ML20236P384
| ML20236P384 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/07/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8708120328 | |
| Download: ML20236P384 (2) | |
See also: IR 05000285/1987013
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LAUG 7
1987
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. Docket: 50-285/87-13
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In Reply Refer To:
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Omaha Public Power District
ATTN:
.R. L. Andrews, Division Manager-
Nuclear Production
1623 Harney Street .
Omaha, Nebraska 68102'
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Gentlemen:
Thanklyou for your letter of July 30,' '1987
in response .to our letter-
and Notice of Violation dated June 30,11987. . 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. future
inspection to determine that full compliance has been achieved and will be
maintained.
Sincerely,
Orignal G1gned By '
J. E. Gagilcrdo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
. W. G. Gates, Manager
Fort Calhoun' Station
P. O. Box 399
- Fort Calhoun, Nebraska 68023
Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae
- 1333 New Hampshire Avenue, NW
Washington, DC 20036
Kansas. Radiation Control Program Director
. Nebraska Radiation Control Program' Director
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Omaha Public Power District
1623 Harney Omaha, Nebraska 68102-2247
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July 30, 1987
LIC-87-543
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J. E. Gagliardo, Chief
Reactor Projects Branch
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V. S. Nuclear Regulatory Commission
Region IV
611 Ryan Plsza Drive, Suite 1000
Arlington, Tx. 76011
Reference:
1.
Docket No. 50-285
2.
Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews)
dated June 30, 1987
Dear Mr. Gagliardo:
SUBJECT:
Inspection Report 50-285/87-13
Omaha Public Power District (0 PPD) received the subject inspection report dated
June 30, 1987. One violation was identified concerning failure to control
special processes during installation of seism' wall supports.
Accordingly, pursuant to 10 CFR 2.201, Attachment A contains OPPD's response to
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this violation.
Attachment B contains a r,esponse to the three previously
identified unresolved items related to the operator training program.
If you
need any further information, please let us know.
Sincerely,
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R. L. Andrews
Division Manager
Nuclear Production
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Attachment
cc: LeBoeuf, Lamb, Leiby & MacRae
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1333 New Hampshire Ave., N. W.
Washington, DC 20036
J. A. Calvo, NRC Project Director
A. Bournia, NRC Project Manager
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P. H. Harrell, NRC Senior Resident Inspector
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Attachment A
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D * ng an NRC inspection conaucted on May 1-31, 1987, a violation of NRC
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requirements was identified. The violation involved a failure to qualify a
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butt weld procedure prior to use for installation of seismic wall supports.
In
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accordance with the " General Statement of Policy and Procedure for NRC
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Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is
listed.
Criterion IX of Appendix B to 10 CFR Part 50 states, in part, that measures
shall be established to ensure that special processes, including welding,
are controlled and accomplished using qualified procedures in accordance
with applicable codes and standards.
Paragraph 4.2.2 of Section 6.6 of the licensee's Quality Assurance Manual
states, in part, that special processes shall be performed in accordance
with written, qualified procedures.
These procedures are to be qualified
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in accordance with applicable codes and standards.
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Contrary to the above, the licensee used, during the 1985 refueling outage,
welding procedure for installation of seismic wall supports with square
butt welds; however, the square butt weld procedure was not qualified to
AWS D1.1-8;. The design instruction (MR-FC-81-180) issued for installation
of the wall seismic supports stated that all weld procedures shall be
qualified in accordance with AWS D1.1-83.
This is a Severity Level IV violation.
(Supplement I) (285/8713-01)
OPPD's Response
Reasons for the Violation if Admitted
OPPD admits the violation.
The design of the welds for the modification were
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based on AWS D1.1-83. The existing plant weld procedures referenced ASME
Boiler and Pressure Vessel Code Section IX: Rather than develop a new weld
procedure, one of the existing weld procedures was used.
Corrective Steos That Have Been Taken and Results Achieved
Calculations based on the as-built weld size and configuration were completed,
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and an evaluation of the results show that, with very conservative assumptions,
the welds are adequate to bear the design. loads.
In April of 1987, a review of
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the welding program was begun.
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Corrective Steps Which Will be Taken to Avoid Further Violations
A review and upgrade of the we] ding program will be completed this year. The
ASME Boiler & Pressure Vessei Code,Section IX weld procedures will be updated,
new weld procedures for AWS D1.1 will be put into effect, and an engineering
guide will be issued. The engineering guide will address preparation of weld
procedures, including procedure review. Training of the affected staff will
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ensure that design engincers are cognizant of the applicable code requirements.
Date When Full Compliance Will be Achieved
OPPD is currently in compliance. The programmatic changes to increase the
number of weld procedures and the review of the documentation requirements
associated with the welding program will be completed by January 1988.
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Attachment B
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Pursuant to a request in Inspection Report 87-13, three previously identified
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unresolved. items related to the operator training program are noted below.
