ML022520353
| ML022520353 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/06/2002 |
| From: | Collins E Division of Nuclear Materials Safety IV |
| To: | Ridenoure R Omaha Public Power District |
| References | |
| EA-02-123 IR-02-010 | |
| Download: ML022520353 (11) | |
See also: IR 05000285/2002010
Text
September 6, 2002
R. T. Ridenoure
Division Manager - Nuclear Operations
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
SUBJECT:
FORT CALHOUN STATION - NRC SUPPLEMENTAL INSPECTION
REPORT 50-285/02-10
Dear Mr. Ridenoure:
On May 17, 2002, the NRC completed a supplemental inspection at your Fort Calhoun Station.
The enclosed report documents the inspection findings, which were discussed on August 28,
2002, with Mr. Phelps, Division Manager, Engineering, and other members of your staff at the
completion of the inspection.
NRC Inspection Report 50-285/02-08 documented a preliminary White finding and apparent
violation that involved the failure to prevent radiation levels from exceeding the Department of
Transportation limits at any point on the external surface of a radioactive waste shipment
package. On July 30, 2002, the NRC issued its Final Significance Determination and Notice of
Violation for NRC Inspection Report 50-285/02-08. The significance of the violation was
determined to have low to moderate (White) importance to safety when processed through the
public radiation safety significance determination process.
This supplemental inspection was conducted to provide assurance that the root cause and
contributing causes of the White finding were understood, the extent of conditions was
identified, and the corrective actions for risk significant performance issues were sufficient to
address the cause and prevent recurrence. To accomplish these objectives, the inspector
reviewed your root cause analysis, evaluation of extent of condition, and corrective actions.
Based on the results of this inspection, the NRC determined that the identification of the root
causes, contributing causes, and corrective actions associated with the White finding were
comprehensive and broad-based.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Omaha Public Power District
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Should you have any questions concerning this inspection, we will be pleased to discuss them
with you.
Sincerely,
/RA/
Elmo E. Collins, Director
Division of Reactor Safety
Docket: 50-285
License: DPR-40
Enclosure:
NRC Inspection Report No.
50-285/02-10
cc w/enclosure:
Mark T. Frans, Manager
Nuclear Licensing
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
James W. Chase, Division Manager
Nuclear Assessments
Fort Calhoun Station
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
David J. Bannister, Manager - Fort Calhoun Station
Omaha Public Power District
Fort Calhoun Station FC-1-1 Plant
P.O. Box 550
Fort Calhoun, Nebraska 68023-0550
James R. Curtiss
Winston & Strawn
1400 L. Street, N.W.
Washington, D.C. 20005-3502
Omaha Public Power District
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Chairman
Washington County Board of Supervisors
Washington County Courthouse
P.O. Box 466
Blair, Nebraska 68008
Sue Semerena, Section Administrator
Nebraska Health and Human Services System
Division of Public Health Assurance
Consumer Services Section
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007
Daniel K. McGhee
Bureau of Radiological Health
Iowa Department of Public Health
401 SW 7th Street, Suite D
Des Moines, Iowa 50309
Omaha Public Power District
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Electronic distribution from ADAMS by RIV:
Regional Administrator (EWM)
DRP Director (KEB)
DRS Director (ATH)
Sanborn (GFS)
Senior Resident Inspector (JGK)
Branch Chief, DRP/C (CEJ1)
Plant Support Chief (GMG)
Senior Project Engineer, DRP/C (WCW)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
RidsNrrDipmLipb
Scott Morris (SAM1)
FCS Site Secretary (NJC)
Dixon-Herrity (JLD)
OEMAIL
DOCUMENT NAME: R:\\FCS\\FCS2002-10-95001-DRC.wpd
RIV:DRS\\PSB
PEER Review
C:PSB
DRP/C
D:DRS
DRCarter:jlh
LTRicketson
GMGood
CEJohnson
EECollins
/RA/
/RA/
MPShannon for
/RA/
/RA/
09/04/02
09/04/02
09/05/02
09/05/02
09/06/02
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
- Previously concurred.
