ML20149L010
| ML20149L010 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/18/1988 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Lieberman J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| LIC-88-116, NUDOCS 8802240071 | |
| Download: ML20149L010 (14) | |
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Omaha Public Power District 1623 Harney Omaha Nebraska 6 BIO 2 402 536 4000 February 18, 1988 LIC-88-ll6 Mr. James Lieberman, Director Office of Enforcement CERTIFIED U. S. Nuclear Regulatory Commission IOMTNCEIFT RFD'ESTED ATTN:
Document Control Desk Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (R. D. Martin) to OPPD (R. L. Andrews) dated January 19, 1988
Dear Mr. Lieberman:
SUBJECT:
Notice of Violation and Proposed Imposition of Civil Penalty NRC Inspection Report No. 50-285/87-21 Omaha Public Power District (0 PPD) received Reference 2, Notice of Violation and Proposed Imposition of Civil Penalty, issued as a result of an inspection j
conducted September 14-18, 1987 at the Fort Calhoun Station, in Section I of Reference 2, two violations were identified pertaining to the control of Very High Radiation Areas.
Section 11 of Reference 2 identifies a violation not assessed a civil penalty for failure to submit an LER pursuant to the require-ments of 10 CFR 50.73.
These violations were discussed in an enforcement conference held in the Region IV office on October 15, 1987.
Subsequent to the enforcement conference of October 15, 1987, a civil penalty was proposed pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR Part 2.205. OPPD acknowledges the violations as stated in Reference 2, Section 1 and does not contest the proposed civil penalty.
Accordingly, please find attached OPPD's response to the Reference 2,Section I violations pursuant to 10 CFR Part 2.201 and a check in the amount of $75,000. OPPD's response to the violation stated in Reference 2,Section II, which was not assessed a civil penalty, is also enclosed.
Omaha Public Power District desires to stress the Company't comitment to open and candid comunications with the NRC. We are disturbed that %r communications during the enforcement conference were considered ins than c?en and candid and we will take whatever steps necessary to rectify this concern.
OPPD has embarked upon a program intended to achieve excellence in operations.
The Company's comitment to excellence is being translated into measurable and objective goals and is being communicated throughout the organization.
Key exempt personnel were provided with details of the excellence in operations f6Iq philosophy and the key factors in achieving and measuring excellence.
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James Lieberman LIC-88-ll6 Page 2 1
During a recent visit to Fort Calhoun Station, Mr. Tom Westerman of Region IV attended an excellence in operations presentation session given by Senior Vice President Bill Jones.
The Company is striving for an environment and attitude of teamwork, professionalism, enthusiasm, efficiency and pride.
Fundamental to
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the goal is a philosophy that the conduct of business with the NRC is open and objective.
i OPPD's management is committed to the excellence in operations program and has i
taken steps which include self assessments currently underway and group meet-ings with personnel as described in the attachment to this letter.
Please do not hesitate to contact us if you should have any additional concerns with this i
matter, or with the responses to the violations.
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Sincerely,
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R. L. Andrews Division Manager i
Nuclear Production 1
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ec: LeBoeuf, Lamb Leiby & MacRae i
R. D. Martin, NRC Regional Administrator i
A. Bournia, NRC Project Manager
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P. H. Harrell, NRC Senior Resident inspector i
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O UNITED STATES OF AMERICA NUCLEAR REGULATORY C0fMISSION In the Matter of Omaha Public Power District Docket No. 50 285 (Fort Calhoun Station Unit No. 1)
AFFIDAVIT R. L. Andrews, being duly sworn, hereby deposes and says that he is the Division Manager - Nuclear Production of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Comission the enclosed response to Notice of Violation and Proposed Imposition of Civil Penalty for NRC Inspection Report No. 50 285/87 21, that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief, dbkd=&
R. L. Andrews Division Manager i
Nuclear Production l
STATE OF NEBRASKA ss COUNTY OF DOUGLAS
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Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this 19' t" day of February, 1988.
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ATTACMENT REPLY TO NOTICE Of VIOLATION Based upon the results of an NRC inspection of the Fort Calhoun Station con-ducted September 14-18, 1987 and additional information provided during the
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enforcement conference at the NRC Region IV office in Arlington, Texas on October 15, 1987, the following violations were identified:
VIOLATION I.A Technical Specification 5.11.2 requires that entrance into each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr (Very High Radiation Area) shall be controlled by the use of locked doors to prevent unauthorized entry.
