ML20214J637
| ML20214J637 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/13/1986 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20214J633 | List: |
| References | |
| LIC-86-336, NUDOCS 8608150108 | |
| Download: ML20214J637 (5) | |
Text
..
n=--
Omaha Public Power District I
1623 Harney Omaha. Nebraska 68102-2247 l
402/536-4000
$$$0N$
D July 13, 1986 LIC-86-336 JUL i 81986 ll -
J. E. Gagliardo, Chief Reactor Projects Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Tx. 76011 References
- 1. Docket No. 50-285
- 2. Inspection Report 50-285/86-08, dated June 13, 1986
Dear Mr. Gagliardo:
Inspection Report 86-08 Notice of Violation Omaha Public Power District (OPPD) recently received Reference 2 containing a notice of three violations.
The first involved a failure to retain calibration data. The second concerned a failure to submit a special report, and the third involved failure to develop operating and calibrating procedures.
OPPD's re-sponses to these violations are attached to this letter.
If you have questions concerning any of these responses, please do not hesitate to contact us.
Sinca el,
/ /W I
R. L. Andrews Division Manager Nuclear Production RLA/me Attachments 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 8606130108 860011 PDR ADOCK 0500 5
O Tc;N6 D
~,g=7-
.s s,m
ATTACHMENT During an NRC inspection conducted on April 7-10, 1986, violations of NRC requirements were identified.
The violations involved: (1) failure to follow procedures, (2) failure to comply with Technical Specifications, and (3) fail-ure to implement calibration procedures.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
A.
Failure to Follow Procedures Technical Specification 5.8.1 requires that " written procedures.... be established, implemented, and maintained that meet or exceed the minimum requirements of Section 5.1 and 5.3 of ANSI N18.7-1972, and Appendix A of USNRC Regulatory Guide 1.33...." This requirement is emphasized in the FCS operating manual, standing order G-1, which states:
" Strict adherence to the provisions of the standing orders is mandatory for all personnel."
Standing order C-2, in the index of Fort Calhoun Qual.ity Assurance (QA) records, Item 14.bb. requires that calibration procedures (data) be retained for 5 years.
Contrary to the above, an NRC~ inspector determined on April 10, 1986, that the August 15, 1985, calibration data for particulate, iodine, and noble gas (PING) gaseous effluent monitor number 214 had not been retained.
This is a Severity Level IV violation (Supplement IV) (285/8608-01),
OPPD Resoonse to Violation A 1.
Reason for the Violation. If Admitted The cause of the violation was the failure to. track and control the filing of a radiation monitor calibration by technicians and supervision respon-sible for performance and review of the calibration and for its proper filing.
Investigation of other PING monitor calibratio'ns indicates only the August 15, 1985, PING number 214 calibration was missing.
It has been determined that the cause was an isolated failure of performance rather than a generic deficiency.
2.
Corrective Steos Which Have Been Taken and the Results Achieved l
Personnel involved trith the calibration, review and filing of PING calibra-l tions have been retrained in the requirements of standin' g order C-2.
PING calibrations since the August 15, 1985, calibration have bcen performed as required and have been, handled properly as required by standing order C-2.
l 3.
Corrective Steps Which Will Be Taken to Avoid Future Violations OPPD believes the actions described in (2) above will assure future compliance.
4.
Date When Full Compliance Will Be Achieved OPPD is currently in compliance.
l l
l ATTACHMENT (Continued)
B.
f_ailure to Submit Special Report i
Technical Specification 2.21 requires that " Post-accident instrumentation shall be operable as provided in Table 2-10.
If the required instrumenta-tion. is not operable, then the appropriate action specified in Table 2-10(a)2 requires the licensee to " prepare ar.d submit a special report to the Commission pursuant to specification 5.9.3 within 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedules for restoring the system to OPERABLE status."
Contrary to the abcve, an NRC inspector determined on April 7, 1916, that the wide range noble gas stack monitors RM-063M and H were not operational for the period September 14, 1984, through April 4, 1986, and that the special report required by Table 2-10(a)2 had not been submitted to the Commission.
This is a Severity Level IV violation (Supplement I) (285/8608-02)
OPPD Response to Violation B 1.
