ML20198P972
| ML20198P972 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/06/1997 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gambhir S OMAHA PUBLIC POWER DISTRICT |
| References | |
| 50-285-97-16, NUDOCS 9711120072 | |
| Download: ML20198P972 (4) | |
See also: IR 05000285/1997016
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UNIT E D STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN IV
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611 RYAN PLAZA DRIVE. SuliE 400
NOV - 6 1997
S. K. Gambhir, Division Manager
Engineering & Operations Support
Omaha Public Power District
Fort Cathcun Station FC-2-4 Adm.
P,0. Box 399
Hwy. 75 - North of Fort Ca!houn
Fort Calhoun, Nebraska 68023 0399
SUBJECT:
NRC INSPECTION REP. ORT 50 285/97-16
Dear Mr. Gambhir:
Thank you for your letter of October 29,1907,in response to our letter and Notice
of Violation t'ated September 29,1997. We have reviewed your reply and find it
responsive tr, the concerns raised in our Notice of V!olation. We will review the
implementation of your corrective actiona during a future inspection to determine that full
compliance has been tchieved and will be maintained.
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Sincerely,
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Project Branch B
Division of Reactor Projects
Docket No.: 50-285
License No.: DPR-40
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cc:
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James W. Tills, 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
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9711120072 971106
ADOCK 05000285
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Omaha Public Power Distinct
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' James W. Chase, Manager
Fort Calhoun Station
P.O. Box 399
Fort Calhoun, Nebraska 68023
Perry D. Robinson, Esq.
Winston & Strawn
1400 L. Street, N.W.
Washington, D.C. 20005 3502
Chairman
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Washington County Board of Supervisors
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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Omaha Public Power Distnct
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bec to DCD (IE01)
bec distrib, by RIV:
Regional Administrator
DRS-PSB
DRP Director
MIS System
Branch Chief (DRP/B)
RIV File
Project Engineer (DRP/B)
Branch Chief (DRP/TSS)
Resident inspector
DOCUMENT NAME: R:\\_FCS\\FC716AK.WCW
To receive copy of document, indicate in boa: "C" = Copy wthout enclosures
"E" = Copy with enclosures "N" = No copy
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Omaha Public Power District
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bec distrib. by RIV:
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DRP Director
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Branch Chief (DRP/B)
RIV File
Project Engineer (DRP/B)
Branch Chief (DRP/TSS)
- Resident inspector
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DOCUMENT NAME: R:\\_FCS\\FC716AK,WCW
To receive copy of document, Ind6cate In box: "C" = Copy wdhout enclosures
"E" = Copy wth enclosures "N" = No copy
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October 29,1997
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LIC-97-0164
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U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Mail Station Pl-137
Washington, DC 20555
References:
1.
Docket No. 50-285
2.
Letter from NRC (T. P. Gwynn) to OPPD (S. K. Gambhir) dated
September 29,1997
SUBJECT:
NRC hspection P-n~r N<
".285/97-16, Reply to a Notice of Violation
i:- subject :r. .; ansanned a reite o Vi'!rtien (N ' resulting from an NRC inspection
conducte * ucun s *!ogh &pta +:r 13, IN7 st 5.he Fe "alhoun Station (FCS). Attached
is the O- @ M .- m c DP: (O 2
., - ' ' : Om ' JV.
If you noua hau e quac. Merse comact nie
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S. K. Garabh'r
Division Manager
Enginee ring and Operations Support
SKG/dild
Attachment
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Winston and Strawn
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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
88-O188
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Employment w.tn Equalopportunity
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Attachment
LIC 97-0164
Page 1
REPLY TO A NOTICE OF VIOLATION
Omaha Public Power District
Docket: 50-285
Fort Calhoun Station
11mw:DPR-40
Durlag an NRC inspection conducted on August 2 through September 13,1997, two
violations of NRC requirements were identified. In accordance with the " General Statemen,
of Policy and Procedure for NRC Enforcement Actions" NUREG 1600, the violations are
listed below:
A.
10 CFR Part 50, Appendix B Criterion V, and the Fort Calhoun Quality Assurance
Plan, Revision 4, Section 2.1, paragraph 4.2.1, state, in part, that activitics affecting
qualhy shall be prescribed by documented instructions or procedures and shall bc
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accomplished in accordance with these instructions or procedures.
Standing Order S0-G-101, " Radiation Worker Practices," Revision 8, Section 5.6.2,
states, in part, that personnel are not to reach across contamination area boundaries.
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Radiation Protection Procedure RP-401, " Issue, Control, and Accountability-of
Radiation Protection Instrumentation," Revision 6, Step 7.4.5, states, in part, that
iadiation protection
rsonnel shall be responsible for removing from service and
tagging out of service any out of calibration radiation protection equipment.
Contrary to the above, the inspectors identitled the following two instances of failure
to follow the requirements of radiation protection procedures:
On August 21, 1997, a maintenance helper located outside a contaminated
area, reached across a contamination area boundary and used a galtronics
phone inside the contaminated area.