1.
Contrary to the above, at approximately 10:30 a.m. on September 9, 1987 the door to the spent fuel storage pool heat exchanger, pump and filter room (Room No. 5), a Very High Radiation Area, was unlocked.
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2.
Contrary to the above, at approximately 2:30 p.m. on October 14, 1987 the i
door to Room No. 11 in the Auxiliary Building, a Very High Radiation Area, j
was unlocked, t
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These are repeat violations.
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AMLSSION OR DENIAL OF THE ALLEGED VIOLATION t
j The violations to Fort Calhoun Station Technical Specification 5.11.2 noted above occurred as stated.
In addition, on January 25, 1988, OPPD identified a further violation of Technical Specification 5.11.2 in that the door to Room 11 l
l was locked but not properly latched.
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J REASONS FOR THE VIOLATIONS
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The violations occurred following personnel exit from the spent fuel storage pool heat exchanger, pump and filter room (Room 5) and the radioactive waste l
demineralizer and filter room (Room 11) on September 9, 1987 and October 14 I
1987, respectively.
Personnel interviews were conducted to determine the i
j reasons for the incidents. The interviews identified the following reasons:
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A.
Lack of attention to detail.
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Personnel not following established procedures for control of Very High Radiation Areas (VHRA).
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Inadequate and incomplete corrective action for previous similar 3
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Various types of locking mechanisms are used on VHRA barriers, i
The circumstances of each event are as follows:
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Seotember 9. 1987 Event Room 5 was entered at approximately 8:00 a.m. during the morning of September 9, 1987 by an individual performing his routine duties. Upon completion of his work, he exited the room and turned the deadbolt type locking mechanism with the key to the point he believed set the deadbolt in the locked position. The key was removed and he left the area without verifying that the door was locked. The door was subsequently found unlocked.
October 14. 1987 Event The following incident was identified by OPPD Quality Assurance and was corrected by OPPO.
It was reported and discussed at the enforcement conference October 15, 1987 and in Licensee Event Report 87-026 dated October 28, 1987.
At approximately 8:30 a.m. on October 14, 1987 the Room 11 door was checked and verified to be locked by the ALARA Coordinator checking postings for VHRA's.
Later that morning, the door to Room 11 was opened by an individual to see if spent demineralizer filters were ready for transfer to the disposal area.
Believing the door was locked in accordance with procedures before opening it, the individual used the key to unlock the spring actuated lockset.
He pulled the door open with the key without grasping the doorknob.
With the door open and the key in the lock, he looked into the room and saw that the filters were ready. He closed the door with the key still in the lock, ensured that the door had latched and removed the key without turning the doorknob to verify that the door was locked.
The spring actuated lockset has push-buttons to set the locked or unlocked configuration of the mechanism. However, a cuver plate had not yet been installed over the push buttons to ensure no inadvertent repositioning could occur.
This configuration cannot be changed by using the key in the lock tumbler.
The door was subsequently found unlocked.
M uary 25. 1988 Event On January 25, 1988 two individuals qualified as health physics technicians, entered Room 11 from Corridor 4 in accordance with established procedures to check for the presence of waste demineralizer filters ready for disposal.
Filters we:e staged and ready for transfer so the individual exited Room 11.
The waste filters were removed from Room 11 in accordance with approved procedures through another entrance to Room 11. Approximately two hours later, the door from Corridor 4 to Room 11 was found to be locked but unlatched.
In summary, the violations occurred as a result of lack of attention to detail, lack of procedural compliance, incomplete and inadequate corrective actions, and non-standardized locking mechanisms.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED On September 9, 1987 after the Room 5 door was discovered to be unlocked, it was verified that no personnel were in Room 5, the door was locked and verified to be locked.
In addition, all other VHRA doors outside containment were verified locked. After September 9 and before October 14, the deadbolt mechanism in the Room 5 door was replaced with a spring actuated type lockset.
This type of locking mechanism can be configured to be locked at all times or unlocked at all times by push button.
The mechanism was set in the locked configuratiun and a coverplate attached with machine screws over the push-button to prevent accidental changing of the configuration.
