ML20207J554
| ML20207J554 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/21/1986 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20207J542 | List: |
| References | |
| EA-86-075, EA-86-75, LIC-86-303, NUDOCS 8607290164 | |
| Download: ML20207J554 (5) | |
Text
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536-4000
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LIC-86-303 J. E. Gagliardo Reactor Projects Branch U. S. Nuclear Reguia*ory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Tx. 76011
References:
- 1. Docket 50-285
- 2. Inspection Report 50-285/86-01 dated March 17, 1986
- 3. April 11, 1986 Enforcement Conference, Meeting Summary dated May 29, 1986.
- 4. Notice of Violation 50-285/86-01 dated May 22, 1986 (EA-86-75)
Dear Mr. Gagliardo:
Inspection Report 86-01 Notice of Violation Omaha Public Pcwer District (0 PPD) received Reference 2, describing an inspection conducted on January 6-10, 1986. At the request of the NRC, OPPD personnel attended an enforcement conference in Arlington, Texas, on April 11, 1986. The meeting summary was provided to OPPD in Reference 3.
OPPD also received Reference 4 containing e Nice of Violations.
The violations involved (1) a failure to idectiFy shipment of radioactive materials, (2) a failure to perform s' rn s,
- i) a failure to control a very l
I high radiation area, and (4) a failute o n,. + fy NRC and individuals of exposure.
The OPPD corrective actions, as noted in Reference 3, include (1) retraining of Fort Calhoun Station personnel in the policy of controlling very high radiation areas, (2) improving radiation protection department procedures concerning con-trol of radioactive materials leaving radiologically controlled areas, (3) increased oversight and facility tours of work areas by the radiation protec-tion department management and supervisory staff, and (4) increased attention to tracking corrective actions for the Fort Calhoun Station Operations Incident 8607290164 860724 PDR ADOCK 05000285 G
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b.E.Gagliardo LIC-86-303 Page 2 Reports. OPPD's specific response to each violation is attached to this letter.
If you have any questions concerning any of these responses, please do not hesitate to contact us.
Sincerely, ff 2- % '
R. L. Andrews Division Manager Nuclear Production RLA/me Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 Mr. D. E. Sells, NRC Project Manager Mr. P. H. Harrell, NRC Senior Resident Inspector
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Attachment to LIC-86-303 During an NRC inspection conducted on January 6-10, 1986, violations of NRC requirements were identified. The violations involved failure to: (1) identify a radioactive shipment, (2) properly control a very high radiation area, (3) provide workers with required radiation termination exposure reports, and (4) perform radiological surveys.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFF. Part 2, Appendix C (1985), the violations are listed below.
Pursuant to the provisions of 10 CFR 2.201, Omaha Public Power District is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation:
(1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.
I.
10 CFR 71.5(a) requires, in part, that each licensee who delivers licensed material to a carrier for transport shall comply with the applicable require-ments of D0T in 49 CFR Parts 170 through 189.
A. Failure to Identify Shipment of Radioactive Materials Fort Calhoun Station (FCS) Operating Procedure Volume VII, Section 6.3,
" Transportation of Radioactive Materials," states: "All shipments of radioactive material must comply with DOT Regulations and regulations of other appropriate Federal and State agencies.
49 CFR 171.2(a) requires, in part: "No person may offer... hazardous material for transportation in commerce unless that material is properly classed, described, packaged, marked, labeled, and in condition for ship-ment as required or authorized by this subchapter..."
49 CFR 173.421(d) requires, in part, for the shipment of limited quanti-ties of radioactive materials, that: "the outside of the packaging itself bears the marking ' Radioactive.'"
Contrary to the above, a main steam valve contaminated with about nine microcuries of radioactivity was shipped to an offsite laboratory on October 9,1985 without having been identified by label or markings as being radioactive.
B. Failure to Perform Surveys 49 CFR 173.475(i) requires, in part, that before each shipment of any radioactive materials package, the shipper shall ensure by examination or appropriate tests that External radiation and contamination levels are within the allowable limits specified in this subchapter.
Contrary to the above, the licensee failed in October 1985 to survey a radioactively contaminated main steam system valve prior to shipping the valve to an offsite laboratory for repair.