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-285
License:
EA No.
Report No:
50-285/02-10
Licensee:
Omaha Public Power District
Facility:
Fort Calhoun Station
Location:
Fort Calhoun Station FC-2-4 Adm
P.O. Box 399, Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska
Dates:
August 26-28, 2002
Inspector:
Daniel R. Carter, Health Physicist
Approved By:
Elmo E. Collins, Director
Division of Reactor Safety
SUMMARY OF FINDINGS
Fort Calhoun Station
NRC Inspection Report 50-285/02-10
IR 05000285-02-10; Omaha Public Power District; on August 26-28, 2002; Fort Calhoun
Station; IP 95001; Supplemental Report.
The inspection was conducted by a regional health physics inspector. The inspection identified
no findings of significance. The NRCs program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 3, dated July 2000.
Cornerstone: Public Radiation Safety
This supplemental inspection was performed by the NRC to assess the licensees
evaluation of a finding involving processing and transportation of radioactive material.
A finding previously characterized as having low to moderate safety significance
(White) was documented in the Final Significance Determination for NRC Inspection
Report 50-285/02-08. During this supplemental inspection performed in accordance
with Inspection Procedure 95001, the inspector determined that the licensee performed
a thorough, broad-based evaluation of the causes of the radioactive material
processing and transportation issue and correctly identified the extent of the conditions
that led to the shipping problem. The licensees evaluation identified one root cause
and two contributing causes. Corrective actions included: (1) procedural revisions that
implement a formal radioactive waste load plan that is commensurate with the
susceptibility of the material shifting during transport; (2) implementation of a formal
method of tracking and controlling the location within the container commensurate with
the radiological risk (dose rate) of radioactive materials being packaged for shipment;
(3) the requirement that the Manager-Radiation Protection will approve all radioactive
waste shipment releases excluding limited quantity shipments; (4) the requirement that
all shipments, except limited quantity shipments, have two independent exit surveys
performed; and, (5) the performance of an effectiveness review of implemented
corrective actions to be completed by December 15, 2002.
Because of the licensees acceptable performance in addressing the processing and
transportation of radioactive material, the White finding associated with this issue will
only be considered in assessing plant performance for a total of four quarters, in
accordance with the guidance in IMC 0305, Operating Reactor Assessment Program.
Report Details
01
Inspection Scope
This supplemental inspection was performed to assess the licensees evaluation of the
root causes, contributing causes, and corrective actions associated with the White
radioactive material processing and transportation finding. This performance issue was
previously characterized as White in the Final Significance Determination for NRC
Inspection Report 50-285/02-08 and is related to the public radiation safety cornerstone
in the radiation safety strategic performance area.
The inspector interviewed radiation workers and reviewed the following documents and
compared them to regulatory and licensee requirements:
Condition Report 2002-01009 and associated root cause evaluation which
documented the radioactive material processing and transportation issue
identified in NRC inspection report 50-285/02-08,
Station Procedures RW-300, Shipping Radwaste and Radioactive Materials,
Revision 7; RW-304, Radwaste Shipments to Barnwell, Revision 7, and RW-315,
Shipments to Vendor Processing Facility of Radioactive Materials, Revision 4,
Standing Order SO-R-2, Condition Reporting and Corrective Action, Revision 20;
Nuclear Operations Division Procedure NOD-QP-19, Cause Analysis Program,
Revision 22; and Corrective Action Group Root Cause Analysis Guideline,
Revision 0,
Radiation Protection Cycle 2 continuing training Industry Events.
02
Evaluation of Inspection Requirements
02.01 Problem Identification
a.
Determine that the evaluation identifies who (i.e. licensee, self revealing, or
NRC), and under what conditions the issue was identified.
