ML19323E429

Responds to NRC 800307 Ltr Re Violations Noted in IE Insp Rept 50-285/80-04.Corrective Actions:Entrances to High Radiation Area Properly Posted & Controlled by Barrier Rope. Appropriate Stickers Affixed to All Radwaste Drums

ML19323E429
Person / Time
Site:	Fort Calhoun
Issue date:	04/02/1980
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19323E425	List: ML19323E429
References
NUDOCS 8005230539
Download: ML19323E429 (5)

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Omaha Public Power District 1623 HARNEY a OMAMA, NESRASMA 68102 8 T E f.E P H O N E 536 4000 AREA CODE 402 April 2,1980 Mr. Glen L. Madsen U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Reference:

Inspection Report No. 50-285/80-04

Dear Mr. Madsen:

In reply to the above referenced inspection report, the Omaha Public Power District herein submits comments to indicate the status of the reported items of noncompliance.

, INFRACTION Contrary to Technical Specification 5.11.1, high radiation areas within containment were (1) not barricaded and conspicuously posted and (2) personnel were allowed access to these areas without a radiation monitoring device or under the positive control of a person qualified in radiation protection procedures at the time of inspection.

RESPONSE

(1) Corrective steps which have been taken and the results achieved.

The area reported by the inspector was the passageway adjacent to the pressurizer. Entrance to this high radiation area was properly posted and controlled by radiation barrier rope. The plant was in a cold shutdown condition and a refueling outage in progress. Radiation surveys were performed and radiation controls established. The plant had been in a static cold shutdown for approximately four weeks and decreased radiation levels had been monitored. Personnel entering the area were well aware of the area designation by the posting and existing radiation work permit. The radiation work permit required persons entering the high radiation area to contact the health physics tech-nician prior to entering the area. The containment health physics technician was controlling the area and radiation mo.:itoring devices were available. The technician was not aware that thert: were personnel in the high radiation area. Immediate corrective actions take6 in-cluded:

8005280S M g .

. . Mr. Glen L.*Madsen April 2,1980 Page Two (a) Reinstructed the health physics technicians an Technical Specification 5.11.1 requirements.

(b) The area was more conspicuously posted and barricaded by adding more signs and barriers.

(c) Workers in the general area were instructed to strictly adhere to the ;.1 trance requirements of the radiation work permits.

(d) Standing Order T-8, " Routine Health Physics Surveys" and Radiation Protection Manual Section 3, " Area Control" were reviewed to ensure that adequate procedures are available.

(e) Instruction for high radiation area entrance and control was posted for general information on plant bulletin boards.

(2) Corrective steps which will be taken to avoid further noncompliance.

(a) Annual radiation protection training for 1980 will place strong emphasis, using video tape sections, on proper per-sonnel conduct in high radiation areas. Retraining will be completed by December 31, 1980.

(b) Radiological sign inserts will be purchased and used in conjunction with area posting to delineate entrance require-ments. Receipt of these inserts is anticipated by June 1, 1980.

(3) Date when full compliance will be achieved.

The licensee is presently in full compliance with Technical Speci- l fication 5.11.1.

INFRACTION Contrary to Technical Specification 5.11.2, very high radiation '

areas within containment were (1) not barricaded and conspicuously posted and (2) personnel were allowed access to these areas without a radiation monitoring device or under the positive control of a person qualified in radiation protection procedures at the time of inspection.

RESP 0NSE (1) Corrective steps which have been taken and the results achieved.

The area observed by the inspector was the metal grating floor at elevation 1036' above A steam generator. Entrance to this very high '

radiation area was properly posted and controlled by radiation barrier rope. The plant was in a cold shutdown condition and a refueling outage was in progress. The reactor internals compensating ring was stored in l l

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l Mr. Glen L.* Madsen April'2, 1980 j Page Three i this area. Radiation surveys had been performed by proper procedure and radiation controls 'stablished. The plant had been in a static cold shutdown for approxmately four weeks and the ring is stored in this

area only during the time the reactor cavity is flooded. Personnel in the area were well aware of the area designation by the posting and existing radiation work permit. All entries into the area were limited to extremely short duration. The radiation work permit required persons entering the very high radiation area to contact the health physics (HP) technician prior to entry. The containment HP technician was control-ling the area and radiation monitoring devices were available. The HP technician was not aware that personnel had entered the very high radiation area. Immediate corrective actions consisted of:

, (a) Reinstructed the HP technicians on Technical Specification 5.11.2 requirements.