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Later in the day on September 9, 1987, the Supervisor 0perations issued a memorandum to the Shif t Supervisors on the su) ject of the incident. That memorandum directed the Shift Supervisors to make sure their crew members were aware of the incident and that crew members were aware of the requirements for entry into High Radiation and VHRA's.
Section 3.1.7.2.B of the Fort Calhoun Station Radiation Protection Manual was referenced for the requirements for entry into High and Very High Radiation Area's.
In addition, the Shift Supervisors were directed to sign the memorandum and have Senior Licensed Operators, Licensed Operators and Auxiliary Building Operator trainees sign the memorandum. Signatures were to indicate and document their review of the memorandum and the referenced section of the Radiation Protection Manual.
All Shift Supervisors and operators designated on the memorandum signed as requind and returned the memorandum to the Operations Supervisor.
The radiation source causing all of Room 5 to be declared a VHRA has been removed.
There still exists a VHRA at the back of Room 5 in the immediate area of the spent fuel storage pool demineralizer and filter units which is controlled by a padlocked cage. There have been no further incidents with the Room 5 door since the September 9, 1987 event.
Administrative 1y, documentation of daily VHRA door checks for the period January 1, 1987 to Sept ober 9, 1987 was reviewed.
No instances of unlocked doors were recorded from over one thousand door checks that were made during that period of time.
The results of this review led OPPD to believe that the incident on September 9, 1987 was an isolated event caused by the Room 5 door lock and the particular operator involved. Therefore, corrective actions were directed at the Room 5 door locks and the Operations staff as described above.
In addition, administrative action was taken to change the Radiation Protection Manual to require that only ANSI qualified health physics technicians are authorized to use a key to open a VHRA door during normal operations. The Auxiliary Building Operator on duty continues to carry a key to VHRA doors, but its use is restricted to emergency situations.
The health physics technician escorting entry to a VHRA was assigned the responsibility of verifying the door to be locked after exit from the VHRA. The Health Physics staff continued the practice of daily VHRA door checks and documentation of cuch checks.
On October 14, 1987 after the Room 11 entrance from Corridor 4 was found to be unlocked, it was verified that no personnel were in the room and the door was locked and verified to be locked.
In addition, all other VHRA doors outside Containment were verified to be locked.
Later that day, a coverplate for the lockset push-buttons on the Room 11 entrance from Corridor 4 was attached with machine screws after ensuring it was ih the locked configuration.
Sub-sequently, VHRA barrier locks were standardized using padlocks and hasps or chains.
The padlocks were placed on all VHRA doors outside containment except for the Volume Control Tank (VCT) Room (Room 29) and the entrance to Room 11 from Corridor 4.
By supervisory direction, the frequency of the daily documented VHRA door checks by the Health Physics staff was increased to every four hours prior to November 1, 1987. This action was implemented by written order from the plant Health Physicist in the Health Physics log book and was formalized by change of the Radiation Protection Manual on February 12, 1988.
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j After implementation of the actions discussed above, there were no incidents involving VHRA doors until January 25, 1988 when the one door to Room 11 with-out a padlock (referenced above) was found in a locked but unlatched position.
It was verified that no personnel were in Room 11 and the door was closed and i
l verified to be latched and locked. Licensee Event Report number 88 001, j
regarding the January 25, 1988 incident, is being prepared for submittal to the NRC by February N, 1988.
Subsequent to the January 25, 1988 incident, a requirement for verification and documentation t'y i.wo individuals that VHRA dnors are closed, latched and locked upon exit from a VHRA was formally implemented.
The practice of Health Physics staff VHRA door checks every four hours continues.
l To further assist OPPD management in resolving generic concerns of developing l
1 and implementing appropriate corrective actions, an independent appraisal of the operational and administrative aspects of the OPPD nuclear operation was e
initiated as a result of other NRC concerns and is in progress.
This appraisal is directed towards improvements in safety of plant operations and compliance j
with NRC regulations, leading to excellence in operations.
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This appraisal is reviewing and developing recommendations as necessary in at l
1 east tie following areas:
4 Organizational responsibilities e
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Management controls and effectiveness Staffing levels l
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Communications i
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e Corporate operating practices j
e Personnel motivation and discipline
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a Our understanding of regulatory and administrative requirements i
e Adequacy of improvements to make lasting changes e
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This appraisal will be complete by June 1, 1988 with implementation of I
recommended corrective actions to follow.
