IR 05000285/1981012
| ML20010B516 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/28/1981 |
| From: | Brown G, Everett R, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010B510 | List: |
| References | |
| 50-285-81-12, NUDOCS 8108170137 | |
| Download: ML20010B516 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Docket: 50-285/81 12 License: DPR-40 Licensee: Omaha Public Power District 1623 Harney Street Omaha, Nebraska 68102 Facility Name:
Fort Calhoun Station Inspection at:
Fort Calhoun Station, Blair, Net,: aska Inspection Conducted:
May 4-7, 1981 Inspectors:
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7d/d/
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R. J. Everett, Radiation Specialist Date 7/14d/
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B. Nicholas,(RadiationSpecialist
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Approved by:
1M Jt_4 m
G M. Brown, Chief, Technical Inspection Branch
/Date Inspection Summary Inspection conducted during the period of May 4-7,1981 (Report: 50-285/81-12)
Areas Inspected:
Routine, announced inspection of the licensee's radiochemistry measurements program including sample collection, treatment and analysis, analytical procedures and quality controls.
The Region IV mobile laboratory was utilized for on site comparisons of sample results.
Actions taken on previous inspection items were reviewed.
The inspection involved 64 onsite hours by two NRC inspectors.
Results:
One item of noncompliance was identified; failure to follow procedure (See paragraph 5).
One open item was identified during the inspection and is described in paragraph 5.
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0108170137 810807 PDR ADOCK 05000285
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DETAILS-t t
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Persons Contacted
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Omaha Public Power District-(0 PPD)-
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9d. C. Jones, Division Manager, Production Operations
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. F. A. Thurtell, Division Manager, Environmental and Regulatory Affairs
- K. J.. Morris, Manager, Adminstrative Services
- R. L. Andrews, Section Manager, Operations
- S. C. Stevens, Manager,' Fort Calhoun Station
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K.' Gasper, Manager, Reactor and Compriter Technical Services
- T. L. Paterson, Licensing Administrator
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- F. F. Franco, Supervisor, Chemistry and Radiation Protection
- G. L. Roach, Plant Chemist, Fort Calhoun Station'
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- B. J. Hickle, Plan +.ealth Physicist, Fort Calhoun Station
- D. L. Kelley, NRC Resident Inspector, Fort Calhoun Station
T. E. Chapman, Radiation Specialist, Fort Calhoun Station
C. J. Brunnert, QA Inspector, Fort Calhoun Station -
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- Denotes those present during the' exit interview. The inspectors also:
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contacted and interviewed several other licensee and contractue personnel i
during the inspection.
I 2.
Action on Previous Inspection Findings
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l (Closed) Violation (50-2?5/78-05/05):
This item identified the failure -
to follow procedures requiring a, biannual calibration of the TN-11 gamma l
spectrometer.
The inspectors reviewed Standing Order A-T-13, which requires:
j the biannual calibration and chemistry procedure,- CP-LAB-15, which'
documents each calibration.
The licensee's corrective actions appear
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adequate.
This item is considered closed.
(Closed) Bulletin (50-285/78-08/01):
This bulletin requested radiation
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surveys and evaluations of radiation levels adjacent to-the fuel transfer
tube during refueling operations. The in.,)ectors reviewed the licensee's i
completed survey and evaluation report dated March 27, 1980..This item-is considered closed.
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(Closed) Open Item (50-265/80-04/01): This item identified a need for a
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procedure to cover the various activities being conducted with regard to the movement of contaminated waste from plates of origin' to final disposition. The inspectors reviewed procedure RPP-14 and had no further questions. This item is considered closed.
(Closed) Open Item (50-285/80-04/02). This item identified the lack of a procedcre to require the fit testing of half-mask respirators with-irritant smoke prior to.each use..The inspectors reviewed Section 2.12 of the Radiation Protection Manual and had no further questions. This item is considered clcsed.
(Closed) Violation (50-285/80-04/06 and 50-285/80-16/07): These violations identified the licensee's failure to label containers of radioactive material as required by 10 CFR 20.203(f).
The inspectors reviewed the corrective actions taken by the licensee as specified in their lette rs of April 2,1980 and February 6,1981. This item is considereo closed.
(Closed) Health Physics Appraisal Item (50-285/80-16/01): This item-was concerned with the reporting level of the Radiation Protection Manager (RPli) and his direct recourse to responsible management.
In addition, the number and stability of the Health Physics staff was of concern. The inspectors reviewed a Technical Specification change request dated April 15, 1981, that indicated the RPM reports directly to the Plant Manager and at a level equivalent to operations and main-tenance supervisors. The Health Physics staff now has nine ANSI N18.1 qualified technicians and the commitments specified in the licensee's response letter of February 24, 1981, appear to have been met.
This item is considered closed.
(Closed) Health Physics Appraisal Item (50-285/30-16/02): This item identified a need for a comprehensive training program for Health Physics technicians. The inspectors reviewed the scope and content of the new program and the qualification records for several technicians.
