ML20008E854
| ML20008E854 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/06/1981 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20008E853 | List: |
| References | |
| FC-011-81, FC-11-81, NUDOCS 8103100070 | |
| Download: ML20008E854 (4) | |
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Omaha Public Power District 1623 MARNEY
' O M A M A. NESRASMA 66102 TELEPHONE 536 4000 AMEA CODE 402 February 6, 1981 FC-011-81 Mr. K. V. Seyfrit U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 i
Reference:
(1) Docket No. 50-285 (2)
Fort Calhoun Station Health Physics Appraisal Report No. 50-285/80-16, Dated December 12, 1980
Dear Mr. Seyfrit:
In reply to the Notice of Violation contained within the above referenced report, the Omaha Public Power District herein submits comments to indicate the status of the reported items of noncompliance.
Noncomoliance r
A.
Technical Specification 5.3.1 requires in part, that "Each member of the plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable posi tions,.... " Section 4.5.2 of ANSI N18.1-1971 states, in part, " Technicians in responsible positions shall have a minimum of two years working experience in their speciality."
Contrary to the above requirement, at the time of the appraisal, one technician performing shift responsibility had approximately
_ one year of related work experience.
Response
(1) Corrective steos which have been taken and the results achieved.
I The item of nonccmpliance does not fully describe the circumstances surrounding the cited violation. The technician in question was a i
contract employee performing in the capacity of a shift technician at the Fort Calhoun Station. As of October 1, 1980, this individual was about 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> short of meeting the two-year experience require-ments prescribed by ANSI N18.1-1971.
However, during the time the inscection was conducted and until the contract technician was fully qualified to ANSI N18.1 criteria, he was continuously paired on snift with an OPPD technician fully meeting ANSI N18.1-1971 criteria.
The OPPD technician was a new employee who had undergone 810s.10 o 07o.
.Mr. K. V. Seyfrit February 6,1981 Page Two indoctrination training but was not considered adequately know-ledgeable on plant systems and procedures to assume the sole responsibility of shift technician.
Therefore, the assignment of these two technicians for this particular shift provided both sufficient experience in accordance with ANSI N18.1 and specific j
plant experience.
The following additional corrective measures have been taken to resolve this issue:
a)
The contract technician accumulated enough hours to meet the ANSI N18.1 experience requirement as of November, 1980.
b)
Indoctrination training of the new OPPD technician was com-pleted on November 25, 1980.
(2) Corrective steps which will be taken to avoid further violations.
The following steps will be taken to avoid further violations:
a)
Written selection criteria, in the form of position descrip-tions, exist for the classification of Chemistry-Radiation Protection personnel. These position descriptions will be upgraded to require the ANSI N18.1-1971 experience require-ments to be met for Technician II and above. This will be accomplished by March 1, 1981.
b)
A system will be established to document health physics technician qualifications as specified in ANSI N18.1-1971.
This program will include contract health physics personnel i
used for technician duties. This will be accomplished by March 1, 1981.
l (3)
Date when full comoliance will be achieved.
7 The Omaha Public Power District is presently in full compliance.
j' Noncompliance B.
10 CFR 20 (f)(1) and (2). " containers" require that each container l
of ~. icensed material bear a label showing the radiation caution symtol, the words, " Caution
. Radioactive Materials" and inform-ati';n sufficient for workers to take precaution to ioid or mini-i mize exposure.
l Co'itrary to this requirement, at the time of the appraisal, several 55 gallon drums of waste materials, stored at 995'6" level of the auxiliary building, were not labeled or information provided as to
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their radioactive contents.
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- Mr. K. V. Seyfrit February 6,1981 Page Three
Response
(1) Corrective steos which have been taken and the results achieved.
The following corrective steps have been taken to resolve this violation:
a)
The subject drums were properly labeled in accordance with 10 CFR 20.203.
b)
A new plant procedure was developed and issued on November 11, 1980, entitled, "HP-8, Labeling of Radioactive Materials."
This procedure ensures that radioactive / contaminated materials are properly controlled and labeled.
c)
The Radiation Protection Retraining prograu for employees 4
holding a blue or red security badge has been revised to emphasize the need for proper radiation materials control.
This training will be conducted as part of the Fort Calhoun Station annual employee retraining program.
(2) Corrective steps which will be taken to avoid further violations.
In order to avoid further violations, procedure HP-8 will be complied with and retraining as noted above will be conducted.
(3) Date when full compliance will be achieved.
The Omaha Public Power District is presently in full compliance.
Noncamoliance C.
10 CFR 2C 409(b), " Notifications and Reports to Individuals,"
requires each licensee to report, in writing, to each individual who terminates his work assignment at the facility, the indivi-dual's record of exposure to radiation and radioactive material during his period of employment or work assignment.
Contrary to this requirement, two individuals who terminated employment on December 22, 1979, and August 15, 1979, were not sent a report of their exposure during their period of employraent.
Resaonse (1) Corrective steos which have been taken and the results achieved.
The following steps have been taken to resolve this violation:
4 i
a)
Termination reports datea September 24, 1980, have been sent to the two individuals wno terminated employment in December and August of 1979.
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l Mr.. K. V. Seyfrit February 6, 1981 Page Four i
b)
A new program has been implemented by the District by which notices of termination are forwarded to the Plant Health Physicist, by the OPPD employment department, for all OPPD employees terminating employment with the District. After these notices are received, termination reports are prepared and sent out as required.
This program will assure that notification of tennination is received by the plant radiation protection group. Contract personnel termination exposure reports are controlled by the monthly personnel dosimetry issuance procedure.
Failure to receive replacement dosimetry devices initiates the termination report.
c)
All radiation protection personnel files for the years 1979 and 1980 were reviewed to ensure that termination reports were sent out as required. No other violations were discovered.
i (2) Corrective steos which will be taken to avoid further violations.
The measures stated above will assure that further violations do not occur.
(3) Date when full comoliance will be achieved.
The Omaha Public Power District is presently in full compliance.
Sincerely, b
.D W. C. Jones Divisi6n Manager Production Operations WCJ/KJM/TLP:jmm cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
. Washington, D.C.
20036 r
Subscribed and sworn to before me this day of
, 1981.
Notary Public
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