ML20137B374

Responds to NRC 850812 Ltr Re Violations Noted in Insp Rept 50-285/85-15.Corrective Actions:Standing Order C-5, Station Mod Control, Changed & Measures Implemented for Controlling Interim Prints & Training Hotline Issued on 850905

ML20137B374
Person / Time
Site:	Fort Calhoun
Issue date:	09/11/1985
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20137B370	List: ML20137B368 ML20137B374
References
LIC-85-421, NUDOCS 8601150304
Download: ML20137B374 (3)

Text

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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102-2247 402!536-4000 September 11, 1985 '

l) b- @ F [] V B' LIC-85-421 Mr. E. H. Johnson, Chief f.

U i' SFP I 3lgg5

'O Reactor Project Branch L_

i' U. S. Nuclear Regulatory Comission _;

Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

Reference:

Docket No. 50-285

Dear Mr. Johnson:

IE Inspection Report 85-15 Notice of Violation The Omaha Public Power District received the subject report dated August 12, 1985. This report forwarded a notice of violation for " Failure to Establish Document Control Procedures." Pursuant to 10 CFR 2.201, please find attached the District's response to this violation.

Sincerely,

/ ':' W i R. L. Andrews

! Division Manager Nuclear Production RLA/DJM/rh Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, DC 20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Inspector 8601150304 860106 gDR ADOCK 05000285 (g/, PDR

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5 ATTACHMENT During an NRC inspection conducted on July 1-August 31, 1985, a violation of NRC requirments was identified. The violation involved a failure to estab-lish document control procedures for plant drawings undergoing revision. In accordance with the " General Statement of Policy and Procedure for NRC Enforce-ment Actions," 10 CFR Part 2, Appendix C (1985), the violation is listed be-low:

A. Failure to Establish Document Control Procedures 10 CFR 50, Appendix B, Section VI, " Document Control," requires that

" measures . . . be established to control the issuance of documents, such as . . . drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that docu-ments, including changes, . . . are distributed to and used at the location where the prescribed activity is perfomed."

Contrary to the above, the licensee failed to establish procedures to control "maded up mechanical and electrical prints" contained in Safety Related Design Change Order (SRDCO) packages approved by the System Acceptance Committee under Step 5.8.5 of Standing Order G-21, " Station Modification Control." The official drawings are not part of a drawing control system that: (1) identifies changes in progress to a specific drawing, and (2) makes the marked up (interim) drawings available to the craf tsmen. These maded up prints are the only documents containing current information for use by plant personnel during " design document updating" perfomed by Generating Station Engineering in accordance with Step 6.1 of Standing Order G-21.

This is a Severity Level IV violation (Supplement 1.D) (50-285/8515-01).

Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District is hereby required to submit to this Office, within 30 days of the date of this letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Wiere good caus3 is shown, consideration will be given to extending the response time.

OPPD's Response (1) Reason for the violation if admitted.

While an informal program did exist, whereby " marked up mechanical and electrical prints" contained in SRDC0 packages approved by the System Acceptance Committee (SAC) were indeed filed in a specific location for use as " interim" drawings, no program existed for identifying these drawings as " official," interim or otherwise.

In addition, the prints located in this "infomal file" were not identified as " interim" or " official." The bulk of the plant staff was unaware of this infomal file of SAC approved packages /

prints since there was no Standing Order or formalized and docu-mented procedure describing the file or its intended use. Hence, the District agrees that a violation occurred pursuant to 10 CFR 50, Appendix B, Section VI.

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4 OPPD's Respons_e (Continued) i (2) Corrective steps taken and results achieved.

As a result of the violation, Standing Order C-5 has been changed and measures have been implemented for controlling interim prints received as a result of a modification package approved by SAC. I i

4 Specifically, when prints are received as part of a design change reqtiest/ modification request package, the Generating Station Engi-neering (GSE) Records Coordinator will be responsible for maintain-  ;

ing the plant file of current prints issued for construction in i the Records Center. These prints will be filed on " stick files" by Modification Request (MR) number.

After acceptance of the Nt by the SAC, the SAC Chaiman will en-sure that one set of the marked up construction drawings is for-warded to the GSE Records Coordinator for the plant file. These marked up drawings will be available to the plant staff during the -

4 interim period when GSE is transferring the marked up information 3 to the as-built originals for controlled issuance. After issuance

and receipt of the as-built drawing, the marked up copy will be destroyed. -

A Training Hotline (index number 3-6-11) was issued September 5,

., 1985, outlining the recent revision to Standing Order C-5. This

] will ensure applicable Station personnel are aware of the availa-

bility of " interim" prints.

(3) Corrective steps which will be taken to avoid further violations.

In order for full compliance to be achieved, the present uncon-trolled " interim print" file previously addressed as the "infor-i mal" storage location for packages / prints following SAC approval, will need to be reviewed in its entirety. This review will entail reviewing all prints associated with these accepted modification ,

packages, ensuring drawings are available either as " official l drawings" or as " interim drawings" and ensuring that the prints are appropriately identified as " interim or " official" drawings. l

(4) Date when full compliance will be achieved. .

i l The actions described in (3), above, will be completed by the end  !

l of September, 1985.

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