IR 05000285/1996010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/96-10.Reply Responsive to Concerns Raised,Review of Implementation of Corrective Actions During Future Inspection

ML20135E146
Person / Time
Site:	Fort Calhoun
Issue date:	12/04/1996
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Tira Patterson OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 9612110044
Download: ML20135E146 (4)

Text

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J, ,t NUCLEAR REGULATORY COMMISSION REGloN IV

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DEC 4 1996 T. L. Patterson, Division Manager Nuclear Operations Omaha Public Power District Fort Calhoun Station FC-2-4 Ad P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 SUBJECT: NRC INSPECTION REPORT 50-285/96-10 Thank you for your letter of November 25,1996,in response to our letter and Notice of Violation dated October 25,1996. 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 maintaine

Sincerely, J. E. Dyer, Director Civision of Reactor Projects ,

l Docket No.: 50-285

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License No.: DPR-40 i

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l 0 l 9612110044 961204 PDR ADOCK 05000285 PDR i

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Omaha Public Power District -2- !

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Perry D. Robinson, Es i Winston & Strawn l 1400 L. Street, Washington, D.C. 20005-3502 I Jack Jensen, Chairman j Washington County Board of Supervisors '

Blair, Nebraska 68008 Cheryl Rogers, LLRW Program Manager l

Environrnental Protection Section Nebraska Department of Health j 301 Centennial Mall, South  !

P.O. Box 95007 Lincoln, Nebraska 68509-5007 l James W. Chase, Manager Fort Calhoun Station j P.O. Box 399 I Fort Calhoun, Nebraska 68023

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DOCUMENT NAME: R:\_FC\FC610AK.WCW l To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy PE:DRP/B D:DRP/B , D:DRP DNGraves;crq WDJohnsonp JEDyer Gfjk l l 12/( /96 \ 12/4 /96 ' 12/4 /96 ]

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Omaha Public PowerDistrict 444 South 16th Street Mall lM 2 6 ; ; .

Omaha NE68102-2247 j

November 25, 1996 l

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LIC-96-0177 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk

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Mail Station P1-137 Washington DC 20555 l References: Docket No. 50-285 Letter from NRC (J. E. Dyer) to OPPD (T. L. Patterson) dated l October 25, 1996 l SUBJECT: NRC Inspection Report No. 50-285/96-10. Reply to a Notice of Violation I The subject report transmitted a Notice of Violation (NOV) resulting from an NRC inspection conducted August 25 through October 5,1996, at the Fort Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD) response to this NO As stated in Reference 2. it is not necessary for OPPD to respond to the second Violation (285/96010-03), since the corrective actions taken to prevent recurrence are already in plac If you should have any questions, please contact m Sincerel . y .

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T. L. Patterson Division Manager Nuclear Operations Division TLP/gmc Attachment c: Winston and Strawn L. J. Callan, NRC Regional Administrator. Region IV l

L. R. Wharton, NRC Project Manager

W. C. Walker, NRC Senior Resident Inspector

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/03O U 45 5124 Employment with Equal Opportunity

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Attachment LIC-96-0177 Page 1 l REPLY TO A NOTICE OF VIOLATION Omaha Public Power District Docket: 50 285 Fort Calhoun Station- Licerse: DPR 40 During an NRC inspection conducted on August 25 through October 5, 1996, 2 violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below: Appendix B of 10 CFR Part 50 Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstance and shall be accomplished in accordance with these instructions, procedures, or drawing Standing Order S0 G 91, " Control and Transportation of Combustible Material "

Revision 7, Step 5.4.1A, requires, in part, that combustibles that are temporarily retained to support an ongoing work activity be minimized and should be limited to 5 gallons of Class B materia Contrary to the above, on September 20, 1996, the inspectors identified that l approximately 150 gallons of epoxy coating and 30 gallons of resin hardener had been left unattended inside the intake structure in close proximity of the diesel i driven fire pum This is a Severity Level IV violation (285/96010 02) (Supplement I). Appendix B of 10 CFR Part 50 Criterion V, states, in pert: that activities ;

affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstance and shall be accomplished in accordance with these instructions, procedures, or drawing Radiation Protection Procedure RP 207, " Personal Monitoring and Decontamination "

Revision 6, Step 7.5.1A, requires, in part, that personnel found to have detectable contamination on skin or clothing shall be documented on FC-RP 207 2,

" Personnel Contamination Log."

