ML20151X876
| ML20151X876 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/10/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gambhir S OMAHA PUBLIC POWER DISTRICT |
| References | |
| 50-285-98-16, NUDOCS 9809170281 | |
| Download: ML20151X876 (4) | |
See also: IR 05000285/1998016
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN IV
611 RYAN PLAZA DRIVE SUITE 400
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ARUNGToN. TEXAS 76011 8064
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September 10, 1998
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S. K. Gambhir, Division Manager
Division Manager - Nuclear Operations
Omaha Public Power District
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Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399
Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska 68023-0399
SUBJECT: NRC INSPECTION REPORT 50-285/98-16 AND NOTICE OF VIOLATION
Dear Mr. Gambhir:
Thank you for your letter of August 28,1998, in response to our July 29,1998, letter
and Notice of Violation concerning the failure to sample waste streams and update scaling
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factors, as required. We have reviewed your reply and find it responsive to the concerns raised
in our Notice of Violation. We will review the implementation of your corrective actions during a
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future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely,
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Blaine Murray, Chief
Plant Support Branch
Division of Reactor Safety
Docket No.:
50-285
~ License No.: DPR-40
cc:
James W. Titis, Manager
Nuclear Licensing
Omaha Public Power District
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399
Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska 68023-0399
9909170281 990910
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ADOCK 05000285
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On.iaha Public Power District
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James W. Chase, Division Manager
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Nuclear Assessments
Fort Calhoun Station
P.O. Box 399
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Fort Calhoun, Nebraska 68023
J. M. Solymossy, Manager - Fort Calhoun Station
Omaha Public Power District
Fort Calhoun Station FC-1-1 Plant
P.O. Box 399
Hwy. 75 - North of Fort Calhoun
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Fort Calhoun, Nebraska 68023
Perry D. Robinson, Esq.
Winston & Strawn
1400 L. Street, N.W.
. Washington, D.C. 20005-3502
~ Chairman
. Washington County Board of Supervisors
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Blair, Nebraska 68008
Cheryl Rogers, LLRW Program Manager
Environmental Protection Section
Nebraska Department of Health
301 Centennial Mall, South
P.O. Box 95007 -
Lincoln, Nebraska 68509-5007
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DISTRIBUTION w/coov of licensee's letter dated Auaust 28.1998:
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DCD (fE35)
Regional Administrator
DRS Director
DRS Deputy
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DRP Director-
Branch Chief (DRP/B)
Project Engineer (DRP/B)
Branch Chief (DRP/TSS)
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FC Resident inspector
MIS System
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RIV File
DRS Action item File (98-G-0114)(Goines)
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. DOCUMENT NAME: R:\\_FCS\\FC816AK.LTR
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To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures *N' = No copy
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OFFICIAL RECORD COPY
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Omaha Public Power District
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' DISTRIBUTION w/coov of licensee's letter dated Auaust 28.1998:
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DRS Action item File (98-G-0114)(Goines)
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DOCUMENT NAME: R:\\_FCS\\FC816AK.LTR
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August 28, 1998
.LIC-98-0114
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U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
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Mail Station P1-137
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Washington, DC 20555
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References: 1.
Docket No. 50-285
2.
Letter from NRC (W. D. Johnson) to OPPD (S. K. Gambhir)
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dated July 29, 1998
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SUBJECT:
NRC Inspection Report No. 50-285/98-16, Reply to a Notice of
Violation
The subject report transmitted a Notice of Violation (NOV) resulting from a
NRC inspection conducted July 6-10, 1998 at the Fort Calhoun Station (FCS).
Attached is the Omaha Public Power District (OPPD) response to this NOV.
If you should have any questions, please contact me.