Reason for the Violation. If Admitted The Omaha Public Power District, on September 5, 1984, sent to the NRC Spec-ial Report LIC-84-301 which, as required by Technical Specification Table 2-10, provided the action taken, the cause of the inoperability of RM-063L, M and H detectors and the plans and schedules for restoring the systems to operable status.
In LIC-84-301, OPPD stated, " Completion of the cali-bration and return to operability of RM-063L, M, and H is expected by September 14, 1984." The calibration was completed by September 14, 1984 for RM-063L. However, calibration was not successful for RM-063M and H.
Button radiation sources needed for the calibration were unavailable and could not be accurately duplicated.
Plans were made to prepare calibration l
procedures employing actual accident level Xe-133 gas as calibration gas.
l The revised calibration was performed during May, 1986.
From August 22, 1984, until the present, the preplanned alternate means of monitoring stack radioactive releases have been available and in use.
A special report pursuant to Table 2-10(a)2 is required when the minimum operable channels requirement of Table 2-10 is not met and when Table 2-10(a)2 is not met. OPPD believes that submittal of Special Report LIC-84-301 met the requirements of Technical Specification 2-10.
- However, OPPD does believe a followup letter to LIC-84-301 should have been sent, noting the continued inoperability and revising the date of expected oper-ability of RM-063M and H.
2.
Corrective Steos Which Have Been Taken and the Results Achieved A followup letter, LIC-86-095, dated March 7, 1986 was sent when it was real ued that no further information had been provided to the NRC. A telephone conversation was also held between Mr. Blaine Murray of your office and OPPD personnel on May 23, 1986. The purpose of this call was to inform the NRC that commitments made in LIC-86-095, had been met, but RM-063H had still not been returned to OPERABLE status.
ATTACHMENT (Continued) 3.
Corrective Steps Which Will Be Taken to Avoid Future Violations OPPD will continue, as it has in the past, to keep the NRC informed when changes to commitments are made.
It is believed that current procedures are adequate to ensure compliance with the Technical Specifications.
4.
Date When Full Comoliance Will Be Achieved OPPD is in full compliance.
C.
Failure to Develoo Procedures Technical Specification 4.8.1 requires that " written procedures... be established, implements, and maintained that meet or exceed the minimum requirements of Section 5.1 and 5.3 of ANSI N18.7-1972, and Appendix A of USNRC Regulatory Guide 1.33..."
Regulatory Guide 1.33, Appendix A, Section 8(aa) requires procedures be written for area, portable, and airborne radiation monitor calibrations.
Contrary to the above, an NRC inspector determined on April 10, 1986, that operating and calibration procedures for the Bicron RS0-5 and Bicron Tech 50 portable radiation monitors had not been developed.
The NRC inspector determined that these survey meters had been used during the period November 1,1985 through February 1,1986, to establish plant radiation levels.
This is a Severity Level V violation (Supplement IV) (285/8608-03).
OPPD Response to Violation C 1.
Reason for the Violation. If Admitted The Fort Calhoun Station Chemical and Radiation Protection Supervisor imple-mented a provision of Standing Order T-13, Quality Control Program for Chemistry and Radiation Protection Equipment, whereby the Chemical and Radiation Protection Supervisor may opt to accept the manufacturer's instrument calibration in lieu of initial on-site calibration. The manu-facturer's calibration procedures and quality assurance program for Bicron portable radiation monitors had not been accepted by OPPD. The Chemical and Radiation Protection Supervisor's decision to approve use of health physics instruments based on manufacturer supplied calibration data and operating manuals was the cause of the violation.
..,r ATTACHMENT (Continued) 2.
Corrective Steos Which Have Been Taken and the Results Achieved 1
The Bicron RS0-5 and Bicron Tech 50 portable radiation monitors were with-drawn from service by April 10, 1986.
Standing Order T-13 has been changed to remove the provision that allowed use of instruments without Plant Re-view Committee approved calibration and function check procedures. There have been no instances of improper instrument acceptance since the Bicron instruments ware withdrawn from service.
3.
Corrective Steos Which Will Be Taken to Avoid Further Violations OPPD believes the actions described in (2) above will assure compliance.
4.
Date When Full Comoliance Will Be Achieved OPPD is currently in compliance.
l l
-