Contrary to the above, on September 20, 1996, the inspectors identified that an auxiliary operator had been contaminated while performing rounds and that the contamination was not logged or properly turned over to the oncoming radiation protection technicia , ,. . . - - - . ~_. . _

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o Attachment LIC-96-0177

Page 2

"i This is a Severity Level IV violation (285/96010 03) (Supplement IV).

I OPPD_ Response

As stated in Reference 2 on the cover letter. Omaha Public Power District (OPPD) is not l required to respond to violation 96010-03 because of corrective actions already taken j and documented within Reference 2. Therefore, OPPD has elected not to respond to that

violation,

OPPD_ Response to Vjolation_96010.02

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< The Reason for the Violation i The cause of this violation was that the Maintenance Planner involved in this

activity did not consider that the materials involved in this incident

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constituted a fire hazard or a fire loading concern. Contributing causes of thic

violation are that the material containers were not identified as flammable or

! combustible; and, employees of the contract company performing the coating i- application were not aware of, or briefed specifically on, the requirements of i Standing Order 50-G-91, " Control and Transportation of Combustible Material ."

i i Corrective Steps Which Have Been Taken and the Results Achieved i l

5 A meeting was conducted with Maintenance Planning. the Supervisor-l Maintenance Support, the Maintenance Planning Coordinator, the Fire i

Protection Engineer, the Hazardous Materials Chemist, an Operations j representative and the Contractor owner / representativ During this

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j meeting, the Supervisor-Maintenance Support clarified expectations for the

conduct and work performance of contractor employees to the contract ,

l representativ Additionally, the Supervisor-Maintenance Support f

clarified that should the contractor have any questions, they should ,

contact the OPPD representative and/or Operations Shift Supervisor immediately. This meeting was held on September 20, 199 A walkdown of contractor work locations was performed to ensure material storage and handling of combustible / flammable materials was in accordance with S0-G-91. This was completed on September 20. 199 The Maintenance Planners were briefed on the event and were required to re-read 50-G-91. This was completed on Septembec 23, 199 The contractors involved in this incident were monitored by OPPD personnel on a continual basis for the remainder of their project. The contractor was released, upon job completion, on September 28, 199 . - - - - - - - -

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Attachment LIC-96-0177 Page 3 Management expectations on the knowledge and accountability of 50-G-91 was addressed in training via the issuance of a required reading " Hotline."

The intent was to improve S0-G-91 work practices and plannin Included <

in this training were General Maintenance, Central Maintenance, Maintenance Planners, appropriate craft Contractors Field Engineer l

, System Engineers. Quality Assurance, Quality Control and Special Service l Engineering. This Hotline was issued on October 10. 199 ! An interim combustible awareness process was implemented in cooperation with the Chemistry Nuclear Procurement Services and System Engineering department This process will be in effect until the riew labeling process to identify chemicals with S0-G-91 applicability is in place,.as

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discussed below. This interim process was in place on November 11, 199 . Corrective Steps Which Will Be Taken to Avoid Further Violations Maintenance Planning will create a contractor checklist of OPPD j expectations and project requirements. This checklist will be used to i brief contractors when they will not be working under the direct supervision of OPPD personne This will be complete by December 22, 199 Standing Order 50-G-91 will be revised to make the guidance less complex and easier for craft individuals to work with. This will be complete by March 30, 199 Procedures will be evaluated and revised, as necessary, to require the application of labels which simultaneously addresses the Standing Order 50-G-70, " Chemical Control," and 50 G-91 requirements. This will be completed to promote the visibility of flammables and combustibles consistent with the labeling of hazardous material This will be complete by December 31, 199 . Date When Full Compliance Will Be Achieved OPPD is currently in full compliance.