Sincerely,
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S. K. Gambhir
Division Manager
Nuclear Operations
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Attachment
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E. W. Merschoff. NRC Regional. Administrator. Region IV
L. R. Wharton, NRC Project Manager
W..C. Walker, NRC Senior Resident Inspector
Winston and Strawn
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- . Attachment '-
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LLIC-98-0114
Page 1:
REPLY TO A NOTICE OF VIOLATION
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Omaha-Public Power District
Docket No.:
50 285
' Fort Calhoun Station
License No.: DPR 40
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During an NRC inspection. conducted 'on July 6-10, 1998, a violation of NRC
requirements was identified.
In accordance with the " General Statement of
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Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation
is listed below:
- Technical Specification 5.8.1 requires written procedures and.
administrative policies be established, implemented, and maintained that
meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI
N18.7-1972Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7-1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. and Appendix A.of USNRC Regulatory Guide 1.33. Appendix A of
USNRC Regulatory Guide 1.33 includes procedures for the solid waste
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system.
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Procedure RW 221,. "10 CFR 61 Sampling," Revision 3, Section 7.9.1
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. requires that annual samples be taken of the dry active waste stream.
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Section 7.15.1, requires that off site laboratory results be compared
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with Fort Calhoun gamma isotopic results for each waste stream sample to
verify consistency between the two analyses. Section 7.16.2 requires
that the annual' off site' laboratory waste stream sampling results be
compared with the previous year's results for the same waste stream.
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Section 7.16.3 requires that. scaling factor values be updated with the
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-new data.
Contrary to the above, the licensee did not implement the requirements
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of Procedure RW 221 in the following ways:
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' ( a)' Dry active waste samples were not taken annually.
Dry active
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waste stream samples were collected in June 1995 and August 1997.
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(b)
Off site laboratory results of the dry active waste stream were
not compared with Fort Calhoun gamma isotopic results for the same
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waste stream sample to verify consistency between the two analyses-
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from August 1995 to July 1998.
(c)
Annual off-s'ite laboratory waste stream sampling results for the
dry active waste stream were not compared with the previous year's
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results from the same waste stream from August 1995 to July 1998.
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Attachment
LIC-98-0114
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Page 2
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(d)
Scaling factors for the dry active waste stream were not updated
from August 1995 to July 1998.
This is a Severity Level IV violation (Supplement IV)(50 285/9816 01).
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OPPD Resoonse-
1.
Reason for the Violation
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Procedure RW-221. "10 CFR 61 Sampling,' requires annual samples to be taken of
the dry active waste stream and a comparison of the results to the previous
year's results. Sampling is conducted in order to verify the stability of
scaling factors of difficult-to-measure radionuclides used.to classify low
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level radioactive waste for disposal per 10 CFR Part 61. This requirement was
not completed in 1996 due to the over-reliance on personnel memory to initiate
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the sampling and follow-up comparisons.
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2.
Corrective Steps Taken and Results Achieved
A Radiological Analysis (98-004) was performed to evaluate and validate the
~ dry active waste stream scaling factors for 1996 and 1997. The calculated
1997 Cesium 137 - Cobalt 60 ratio was eight (8). The 1995 Cesium 137 - Cobalt'
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60 ratio was four (4). The change in these ratios is a factor of two (2),
which is much less than the factor of ten (10) required by the NRC as the
required precision. The mean change in scaling factor ratio for all
radionuclides was 5.7.
The results of this analysis were reviewed and
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verified and 'were'used to update the ' dry active waste classification
worksheet. FC-RW-218-3.
Results of the off-site analysis of the dry active waste stream for 1998 were
received and are currently under review and comparison with previous data.
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Since samples were not taken in 1996, off-site analyses cannot be completed
--for 1996. However, the Radiological Analysis described 6bove verified that
scaling factors were within NRC guidelines.
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' 3.
' Corrective Steps That Will Be Taken To Avoid Further Violations
Dry active waste stream sampling will be included in a computerized action
tracking system prior to 1999. The action tracking tasks will include
sampling and timely review, including off-site analysis, of results and
updating necessary forms / procedures.
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4.
The date when full compliance will be achieved
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. Fort Calhoun Station is in full compliance.
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