ML20127L489
| ML20127L489 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/23/1985 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20127L459 | List: |
| References | |
| LIC-85-219, NUDOCS 8506280035 | |
| Download: ML20127L489 (6) | |
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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536 4000 May 23, 1985 LIC-85-219 Mr. Richard P. Denise Division of Resident, Reactor p -, G B Oh/qb__R
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Project and Engineering Programs 1W or U.S. Nuclear Regulatory Commission j
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a Plaza Drive, Suite 1000
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MAY 2 81985 Arlington, Texas 76011 a
Reference:
Docket No. 50-285
Dear Mr. Denise:
Notice of Violation IE Inspection Report 85-02 The Omaha Public Power District received the subject Inspection Report dated April 23, 1985.
This report forwarded five (5) Notices of Violation from an inspection of the District's radiation protection program conducted March 4-8, 1985.
Accordingly, pursuant to 10 CFR 2.201, please find attached the District's responses to these violations.
Sincerel an R. L. Andrews Division Manager Nuclear Production RLA/DJM:glp 8506280035 850624 Attachment
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LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, Senior Resident Inspector asse4 cmpioumengan cau; opponunnu
Attachment Based on the results of an NRC inspection conducted during the period of March 4-8, 1985, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following violations were identified:
1.
Failure to Follow Procedures Technical Specification 5.8.1 requires that " written procedures... be established, implemented, and maintained that meet or exceed the minimum requirements of Section 5.1 and 5.3 of ANSI N18.7-1972, and Appendix A of USNRC Regulatory Guide 1.33...."
The FCS Operating Manual states in Section 1.3 that:
" adherence to the Operating Manual is mandatory." Radiation Protection Procedure (RPP) 14 in Section B of the Operating Manual states that:
"high level waste is any material disposed of having contact radiation readings of greater than 100 mR/hr.... hot spot st1 ders will be attached to the bag stating the radiation levels and any special precautions that should be taken."
Contrary to the above, an NRC inspector determined on March 5, 1985, that a plastic bag, without a hot spot sticker attached, and yielding a contact
. radiation dose rate of approximately 300 mR/hr was observed in an unposted waste bin located in the lower level of the auxiliary building. The outside surface of the waste bin was observed to yield a contact dose rate of approximately 110 mR/hr.
This is a Severity Level IV Violation.
(Supplement IV)
(285/8502-05)
Response
(1) The corrective steps which have been taken and the results achieved.
Changes to procedures HP-8, " Labeling and Bagging of Radioactive Mate-rials", and RPP-14, "In-Plant Collection and Disposal of Radioactive Waste" have been prepared to ensure consistency between these two pro-cedures and HP-25, " Radiation Hot Spot Verification / Update", and to ensure full compliance with 10 CFR Part 20.203(f)(2).
Immediate action was taken on March 5,1985, after the discovery of the 300 mR/hr bag, to properly post both the bag and its waste box with the level of hazard. A survey was conducted on March 5 and 6 to identify if any other bags or containers were iceoperly posted.
Based on the results of the survey, no additional bags or containers were found to be improperly labeled.
The changes to procedures HP-8, and RPP-14 have been completed and approved which have corrected inconsistencies between implementing procedures.
1 (2) Corrective steps which will be taken to avoid further violations.
The actions described in (1) above have resolved the issue. No further action is considered necessary.
j
(3) The date when full compliance will be achieved.
The District is presently in full compliance.
2.
Instructions to Workers 10 CFR Part 19.12 states, that:
"All individuals working in or frequenting any portion of a restricted area shall be kept informed of... the health protection problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed; and shall be advised as to the radiation exposure reports which workers may request pursuant to 10 CFR Part 19.13. The extent of these instruction shall be commensurate with potential radiological health protection problems in the restricted area.
The FCS Updated Safety Analysis Report (USAR) states in Section 1.2.1,
" Plant Site," that the restricted area as defined in 10 CFR Part 20 is that area bounded by the site protected area fence, as depicted in Figure 1.2-2 of the USAR.
i Contrary to the above, an NRC inspector determined on March 4, 1985, that the licensee had not provided appropriate radiation protection instructions to approximately 140 workers currently badged to enter the restricted area.
This is a Severity Level V Violation.
(Supplement IV)
(285/W02-01)
Response
(1) Corrective steps which have been taken and the results achieved.
A memorandum of training (training " hotline") was sent to all individuals badged with green or yellow identification badges. Holders of green or yellow badges are not permitted unescorted status into the Radiation Controlled Area of Fort Calhoun Station, but are permitted entry into other parts of the restricted area. The " hotline" was distributed March 8, 1985 and provided green and yellow badged personnel with the additional infor-mation necessary for full compliance with 10 CFR Part 19.13. The infor-mation provided was commensurate with the radiation hazards found infre-quently within the restricted area but outside the Radiation Controlled Area.
