IR 05000285/1988021

Insp Rept 50-285/88-21 on 880627-0701.Violations Noted. Major Areas Inspected:Corrective Action Program

ML20207C002
Person / Time
Site:	Fort Calhoun
Issue date:	07/25/1988
From:	Barnes I, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207B993	List: IR 05000285/1988021 ML20207B988 ML20207B997
References
50-285-88-21, NUDOCS 8808040385
Download: ML20207C002 (6)

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I APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION Region IV NRC-Inspection Report: _50-285/88-21 Operating License: DPR-40 Docket: 50-285 Licensee: Omaha Public-Power District (0 PPD)

1623 Harney Street Omaha, Nebraska 68102 Facility Name: Fort Calhoun Station (FCS)

Inspection At: FCS, Blair, Nebraska Inspection Conducted: June 27 through July 1, 1988 Inspector: 8<e 7- 2f-6'r

/h W. M. McNeill, Reactor Engineer, Materials and Date Quality Programs Section, Division of Reactor Safety Approved: 8% 7-25-PP I. Barnes, Chief, Materials and Quality Programs Date Section, Division of Reactor Safety Inspection Summary Inspectior. Conducted June 27 through July 1, 1988 (50-285/88-21)

Areas Inspected: Routine, unannounced inspection of the corrective action progra Results: Within the area inspected, one violation was identified (failure to establish procedural controls in regard to conditional release of nonconforming items, paragraph 2).

8808040385 880727 PDR ADOCK 050002G5 Q PDC

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DETAILS Persons Contacted

• C. Brunnert, Operations Quality Assurance (QA) Supervisor M. Butt, Human Performance Evaluation System Coordinator S. Clayton, Shift Technical Advisor

• J. Fisicaro, Nuclear Licensing and Regulatory Affairs Manager

• R. Jaworski, Station Engineering Manager

• J. Kecy, Reactor Engineer K. Miller, Maintenance Supervisor

• K. Morris, Nuclear Operations Division Manager

• A. Richards, QA & Quality Control (QC) Manager B. Shubert, Shift Technical Advisor

• C. Simmons, Onsite Licensing Engineer

• Denotes personnel attending exit meetin The NRC inspector also contacted other personnel including administrative and clerical personne . Corrective Action (92720)

The objective of this inspection was to detennine whether the licensee has developed a comprehensive corrective action program to identify, follow, and correct safety-related problems. In this regard, the NRC inspector reviewed: (a) the QA program description found in Appendix A of the Updated Safety Analysis Report, Revision 4, dated July 1987; (b) QA Plan for Fort Calhoun Station, Unit No.1, Revision 12; and (c) the implementing procedures contained in the Attachment to this repor Operating Events The NRC inspector found that a program for reporting operational events was documented in station standing orders. Events are documented and prioritized; initial corrective actions are established, followed and reported as necessary to the NRC via the Licensee Event Reports (LERs). However, the program had been subject to significant changes, namely computerization of the infortnation, since the beginning of the yea The new computerized program was not yet described in procedure Based on a sample review of recent "Incident Reports," it was found that the computer coding of the reports was not consistent. It was difficult to relate reports of a similar characte For example, two recent reports on the inservice inspection (880107 and 880031) were found to be coded differently. The consideration of root cause analysis was not yet addressed in practice or procedures, but the licensee reportedly will do so at some time in the futur *

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b. Internally Identified Problems The NRC inspector found that internally identified problems requiring corrective maintenance were identified and trended with other i

maintenance activities as part of the station performance indicator Yet this was recent, within the past several months, and was not defined in a program and procedures. The licensee in this area has identified in his planning documents that a comprehensive approach such as correlating corrective maintenance with LERs, QA surveillance findings, and other information will be undertaken. Generic consideration and root cause analysis has yet to be undertaken in this are The NRC inspector found that quality documents such as nonconfomance reports (NRs), deficiency reports (DRs), surveillance items (sis), and quality reports (QRs) were addressed in QA department procedures. Based on a review of recent quality trend reports, it was found by the NRC inspector that the licensee was using items which were identified on open or unresolved NRs. A total of six such NRs (i.e., NRs 86-01, 86-03, 86-54, 87-40, 87-67, and 87-75) were identifie The NRC inspector noted that the QA plan provided a

"conditional release basis," but this process was not defined in QA department procedures. The absence of procedures in this area appears to have resulted in the following:

Technical justifications for use of nonconforming items were documented for each of the above NRs, but the justifications did not address that the releases were conditiona The lack of defined authority resulted in technical justifications originating from a variety of station staff (e.g., maintenance, station engineering, station manager, and nuclear production engineering).