(b) The area was more conspicuously posted and barricaded by

adding more signs and. barriers.

(c) Workers in the general area were instructed to strictly adhere to the entrance requirements of the radiation work

permits.

(d) Standing Order T-8, " Routine Health Physics Surveys" and i Radiation Protection Manual Section 3, " Area Control" were reviewed to ensure that adequate procedures are available.

(e) Instruction for very high radiation area entrance and control was posted for general information on plant bulletin boards.

(2) Corrective steps which will be taken to avoid further noncompliance.

(a) Annual radiation. protection training for 1980 will place strong emphasis, using video tape sections, on proper per-sonnel conduct in very high radiation areas. Retraining will be completed by December 31, 1980.

(b) Radiological sign inserts will be purchased and used in con, junction with area posting to delineate entrance require-ments. Receipt of these inserts is anticipated by June 1, 1980.

(3) Date when full compliance will be achieved.

The licensee is presently in full compliance with Technical Speci-fication 5.11.2.

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Mr. Glen L.' Madstn April 2, 1980 i Page Four -

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DEFICIENCY j Contrary to 10CFR20.203(f), containers containing solidified and  !

compacted radioactive wastes, stored in a working area of the auxiliary building, were not labeled with a label clearly identifying their radioactive contents at the time of inspection.

RESPONSE

(1) Corrective steps which have been taken and the results achieved.

(a) "Radwaste LSA" stickers have been affixed to all drums con-taining radioactive waste.

(b) The HP technicians have been instructed on proper labeling methods to be used when participating in waste processing.

(c) Health Physics Procedure HP-3, " Solid Waste Shipment Pro-cedure", Standing Order T-4, " Waste Solids Release", and Operating Instruction OI-WDS-2, " Solids Waste Disposal" were reviewed and verified that proper labeling was provided for by the procedure.

(d) The operating procedures now include a requirement that a health physics technician be summoned for survey and follow-up actions at the time each drum or group of drums have been filled and capped.

(2) Corrective steps which will be taken to avoid further no.mmpliance.

Limited availability to land burial sites has necessitated the use of wo. king areas for temporary storage. Construction projects for 1980-81 include erection of a larger on-site waste storage facility. This building will eliminate storage in the present auxiliary building.

(3) Date when full compliance will be achieved.

The licensee is presently in full compliance with 10CFR20.203(f).

DEFICIENCY Contrary to 10CR19.11(a) or (b), neither the documents required by 10CFR19.11(a) nor the notice required by 10CFR19.11(b) were posted at the time of inspection.

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l Mr. Glen L*. Madsen April ' 2, 1980 Page Five

RESPONSE

At the time of the inspection, neither the NRC inspector nor tne 4

licensee representative could locate the posting required by 10CFR 19.11(a) (1), (2), and (3). In lieu of the above posting requirements, 10CFR19.11(b) allows the licensee to post a notice which describes the documents in question and states where they may be exemir.ad. Likewise, this posting could not be located by the NRC inspector or the licensee representative.

It has been the District's position to comply with 10CFR19.11(b) in lieu of 10CFR19.11(a) (1), (2), and (3). In order to comply with the alternate posting requirement of 10CFR19.11(b), the Fort Calhoun Station issued Standing Order G-31 on September 26, 1975. Conspicuous posting of this Standing Order on various plant bulletin boards ensures com-pliance with 10CFR19.11(b). As noted above, this posting could not be found at the time of the inspection.

(1) Corrective steps which have been taken and the results achieved.

The Chemistry / Radiation Protection Supervisor immediately posted a copy of Standing Order G-31 in both the Fort Calhoun Station service building and control room. This action brought the District into full compliance with the provisions of 10CFR19.11(b).

(2) Corrective steps which will be taken to avoid further noncompliance.

In order to prevent further items of noncompliance of this type, the District will make provisions, where practicable, to post such notices at selected locations in lockable glass cabinets.

(3) Date when full compliance will be achieved.

As stated above, the District is presently in full compliance.

Sincere ,

es W. C. Jon#

Division M anager Production Operations WCJ/KJM/BJH/TLP:jmm cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.

Washington, D. C. 20036

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