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OPPD management recognizes that effective implementation of corrective action i
1 would have eliminated the recurrences of VHRA door events.
As evidenced by the
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events of October 14, 1987 and January 25, 1988, the actions taken up to January 25, 1988 were not effective in ensuring compliance.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l
Employee Management conferences are being initiated to emphasize procedural l
ccepliance.
These conferences are to be conducted on a one-to one basis 1
between the Station Supervisors and their employees.
Topics of the discussions i
include, but are not limited to, strict procedural compliance, the means by i
j which procedural concerns can be brought to Management's attention, and the appropriate actions to be taken to rectify concerns.
These conferences will continue until appropriate personnel have been through the process.
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l A changeout of all VHRA barrier locking mechanisms outside of containment will provide positive control without the use of padlocks. There is a personnel safety concern when using )adlocks. Due to the possibility of personnel i
becoming locked in a VHRA sy an individual closing the VHRA barrier padlock j
without confirming if peopic are inside. The change to the locking mechanisms I
will be completed by July 15, 1988. During the interim, enhancements to key i
control, four hour door checks, and a "two man" rule for VHRA entry will continue.
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The reduction in size and/or isolation of VHRA's, when localized inside a large room, is an ongoing activity.
The further evaluations necessary for size i
reductions and/or isolation of localized VHRA's will be expedited.
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l An electrically supervised monitor strike system to monitor VHRA doors I
including lock engaged as well as door closed will be installed during the 1988 i
refueling outage.
Preventive maintenance and surveillance procedures will be established and implemented for the door alarms. A local alarm for the monitored strike will be pursued to heighten personnel awareness of VHRA door l
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status.
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A task force of OPPD management and supervisory personnel has been formed to
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develop a comprehensive plan for overall improvement of the Fort Calhoun Sta-1 tion radiation protection program. This task force will examine and evaluate l
the radiation protection procedures currently in place, identify generic areas I
of concern, review specific actions, provide recomendations for improvements l!
and assist in implementation of recomendations. A draft improvement program f
will be completed before March 15, 1988 for review and comment by OPPD manage-ment and presentation to NRC Region IV personnel.
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I DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED j
The Omaha Public Power District is presently in full compliance.
Enhanced hardware and administrative controls are in place which should prevent recurrence.
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o VIOLATION I.B i
Technical Specification 5.11, Radiation Protection Program, requires that pro-cedures for personnel radiation protection shall be prepared consistent with i
the requirements of 10 CFR Part 20 and adhered to for all operations involving 3
q personnel radiation exposure. The Fort Calhoun Station Radiation Protection i
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Manual provides procedures to implement the requirements of Technical Speci-fication 5.11.
Section 3.1.7.2.b of high radiation area shall be provided l
continuous health physics coverage by a technician who is equipped with a l
radiation dose rate instrument.
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Contrary to the above, on September 9, 1987 an Auxiliary Building equipment l
operator entered Room No. 5 (a VHRA) without obtaining continuous health physics coverage by a technician equipped with a radiation dose rate instrument.
3 ADMISSION OR DENIAL OF THE ALLEGED VIOLATION I
i The violation to the Fort Calhoun Station Technical Specifications occurred as stated above.
REASONS FOR THE VIOLATION
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4 This violation occurred because of agreements between various operators and health physics technicians that entry just inside Room 5, no further than the ten millirem per hour dose rate zone, did not require a health physics techni-cian in attendance. There was also the interpretation by some operators that i
j the "Contact HP Before Entry" requirement posted outside Room 5 meant contact j
at the beginning of their shift rather than imediately prior to entry.
The agreements were not reviewed and approved by OPPD management and the interpre-l i
tation is not acceptable to OPPD management.
The root cause of the violation l
l was determined to be a lack of management attention sufficient to ensure l
policy and procedural compliance.
The configuration of Room 5 is discussed i
below:
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i All of Room 5 was declared a VHRA because there was a localized radiation source near the middle of the room greater than 1000 millirem per hour.
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was no positive means for centrol of access to the very high radiation field other than the entrance door to the room. Room 5 is large enough that the l
3 area within approximately five feet of the room entrance has a radiation fleid 4
i of ten mrem / hour.
