IR 05000285/1994020
| ML20024J249 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/06/1994 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Tira Patterson OMAHA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20024J250 | List: |
| References | |
| EA-94-193, NUDOCS 9410130074 | |
| Download: ML20024J249 (6) | |
Text
{{#Wiki_filter:Q UN11 E D ST ATES j ; P "' % / A NUCLEAR REGULATORY COMMISSION , ? RE GION IV j[ G11 R Y AN PL AZ A DRIVE, SutT E 00 p, ARLINGTON T E X A5 760118064
' " OCT - 61994 '....- Docket: 50-285 License: DPR-40 EA 94-193 Omaha Public Power District
ATIN: T. L. Patterson, Division Manager Nuclear Operations Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 SUBJECT: NOTICE OF VIOLATION AND ENFORCEMENT CONFERENCE SUMMARY (NRC INSPECTION REPORT NO. 50-285/94-20) This refers to the enforcement conference held on September 27, 1994, with Mr.
W. C. Jones and c,ther members of his staff, related to the decisions made on May 26, 1994 connected with a spill of h..drazine in the Fort Calhoun Station turbine building and the subsequent actions to neutralize the spill. The ' details of these events are documented in NRC Inspection Report 50-285/94-20, issued on September 19, 1994. This report identified as an apparent violation the f ailure to properly assess and classify the conditions as an Alet t in accordance with your Radiological Emergency Response Plan and Emergency Plan implementing Procedures.
During the enforcement conference, Omaha Public Power District (0 PPD) representatives presented a summary of the actions and decisions made in connection with the events of May 26, 1994. OPPD representatives concluded that the operating staff failed to properly assess and dassify conditions as a Notification of Unusual Event shortly after the spill and neutralization attempt. 0?PD representatives also acknowledged that the operating staff 'ater failed to classify conditions as an Alert when measurements of airborne concentrations of hydrazine in the turbine building exceeded the specified Emergency Action Level. The root causes and safety significance related to the events were discussed and the lessons learned and corrective actions presented. A list of those attending the enforcement conference and the OPPD presentation material are provided (Enclosures 2 and 3).
- Based on the results of the inspection and the information provided during the enforcement conference. certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice'of Violation
, (Notice). The violation is for failure to promptly assess and classify emergency conditions on May 26, 1994, in accordance with your Radiological r Emergency Response Plan and Emergency Plan Implementing Procedures.
The violation relates to your failure to classify actual plant conditions as a Notification of Unusual Event at or about 3:25 a.m. following a toxic gas release in the protected area.
9410130074 941006 PDR v. DOCK 05000205 f,
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> A violation is not being issued for the failure to declare an Alert at or i about 6:48 a.m. when the initial measurements of hydrazine in the turbine i
building were reported above I part per million (ppm). According to your emergency classification procedures, such a classification was required for a i toxic gas release resulting in hydrazine concentrations greater than 1 ppm
within the protected area of the plant.
In reaching this decision, we i concluded that such a citation would not address our concerns, as discussed in ? the paragraph below.
In addition, we considered the significance of not I declaring an ALERT at this stage of the event to be reduced because by the l i time measurements of airborne hydrazine were reported to the Shift Supervisor, the release of the toxic gas had ended, access to the area had been i controlled, and additional plant staff had arrived onsite to augment emergency l resources.
Therefore, at that time, conditions were not such that a , significant threat to the safe operation of the plant existed. Also, as noted i in the inspection report, a retrospective review of the events found that you l had a sufficient number of qualified operating staff on shift at the time of , the release to have assumed the critical duties of the operators affected by i the release had that need arisen. Therefore, your capability to achieve and } maintain a safe shutdown condition was not significantly affected.
l
i Of greater importance, the inappropriate actions taken, at or about 3:25 a.m., to neutralize the spill created a potential degradation in the level of plant l safety as well as a potential to cause serious personnel injury.
Had j additional operating staff been exposed to the toxic gases, or had the i exposures been more severe, the degradation in the level of plant safety could have been significant.
In addition, the effects of the release impacted your i ability to obtain prompt measurements of the toxic gases.
Had prompt I measurements been obtained, there is little question that hydrazine ! concentrations would have been higher than those reported at 6:48 a.m., which ! exceeded your Emergency Action Level criteria for an Alert.
Had these events ! been properly assessed and acted upon, your emergency response organization ! would have been activated to provide the level of staff augmentation needed to
respond if conditions had worr ned. At the least, you should have timely classified this event as a No' 'ation of Unusual Event (NOVE).
Therefore,
v to declare a NOUE at or about 3:25 a.m.
the violation is for your fail j While the violation being cited has been classified at Severity Level IV, we ! are nonetheless concerned with the events of May 26, 1994, and the actions noted above that resulted in the violation.
In addition to our concerns
regarding the prompt classification of these events, we are concerned with the a poor decisions made by your staff with respect to the method used for neutralizing the concentrated hydrazine, the failure to obtain prompt ! ' measurements of the airborne toxic gas concentrations, and the repeated failures to accept analytical results as valid in the absence of better information.
While there are no apparent violations of NRC requirements associated with the wcific actions taken to neutralize the spill, those.
i ' i actions reflected poo; judgment and poor performance on the part of your ' staff.
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. . Omaha Public Power District-3-
The NRC recognizes that OPPD has taken, or initiated several corrective actions to address the weaknesses revealed by these events. These actions include: 1) verification of the chemical storage system integrity; 2) development and training in an approved hazardous materials incident response plan; 3) development and training in approved chemical delivery and installation procedures; and 4) revision and training in toxic chemical release classification Emergency Action Levels.
You are required tc respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
. In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96.511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, Samuel J. Collins, Director Division of Radiation Safety and Safeguards Enclosures: 1.
Notice of Violation
2.
List of Enforcement Conference Attendees 3.
Licensee Presentatior. Material l
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t - Omaha Public Power District-4-
i i i cc w/ enclosures: LeBoeuf, Lamb, Greene & MacRae
ATTN: Mr. Michael F. McBride I 1875 Connecticut Avenue, N.W.
Suite 1200 Washington, D.C.
20009-5728 , Washington County Board ' of Stpervisors ATTN: Jack Jensen, Chairman - Blair, Nebraska 68008 , Combustion Engineering, Inc.
! ATTN: Charles B. Brinkman, Manager Washington Nuclear Operations
12300 Twinbrook Parkway, Suite 330 [ Rockville, Maryland 20852 , i Nebraska Department of Health i ATTN: Harold Borchert, Director i Division of Radiological Health l 301 Centennial Mall, South ! P.O. Box 95007 Lincola, Nebraska 68509-5007 , i Department of Environmental Quality ! ATTN: Thomas Lamberson, Deputy Director ! P.O. Box 98922
Lincoln, Nebraska 68509-8922 j ! fort Calhoun Station ATTN: James W. Chase, Manager . P 0. Box 399 { fort Calhoun, Nebraska 68023 Program Manager FEMA Region 7 l 911 Walnut Street, Room 200 Kansas City, Missouri 64106 ' Director Nebraska Civil Defense Agency { 1300 Military Road l Lincoln, Nebraska 68508 l i , ! , , - -, ~ ',. - - - -. e , ,
. . Omaha Public Power District-5-
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