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| {{Adams
| | #REDIRECT [[IR 05000285/1997016]] |
| | number = ML20198P972
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| | issue date = 11/06/1997
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| | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/97-16 on 970803-0913
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| | author name = Johnson W
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| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
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| | addressee name = Gambhir S
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| | addressee affiliation = OMAHA PUBLIC POWER DISTRICT
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| | docket = 05000285
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| | license number =
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| | contact person =
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| | document report number = 50-285-97-16, NUDOCS 9711120072
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| | title reference date = 10-29-1997
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| | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
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| | page count = 4
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| }}
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| See also: [[see also::IR 05000285/1997016]]
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| =Text=
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| {{#Wiki_filter:.
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| . . . .
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| p4 4"b y UNIT E D STATES
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| *
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| 3- t NUCLEAR REGULATORY COMMISSION
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| o
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| g g REGloN IV
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| / 611 RYAN PLAZA DRIVE. SuliE 400
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| (% * * * * * ,0 AR LINGToN. TEXAS 760118064
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| NOV - 6 1997
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| S. K. Gambhir, Division Manager
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| Engineering & Operations Support
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| Omaha Public Power District
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| Fort Cathcun Station FC-2-4 Adm.
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| P,0. Box 399
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| Hwy. 75 - North of Fort Ca!houn
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| Fort Calhoun, Nebraska 68023 0399
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| SUBJECT: NRC INSPECTION REP. ORT 50 285/97-16
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| Dear Mr. Gambhir:
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| Thank you for your letter of October 29,1907,in response to our letter and Notice
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| of Violation t'ated September 29,1997. We have reviewed your reply and find it
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| responsive tr, the concerns raised in our Notice of V!olation. We will review the
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| implementation of your corrective actiona during a future inspection to determine that full
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| compliance has been tchieved and will be maintained.
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| .
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| Sincerely,
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| .
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| Project Branch B
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| Division of Reactor Projects
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| Docket No.: 50-285
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| License No.: DPR-40
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| _
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| cc:
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| James W. Tills, Manager /
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| Nuclear Licensing
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| Omaha Public Power District
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| Fort Calhoun Station FC-2 4 Adm.
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| P.O. Box 399
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| Hwy. 75 - North of Fort Calhoun
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| Fort Calhoun, Nebraska 68023-0399
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| I:
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| 9711120072 971106
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| PDR ADOCK 05000285
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| Omaha Public Power Distinct 2-
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| ' James W. Chase, Manager
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| Fort Calhoun Station
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| P.O. Box 399
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| Fort Calhoun, Nebraska 68023
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| Perry D. Robinson, Esq.
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| Winston & Strawn
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| 1400 L. Street, N.W.
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| Washington, D.C. 20005 3502
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| Chairman i
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| Washington County Board of Supervisors
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| Blair, Nebraska 68008
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| Cheryl Rogers, LLRW Program Manager
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| Environmental Protection Section
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| Nebraska Department of Health
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| 301 Centennial Mall, South
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| P.O. Box 95007
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| Lincoln, Nebraska 68509 5007
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| Omaha Public Power Distnct -3- NOV - 61997
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| bec to DCD (IE01)
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| bec distrib, by RIV:
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| Regional Administrator DRS-PSB
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| DRP Director MIS System
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| Branch Chief (DRP/B) RIV File
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| Project Engineer (DRP/B) Branch Chief (DRP/TSS)
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| Resident inspector
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| DOCUMENT NAME: R:\_FCS\FC716AK.WCW
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| To receive copy of document, indicate in boa: "C" = Copy wthout enclosures "E" = Copy with enclosures "N" = No copy
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| RIV:PE:DRP/B C:D'RP/B 6
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| 0;FICIAL RECORD COI)Y
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| Omaha Public Power District 3- NOV - 61997
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| M N OCD #E01 0
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| bec distrib. by RIV:
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| Regional Administrator DRS PSB
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| DRP Director
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| -
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| MIS System
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| Branch Chief (DRP/B) RIV File
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| Project Engineer (DRP/B) Branch Chief (DRP/TSS)
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| - Resident inspector
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| 1
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| DOCUMENT NAME: R:\_FCS\FC716AK,WCW
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| To receive copy of document, Ind6cate In box: "C" = Copy wdhout enclosures "E" = Copy wth enclosures "N" = No copy
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| RIV:PE:DRP/B C:DRP/B 6
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| DNGraves;df y
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| 11/b /97 11/ (p/97 -;
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| O':FICIAL RECORD COPY
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| Onaha. Nobraska 68102D47 ,
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| October 29,1997
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| kl >
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| LIC-97-0164 '% /
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| s
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| U.S. Nuclear Regulatory Commission
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| ATTN: Document Control Desk
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| Mail Station Pl-137
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| Washington, DC 20555
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| References: 1. Docket No. 50-285
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| 2. Letter from NRC (T. P. Gwynn) to OPPD (S. K. Gambhir) dated
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| September 29,1997
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| SUBJECT: NRC hspection P-n~r N< ".285/97-16, Reply to a Notice of Violation
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| i:- subject :r. .; ansanned a reite o Vi'!rtien (N ' resulting from an NRC inspection
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| conducte * ucun s *!ogh &pta +:r 13, IN7 st 5.he Fe "alhoun Station (FCS). Attached
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| is the O- @ M .- m c DP: (O 2 ., - ' ' : Om ' JV.