The licensee documented the event; however, the event was self revealing in that the
licensee received a phone message from its waste processing vender stating that
shipment FCS-NW-02-08 exceeded regulatory limits. The NRC was notified of the
event by the State of Tennessee after the state was contacted by the waste processing
vendor.
b.
Determine that the evaluation documents how long the issue existed, and prior
opportunities for identification.
The evaluation documented that the licensee was notified of the event on April 24, 2002,
the day the shipment arrived at the waste processing vendor. The shipment departed
the licensees facility on April 22, 2002. The evaluation determined that this was the first
time this type of event had happened.
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c.
Determine that the evaluation documents the plant specific risk consequences
(as applicable) and compliance concerns associated with the issue.
A plant specific probabilistic risk assessment is not applicable to this radioactive material
transportation finding. However, the evaluation did determine that nuclear safety was
not impacted by the event and that neither the drivers safety nor public safety were
compromised during the shipment due to the location of the radiation source. The
evaluation identified that the licensees procedures incorporated regulatory
requirements, and in some cases implemented procedural limits more restrictive to
ensure that regulatory limits are not exceeded.
02.02 Root Cause and Extent of Condition Evaluations
a.
Determine that the problems were evaluated using a systematic method(s) to
identify root cause(s) and contributing cause(s).
The inspector concluded that the root cause analysis was performed in a systematic
manner which correctly and completely determined the root cause and contributing
factors. The evaluation team performed the root cause analysis using an industry
accepted methodology which employed the following techniques: records review,
personnel interviews, and barrier analysis.
The licensees root cause evaluation identified one root cause and two contributing
causes. The evaluation determined that the root cause was the failure to package
radioactive material within the sea/land container in such a manner that it could not shift
during transport. Contributing causes were failures to: (1) establish a formal loading
plan that requires an increasing level of management oversight for materials that have a
higher risk of shifting during transport, and (2) implement a formal method of
documenting the location of more highly radioactive materials within the container.
The inspector determined that the above root cause evaluation was performed in
accordance with Station Procedure NOD-QP-19, Cause Analysis Program, Revision 22,
and Root Cause Analysis Guideline, Revision 0.
b.
Determine that the root cause evaluation was conducted to a level of detail
commensurate with the significance of the problem.
The root cause evaluation detailed the performance of a safety evaluation of the event.
The safety evaluation determined neither the shipment driver nor public safety were
compromised during the shipment. The inspector determined that the root cause
evaluation focused on the overall event and was conducted to the appropriate level of
detail commensurate with the significance of the problem. The evaluation was
thorough, broad-based, and conducted to a sufficient level of detail to enhance the
radioactive material processing and transportation program.
c.
Determine that the root cause evaluation included a consideration of prior
occurrences of the problem and knowledge of prior operating experience.
The inspector concluded that the root cause evaluation considered similar events
associated with the problem of radioactive material processing and transportation for the
past two years. From a review of the evaluation and discussions with the licensees
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staff the inspector determined that industry experience was reviewed to help improve
their program.
d.
Determine that the root cause evaluation included consideration of potential
common cause(s) and extent of condition of the problem.
The licensees evaluation considered the potential common causes and extent on the
conditions associated with the processing and transportation of radioactive material.
Common causes included no formal loading plan for the loading of elevated dose rate
items in a sea/land container, and the tracking of radioactive material placed in the
sea/land container was informal and not diligently maintained.
The root cause evaluation extent of condition identified that the problem was a unique
event. The licensee determined that no similar transportation events had occurred in
the past. The inspector determined that the evaluation did not detail the applicability of
the root cause across other disciplines or departments, of similar programmatic activities
or human performance issues. The inspector interviewed the root cause evaluator and
determined that an evaluation of these issues was conducted in accordance with the
licensees Root Cause Analysis Guideline; however, the evaluator did not document this
fact in the evaluation. The licensee initiated Condition Report 2002-03028 to address
this issue.
02.03 Corrective Actions
a.
Determine that appropriate corrective action(s) are specified for each
root/contributing cause or that there is an evaluation that no actions are
necessary.
