ML20058N064
| ML20058N064 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/15/1993 |
| From: | Chamberlain D Office of Nuclear Reactor Regulation |
| To: | Tira Patterson OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9312210221 | |
| Download: ML20058N064 (2) | |
See also: IR 05000285/1993023
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN IV
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611 RYAN PLAZA DRIVE, SUITE 400
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$74
ARLINGTON, TEXAS 760114064
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DEC l 51993
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Docket:
50-285
License: DPR-40
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Omaha Public Power District
ATTN:
T. L. Patterson, Division Manager
Nuclear Operations
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Fort Calhoun Station FC-2-4 Adm.
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P.O. Box 399, Hwy. 75
North of-Fort Calhoun
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Fort Calhoun, Nebraska 68023-0399
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SUBJECT: NRC INSPECTION REPORT 50-285/93-23
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Thank you for your letter of Novembar 29, 1993,'in response to our.
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letter and Notice of Violation dated October 29, 1993. We have reviewed ~your
reply and find it responsive to the concerns raise'd-in our. Notice of.
Violation. We will review the implementation of your corrective actions
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during a future inspection to determine that full' compliance has been achieved
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and will be maintained.
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Sincerely,
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Acting Director
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Division-of Radiation Safety
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-and Safeguards-
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LeBoeuf, Lamb, Leiby & MacRae
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ATTN: Mr. Michael F. McBride
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1875 Connecticut Avenue, NW
Washington, D.C.
20009-5728
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Washington County Board
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ATTN: Jack Jensen, Chairman
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Blair, Nebraska 68008
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ATTN: Charles B. Brinkman, Manager
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Washington Nuclear Operations
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12300 Twinbrook Parkway, Suite 330
Rockville, Maryland 20852
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Nebraska Department of' Health
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ATTN: Harold Borchert, Director
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Division of Radiological Health:
301 Centennial Mall, South
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P.O. Box 95007
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Lincoln, Nebraska 68509-5007-
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Fort Calhoun Station
ATTN: James W. Chase,, Manager
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Fort Calhoun, Nebraska 68023
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bec w/ copy of licennsee's letter dated November 29, 1993:
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FCS Resident Inspector
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November 29, 1993
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LIC-93-0283
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U. S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
Mail Station PI-137
REGICN IV
Washington, DC 20555
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References: 1.
Docket No. 50-285
2.
Letter from NRC (L. J. Callan) to 0 PPD (T. L. Patterson) dated
October 29, 1993
Gentlemen:
SUBJECT:
NRC Inspection Report No. 50-285/93-23, Reply to a Notice of
Violation (NOV)
The subject report transmitted a NOV resulting from an NRC inspection conducted
October 12-15, 1993 at the Fort Cal:ioun Station. Attached is the Omaha Public
Power District (0 PPD) response to this NOV.
If you should have any questions, please contact me.
Sincerely,
j}lm roh
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)OVicePresident
W. G. Gates
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WGG/grc
Attachment
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LeBoeuf, Lamb, Leiby & MacRae
J. L. Milhoan, NRC Regional Administrator, Region IV
S. D. Bloom, NRC Project Manager
R. P. Mullikin, NRC Senior Resident Inspector
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Attachment
LIC-93-0283
Page 1
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REPLY TO A NOTICE OF VIOLATION
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Omaha Public Power District'
Docket:
50-285
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Fort Calhoun Station
' License:
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VIOLATION
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During an NRC ins >ection conducted on October '12-15, '1993, one violation of NRC
requirements was < dentified. In accordance with the " General Statement of Policy:
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and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C,, the r
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violation is listed below:
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Technical S>ecification 5.8.1 states, in part, _ " Written procedures' and -
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administrat' ve policies shall be established. implemented, and maintained
that meet or exceed . . . Appendix A of USNRC. Regulatory Guide' 1.33 . . _ . .
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Section 7.e.(1) of Regulatory Guide l.33 lists radiation protection
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procedures governing access control- to radiation ' areas, including 3 a'
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radiation work permit system.
' Radiation
Protection
Surveillance
Program.
Procedure
RP-AD-200,
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Administrative Procedure," Revision 9, states, .in' part, in Section-4.12.2
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that personnel signed in on a radiation' work permit are responsible for
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adhering to the requirements and instructions listed on the radiation work
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permit.
Section 5.3.2.A. states, in part, that- personnel entering the_-
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radiolo91 cal. controlled -area are. required- to wearn approved personnel-
monitoring equipment.
