ML20087F329
| ML20087F329 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/03/1984 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20087F319 | List: |
| References | |
| LIC-84-037, LIC-84-37, NUDOCS 8403190061 | |
| Download: ML20087F329 (3) | |
Text
BTB l
l l
Omaha Public Power District l
1623 Harney Omaha. Nebraska 68102 402/536 4000 February 3, 1984 LIC-84-037
% @ @ @ 0N S St Mr. Richard P.
Denise, Director
((@ - 6 @f Q
Division of Resident, Reactor Project
& Engineering Programs L
U.
S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Reference:
Docket No. 50-285
Dear Mr. Denise:
Notice of Violation Inspection Report 83-31 The subject report, dated January 5, 1984, identified a violation concerning procedural compliance.
Accordingly, please find attach-ed the Omaha Public Power District's response to this Notice of Violation.
Sincerely, T
f]lf. '
J W. C. Jorjes Divisich/ Manager Production Operations WCJ/DJM:jmm Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Mr.
E.
G.
Tourigny, Project Manager Mr.
L.
A.
Yandell, Senior Resident l
Inspector 8403190061 840308 PDR ADOCK 05000285 0
PDR 45.5124 Employment with Equal Opporturuty Male / Female
Attachment Based on the results of an NRC inspection conducted during the period of November 14-18, 1983, and in accordance with NRC En-forcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated J
March 9, 1982 the following violation was identified:
Procedural Compliance Technical Specification 5.11, " Radiation Protection Pro-gram," states:
" Procedures for personnel radiation pro-tection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be maintained and adhered to Radiation procedures are also addressed in your Standing Order T-1,
" Radiation Protection Manual," which states:
"All station personnel
. will abide to every provision of the Radiation Protection Manual In addition,Section IV.I.1, " Weekly Review of Standing R.W.P.'s,"
of Radiation Protection Procedure (RPP)-20, "Radi-ation Work Permit," which is part of the Radiation Pro-tection Manual, states:
"All R.W.P.'s written for a period greater than five working days will be reviewed by a desig-nated individual within the Radiation Protection Group the R.W.P. Will be dated and initialed in the space pro-vided."
i Contrary to the above, on November 16, 1983, the NRC in-spector determined that the licensee had not performed the proper weekly review of approximately 14 Standing radiation work permits for the month of February 1983 and also a similar number for the month of May 1983.
l This is a Severity Level V Violation.
(Supplement IV)
(285/8331-01)
Response
(1)
The corrective steps which have been taken and the results achieved.
Concerning the February, 1983 RWP reviews:-
Weekly reviews were not performed on these 14 RWP's because all 14 were terminated before the weekly. review was required to be conducted.
Therefore, further action ~is not required concerning the February, 1983 RWP's.
. ~.
- ..e
. Concerning the May, 1983 RWP reviews:
On November 16, 1983, the date when the missed RWP reviews were identified, an immediate review of radiation, contami-nation and airborne surveys was conducted for the affected period in May, 1983.
This review-demonstrated that radio-logical conditions immediately before, during, and after the missed review period were stable and unchanged, indicating that the protective measures described in the unreviewed RWP's were appropriate.
No individual received either ex-cessive or unexpected radiation exposures, contaminations due to improper protective clothing, or internal exposure as a result of improper respiratory protection.
The results of this review were provided to the inspector prior to the exit interview.
The RWP program was reviewed and it was determined that the formalized weekly review process on the RWP was redundant to another activity.
This activity is the ongoing program of daily, weekly, monthly, and special surveys of radiological conditions within the radiological controlled area.
The pri-mary purpose of this program is to assure that the RWP'c are changed to reflect changed conditions.
The survey process had always resulted in appropriate changes before the admini-strative weekly review process so that no administrative weekly review resulted in changes to RWP's.
The weekly re-view of Standing RWP's was determined to have neither oper-ational purpose nor administrative value.
Based upon this review and the operational need to improve the RWP system, a procedure change to the RWP form (2C-236) and procedure RPP-20 was completed.
The deletion'of the administrative weekly review process was included in these changes.
In addition, Section 4.0 of the Radiation Pro-tection Manual was revised to clarify that upon completion of routine and special surveys, health physics personnel re-view these surveys to determine if Standing or Extended RWP's remain adequate.
The current system of RWP updates as a result of routine and special surveys' continues to assure that the radiological safety of workers is maintained and not reduced.
Since the approval of the new RWP system, up-dates to the RWP's have been made as appropriate.. Many im-proved effects have resulted from these changes.
(2)
Corrective steps which will be taken to avoid further vio-lations.
The action previously taken, as described in-(l) above, is considered appropriate to prevent a recurrence of the vio-lation.
(3)
The date when full compliance will be achieved.
The District is currently in full compliance.
_