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| If you noua hau e quac. Merse comact nie
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| .ig:rt
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| '
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| .
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| S. K. Garabh'r
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| Division Manager
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| Enginee ring and Operations Support
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| SKG/dild
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| Attachment
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| '
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| c: Winston and Strawn
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| E. W. Merschoff, NRC Regional Administrator, Region IV
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| L. R. Wharton, NRC Project Manager
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| W. C. Walker, NRC Senior Resident Inspector
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| 88-O188
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| 45 5 t2c
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| Employment w.tn Equalopportunity
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| -
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| bSf/0 50 0'!
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| Attachment
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| LIC 97-0164
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| Page 1
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| REPLY TO A NOTICE OF VIOLATION
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| Omaha Public Power District Docket: 50-285
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| Fort Calhoun Station 11mw:DPR-40
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| Durlag an NRC inspection conducted on August 2 through September 13,1997, two
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| violations of NRC requirements were identified. In accordance with the " General Statemen,
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| of Policy and Procedure for NRC Enforcement Actions" NUREG 1600, the violations are
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| listed below:
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| A. 10 CFR Part 50, Appendix B Criterion V, and the Fort Calhoun Quality Assurance
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| Plan, Revision 4, Section 2.1, paragraph 4.2.1, state, in part, that activitics affecting
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| qualhy shall be prescribed by documented instructions or procedures and shall bc )
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| accomplished in accordance with these instructions or procedures.
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| Standing Order S0-G-101, " Radiation Worker Practices," Revision 8, Section 5.6.2,
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| states, in part, that personnel are not to reach across contamination area boundaries. !
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| l
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| Radiation Protection Procedure RP-401, " Issue, Control, and Accountability-of
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| Radiation Protection Instrumentation," Revision 6, Step 7.4.5, states, in part, that
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| iadiation protection rsonnel shall be responsible for removing from service and
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| tagging out of service any out of calibration radiation protection equipment.
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| Contrary to the above, the inspectors identitled the following two instances of failure
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| to follow the requirements of radiation protection procedures:
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| On August 21, 1997, a maintenance helper located outside a contaminated
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| area, reached across a contamination area boundary and used a galtronics
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| phone inside the contaminated area.
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| '
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| On August 5,1997, radiation protection personnel did not remove an
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| uncalibrated electronic dosimeter from service.
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| This is a Severity Level IV Violation (Supplement I) (285/97016-01)
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| B. Appendix B of 10 CFR Part 50, Criterion V, states, in part, tnat activities affecting
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| quality shall be prescribed by doenmented instructions, procedures, or drawings: of
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| a type appropriate to the circun. ; mee and shall be accomplished in accordance with
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| these instructions, procedures, or drewings.
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| !
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| __-_____ _ _ _ _ _ _ - _ _ _ _ _
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| Attachment
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| LIC 97-0164
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| Page 2
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| Contrary to the above, on July 11,1997, the inspectors identified that Maintenance
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| -Procedure GM RM-FP A01, " Fire Door Lockset Inspection and Repetitive
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| Maintenance," Revision 5, Step 7, did not contain appropriate instructions for
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| ensuring that the locked fire doors would open using a key following maintenance on
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| the doors. As a result ofimproperly performed maintenance and failure to perform
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| postn:alntenance testing, two locked fire doors could not be opened using keys.
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| This is a Severity Level IV Violation (285/97016-04) (Supplement IV)
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| i
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| OPPD_Res ponse _to3'iola tionJLExample_1
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| 1, The Reason for the Violation
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| The reason for this violation was a failure to follow the procedural requirements of
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| Standing Order S0-G-101, " Radiation Worker Practices," which states, in part, "that
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| personnel are not to reach across contamination area boundaries." This violation occurred
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| when a maintenance worker, newly assigned to work at Fort Calhoun Station, under the
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| c 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.
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| 2. Corrective Steps Which Have Been Taken and the Results Achieved
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| a. The individuals involved were counseled by the Supervisor of Radiological
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| Operations.
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| b. This event was reviewed with site personnel during the September 24,1997 Human
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| Performance Day.
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| 3. Corrective Steps Which Will Be Taken to Avoid Further Violations
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| A work practice improvement plan for radiation workers is being developed. Part of this
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| plan is to develop a knowledge based questionnaire which will be used to evaluate radiation
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| worker skills and knowledge. The results will be used to improve processes, training, and
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| better define and enforce management expectations. The work practice improvement plan
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| is scheduled to be completed by September 30,1998.
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| 4. Date When Full Compliante Will Be Achieved
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| OPPD is currently in full compliance.
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| Attachment
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| LIC 97-0164
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| Page 3
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| OPfD_Responselo3'iolatiorLA Examplel
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| 1. The Reason for the Violation
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| The reason for this violation is a failure to follow the procedural requirements of RP-401,
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| "Isine, Control and Accountability of Radiation Protection lastrumentation." This
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| violation occurred when radiation protection personnel failed to remove one electronic
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| dosimeter from the active inventory for calibration before its due date.
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| 2. Corrective Steps Which Have Been Taken and the Results Achieved
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| a. Immediate corrective action was taken to verify that there were no other in-service >
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| electronic dosimeters that were out of calibration. No other electronic dosimeters
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| were found with expired calibration dates,
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| b. The subject electronic dosimeter was demonstrated to be operating properly by
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| exposing it to a known source of radiation.
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| 3. Corrective Steps Which Will Be Taken to Avoid Further Violations
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| a. A Request for Training (RFT) was generated to include in General Employee
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| Radiation Worker Training the requirement to validate the calibration due date by
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| the user prior to entry into the RCA. This will be incorporated into Level II
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| General Employee Radiation Worker Training by December 1,1997,
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| b.- A system problem report was generated and submitted to the electronic dosimeter
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| vendor, the developers of the personnel access control program used at Fort
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| Calhoun Station. This request tasks that the software revision will include the
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| ability to test against the electronic dosimeter data base and prevent the issue of an
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| out of calibration electronic dosimeter. The software change has been accepted by
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| the vendor and is scheduled to be delivered to OPPD by April 30, 1998.
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| Following Quality Assurance (QA) software acceptance testing the revised software
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| will be implemented by December 31,1998.
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| 4. Date When Full Compliance Will Be Achieved
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| :
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| OPPD is currently in full compliance.
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| I
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| Attachment
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| LIC 97-0164
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| Page 4
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| *
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| OPED. Response _to_Yiolation.B
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| 1. The Reason for the Violation
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| a. The reason for the violation was a deficient procedure, in that, the procedure did
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| not include steps to perform a functional check of the door locks after repairs were
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| completed.
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| 2. Corrective Steps Which Have Been Taken and the Results Achieved
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| a. An investigation was performed to determine which doors in the Radiologically
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| Protected Area had incorrectly installed locksets. Eight doors were determined to
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| have locksets installed incorrectly and would have prevented access if locked.
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| b. The incorrectly installed locksets of all eight doors were repaired and fuctionally
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| tested for operability under a maintenance work order.
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| c. Procedures for fire door maintenance were reviewed and revised to address
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| identified weaknesses. Specific areas reviewed included function checks of the
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| Radiologically Controlled Area doors, quality verification, Radiation Protection
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| requirements, and Secuity requirements.
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| 3. Corrective Steps Which Will Be Taken to Avoid Further Violations
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| No further corrective actions are required.
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| 4. Date When Full Compliance Will Be Achieved
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| OPPD is currently in full compliance.
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| }}
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