For
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each item, actions OPPD intends to take are provided, along with the dates when
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completion is anticipated.
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Unresolved Item (URI) 285/8624-01 related to establishing an effective training
records program to document completion of training activities. A discussion of
the follow-up performed on URI 285/86242-01 was provided in paragraph 2 of the
NRC Inspection Report 50-285/87-10. The followup inspection indicated that the
licensee had just recently initiated actions to establish an auditable record
system.
Response: OPPD recognized the need for an improved training records system
prior to the August 1986 inspection and was in the process of purchasing a new
computerized training records system at that time. A purchase order was placed
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for the computerized training records system, OPTIM, in September 1986. The
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software design for OPTIM was approved by 0 PPD in December 1986. OPTIM was
delivered for testing in March 1987 and is currently installed and running in
the " Test CICS" mode on the OPPD Main Frame Computer System. OPTIM is
functional and producing training records for the following programs:
1987/88 Licensed Operator Requal Training
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.1987 Licensed Operator Simulator Training
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Licensed 0'ty (Operator Watchstanding)
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Reports can be generated which indicate the training each individutl has
completed.
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In January 1987, OPPD retained the services of a training records consultant
who had previously corrected deficiencies in the training records system at
another nuclear facility. This individual redesigned a portion of the OPPD
training records system and is currently implementing the training records
system on OPTIM.
In addition to the above records, up-to-date data for the
following additional records will be available on OPTIM by January 1,1988:
R0 Initial Training Program
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SRO Up grade Training Program
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Initial Simulator Training
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Accelerated Requalification Training
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During the completion of OPTIM software design and data loading, a manual
training records system has been implemented which assures 1987 training
records are maintained in accordance with 10 CFR Part 55. This system will be
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added to OPTIM by January 1, 1988. Utilization of OPTIM will greatly increase
the speed and efficiency of conducting record searches.
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Attachment B
(Continued)
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Unresolved Item 285/8624-02 related to not providing on-the-job training for
all aspects of plant operations by failing to give classroom lectures for the
loss of instrument air and the loss of shutdown cooling. A discussion of this
item was provided in Paragraph 2 of NRC Inspection Report 50-285/87-10.
The
follow-up inspection indicated that no corrective actions had been initiated in
providing these classroom lectures since the problem was initially identified
in August 1986.
Resoonse: Training on the abnormal operating procedures for loss of instrument
air and loss of shutdown cooling was conducted during the second and third
requalification rotations of 1987, respectively. All licensed operators, and
some licensed staff members, have completed this training.
Licensed staff
members who have not received training are required to review these abnormal
operating procedures and pass a quiz by August 28, 1987.
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Unresolved Item 285/8624-03 related to providing a preplanned lecture series on
E0Ps. This item was. discussed in paragraph 2 of NRC Inspection Report
50-285/87-13. The follow-up inspection indicated that some E0Ps were discussed
during simulator training given in the early part of 1987, but training on all
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E0Ps had not been provided.
Response: This item related to a lack of objective evidence that 15 of the
R0's and-SR0's had attended preplanned lectures on emergency procedures during
1984 and 1985.
It is OPPD's belief that these 15 licensed individuals did
attend proplanned lectures on emergency procedures prior to the implementation
of the revised E0Ps in January 1986, but that this training was not
documented.
In addition, E0P training was also conducted during simulator
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training in July and August of 1986. OPPD believes this unresolved item is due
to inadequate training records rather than a failure to provide E0P training.
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Therefore, OPPD believes adequate E0P training was provided.
During 1986, the OPPD Training Organization received feedback from licensed
operators that additional E0P training on the simulator was needed rather than
additional preplanned lectures. Therefore, the training organization scheduled
E0P simulator training for the first quarter of 1987.
All Licensed individuals received training on at least six of the seven E0P's
during simulator training the first quarter of 1987.
This training consisted
of classroom sessions and/or practical sessions on the simulator floor. All
but ten licensed individuals have received training on all E0Ps during 1987.
Ten Licensed individuals (seven operators and 3 staff members) have not yet
received training on E0P-02, " Electrical Emergency." during 1987. Training on
E0P-02 will be conducted during the next requal rotation scheduled to start
August 24, 1987 and end Octobef 9, 1987.
It is OPPD's belief that practicing
the execution of E0Ps on the simulator is the most important aspect of E0P
training. Therefore, execution of the E0Ps was emphasized during the 1987
requalification training on the CE simulator..
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A review of the lectures given during the 1987 simulator training identified
certain licensed individuals who have not received " preplanned lectures" on
certain F9Ps. Therefore, additional preplanned lectures on E0Ps will be
incorporated into the requalification schedule during the 1987-1988
requalification interval. This will most likely be done during simulator
training in 1988.
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