Conflicting information was contained in the technical justifications such as the status of the engineering evaluation of the upper guide structure lift rig on NR 86-03 and the material composition of replacement Limitorque declutch shafts on NR 87-4 *

The status of equipment was not clear because the scope of hrs was changed to include additional items such as Valcor valve springs on NR 86-01 and charging pump gaskets on NR 87-7 The lack of procedural controls in regard to "conditional release" of nonconforming items was identified as an apparent violation (285/8821-01).

Another observation of the NRC inspector was that, although quality problenis are trended in monthly reports to upper management, the effectiveness of these trend reports may be questionable. It was noted that the quality trend reports for the past year have consistently identified a problem with implementation of maintenance procedure =

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This was.also identified as a problem in a recent management review of FCS by Stone & Webster. The Stone & Webster report also cited the same sort of problem in the health physics area. The quality trend reports address this area but did not identify a similar proble c.- Externally Identified Problems NRC inspection findings were tracked in'the quality trending reports but this was not procedurally required to be performed. NRC reports such as Information Notices, Bulletins, Generic Letters, were addressed in corporate office procedures. The implementation of these procedures will have to be addressed in a corporate office' inspectio INP0 reports such as Significant Operating Experience Reports, and Significant Event Reports were addressed in site procedures. Based on a review of a sample of such reports, the identification and review of problems was found to be in conformance with procedure One observation by the NRC inspector was that the NRC and INP0 reports often cover the same subject and it was difficult to see how, when both NRC and INP0 addressed the same subject, the review activities would be coordinated between site and corporat Human Performance Evaluation System FCS has established a Human Performance Evaluation System program, but this has not been formalized in procedures. The program is based on INP0's "near miss" event concept. The only case addressed to date was reviewed. The NRC inspector noted that the program as drafted does not include subjects such as allegations or employee concern Summary This inspection identified that a basis for a comprehensive corrective action program was present at FCS; however, significant elements of the program were found to be in development (as part of a general improvement program) and were neither formalized in procedures nor fully implemented. Additional review of the program and its implementation will be performed during a subsequent inspectio . Exit Meeting The NRC inspector conducted an exit meeting on July 1,1988, with the licensee personnel denoted in paragraph 1. The NRC resident inspector also attended. At this meeting, the scope and findings of the inspection were summarize The licensee did not identify any of the information discussed at the exit as proprietary.

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ATTACHMENT

' Control of Nonconforming Items, QAM 7.4, Revision 0, dated September 1, 198 . Deficiency Control and Corrective Action, QAM 10.4, Revision 0, dated September 1, 198 . 10 CFR 21 Reporting of Defects and Noncompliance, QAM 10.5, Revision 2, dated January 12, 198 . Nonconformance Control, SO G-18, Revision 11, dated December 29, 198 . Re:eiving,. Shipping, Stores Control and Storage of Critical Element and Radioactive Material Packaging, Fire Protection Materials and Limited CQE, S0 G-22, Revision 27, dated March 14, 198 . Reporting of Defects and Non-Compliance to the Nuclear Regulatory Conunission, S0 G-42, Revision 7, dated December 22, 198 . Operating Experience Review, SO G-55, Revision 3, dated January 25, 198 . Procedures for Feedback of Operating Experience to Plant Staff, S0 0-39, Revision 4, dated September 24, 198 . Reportable Occurrences, S0 R-3, Revision 9, dated March 18, 1987, 1 Station Incident Reports, S0 R-4, Revision 14, dated November 6, 198 . Notification of Significant Events, S0 R-11, Revision 9, dated December 17, 198 . Control of Nonconforming Items and Materials, QADP-13, Revision 4, dated January 14, 198 . Deficiency Tracking and Trending, QADP-14, Revision 4, dated March 31, 198 .- Control of Deficiencies and Corrective Action, QADP-17, Revision 4, dated February 3, 198 . 10 CFR 21, Reporting of Defects and Noncompliance, QADP-19, Revision 4, dated May 2, 1988.

16. Control of Deficiencies and Corrective Action, GSEP A-8, Revision , dated l February 198 . Regulatory Requirements Log, NPD G-2, Revision 1, dated December 31, 198 . Nuclear Production Division Action Log, NPD G-3, Revision 0, dated August 1, 198 . . ._ _ _ . _ _ _ _ ..- . _ . . _ . . . _ _ _ _ . _ . . . . _ . - _ - .

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4- '19. ' Reporting and Corrective Action of Conditions Adverse to Quality, NPD QA-11, Revision 2, dated February 26, 1988, i-

'2 Reporting of Defects and Noncompliance to the Nuclear Regulatory

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Comission, NPD QA-12, Revision 1, dated May 5,198 i-f-1 s

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