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On August 5,1997, radiation protection personnel did not remove an
uncalibrated electronic dosimeter from service.
This is a Severity Level IV Violation (Supplement I) (285/97016-01)
B.
Appendix B of 10 CFR Part 50, Criterion V, states, in part, tnat activities affecting
quality shall be prescribed by doenmented instructions, procedures, or drawings: of
a type appropriate to the circun. ; mee and shall be accomplished in accordance with
these instructions, procedures, or drewings.
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Attachment
LIC 97-0164
Page 2
Contrary to the above, on July 11,1997, the inspectors identified that Maintenance
-Procedure GM RM-FP A01, " Fire Door Lockset Inspection and Repetitive
Maintenance," Revision 5, Step 7, did not contain appropriate instructions for
ensuring that the locked fire doors would open using a key following maintenance on
the doors. As a result ofimproperly performed maintenance and failure to perform
postn:alntenance testing, two locked fire doors could not be opened using keys.
This is a Severity Level IV Violation (285/97016-04) (Supplement IV)
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OPPD_Res ponse _to3'iola tionJLExample_1
1,
The Reason for the Violation
The reason for this violation was a failure to follow the procedural requirements of
Standing Order S0-G-101, " Radiation Worker Practices," which states, in part, "that
personnel are not to reach across contamination area boundaries." This violation occurred
when a maintenance worker, newly assigned to work at Fort Calhoun Station, under the
direction of a journey person, reached across a contamination area boundary to use a
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gaitronics phone located inside of a contaminated area.
2.
Corrective Steps Which Have Been Taken and the Results Achieved
The individuals involved were counseled by the Supervisor of Radiological
a.
Operations.
b.
This event was reviewed with site personnel during the September 24,1997 Human
Performance Day.
3.
Corrective Steps Which Will Be Taken to Avoid Further Violations
A work practice improvement plan for radiation workers is being developed. Part of this
plan is to develop a knowledge based questionnaire which will be used to evaluate radiation
worker skills and knowledge. The results will be used to improve processes, training, and
better define and enforce management expectations. The work practice improvement plan
is scheduled to be completed by September 30,1998.
4.
Date When Full Compliante Will Be Achieved
OPPD is currently in full compliance.
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Attachment
LIC 97-0164
Page 3
OPfD_Responselo3'iolatiorLA Examplel
1.
The Reason for the Violation
The reason for this violation is a failure to follow the procedural requirements of RP-401,
"Isine, Control and Accountability of Radiation Protection lastrumentation." This
violation occurred when radiation protection personnel failed to remove one electronic
dosimeter from the active inventory for calibration before its due date.
2.
Corrective Steps Which Have Been Taken and the Results Achieved
Immediate corrective action was taken to verify that there were no other in-service
a.
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electronic dosimeters that were out of calibration. No other electronic dosimeters
were found with expired calibration dates,
b.
The subject electronic dosimeter was demonstrated to be operating properly by
exposing it to a known source of radiation.
3.
Corrective Steps Which Will Be Taken to Avoid Further Violations
A Request for Training (RFT) was generated to include in General Employee
a.
Radiation Worker Training the requirement to validate the calibration due date by
the user prior to entry into the RCA. This will be incorporated into Level II
General Employee Radiation Worker Training by December 1,1997,
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A system problem report was generated and submitted to the electronic dosimeter
vendor, the developers of the personnel access control program used at Fort
Calhoun Station. This request tasks that the software revision will include the
ability to test against the electronic dosimeter data base and prevent the issue of an
out of calibration electronic dosimeter. The software change has been accepted by
the vendor and is scheduled to be delivered to OPPD by April 30, 1998.
Following Quality Assurance (QA) software acceptance testing the revised software
will be implemented by December 31,1998.
4.
Date When Full Compliance Will Be Achieved
OPPD is currently in full compliance.
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Attachment
LIC 97-0164
Page 4
OPED. Response _to_Yiolation.B
1.
The Reason for the Violation
The reason for the violation was a deficient procedure, in that, the procedure did
a.
not include steps to perform a functional check of the door locks after repairs were
completed.
2.
Corrective Steps Which Have Been Taken and the Results Achieved
An investigation was performed to determine which doors in the Radiologically
a.
Protected Area had incorrectly installed locksets. Eight doors were determined to
have locksets installed incorrectly and would have prevented access if locked.
b.
The incorrectly installed locksets of all eight doors were repaired and fuctionally
tested for operability under a maintenance work order.
c.
Procedures for fire door maintenance were reviewed and revised to address
identified weaknesses. Specific areas reviewed included function checks of the
Radiologically Controlled Area doors, quality verification, Radiation Protection
requirements, and Secuity requirements.
3.
Corrective Steps Which Will Be Taken to Avoid Further Violations
No further corrective actions are required.
4.
Date When Full Compliance Will Be Achieved
OPPD is currently in full compliance.
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