ML20096G261
| ML20096G261 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/18/1992 |
| From: | Gates W OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-92-177R, NUDOCS 9205260006 | |
| Download: ML20096G261 (9) | |
Text
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Omaha Public Power District 444 South 16th Street Mall C41ha, Nebraska 68102-2247 402/636-2000 May 18, 1992 LIC-92-177R U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (A. B. Beach) to OPPD (W. G. Gates) dated April 17, 1992 Gentlemen:
SUBJECT:
NRC Inspection Report No. 50-285/92-07 Reply to a Notice of Violation (,10V)
The subject re) ort transmitted a NOV resulting from an NRC inspection conducted March 23 27, he Omaha Public Power District (OPPD) response to this NOV. gram.
L992 of-the Fort Calhoun Station Radiation Protection Pro Attached is t Although several procedural non-compliances associated with the personnel contamination event were identified, OPPD has verified through a Root Cause Analysis that the non-compliances were isolated cases of poor performance by the Radiation Protection personnel involved, and were not indicative of programmatic
- problems.
If you should have any questions, please contact me.
Sincerely
- e. _J. h W. G. Gates Division Manhger Nuclear Operations WGG/sel Attachment c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator, Region IV R. P. Mullikin, NRC Senior Resident Inspector D. L. Wigginton, NRC Senior Project Manager S. D.- Bloom, NRC Project Engineer I
L 92G52600069205he nk gDR ADOCK 0500 5
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m Attachment LIC-92-177R Page 1 REPLY TO A NOTICE OF VIOLATION
)
y_LOLATION During an NRC inspection conducted March 23-27, 1992 violations of NRC requirements were identified.
The violation involved failure to follow procedures.
In accordance with the " General Statement of Policy and Procedure
-for NRC Enforcement Actions," 10 CFR Part 2 Appendix C, the violations are listed below:
Technical Specification (TS)l be established, implemented and maintained that 5.8.1 states, in part, that written procedures and administrative )olicies shal meet or exceed
- he minimum requirements of Regulatory Guide 1.33. -
i Regulatory Guide 1.33, Appendix A, Section 7.e.(1) k permit system shouldstates, in A.
access control to radiation areas by a radiation wor l
be covered by written procedures.
Radiation Protection Administrative Procedure RP-AD-200, Section 4.6, states, in part, that radiation protection technicians are responsible for
.... ensuring that RWP requirements are complied with.
Contrary to the above, the licensee identified that on February 28, 1992, a radiation protection technician instructed personnel to work without respiratory protection on Radiation Work Permit (RWP) ired.92-2538, even though the RWP stated that respiratory protection was requ This is a Severity Level IV violation (Supplement IV) (285/9207-01).
B.
Regulatory Guide 1.33, Appendix A. Section 7.e.(4) states, in part, that I
contamination control should be covered by written procedures.
Radiation Protection Procedure RP-207, Section 7.4.B., states, il part, that-all personnel ' skin and/or clothing contamination events not attributed to noble gases and/or naturally occurring radionuclides shall be documented on Form FC-RP-207-1, " Personnel contamination Report."
Contrary to the above, the licensee identified that on February 28, 1992, three individuals had facial contamination that was not attributed to noble gases and naturally occurring radionuclides and the contaminations were/or not documented on Form FC-RP-207-1.
This is a-Severity Level V violation (Supplement IV) (285/9207-02).
-C.
Regulatory Guide 1.33, A)pendix A Section 7.e.(5) states, in part, that respiratory protection saould be covered by written procedures.
2.
Radiation Protection Procedure RP-203, Section 7.1.2.B., states, in I
part, that job coverage air samples shall be taken as directed by the RWP-during work requiring respiratory protection, l
Attachment LIC 92-1770 Page 2 bI Contrary to the above, the licensee identifled that on February ed, e
1992 that no air sample was taken to support RWP 92-2538 work which requIredrespiratoryprotection.
This is a Severity Level IV violation (supplement IV) (285/9207-04).
D.
Regulatory Guide 1.33, Appendix A. Section 7.e.(8) states, in part, that the bioassay program should be covered by written procedures.
