR.
6. Provide clear authority as to who shall authorize the release of the mater-
tal for use.
7. Revise QADP 13 and Standing Order G 22 to include provisions for engineer-
ing review.
Date of Full Comoliance
OPPD will be in full compilance by December 1. 1988.
.