Radiation Work Permits 93-0004, 93-0103, 93-1137, and 93-1197 require that
individuals have a thermoluminescent dosimeter and an alarming dosimeter.
Contrary to the above:
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On June 28, 1993, an individual,, working :in accordance with
Radiation Work Permit 93-0004, entered the radiological controlled
area without an alarming . dosimeter.
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On September 1,1993, a vendor representative, working in accordance
with Radiation Work Permit 93-0103, entered 1the radiological-
controlled area to work on counting ; room L equipment without a
thermoluminescent dosimeter.
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On September 20, 1993, a contract worker, working in accordance with
Radiation Work Permit 93-1197, entered the radiological controlled
. area without an alarming dosimeter.
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On October 6,
1993, an individual, working intaccordance with
Radiation Work Permit- 93-1137. - entered into the radiological
controlled area without an alarming dosimeter.
This is a Severity Level IV violation (Supplement;IV) (285/9323-01)
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Attachment
LIC-93-0283
Page 2
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OPPD RESPONSE
A.
The Reason for the Violation
Omaha Public Power District (OPPD) completed two comprehensive Root Cause
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Analyses as a result of the events listed in the Notice of Violation.
Each of the cases listed in the violation occurred under different
circumstances.
However, the common cause of the events was a lack of
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attention-to-detail on the part of the personnel involved.
B.
Corrective Steos That Have Been Taken and the Results Achieved
Individual accountability for compliance with Radiation Protection (RP)
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requirements was discussed with Bechtel craft employees at a refresher
training meeting. This was completed on September 21, 1993.
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Individual
accountability for compliance with RP requirements was
discussed in OPPD Craft Shop Meetings. This was completed by November 19,
1993.
The " Outage Countdown," a Fort Calhoun Station (FCS) publication issued
periodically during -the 1993 outage,
in several articles reminded-
employees to pay attention-to-detail concerning RP_ practices.
This was
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completed at various times during the 1993 Refueling Outage,
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The FCS Plant Manager met with personnel on both outage shifts to discuss
attention-to-detail. This was completed on October.2, 1993
To improve continuity, the functional responsibilities for access control
were transferred from the RP Operations group to an individual supervisor
in the Radiological Health and Engineering group.
This individual's
supervisory duties include the training of access control technicians on
their
responsibilities
and
authority.
Since
this
transfer
of
responsibilities, there have been no further improper entries into the
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Radiologically Controlled Area (RCA). This was completed October 6,1993.
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C.
Corrective Steos That Will Be Taken to Avoid Further Violations-
1.
Individual accountability for compliance with RP requirements will
be discussed in Department Meetings for badged personnel. This will
be completed by December 31, 1993.
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2.
As a result of this violation, individuals that' have completed GET
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and have not been in the RCA in the . prior 'three months will be-
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required to have an additional briefing on the requirements of their
particular Radiation Work Permit.
This briefing will- include
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information on dosimetry and dressout
requirements.
-These
individuals will also demonstrate the dressout to RP. This will be
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implemented by December 31, 1993.
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Attachment
LIC-93-0283
Page 3
C.
Corrective Steos That Will Be Taken to Avoid Further Violations (Cont'd)
3.
The Radiation Worker Requalification Training Program has been
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revised to incorporate "RCA Access Skills Training." Icplementation
will begin in January 1994 and will be completed by February 28,
1995.
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4.
Additional emphasis on RP requirements will be included in General
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Employee Training (GET) and requalification.
This will include a
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videotape demonstration on the access control procedure and a
question and answer session. This will be incorporated by February
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18, 1994.
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5.
To ensure that OPPD expectations and requirements for RCA entries
are clearly defined, RP requirements that apply to station personnel
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will be incorporated into an FCS Standing Order.
This will be
completed by March 31, 1994.
6.
To ensure accountability for RP practices at all levels, Supervisors
will have performance measures established relating to their
departments adherence to RP practices (contaminations, etc.). This
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will be completed by April 30, 1994.
7.
The RP Department upgrading of access into the RCA has been ongoing.
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As a result of this violation, completion of automated access into
the RCA will be expedited.
Automated access will ensure that
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individuals entering the RCA have the proper dosimetry. This will
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be completed by June 30, 1994.
D.
Date When Full Comoliance Will Be Achieved
OPPD is presently in full compliance based on the completed actions listed
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above.
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