This is a Severity Level III problem (Supplement V).
- -i Attachment to LIC-86-303 4
Page 2 i
OPPD Response to Violation IA and IB 1.
Reason for the Violations, If Admitted Valve MS-280 is located in Room 81 on the main steam line from "B" steam generator to the main steam isolation valve (MSIV).
"B" steam generator s
and its steam line up to the MSIV were contaminated during the May, 1984 rupture of a tube in "B" steam generator. While the steam lines were sub-sequently decontaminated by steam flow during a cycle of operation, certain i
"B" steam line dead legs such as MS-280 remained contaminated. The station included written precautions regarding health physics surveys of secondary system components in new procedures written for the 1985 refueling outage, but relied upon verbal directions and cautions to supervisors and lead persons regarding use of existing procedures on secondary side equipment.
Main Steam valve MS-280 which contained a level of radioactive materials requiring radiation surveys and radiation shipment identification was not j
properly handled because maintenance personnel and shipping personnel were unaware that the valve was contaminated and because health physics per-sonnel were unaware of the valve's planned removal and shipment.
Contributing to the violation was the fact that an Operations Incident Re-port (No. 2183) had been written in October, 1985, but had not been closed as of the time of the inspection.
2.
Corrective Steps Which Have Been Taken and the Results Achieved As noted in (1) above, Fort Calhoun Station Operations Incident Report No.
2183 was written on October 15, 1985 and described the incident, levels of contamination in the MS-280 flange, results of Room 81 surveys and a calcu-lated confirmation of the measurements provided by Wyle Laboratory, the recipient of MS-280. The area surrounding the MS-280 location in Room 81 was barricaded and properly posted as a Radiation Area with Radiation Work Permit (RWP) requirements applicable. The situation regarding MS-280 and the radiological requirements in Room 81 were relayed to members of super-vision at the morning and afternoon refueling outage shift turnover meetings. Reportability under applicable federal regualtions was investi-i gated and found to be not required. The actions taken above were immediate l
actions.
T When MS-280 was returned to the station, a detailed work instruction was written for the valve's reinstallation which required the issuance of a Radiation Work Permit. RWP #705 was written on December 17, 1985 to pro-l vide contamination control for the reinstallation. All other "B" steam side components that were opened up to the MSIV's were surveyed and found to be clean.
I As final corrective action, special procedure SP-RP-1, " Refueling Shutdown Initial Radiological Survey Procedure" has been changed to include all cold shutdown occurrences and has had specific requirements added that require radiological posting of any potentially contaminated main steam components warning of possible internal contamination and the need for contacting health physics personnel before a system is opened.
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Attachment to LIC-86-303 Page 3 OPPD Response to Violations IA and IB (continued) 2.
Corrective Steps Which Have Been Taken and Results Achieved (continued)
Since the initiation of the interim corrective action, all shipments of radiologically contaminated equipment have been made properly and with no instance of improper or missing pre-shipment radiological surveys.
3.
Corrective Steps Which Will Be Taken To Avoid Future Violations It is believed that the actions described in (2) above will assure that properly documented and properly surveyed radioactive shipments are made.
As noted in Reference (3), increased attention will be given to tracking corrective actions and timely closeout of Fort Calhoun Station Operations Incident Reports.
4.
Date When Full Compliance Will Be Achieved OPPD is currently in compliance.
Violation II.
Failure to Control Very High Radiation Area Facility Operating License Technical Specifications (TS) 5.11.2 states, in part, that "in each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr (Very High Radiation Area)... locked doors shall be provided to prevent unauthorized entry into such areas..."
Contrary to the above, the licensee failed on January 2,1986 to use locked doors to control access to Room 27 of the Reactor Auxiliary Building in which were stored several plastic bags containing radioactive waste that produced radiation levels of 1200 mR/hr measured about 18 inches from the surface of the bags.
This is a Severity Level III violation (Supplement IV).
OPPD Response to Violation II 1.
Reason for the Violation, If Admitted The violation resulted when Fort Calhoun Station health physics personnel interpreted section 5.11.2 of license DPR-40 Technical Specifications 4
inappropriately.
