ML20154R374

Ack Receipt of 880727 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/88-21

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

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. 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 ,

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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

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LIC-88-760 - _ _

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U. S. Nuclear Regulatory Commission

Attn: Document Control Desk i

Mail Station PI-137 l

Washington, DC 20555  ;

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References: 1. Docket No. 50-285

2. Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated

July 27, 1988

Gentlemen:

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SUBJECT: Response to Notice of Violation - NRC Inspection Report

50-285/88-21 l

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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

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discussed between Mr. R. Mullikin of Region IV and Mr. J. J. Fisicaro of my  !

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staff. l

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1 If you have any questions concerning this matter, please contact us. I

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( Sincerely, ,

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I k.J. Morris  !

l Division Manager

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Nuclear Operations l

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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

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, ATTACHMENT

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! 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

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listed below: l

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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- [

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ity and technical justification is prepared. Paragraph 4.3.1 of the same  !

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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

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j This is a Severity Level IV Violation (Supplement I.D.) (285/8821-21) l

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OPPD RESPONSE j

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The Reason for the Violation if Admitted l

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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  !

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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

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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.

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Aktachment(Continued)

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The Corrective Stoos Which Will Be Taken

I Each of the six cited NRs will be closed as expeditiously as possible over the

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next 90 days,

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! 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-

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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.

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