The new training program defines training required to advance from technician levels II, I and Senior levels to Specialist and Health Physicist. The technician training program will be encorporated into the plant training manual presently under final revision. The inspectors had no further questions on this item and considered it closed.
(Closed) Violation (50-285/80-16/06): This item cited
.a failure of a Health Physics technician, providing shift coverage, to have the minimum qualifications specified in ANSI N18.1-1971. The licensee has prepared position descriptions for technician levels I and II.
These descriptions and a statement of Ai!SI N18.1 qualification requirements have been for-warded to the plant personnel department.
Each technician's qualifica-tions are documented in his qualification record which has been issued to
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each technician. The inspectors had no further questions concerning this item and considered it closed.
(Closed) Violation (50-285/80-16/08):
This item identified a failure to report personnel exposure data as required by 10 CFR 20.409(b).
The inspectors verified the corrective actions specified in the licensee's response letter of February 6, 1981, had been completed. This item is considered closed.
(Closed) Open Item (50-285/80-16/11):
This item identified a need for selection criteria for Health Physics technicians.
The licensee's corrective actions on Item 80-16/02 effectively satisf_ies this item.
This item is considered closed.
(Closed) Open Item (50-285/80-16/12): This item identified a need to certify technician qualifications. The licensee's corrective actions on Item 80-16/02 effectively satisfies this item.
This item is cor-sidered closed.
(Closed) Open Item (50-285/80-16/13):
This item called for improvements in the Health Physics training program.
The licensee's newly developed
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technician training program, reviewed in closing out Item 80-16/02 satisfies this item.
This item is considered closed.
(Closed) NUREG-0578 Item 2.1.8.a (50-285/80-16/40):
This item is con-cerned with interim procedures and equipment to satisfy NUREG-0578 post accident sampling requirements.
The inspectors reviewed the licensee's prepared procedures and equipment and visited sample locations and the laboratory facilities.
The inspectors discussed with the NRC staff the problems associated with the present location of the laboratory facilities'.
The inspector stated that although materials have been collected and procedures prepared, the licensee's interim plans do not'give reasonable assurance that personnel exposures could be kept below applicable limits in the collection of RCS samples and samples sucessfully analyzed in present laboratory facilities.
This item i; considered open.
(Closed) NUREG-0578 Item 2.1.8.b (50-24 /80-16/41):
This item is con-cerned with interim procedures and equ 4 ment to satisfy NUREG-0578 effluent monitoring requirements. The inspectees reviewed the procedures and equipment provided by the licensee tc satisfy interim requirements and visited monitoring locations to verify ~ equipment placement.
This item is consi:" red closed.
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(Closed) NL.C ai8 Item 2.1.8.c (50-285/80-16/44):
This item is con-cerned with interim measures and procedures necessary to have an inplant
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iodine monitoring capability.
The licensee has a SAM-2 monitoring instru-j ment in the plant conference room.
Procedures have been established and the instrument has been calibrated.
Silver zeolite cartridges are available eliminating the need for sample purging.
Availability of laboratory facilities would allow sample collection and measurement I
using convencional equipment.
Interim action on this item is considered closed.
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(0 pen) Open Item (50-285/78-05/02):
This item identified the lack of detailed sample collection procedures for certain samples.
The inspectors reviewed a draft sampling procedure for gas sampling from WD-32 gas analyzer which will be incorporated into Appendix A of CMP-2 in the station chemistry manual.
A licensee representative stated that sampling procedures were being written for all major chemistry samples and they will be incorporated into Appendix A of CMP-2 including existing operating instruction 0I-SL-1 which describes primary coolant sampling.
This item remains open pending completion of procedures to cover all major chemistry samples.
(0 pen) Open Item (50-285/78-05/03):
This item involved the installation and use of a remote containment air sampling system.
Installation of this system has been attempted but not completed so that representative samples of containment air can be routinely taken.
This item remains open pending verification data showing that representative samples of containment air can be taken from the remote location.
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Open Items this Inspection (0 pen) Open Item 81-12/01 Quality Control of Chemistry Instrument Func-tion Checks: The function check log FC-353 for non-radiological chemistry instrumentation in both the cold laboratory and the hot laboratory were not completed so,isfactorily prior to filing.
(See paragraph 5)
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Licensee's Internal Audits The NRC inspectors examined the licensee's internal audit program to determine compliance with their QA requirements.
Audit report No. 3-81, entitled, " Surveillance Testing and Technica' Specification Requirer.ents,"
which covered chemistry activities, was conducted by R. L. Hyde, P1 ant QA Supervisor, on February 2-3, 1981.
The report was reviewed for scope and timely follow-up action for problem areas identified during the audit.
The plant QA staff also perform monthly audits of radiochemistry responsibilities.
The audit reports which were reviewed did not identify any significant problems.
No items of noncompliance or deviations were identified.