Station personnel applied subsection (a) of 5.11.2 in this instance. This method was selected because of the view that the affected area (dose rate above 1000 mrem per hour) was a small portion of the drumming room total area.
2.
Corrective Steps Which Have Been Taken and the Results Achieved On January 10, 1986, the entire drumming room was declared a Very High Radiation Area, a lockable door was locked, one sliding door was chained and padlocked, and the room was properly posted.
This was accomplished before the NRC inspector's departure January 10, 1986.
Subsequently, the i
4.
Attachment to LIC-86-303 Page 4 OPPD Response to Violation II (continued) 2.
Corrective Steps Which Have Been Taken and the Results Achieved (continued) material generating the high dose rate was dispersed and transferred to other locations. The drumming room then no longer qualified as a Very High Radiation Area and was deposted.
Since the inspection, no Very High Radiation Areas outside containment have been posted and controlled using the Technical Specification 5.11.2(a) method.
Additionally, retraining of appropriate personnel has been completed emphasizing the need for proper and positive control of High and Very High Radiation Areas.
The frequency of health physics supervisory tours of the Radiation Control-led Area has been increased.
3.
Corrective Steps Which Will Be Taken to Avoid Future Violations In the future, no areas outside containment will be posted using the 5.11.2(a) method without first discussing such an action with the NRC.
OPPD is reviewing the basis of this Technical Specification and may seek clarification of this matter with the NRC, possibly via an Application for Amendment of the Technical Specifications.
4.
Date When Full Compliance Will Be Achieved OPPD is currently in full compliance.
Violation III.
Failure to Notify NRC and Individuals of Exposure 10 CFR 20.408(b) requires, in part: "When an individual terminates employ-ment with a licensee... the licensee shall furnish to the... Nuclear Regulatory Commission... a report of the individual's exposure to radia-tion... during the period of employment or work assignment... Such report shall be furnished within 30 days after the exposure of the individ-ual has been determined by the licensee or 90 days after the date of termination... whichever is earlier."
l 10 CFR 20.409(b) requires, in part: "When a licensee is required pursuant to 20.405 or 20.408 to report to the Commission any exposure of an individu-al 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, as of January 7,1986, the licensee had failed to provide to the individuals and the NRC the required exposure information within the specified time period for about 30 individuals.
This is a Severity Level IV violation (Supplement IV).
o.
Attachment to LIC-86-303 Page 5 OPPD Response to Violation III 1.
Reason for the Violation, If Admitted An NRC inspection in March, 1985 identified inadequacies in OPPD's equiva-lent (form FC-228) to form NRC-5 for recording radiation exposure of individuals covered by 10 CFR 20.202.
Form FC-228 was revised to require exposure bookkeeping by quarters and provided a running calculation of remaining 5(N-18) exposure. The revision to form FC-228 inappropriately deleted a monthly check system that had been utilized to ensure compliance with the referenced regulations.
Supervisory failure to recognize the impact of deleting the monthly check system was the direct cause of the violation.
2.
Corrective Steps Which Have Been Taken and the Results Achieved Operations Incident Report No. 2297 was initiated on January 9, 1986 and identified forty-three termination letters that had not been prepared and sent as required by 10 CFR 20.408.
Immediate action was taken and the re-quisite letters were prepared and distributed appropriately. Additionally, form FC-228 was revised to include full year by quarters and months includ-ing starting and ending employment dates, quarterly totals, and calcula-tions of permissible dose remaining.
Personnel preparing termination letters receive a weekly District report of OPPD employees who have departed. Since non-0 PPD personnel are not automat-ically reissued dosimetry during monthly issuance, the monthly cross-check of currently issued dosimetry provides an effective method for determining non-0 PPD departures.
Termination whole body count listings are used as a backup check.
Personnel involved with preparation of termination letters have been retrained in the applicable methods and procedures.
3.
Corrective Steps Which Will Be Taken to Avoid Future Violations OPPD believes the actions described in (2) above will assure compliance.
4.
Date When Full Compliance Will Be Achieved l
OPPD is currently in compliance.
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