In addition, the information provided in the training " hotline" is being provided to green and yellow badge candidates during initial and requalification training along with the training previously provided in Station General Employee Training for yellow and green badge qualification.
(2) Corrective steps which will be taken to avoid further violations.
The actions described in (1) above resolved the issue.
No other action is considered necessary.
(3) The date when full compliance will be achieved.
The District is presently in full compliance.
e.
3.
Form NRC-4 10 CFR Part 20.102(b) requires, in part, that before permitting any indi-vidual in a restricted area to receive an occupational radiation dose in excess of 1.25 rem whole body exposure in a calendar quarter each licensee shall:
" Calculate on Form NRC-4...., the previously accumulated occupational dose received by the individual and the additional dose allowed for that individual under 10 CFR Part 20.101(b)."
Contrary to the above, an.NRC inspector determined on March 6,1985, that four individuals exceeded the 10 CFR Part 20.101(a) whole body exposure limit during 1984 without having calculated and recorded the permissible life time dose-whole body required by Section 13 of Form NRC-4.
i This is a Severity Level V Violation.
(Supplement IV)
(285/8502-02)
Response
-(1) The corrective steps which have been taken and the results received.
The District's procedures and their implementation have resulted in no individual exceeding 3 Rem whole body exposure for any quarter or 5 Rem whole body exposure for any year.
However, action was taken to complete Section 13 of Form NRC-4 for individuals at Fort Calhoun Station for which monitoring under 10 CFR 20.202 is required. This action was completed by March 8, 1985. The District is completing Section 13 for newly generated NRC-4 forms.
(2) Corrective steps which will be taken to avoid further violations.
The actions described in (1) above resolved the issue.
No other action is considered necessary.
(3) The date when full compliance will be achieved.
The District is presently in full compliance.
4.
Form NRC-5 10 CFR Part 20.401(a) requires that:
"Each licensee shall maintain records showing the radiation exposures of all individuals for whom personnel monitoring is required under 10 CFR Part 20.202. Such records shall be kept on Form NRC-5, in accordance with the instructions contained in that form or on clear and legible records containing all the information re-quired by Form NRC-5. The dose entered on the forms or records shall be for periods of time not exceeding one calendar quarter."
Contrary to the above, the NRC inspector determined on March 6,1985, that the licensee's equivalent Form NRC-5 did not contain all the information required by Form NRC-5 in that the licensee's form did not provide for input and calculation of the unused part of permissible accumulated life
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4.
Form NRC-5 (Continued) time dose as required in Items 17 and 18 of Form NRC-5. Also, the licen-see's equivalent Form NRC-5 contains whole body, skin and extremity expo-sure data on the same Form NRC-5 and for periods exceeding one calendar
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. quarter which is in violation of 10 CFR Part 20.401 and the instructions j
contained on Form NRC-5.
I This is a Severity Level V Violation.
(Supplement IV)
(285/8502-03) i
Response
(1) The corrective steps which have been taken and the results achieved.
4 The District has revised Form FC-228 to include all information contained on Form NRC-5.
(2) Corrective steps which will be taken to avoid further violations.
The actions described in (1) above resolved the issue.
No further action is considered necessary.
r (3) The date when full compliance will be achieved.
The District is presently in full compliance.
- 5. -
Notification of Exposure to Individuals j
10 CFR Part 20.408(b) requires that:
"When an individual terminates employment with a licensee....
the licensee shall furnish... the NRC..., a report of the individual's exposures to radiation... during the period of employment.... Such report shall be furnished within 30 days after the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment...
whichever is earlier." 10 CFR Part 20.409(b) requires-that:
"When a licensee is required pursuant to 10 CFR Part 20.408 to report to the Commission any exposure of an individual to radiation... the licensee shall also notify the individual. Such notice shall be transmitted at a
. time not later than the transmittal to the Commission...."
Contrary to the above, an NRC inspector determined on March 6,1985, that the' licensee failed to provide the required exposure information within the specified time period on at least three occasions involving workers 4
terminating employment in 1984 and 1985.
This is a Severity Level V Violation.
(Supplement IV)
(285/8502-04) 1 1
Response
(1) The corrective steps which have been taken and the results achieved.
The District has reviewed the status of radiation workers who have terminated employment and prepared and transmitted to them and to the Commission reports of radiation exposure as required by 10 CFR Parts 20.408(b) and 20.409(b). A review of internal methods of determining termination dates of radiation workers has been conducted. As a result of this review, the District's practice has been changed to provide a weekly notification to health physics personnel regarding radiation workers who have terminated employment.
(2) Corrective steps which will be taken to avoid further violations.
The actions described in (1) above resolved the issue.
No further action is considered necessary.
(3) The date when full compliance will be achieved.
The District is presently in full compliance.