Section 7.4.3. A. states,ithin part, Radiation Protection Procedure RP-207 required for individuals w
skin that whole body counts are 5
contamination in the area of the mouth or nose measured prior to decontamination.
g Contrary to the above the licensee identified that on Februery 28, 1992, three individuals akarmed the p6rsonnel contamination monitor and exhibited contr.:Aination in the area of the mouth or nose. but a whole body count was not performed.
This is a Severity Level IV violation (Supplement IV) (285/9207-05).
QPPD Read 2H12 RcAlps for Violations (285/920741, 9207 02, 9207-04, 9207-05)
These four violations were identified by OPPD as a result of completing RCA) discussed below.
The RCA was initiated in the Root Cause Analysis (Occurrence Report (ROR) 92-09.
response to Radiological On March 13 1992, durin a routine random whole body count, it was determinedtfiatanOPPDIdtechnicianreceivedanintakeofradioactive "aterial greater than the lower limit of detection for Cs-137. During the investigation to determine the causs of the internal contamination, it was discovered that the individual had been contaminated on February 28, 1992 while working inside the reactor vessel seismir skirt area.
I RCA was compliances associated with a single event had occurred. procedural non' immMiately initiated.
The RCA identified ti.st four The specific procedural violations identified during the RCA consisted of the following:
Work inside the vessel skirt had been condu:ted without respiratory protection equipment as required by the PWP (Violation No. 9207-01).
No air sample had been taken during the performance of the job (ViolationNo. 9207 04).
Failure to document the intake on the personnel contamination report form had occurred and an investigational whole body count had not been performed (Violation Nos. 32'07-02 and 9207-05).
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Attachment LIC-92-177R Page 3 It -was further determined, by the RCA, that an OPPD shift Radiation Protection (RP) technician and a contractor RP technician had been the only two individuals directly involved in the procedural non-compliances.
The reason for each of the four OPPD Self-ider tified violations is discussed below.
i Violation 205/9207-01 This violation was the result of the OPPD shift RP technician instructing the workus to work inside the reactor vessel seismic skirt area without using respiratory protection ecuipment required by the Radiation Work RPtechn(RWPNo. 92-2538).
Inves".igation revealed that although the shif t Permit ician was aware of the requirement to read the RWP, he failed to do so and was thus uneware of the RWP requirement for respiratory protection equipment.
Failure to read the RWP was attributed to inattention to detail. Typically, RWPs give the shift RP technician the latitude to determine the need for respiratory protection equipment on a case by case basis. Although the workers involved questioned the decision not to wear respirators, they deferred to the authority of the shift RP technician, which is the preferred practice.
Violation 285/9207-02 This virlation has been attributed to inattention to detail.
The individuals involved it. the work inside the vessel skirt alarmed the personnel contamination monitors (PCHs) at the Radiologically Controlled Area exit.
The contractor RP technician directed the contaminated individuals to self-decontaminate. Af ter decontamination, the individuals cleared the PCMs.
The contractor technician failed to document the contamination in accordance with procedure RP-207, " Personnel Monitoring and Decontamination".
The contractor RP technician contacted the OPPP shift RP technician and informed him that - u the contaminations had been handled successfully.nder his supervision, The contractor technician did not inform the shift RP technician that there had been detectable facial contamination.
The contractor RP technician did not believe that a Personnel Contamination L
Report (PCR) was required because the contamination was less than 100 CPM (counts per minute above background. As a result, there was a violation of the procedural r)equirement to doceent all facial contaminations.
The 100 CPM limit applies to all contaminations except facial contaminations.
Additionally, the shift RP technician failed to ensure that the PCR form FC RP-207-1.had been completed.
Violation 285/9207-04 This violation resulted from poor judgement and a failure to implement good work practices.
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Attachment 1.lC 92-177R-Page 4 The contractor RP technician failed to perform the required air sample because he judged that it wasn't needed due to the expected short duration of the work inside the vessel skirt area fapproximately 15 minutes). The contractor RP technician also did not antscipate any airborne radioactive contamination as a result of the scope of work to be performed in the area.
Violation 285Z9291.-9ji This violation is directiv connected with the failure to document the personnel contamination referenced in Violation 9207-02. Form FC-RP-207-1 (Personnel Contamination Report if contamination is detected in)the area of the nose or month area.specifically requires a w The l
failure to document the facial contaminations resulted in tir railure ta perform a whole body count.
As with Violation 9207-02 this violation has been attributed to inattention to detail by tbe contractot RP techniciah and indequate followup by-the shift RP technician involved.
CorrectlyLgdons That HavtBeen Taken (Violations 9207-01, 9207-02, 9207-04, 9207 05) 1.
A RCA was performed as discussed above.
The RCA (ROR 92-09) determined that this was an isola ed event that resulted in several procedural non compliances.
2.
A review was coducted of random whole body counts performed from January 1991 through April 1992. A review of exit whole body counts performed from January 1992 through April 1992 was also conducted.
Of the 177 random whole - body counts reviewed, the appropriate documentation was completed in all cases.
Of the exit whole body counts reviewed there were no cases where an intake of radioactive material wss rec,eived by an individual without proper documentation in accordance with station procedures.
3.
Interviews were cor. ducted with several contractor RP technicians and the entire day shif t crcw of OPPD RP technicians.
It was concluded that there was no knowledge of any similar events where documentation had not been pre ared.
Additionally, individuals interviewed were fully knowle eable of the requirements for documentation of PCRs and investi ative whole body counts.
4.
A review of the 14 Radiological Occurrence Reports generated in 1992 was conducted to determine if there were any other generic
. implications.
Two of the RORs reviewed, 92-02 and 92-08, involved small intakes of radioactive material.
It was determined that in both cases, complete documentation of the events was properly _
performed.
5.
A Radiatioc Protection departmental meeting was conducted to discuss the -procedural-violations associated with this event and to emphasize the necessity of verbatim procedural cowpliance and self-checking.
7 Attachment LIC 92-177R l
Page 5 j
linarfechnician. action was taken with the OPPD sh 6.
Aba$viate distifion The contractor Radiation R
ion Protec Protection technician involved had already resigned as of the date of discovery of the uptake.
Ho.,ever the contractor site representative was notified about these violations.
7.
The Training department distributed required reading " Hot Lines" to Radiation Protection personnel on the procedures that were violated.
Personnel were required to review and certify their understanding of the procedural requirements of RP-201, RP 207 and RP-650.
Lorrective Actd ons That Will Be Taken (Violations 9207-01, 9207 02, 9207-04 and 9207-05) 1.
During the next scheduled RP training cycle, these procedural violations and the associated event will be discussed and reviewed.
This will be completed by August 31, 1992.
2.
During the next schaduled RP training cycle, self-checking training will be instructed to the RP technicians.
The self-checking training will also be incorporated into the initial training for RP technicians. This will be completed by August 31, 1992.
The requirements of procedure RP-203, " Air Sampling"il be reinforced 3.
and RP-AD-200,
" Radiation Protection Administrative Procedure", wi during the next scheduled training cycle. This will be completed by August 31, 1992.
4 These procedural violations and the associated event will be included in the Significant/ industry Events training program for RP con.ractors. This will be umpleted by December 31, 1992.
Date of Full Comoliance OPPD is prestatly in full compliance.
VIOLATION C.
Regulatory Guide 1.33, A)pendix A Section 7.e.(5) states, in part, that respiratorv protection saould be covered by written orocedures.
1.
Re ation Protection Procedure, RP-201, Section 7.4.1. A., states, in pad, that respiratory protection equi) ment selection is to be documented on Form FC-RP-201-6 and autached to the RWP when respiratory protection equipment is specified on a RWP.
Contrary to the above, on March 27, 1992, the inspectors determined that Form FC-RP-201-6 was not attached to RWP 92-2538 which required-respiratory protection equipment.
This is a Severity i.evel V violation (Supplement IV) (285/9207-03).
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-l Attachment LIC 92 177R Page 6 OPPD RESPONSE Reason for violatica The " Respirator Selection" form FC-RP-2016 is pt 3 pared as a supplement to the RWP. This form provides documentation on the reasons why respiratory protection equipment responsibility of the ALARA technicians. pletion is required.
Com of this form is the The ALARA technician who prepared RWP 92-2538 failed to comply with the Radiation Protection Procedure RP-201 by not attaching form FC-RP-201-6 to the RWP.
The ALARA technician who prepared RWP 92-2538 was interviewed and remembered that a FC-RP-201-6 form was prepared for the RWP at the time and that it must have been misplaced if it was missing.
