05000285/LER-1987-026, Discusses 871015 Enforcement Conference W/Nrc Re Violations Noted in Insp Rept 50-285/87-21.Violation Re Failure to Issue LER for Unlocked Door.Util Prepared & Submitted LER 87-026 Re Violation,Per 871015 Discussion

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Discusses 871015 Enforcement Conference W/Nrc Re Violations Noted in Insp Rept 50-285/87-21.Violation Re Failure to Issue LER for Unlocked Door.Util Prepared & Submitted LER 87-026 Re Violation,Per 871015 Discussion
ML20236Q871
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 11/04/1987
From: Andrews R
OMAHA PUBLIC POWER DISTRICT
To: Bangart R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
LIC-87-732, NUDOCS 8711200334
Download: ML20236Q871 (2)


LER-2087-026, Discusses 871015 Enforcement Conference W/Nrc Re Violations Noted in Insp Rept 50-285/87-21.Violation Re Failure to Issue LER for Unlocked Door.Util Prepared & Submitted LER 87-026 Re Violation,Per 871015 Discussion
Event date:
Report date:
2852087026R00 - NRC Website

text

__-__ ______

l .

Omaha Public Power District -

1623 Harney Omaha. Nebraska 68102 3 402/536-4000 ,,~' ,

November 4, 1987 .

\ ,

LIC-87-732 hii s i0 R. Bangart g 6 BB5 U. S. Nuclear Regulatory Commission Region IV  ;

611 Ryan Plaza Drive, Suite 1000 l Arlington, Texas 76011 i

Reference:

1. Docket No. 50-285
2. NRC Enforcement Conference held October 15, 1987 for NRC Inspection Report 285/87-21
3. Licensee Event Report 87-026 dated October 28, 1987

Dear Mr. Bangart:

SUBJECT:

Follow-up to Enforcement Conference for Report 285/87-21 The Omaha Public Power District (OPPD) received Inspection Report 87-21 dated October 7, 1987. In response to that letter, representatives of OPPD met with Region IV on October 15, 1987. At that meeting, Mr. Ron Baer of your office summarized Violations 87-21-01 and 87-21-02, Mr. W. C. Jones provided opening remarks, and Mr. G. L. Roach provided most of OPPD's presentation.

The facts related to the two violations are correct as stated in Inspection Report 87-21 paragraph 6. The operator involved in the incident is considered to be a good employee with a history of procedural compliance. During his September 9, 1987 entry into Room 5, he went no further than the step-off pad and spent about one minute in a 10 mrem /hr field. His exposure for the day was 5 mrem.

Upon being notified of the unlocked door, immediate action taken was to confirm that no person was in Room 5, and the door was locked. The Supervisor -

Operations prepared a memorandum to the shift supervisors reminding them of the necessity to adhere to the requirements of technical specifications and station procedures and insuring they inform their crews to do likewise. Procedures governing Very High Radiation Areas were emphasized.

The root cause for the first violation was determined to be human error in that the operator failed to verify that the door was locked. To reduce the possi-bility of a recurrence, the task of checking Very High Radiation Area doors to ensure they are locked has been explicitly assigned to health physics techni-cians whenever an entry has been completed. This responsibility is clarified in a recent change (awaiting training) to Section 3 of the Radiation Protection Manual. In addition, the lock on Room 5 was replaced with a spring actuated lockset. Two buttons on the door edge, concealed under a faceplate to avoid advertent change, allow the door to be set in a manual or automatic lock mode.

Other doors that can accommodate such a lockset will be changed out on receipt of the requisite fire-rated hardware.

8711200334 871104 5 g/

ADOCK 0500 4s m4 pg {DR

R. Bangart LIC-87-732 Page 2 The second violation, (87-21-02), occurred at the same time as the first. Pur-suant to requirements of the Radiation Protection Manual, any entry into a Very High Radiation Area must involve a health physics technician with a dose rate instrument. The operator failed to arrange for the presence of a health phy-sics technician during his entry to Room 5 despite the fact that a card reading

" Contact H.P. prior to entry" was posted outside the door, below the words "Very High Radiation Area". The operator, when interviewed, believed he was in compliance with Technical Specification 5.11.2. This is true, however, he was not in compliance with the more restrictive Fort Calhoun Station Radiation Protection Manual.

The investigations of the Supervisor - Chemical and Radiation Protection and the Acting Supervisor - Operations resulted in the conclusion that management had not effectively communicated the purposes of the procedural requirements of Health Physics Technician attendance during Very High Radiation Area entries and of the necessity of establishing the Very High Radiation Area boundary for Room 5 beyond the 1000 mrem /hr isodose line in that room.

Group meetings and more rigorous management field oversight is being under-taken. Initial meetings to provide more explicit communication of management expectations were held prior to November 2. A review and update of General

! Employee Training with regard to radiation protection requirements is complete.

l These changes are expected to provide a fresh perspective on management communication of regulatory requirements including procedural compliance.

The last portion of the meeting concerned an apparent violation of 10 CFR 50.73 regarding failure to issue an LER for the unlocked door. OPPD noted at the meeting that our perspective has been that the LER system is for " Licensee" events. This event we,s found by the NRC and was documented in an inspection report. OPPD does not believe that the intent of the LER process was to write an LER for NRC-identified violations. We believe that this would constitue an unnecessary duplication in reports. Based on the discussions at the meeting on October 15, however, OPPD did prepare and submit LER-87-026 which addresses this incident in part.

If you should have additional questions, please do not hesitate to contact us.

Sincerely, R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.

Washington, DC 20036 R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector