LIC-03-0076, NRC Inspection Report 50-285/03-09, Reply to a Notice of Violation (NOV)

NRC Inspection Report 50-285/03-09, Reply to a Notice of Violation (NOV)

ML031480508
Person / Time
Site:	Fort Calhoun
Issue date:	05/20/2003
From:	Ridenoure R Omaha Public Power District
To:	Document Control Desk, NRC Region 4
References
IR-03-009, LIC-03-0076
Download: ML031480508 (4)

Text

Omaha Public Power District 444 Southi 16th Street Mall Omahla NE 68102-2247 May 20, 2003 LIC-03-0076 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. Letter from NRC (T. W. Pruett) to OPPD (R. T. Ridenoure) dated April 22, 2003 (NRC-03-061)

3. Letter from NRC (T. W. Pruett) to OPPD (R. T. Ridenoure) dated May 13, 2003. (NRC-03-099)

SUBJECT:

NRC Inspection Report 50-285/03-09, Reply to a Notice of Violation (NOV)

Reference 2 transmitted a Notice of Violation (NOV) to the Omaha Public Power District (OPPD). The NOV resulted from security officers failing to follow radiation protection procedural requirements by not signing in on the required radiation work permit (RWP), and not obtaining an electronic alarming dosimeter (EAD) when assigned to a security post located inside the radiation controlled area (RCA). Attached is the OPPD response to this NOV.

This letter does not contain any regulatory commitments.

If you should have any questions, please contact me.

c: E. W. Merschoff, NRC Regional Administrator, Region IV A. B. Wang, NRC Project Manager J. G. Kramer, NRC Senior Resident Inspector Winston & Strawn gS .0 I' Ernploynent With1 Equal Opportunity

LIC-03-0076 Attachment Page I REPLY TO A NOTICE OF VIOLATION Omaha Public Power District Docket No. 50-285 Fort Calhoun Station License No. DPR-40 EA-03-071 During a reviev of Condition Report CR-200203574 between Marci 5 and larch 27, 2003, a violation of NRC requirements was identified. In accordance witl the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 5.8.1. a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978, Appendix A.

Regulatory Guide 1.33, Appendix A, Section 7.e.(1), recommends procedures for a radiation work permit (RWP) system.

Section 2.3.10 of Procedure RPP, "Radiation Protection Plan," Revision 20, states, in part, that each station individual is responsible for obeying the requirements in Standing Order SO-G-101, "Radiation Worker Practices." Section 5.7.1 of SO-G-101, Revision 20, states, in part, that RWPs are required for entry into any posted Radiologically Controlled Area (RCA). In addition, Section 5.8.2 of SO-G-101 states, in part, that persons entering a RCA shall read and understand the information provided and follow the requirements of the appropriate RWNIP, obtain an electronic alarming dosimeter (EAD), and proceed to the EAD reader and log in to the access computer (electronic sign in).

Contrary to the above, between April 27 and October 8, 2002, 14 security officers on 62 occasions deliberately did not read and understand the information provided and follow the requirements of RWP 02-004, did not obtain the EAD required wlhen assigned to the Alpha 1 security post as a RCA, and did not electronically sign in on the required RWVP.

This is Severity Level IV violation. (Supplement IV).

OPPD Response

1. Reason for the Violation On October 10, 2002 it was suggested to security management that there were occasions when officers posted on the Radwaste Building roof were not signed in on a radiation work permit (RWP) and did not obtain an electronic alarming dosimeter (EAD) prior to assuming the post. On October 14, 2002, Security Department management determined

LIC-03-0076 Attachment Page 2 from interviews with security department personnel that this problem could be substantiated and condition report 200203574 was written. Subsequently, an investigation was conducted.

A root cause analysis of these events was completed. As a result, Fort Calhoun Station (FCS) determined that there were two root causes of this violation:

1) A failure on the part of the management organization to adequately or formally monitor the application of performance behaviors related to the manning of a security post, and;

2) A failure to adequately use FCS guideline FCSG-17, "Change Management,"

when changing the roof of the Radwaste Building to a guard post and then later changing it to a radiologically controlled area.

2. Corrective Steps Taken and Results Achieved

1) On October 10, 2002 it was determined that the security officer currently standing the security post had logged in on the required RWP and was wearing his EAD. The Senior Nuclear Security Coordinator also directed the on-shift Shift Security Supervisor to ensure that all security personnel were aware of the requirement to log in to the RWP and obtain an EAD prior to standing the security post, and to reinforce this requirement when making the required on-shift post checks. The requirement to obtain an EAD prior to standing the security post continued to be carried fonvard on the Shift Security Supervisor's Report and this requirement was reinforced to all security personnel by electronic mail on October 10, 2002.

2) On October 14, 2002, sufficient information was gathered to determine that the report could be substantiated and condition report 200203574 was written. To date, no further willful non-compliances with this requirement have been documented.

3) A new scorecard entitled "Human Performance Behaviors" was initiated. This scorecard is a tool that provides guidance to supervision on what items to evaluate under human performance. Each item can be checked to indicate the level of expertise observed by the supervisor. Under the column labeled "Expectations" subheading "Post Checks," this scorecard lists, among other items, EAD. A copy of the new scorecard and a copy of FCS guideline FCSG-7, "Human Performance," were provided to all security personnel responsible for performing scorecards.

4) Following the completion of the root cause analysis of this event, the severity of the actions associated with this issue, and the requirement to comply with RWPs were discussed with members of the security organization during various shift briefings and personnel discussions from November 22 through December 6, 2002. The results of the root cause analysis and description of the root and contributing causes were explained.

Fourteen officers were counseled and disciplinary actions were taken to correct their

LIC-03-0076 Attachment Page 3 unacceptable human performance behaviors. All members of the security force were encouraged to learn and grow from this adverse experience.

5) On December 13, 2002, electronic mail was distributed to all shift security supervisors and sergeants outlining future expectations regarding observations conducted in accordance with the department's scorecard program. Each supervisor and sergeant was reminded of the recent root cause analysis that indicated the absence of quality observations of the activities at the noted post lead to failures to follow procedures properly. In addition, FCS security management directed that the frequency of field observations be increased from three to five per month beginning January 1, 2003. Those observations are documented on scorecards.

6) FCSG-17 will be used with future significant proposed security changes, either whole or in part, to ensure an adequate understanding exists before any significant change to security at FCS occurs.

3. Corrective Steps That 'ill Be Taken To Avoid Further Violations Corrective actions to prevent recurrence have been completed as noted above. Further enhancements may be implemented by the corrective action system.

4. The Date Wlien Full Compliance Will Be Achieved Fort Calhoun Station is currently in full compliance.