ML20151L528
| ML20151L528 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/25/1988 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-580, NUDOCS 8808040068 | |
| Download: ML20151L528 (3) | |
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em Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 July 25, 1988 LIC-88-580 U. S. Nuclear Regulatory Commission Atti Document Control Desk Mail Station Pl-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD (R. L. Andrews) dated June 9, 1988 Gentlemen:
SUBJECT:
Response to Notice of Violation - NRC Inspecti;n Report 50-285/88-13 Omaha Public Power District (0 PPD) recently received the subject Notice of Violation, Reference 2.
One violation was identified pertaining to the failure to provide a procedure for a radiation portal monitor alarm.
The submittal date of July 25, 1988 was agreed to by Mr. J. Fisicaro of my staff and Mr.
T. Westerman of NRC Region IV.
Pursuant to 10 CFR Part 2.201, please find attached OPPD's response.
If you have any questions concerning this matter, please contact us.
Sincerely, s
/l 7/9-
. Morris D vision Manager Nuclear Operations KJM/me 8808040068 880725 PDR ADOCK 05000285 0
Attachment PNU c:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector
.r6d /
455124 Employment with Equal Opportunity Vale. Female
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d RESPONSE TO NOTICE OF VIOLATION During an NRC inspcction conducted on April 1-30, 1988, a violation of NRC requirements was identified.
The violation involved the failure to provide procedures for limiting radioactive materials released to the environment.
In accordance with the "General Statement of Policy and Procedure for ARC l
Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below.
Section 5.8.1 of the Technical Specifications states, in part, that written procedures shall be established, implemented, and maintained that meet or exceed the requirements of Appendix A to Regulatory Guide 1.33.
Paragraph 7 of Appendix A to Regulatory Guide 1.33 states, in part, that the control of radioactivity (for limiting materials released to the environment and limiting personnel exposure) shall be covered by written procedures.
Paragraph 2.21.1 of Section VII-2 of the Radiation Protection Manual states, in part, that personnel suspected of skin contamination, due to monitoring instrument alarms, must contact a radiation protection technician.
Contrary to the above, on April 12, 1988, the NRC inspector witnessed five individuals that passed through and alarmed the radiation portal monitor located in the security building but did not contact a radiation protection technician.
This is a Severity Level V violation. (Supplement IV)(285/8813-02)
OPPD'S RESPONSE 1.
The Reason for the Violation if Admitted Radiation Protection Manual Section 2.21.1 states, in part, that personnel suspected of skin contamination identified by monitoring instrument alarms must contact a Radiation Protection Technician.
This proceduralized guidance, though correct, was inadequate to provide workers, security officers and training personnel with information and instructions necessary to meet the intent of Appendix A to Regulatory Guide 1.33.
2.
The Corrective Steos That Have Been Taken and the Results Acnieved l
The security computer printout was examined to determine the names of personnel exiting the portal monitors at the time the NRC Inspector exited l
the monitors.
The identified individuals were interviewed by the Plant l
Health Physicist to determine if they had observed alarms of the monitors.
The interviews indicated that no alarms had originated from the in-service monitor through which all parties including the inspector had passed. An out of-service portal monitor a few feet from the in-service monitor had been observed to produce random alarms which occurred during the passage j
Attachment (Continued) of personnel nearby.
Instrumentation and Control personnel and health physics personnel were able to confirm this effect.
It was also determined that personnel who had been in the Radiation Controlled Area of the station i
had been released by the appropriate monitors in the RCA. A junior health physics technician was stationed at the security building exit portal monitors during periods of high traffic to ensure personnel exited the monitors properly, to observe the operation of the monitors and to record I
the frequency of alarms occurring with no one in the counting zone of the monitor.
Security Bulletin 88-11 was istued to security personnel instructing them as to what actions to take in the event that the portal monitor should alarm.
These include locking the turnstiles and directing personnel back through the monitor.
New procedure, Standing Order G-76, "Use of the Gamma-10 Portal Monitors" was issued on April 29, 1988.
The procedure assigns responsibilities to workers for proper exit, to the Security force for control of exit and to Instrumentation and Control personnel for calibration and repair.
Instructions are provided in the procedure for proper counting and actions to be taken to resolve alarms.
After implementation of Standing Order G-76, the junior radiation l
protection technician was withdrawn from observing the portal monitor i
exit.
The objective of these program improvements was to assure that contaminated
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individuals are identified and properly processed after identification.
Implementation of the improvements has resulted in achievement of the I
objective.
l 3.
The Corrective Steos That Will be Taken to Avoid Further Violations The actions noted above are considered adequate to avoid further viola-tions. No additional actions are planned at this time.
4.
The Date When Full Comoliance Will be Achieved Full compliance was achieved April 29, 1988 with implementation of Standing Order G-76.
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