The instrument readings needed by the Auxiliary Building 1
operators are within the 10 mrem / hour radiation field near the door.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED I
j The following corrective actions were taken after the incident:
j A.
The Operations Supervisor issued a memorandum to all Station Shift
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j Supervisors on the subject of VHRA doors.
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Meetings between Station management and workers regarding expectations for I
l positive control of VHRA's were conducted.
C.
A review and update of the General Employee Training (GET) program with
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regard to radiation protection and VHRA entry requirements was initiated q
and completed, f [
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Postings outside VHRA's were revised to explicitly state that a health physics technician accompany entries to VHRA's.
E.
Supervisory tours of the Auxiliary Building by the Plant Health Physicist and Supervisor-Chemical and Radiation Protection were increased.
F.
Changes in personnel assignments for supervision of the Health Physics staff were made.
G.
The radiation source causing all of Room 5 to be declared a VHRA was removed.
H.
An individual with extensive H.P. experience has been reassigned to the H.P. group.
His office has been relocated to the H.P. work area.
Further details of each action are presented below:
A.
Later in the day on September 9, 1987 the Operations Supervisor issued a memorandum to the Shift Supervisors on the subject of the incident.
That memorandum directed the Shift Supervisors to make sure their crew members t
were aware of the incident and taat crew members were aware of the requirements for entry into High Radiation and VHRA's.
Section 3.1.7.2.B of the Fort Calhoun Station Radiation Pi rtection Manual was referenced for the requirements for entry into High and Very High Radiation Area's.
In addition, the Shift Supervisors were directed to sign the memorandum and i
have Senior Licensed Operators, Licensed Operators and Auxiliary Building i
Operator trainees sign the memorandum. Signatures were to indicate and i
document their review of the memorandum and the referenced section of the Radiation Protection Manual. All Shift Supervisors and operators l
designated on the memorandum signed as required and returned the i
memorandum to the Operations Supervisor, i
B.
Fort Calhoun Station management conducted meetings with health physics technicians and operators to present expectations with regard to positive
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control of VHRA's. The management position is consistent with the Radia-tion Protection Manual in that entries into VHRA's are to be accompanied L
by health physics technicians to monitor the radiation fields for the protection of personnel. Compliance with this requirement is mandatory.
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C.
The GET program related to policies and procedures was reviewed and updat-ed to place additional emphasis on procedural compliance and on require.
7 ments for entry to VHRA's, t
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The wording on the signs posted outside all VHRA's providing requirements for entry was imp oved by adding the phrase "Health Physics Technician Must be Present for Entry." This was done so that requirements are clear and concise and not subject to variable interpretation.
E.
The Plant Health Physicist and the Supervisor C&RP increased the frequency of tours of the Auxiliary Building to provide increased management over-sight of the conduct of operations there.
This action has improved access
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to supervisory personnel for questions and concerns about radiation protec-l l
tion policies and procedures at the Fort Calhoun Station.
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management oversight is assuring that inappropriate practices are not allowed to develop or persist.
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In order to provide a fresh perspective on canagement of the radiation protection program at the first line supervisory level, three personnel
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changes were made. On October 15, 1987, the Plant Health Physicist at the time of the September 9,1987 incident was reassigned as the AL ARA Program Coordinator.
The Radioactive Waste Coordinator at the time of the incident was reassigned to the position of Plant Health Physicist.
This individual possesses an extensive knowledge of the Fort Calhoun Station radiation protection policies and procedures from his past experience as a health physics technician and his work in the radioactive waste management area.
The At. ARA Coordinator was subsequently reassigned to the position of Radioactive Waste Coordinator.
G.
The radiation source causing all of Room 5 to be declared a VHRA was a pipe near the middle of the room which had become plugged with spent demineralizer resin.
The plugged pipe has been cleared of the spent resin and Room 5 returned to its normal configuration.
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In order to provide more direct senior coordination of the H.P. field activities, an experienced H.P. has been reassigned from training instructor responsibilities to the H.P. work area in the Auxiliary Building.
His imediate presence in conjunction with additional field 1
observation by the H.P. Supervisor, is expected to add emphasis to consistent implementation of H.P. practices.
From the time the actions A through H were implemented, there have been no violations of the VHRA entry requirements contained in Technical Specification 5.11.2.
However, on February 4, 1988, the health physics technician who ace-ompanied another individual into a designated VHRA left the area for a short time while the other person was in the area.