The inspector concluded that the corrective actions appropriately addressed the
associated root/contributing causes. Corrective actions included: (1) procedural
revisions that implement a formal radioactive waste load plan that is commensurate with
the susceptibility of the material shifting during transport; (2) implementation of a formal
method of tracking and controlling the location within the container commensurate with
the radiological risk (dose rate) of radioactive materials being packaged for shipment;
(3) the requirement that the Manager-Radiation Protection will approve all radioactive
waste shipment releases excluding limited quantity shipments; (4) the requirement that
all shipments, except limited quantity shipments, have two independent exit surveys
performed; and, (5) the performance of an effectiveness review of implemented
corrective actions.
The inspector determined that the corrective actions appeared to be appropriate to
prevent similar occurrences.
b.
Determine that the corrective actions have been prioritized with consideration of
the risk significance and regulatory compliance.
The inspector concluded that the corrective actions were properly prioritized. A
completion date and priority were assigned for each corrective action.
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c.
Determine that a schedule has been established for implementing and
completing the corrective actions.
From a review of the root cause evaluation, the inspector determined that a schedule
had been developed for the completion of each corrective action. As of June 30, 2002
all corrective actions were completed with the exception of the effectiveness review that
has a due date of December 15, 2002.
d.
Determine that quantitative or qualitative measures of success have been
developed for determining the effectiveness of the corrective actions to prevent
recurrence.
An effectiveness review evaluation of the corrective actions implemented to prevent
recurrence of the event is scheduled to be completed by December 15, 2002. The
effectiveness review will include the following:
Review implemented requirements to ensure radioactive material will not shift
during shipment.
Review of shipping container load plans to verify sufficient detail and quality such
that field personnel have clear direction on the proper loading of materials.
Field observations to determine the quality of preparing material for shipment.
Interview personnel whose tasks support the shipment of radioactive material to
ensure an understanding of the requirements that must be adhered to.
Review the process implemented to track radioactive material placed into a
sea/land container for completeness and accuracy.
The inspector concluded that the proposed effectiveness review will adequately assess
the corrective actions implemented to prevent recurrence.
4.
OTHER ACTIVITIES
4OA3 Event Followup
(Closed) Violation (VIO) 50-285/0208-01
The Final Significance Determination for NRC Inspection Report 50-285/02-08
documented a violation of NRC and Department of Transportation requirements. The
inspector reviewed the licensees root cause evaluation, associated corrective action
document, and reply to a notice of violation, dated August 26, 2002, pertaining to the
10 CFR 71.5 violation. The licensees evaluation identified corrective actions taken to
correct the violation and prevent recurrence. The licensee is currently in full
compliance.
The inspector concluded that the licensees corrective actions adequately addressed the
root cause and two contributing causes.
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4OA6 Management Meetings
Exit Meeting Summary
The inspector presented the inspection results to Mr. R. Phelps, Division Manager,
Nuclear Engineering, and other members of licensee management at the conclusion of
the inspection on August 28, 2002. The licensee acknowledged the findings presented.
This meeting constituted the regulatory performance meeting specified in the Inspection
Manual Chapter 0305 action matrix.
The inspector asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
ATTACHMENT
Supplementary Information
Licensee Contacts :
R. Clemens, Division Manager, Nuclear Assessments
D. Dryden, Licensing Engineer
M. Fans, Assistant, Plant Manager
R. Haug, Manager, Chemistry
J. Mattice, Supervisor, Radwaste
E. Matzke, Licensing Engineer
R. Phelps, Division Manager, Engineering
M. Puckett, Manager, Radiation Protection
R. Reno, Supervisor, Radiation Protection
R. Westcott, Manager, Training
NRC:
J. Kramer, Senior Resident Inspector
ITEMS OPENED AND CLOSED
Closed
50-285/0208-01
Failure to prevent radiation levels from exceeding regulatory
requirements on the external surface of a shipment package