The inattention to detail b resulted in the procedural non-compliance. y the ALARA technician Corrective Actions That Have Been Taken 1.
The ALARA Grous conducted an audit of the RWPs generated during 1992.
This audit of over 600 RWPs determined that there were five RWPs requiring respiratory protection without the associated Resoirator Selection form FC-RP-201-6.
For those RWPs that were still active, the forms were completed and attached to the RWPs.
For thosc RWPs that were terminated, a list was generated showing which RWPs were improperly completed, and documentation was provided in each terminated RWP file.
In each of the five cases w1ere the form was missing, the proper respiratory protection was actually used.
2.
Station " Hot Lines" were issued to the RP technicians reg"arding the re uirements of Radiation Protection procedure RP-201 Radiation Wo k Permits".
Corrective Actions That Will Be Taken 1.
The Radiation Protection Deuartment will evaluate possible procedural / process enhancements to ensure that the Respirator Selection -form is prepared.
This will be completed by July 31, 1992.
2.
During the next scheduled RP training cycle, these procedural violations and the associated event will be discussed and reviewed.
This will be completed by August 31, 1992.
3.
During the next scheduled RP training cycle, self-checking training will be instructed to the RP ter.hnicians.
The self-checking training will also be incorporated into the initial training for RP technicians.
This will be completed by August 31, 1992.
Qa.te of full Compliance OPPD is presently in full compliance.-
Attachment LIC-92-177R Page 7 U_QLAllDE E.
Regulatory Guide 1.33 Appendix A, Section 8.b.(1)(aa)inspectionsstates, in part, that specific procedures for surveillance tests, and calibrations should be written for area, portable, and airborne radiation monitors.
Radiation Protection Procedure RP-402, 51ction 7.2.3.A. states, in part, that when in service, instruments shall be calibrated at least semiannually.
Section 7.2.4 B. states, in part, that schedules say be adjusted + or - 25 percent.... To extend a calibration due date attach a second calibration label to the instrument which reflects the new due date.
Contrary to the above, on March 24, 1992, the inspectors noted that the calibration sticker on PING-1A performedonSeptember12,199I,S/N212,statedthatthecalibrationwas and was dua on March 12, 1992.
This is a Severity Level IV violation (Supplement IV) (285/9207-06).
QPPD RESPONSE Reason for Violation This violation resulted from inattention to detail by the contractor RP technician involved.
The calibration due dates for non-portable instrumentation are tracked by the Instrument & Control
!&C Department's computer system.
Preventive Maintenance Work Orders (P(MO) )are issued prior to the c.alibration duc date for instrumentation undar I&C control. Due to I&C's outage work load the calibration was not performed as scheduled, and was rescheduled.
The calibration due date was then automatically extended by 25% of the due date as allowed by procedure.
1&C did not notify RP that the calibration due date had been extended.
The contractor RP technician who response-tested the instrument overlooked the calibration due date 'abel and as a result failed to affix a new label or tag the instrument
..t of service.
Even though a new label had not been attached, the P1NG-1A was still considered calibrated since it was within the allowed +25%
r,. tension period.
Corrective Actions That Have Been Taken 1.
The PING was tagged out-of-service immediately after notification of the problem.
2.
I&C immediately scheduled the PING for calibration, which was completed on March 27, 1992.
3.
The RP Instrument group audited the 726 in-place and
)ortable instruments.
They found three portal monitors at the norti access point that were within the +25% window but did not have revised calibration labels attached.
These three portal monitors were tagged out of service, calibrated, and current calibration labels attached.
Attachment LIC-92-177R Page 8 4.
Memo FC-RP 159 92 was sent to the RP Instrument technicians for their review and signatures, it strested that calibration due datos are to be verified orlor to response testing.
5.
The Radiation Protection Instrument group has updated their instrument tracking system to include the calibration due dates of non-portable instrumentation. This will serve as an alternate means of tracking to ensure that any instruments due for calibration will be tagged out of service on on prior to the calibration due dates.
[orrective Actions That Will Be Taken During the next scheduled RP training cycle self-checking will be instructed to the RP technicians. The self check,ing trainin ir.corporated into the initial training for RP technicians. g will also be This will be completed by August 31, 1992.
Date of full Compliance OPPD is presently in compliance.
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