IR 05000285/1998006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/98-06 Issued on 980530.Corrective Actions Will Be Reviewed During Future Insp to Determine That Full Compliance Achieved

ML20249C080
Person / Time
Site:	Fort Calhoun
Issue date:	06/23/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
References
50-285-98-06, 50-285-98-6, NUDOCS 9806250288
Download: ML20249C080 (4)

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k' E' 4 UNITE 3 STATES

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E REGION IV

g 611 RYAN PLAZA DRIVE.' SUITE 400 h4 [ AR LINGTON, TEXAS 76011-8064 9*****+0 June 23, 1998 f

S. K. Gambhir, Division Manager Engineering & Operations Support Omaha Public Power District Fort Calhoun Station FC-2-4 Ad . P.O. Box 399 Hwy 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399  ;

i SUBJECT: NRC INSPECTION REPORT 50-285/98-06

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Thank you for your letter of May 29,1998, in response to our May 30,1998, letter and Notice of Violation concerning . We have reviewed your reply and find it responsive to the l

concerns raised in our Notice of Violation. We will review the implementation of your corrective actione during a future inspection to determine that full compliance has been achieved and will )

be maintaine Sincerel Blaine Murray, Chief Plant Support Branch Division of Reactor Safety Docket No.: 50-285 License No.: DPR-40 cc:

James W. Tills, Manager i Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Ad l l P.O. Box 399 Hwy. 75 - North of Fort Calhoun l Fort Calhoun, Nebraska 68023-0399

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Omaha Public Power District -2-James W. Chase, Manager Fort Calhoun Station P.O.' Box 399 Fort Calhoun, Nebraska 68023 Perry D. Robinson, Es Winston & Strawn l- '1400 L Street, : Washington, D.C. 20005-3502 Chairman Washington County Board of Supervisors

Blair, Nebraska 68008 '

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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 District -3-l DISTRIBUTION w/coov of licensee's letter dated May 29.1998:

Regional Administrator DRS Director DRS Deputy Director DRS-PSB DRP Director .

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Branch Chief (DRP/B)

Project Engineer (DRP/B)

- Branch Chief (DRP/TSS)

Resident inspector MIS System RIV File DRS Action item File (98-G-0071)

DOCUMENT NAME: R:\_FCS\FC806AK.LTR To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PSB - 1 _. 1E C:DRS\PSB 1 LTRicketsonfrifD7 BMurray

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OFFICIAL RECORD COPY

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Omaha Public Power District -3-DISTRIBUTION w/coov of licensee's letter dated May 29.1998:

l Regional Administrator l DRS Director DRS Deputy Director

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DRS-PSB DRP Director -

Branch Chief (DRP/B) ~

l Project Engineer (DRP/B)

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Branch Chief (DRP/TSS)

Resident inspector MIS System RIV File DRS Action item File (98-G-0071)

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DOCUMENT NAk*3 R.\_FCL" -C806AK.LTR To secohm copy of docuehent, indicate in box: "C" = Copy without enclosures "E" = Copy wth enclosures "N" = No copy RIV:PSB 1 M C:DRS\PSBx LTRicketsonSfDF . BMurray [J~

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L'0998 Omaha P& Power District 444 South lah Steet MnD  %~ %, '"

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May 29,1998 LIC-98-0073 t

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U.S. Nuclear Regulatory Commission .

ATTN: Document Control Desk f Mail Station PI-137 Washington, D.C. 20555 References: Docket No. 50-285 l_etter from NRC (B. Murray) to OPPD (S. K. Gambhir) dated April 30,1998 SUBJECT: Reply to a Notice of Violation, NRC Inspection Report No. 50-285/98-06 The subject report (Reference 2) transmitted a Notice of Violation (NOV) resulting from an NRC inspection conducted April 6-10,1998, at the Fort Calhoun Station (FCS). Attached is the Omaha Public Power District (OPPD) response to this NO If you should have any questions, please contact m Sin rely, O h S. K. Gambhir Division Manager Engineering & Operations Support EPM / epm Attachment c: 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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NOTICE OF VIOLATION Omaha Public Power District Docket No. 50-285 Fort Calhoun Station License No. DPR-40 During an NRC inspection conducted on April 6-10,1998, a violation of NRC requirements was identifie In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

NUREG-1600, the violations are listed below:

10CFR20.1003 defines a high radiation area as an area accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.1 rem (100 millirems) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrate Technical Specification 5.11 requires, in part, that entrance into high radiation areas be controlled by radiation work permit Radiation Work Permit 98-0011, " Routine Operations Duties Throughout Containment," Revision 0, requires continuous radiation protection coverage for entry into restricted high radiation areas (high radiation areas with dose rates greater than 1000 millirems / hour)

Contrary to the above, on April 7,1998, an individual working in accordance with Radiation Work Permit 98-0011 entered a restricted high radiation area in Steam Generator Bay B without continuous radiation protection coverag This is a Severity Level IV violation (Supplement IV)(50-285/9806-05). l D==ha Public Power District (OPPD) Resnonse

'A.- Reason for the Violation The reason for this violation was personnel error in that an Operator entered a Restricted liigh Radiation Areas (RilRA) without continuous Radiation Protection (RP) coverage as required by the governing Radiation Work Permit (RWP).

On April 7,1998, at approximately 0730 the Operations Control Center (OCC) assigned an Equipment Operator to remove tags on the Demineralized Water System in containment. At approximately 0745, the .

Operator wcat to the RP access control point. There he consulted the Shift RP Technician to ascertain the appropriate RWP to be used for this entry. The Shift RP Technician instructed the Operator to use RWP 98-0011. This RWP is written for routine operations duties in containment. This RWP allows for access

. to areas posted up to and including RHRAs. The RWP includes an instruction stating " Continuous RP coverage required for entry into RHRAs."  ;

The Shift Technician stated that the Operator who removed the tags required entries into both Steam

. Generator (SG) bays. The Shift Technician stated that he instructed the Operator to inform the .

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Containment RP Rover as to the locations of the valves that were tagged. The Shift Technician also stated that he called the Containment Rover and informed him that an Operator may be needing assistance. He

also discussed clothing requirements for entering a Highly Contaminated Area (HCA).

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-* . , LIC-98-0073 g Page 2 S The Operator recalled the conversation with the Shift RP differently. He stated that he informed the RP of the locations of the valves, including inside the SG bays, and that the majority of the discussion involved the appropriate dress requirements for entering an HC It appears that these two individuals left the discussion with an understanding as to the requirements for entering an HCA, but, neither of the individuals effectively closed the loop concerning the requirements for entering the SG bay The Operator logged into RWP 98-0011 at 0752 and proceeded to enter Containment to remove the tag : The valves involved included one located inside the "B" SG Bay, another located between the entrances of both SG Bays in an HCA and the last located inside the "A" SG Bay. The Operator located the Containment RP Rover and apprised him of the locations of the valves and the need to remove tags.- The RP showed the Operator the location of the necessary protective clothing. The Containment RP Rover discussed the requirements for entry with the Operator. He understood that the. Operator would enter the HCA, remove the tag on the valve located there, exit the HCA and then require continuous coverage for the remaining two valves. The Operator entered the HCA and removed the tag on the valve located ther As he finished with that valve, several Electricians and a RP Technician were entering the "B" SG Ba The RP Technician was the first to enter the bay, followed by the crew. The Operator followed this crew -

into the bay and removed the tag from the valve in that bay without continuous RP coverage as required

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by the RW The RHRA posting for the bay is located on the door. This door swings outward which removes the 4 posting from view while the door is open. Since the Operator followed closely behind the Electricians, he

- was not able to read the postings on the door. After entering the bay, the job coverage RP Technician ,

with the Electricians questioned the Operator if he needed continuous RP coverage. The Operator stated 'j he was OK as he had spoken with the Containment Rover. During the 1996 Refueling Outage, the SG bays were posted as HRA and Operators were allowed to enter these areas after a briefing with an RP Technicia The Operator removed the tag on the valve in that bay and exited through the "B" RCP Bay. He then asked the RP rover to unlock the door to "A" SG Bay to perform the final tag removal. The rover !

unlocked "A" SG bay and escorted the Operator into the RHRA for the final tag. The Operator then exited Containment. The Operator logged out of the RWP at 090 ' There were several chances for this event to have been prevented. The Operator spoke with two different ,

RP Technicians on separate occasions prior to entering the RHRA. The communications between the L Operator and each of the Technicians seemed to focus more on the dress out requirements for entering an HCA than the RHRA concern Corrective S**na Which Have Been T*== anni the Daenha JLehlaved In the short term the RP Technicians are controlling the access doors to ensure that proper control is

maintained. In addition, this event was discussed with plant supervision, the RP Technicians and

Operations personnel. 'Ihe event was publicized on the plant information viewing system (3N) to insure

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i that personnel were aware of the event and what should have been don !

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, Corrective Stens whh Will Be Taken Both the initial and continuing training material for General Employee Training (GET) will be revised to ensure that Management's expectations for radiation area controls are adequately communicated including following: the requirements for entering an RHRA is covered,

. ensure that the concept of continuous coverage is clearly defined proper restoration of radiological postings, the restrictions on " tailgating" through radiation boundaries and the need to establish a boundary monitor while a boundary is defeate These revisions will be completed prior to October 31,199 ' Currently qualified radiation workers will be trained on this material prior to the start of the next refueling outage, currently scheduled to begin in the fall of 199 Date When Full Compliance Will Be Achie5ed OPPD is currently in full complianc .

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