This action was not in accord.
I ance with a recently revised procedure to the Radiation Protection Manual for 1
i personnel entries to VHRA's.
The health physics technician was seen leaving the area by two members of an NRC Region IV inspection team, the Plant Health Physicist and the Supervisor-Chemical and Radiation Protection. When questioned by OPPD Management, the health physics technician indicated that a i
person was still in the VHRA and then the technician imediately returned to i
the area.
CORRECTIVE STEPS THAT Will BE TAKEN TO AVOID FURTHER VIOLATIONS A task force of OPPD management and supervisory personnel has been formed to develop a comprehensive plan for overall improvement of the Fort Calhoun Sta.
tion radiatton protection program.
This task force will examine and evaluate I
the radiation protection procedures currently in place, identify generic areas of concern, review specific actions, provide recomendations for improvements and assist in implementation of recomendations. A draft improvement program l
will be completed before March 15, 1988 for review and coment by OPPD l
management and presentation to NRC Region IV personnel.
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l Employee Management conferences are being initiated to emphasize procedural t
compliance.
These conferences are to be conducted on a one to one basis between the Station Supervisors and their employees.
Topics of the discus-sions include, but are not limited to, strict procedural compliance, the means
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by which procedural concerns can be brought to Management's attention, and the I
l appropriate actions to be taken to rectify concerns.
These conferences will continue until appropriate personnel have been through the process.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l
The Omaha Public Power District is currently in full compliance with the f
requirements for access to VHRA's.
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VIOLATION 11 Not Assessed a Civil Penalty 10 CFR 50.73 requires, in part, that the holder of an operating license for a i
nuclear power plant shall submit a Licensee Event Report (LER) for any con-dition prohibited by the plant's Technical Specifications within 30 days after the discovery of the event.
Technical Specification 5.11.2 states, in part, that each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr (very high radiation area) shall be provided with locked doors to prevent unauthorized entry.
Contrary to the above, the licensee failed to submit an LER within 30 days for a condition prohibited by Technical Specifications, i.e., a very high radia-tion area consisting of Room No. 5 which had a door unlocked on September 9, 1987.
ADHISSION OR DENIAL OF THE ALLEGED VIOLATION On September 9, 1987, the door to Room 5, a very high radiation area, was found unlocked at fort Calhoun Station.
This was a violation of Technical Specification 5.11.2.
Technical Specification 5.11.2 states, in part, that each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr (very high radiation area) shall be provided with locked doors to prevent unauthorized entry.
Title 10 CFR 50.73 requires, in part, that the holder of an operating license for a nuclear power plant shall submit a Licen-l see Event Report (LER) for any condition prohibited by the plant's Technical Specifications within 30 days after the discovery of the event.
A LER was not submitted within 30 days.
REASON FOR THE VIOLATION i
The method used for the review of Incident Reports was insufficient at the i
time of the incident.
An Incident Report was initiated on the day of the event; however, during the review by the Plant Review Committee (PRC) on l
September 14, 1987, a decision was made that the event was not reportable.
OPPD's belief at the time of the incident was that NRC-identified violations were not required to be reported under provisions of the LER rule.
This was also stated in a letter to R. Bangart, dated November 4, 1987 that provided followup to the October 15, 1987 enforcement conterence.
For this reason, no LER was believed to be necessary.
CORRECTIVE STEPS VHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The procedure for the writing and handling of incident reports (Standing Order t
R 4) has been revised. This revision incorporates a new process which ensures that incident reportability will be properly and promptly assessed.
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the Shift Technical Advisor (STA) completes a safety evaluation and an evalua-tion of reportability on significant incidents that may effect plant s.afety.
Second, the Reactor Engineer performs a LER reportability evaluation of every incident report prior to assigning the report to the Action Addressee or introducing it to the Plant Review Comittee (PRC).
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To date, these actions appear to have improved the effectiveness of the Incident Report system and have aided in the proper screening of potentially re sortable items.
As more experience with the revised process is gained, i
ensancements may become apparent, and will be evaluated and implemented.
f CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS OPPD believes that the new incident reporting process will ensure that LER t
reportability for applicable incidents will be addressed in a timely and accurate manner. No further corrective actions are considered necessary at this time.
l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance to this new process was achieved on November 15, 1987.
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