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Quality Control of Plant Chemistry Laboratory Analytical Measurements The NRC inspectors reviewed the plant chemistry laboratory QC program for radiological and nonradiological analyses.
Standing Order A-T-13,
" Quality Control Program for Chemistry and Radiation Protection Equip-ment" was reviewed for any revisions since the last inspection and for compliance with the established requirements of the QC procedures.
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(a) Calibration Procedures The NRC inspectors noted that Standing Order A-T-13 requires that all calibration procedures for chemistry analytical instruments and health physics radiation protection equipment be reviewed at least every two years.
A review of the master document index for these procedures indicated that 16 out of 22 chemistry instrument calibration procedures and 17 out of 19 health physics instrument calibration procedures had not been reviewed within the last two years.
Failure to review the instrument calibration procedures is an item of noncompliance against Technical Specification 5.8.1.
Technical Specification 5.8.1 states, " Written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI-N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 except rovided in 5.8.2 and 5.8.3 below."
..is is a Sevet icy Level V Violation (Supplement I.E).
(b) Function Check Procedures The NRC inspectors reviewed the following function check logs for radiological laboratory counting instrumentation and nonradiological laboratory analytical instrumentation covering the 1st Quarter of 1981.
Form FC-272
" Wide Beta II QC Function Test Data Sheet" Form FC-265
"I.P C. QC Function Test Data Sheet" Form FC-264
"G.M. QC Function Test Data Sheet" Form FC-274
" Liquid Scintillator QC Function Test Data Sheet" Form FC-200
" Canberra Ge-Li System QC Function Test Data Sheet" Frrm FC-353
"Non-radiological Analytical Instrument QC Function Test Data Sheet" In general, data is to be entered on the above forms daily to indicate which instruments in the respective laboratory areas are function checked that day.
The function check procedures require that each instrument be function checked daily or prior to use if the instrument is not, operated daily on a routine basis.
Each log sheet records functional check data for an entire month.
It was noted that many of the data sheets did not have a completed current procedure revision verification stamp on them.
Also, many days during the 1st Quarter 1981 had no indication as to whether the analytical instruments were used or not used, especially for non-radiological analytical instrumentation in the cold laboratory and hot laboratory.
More care and attention must be taken in reviewing
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e these logs prior to filing so that they thoroughly and accurately document the chemistry instrument quality control program.
This item is considered to be an open item (50-285/81-12/01) pending further review.
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Analytical Measurements a.
Confirmatory Measurements
Confirmatory measurements were performed on the following samples in the mobile laboratory at Fort Calhoun Station during the inspec-tion:
(1) Stack Charcoal Cartridge (2) Stack Particulate Filter (3) Gaseous Waste (4) Liquid Waste (5) Reactor Coolant (6) RESL Particulate Filter Standard (7) RESL Charcoal Cartridge Standard The confirmatory measurements tests consist of comparing measurements
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made by the licensee, NRC's mobile laboratory, and NRC's reference laboratory, Radiological and Environmental Sciences Laboratory (RESL)
RESL's and the NRC's mobile laboratory mea-surements are referenced to the National Bureau of Standards by laboratory intercomparisons.
Confirmatory measurements are made only for those nuclides identified by the mobile laboratory or RESL i
as being present in concentrations greater than 10% of the respective iset gic values for liquid and gas concentrations as stated in 10 CFR Part 20, Appendix B, Table II, and above the Lower Limit of Detection (LLD) for stack samples.
Stack charcoal cartridge and stack particulate filter comparisons are based on established Lower Limits of.Detec+ ion (LLD) for total activity per sample.
Attachment No. 1 contains the criteria used to compare results.
Attachment No. 2 lists the LLD's for stack samples.
The following tables show the various sample comparisons:
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Stack Charcoal Cartridge (Collected 11:58, May 2,1981)
Nuclide NRC Measurement Licensee ' Measurement Decision 131 2.81+0.09E-13 uCi/cc 3.27+0.14E-13 uCi/cc Agreement
1331 1.1810.51E-13 uCi/cc
<1.22E-13 uCi/cc (1)
(1) Activity concentration identified by the NRC was less than 10% of the isotopic valve as stated in 10 CFR Part 20, Appendix B, Table Il and less than the recommended detection capabilities for the specific nuclide in the sample media as presented in the proposed Standard Technical Specifications for Pressurized Water Reactors; therefore, no formal comparison is made.
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Stack Particulate Filter (Collected 11:58, May 2,1981)
Nuclide concentrations identified by NRC Region IV mobile laboratory were less than LLDs. No comparison made.
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Gas (Waste Gas Decay Tank, "A", collected 17:11, May 5,1981)
Nuclide NR[ Measurement Licensee Measurement Decision 133 4.81+0.05E-02 uCi/cc 4.38+0.02E-02 uCi/cc Agreement 133kje 1.3610.05E-04 uCi/cc 1.1410.04E-04uCi/cc Agreement 131mXe 1.6210.04E-03 uCi/cc 1.6110.04E-03 uCi/cc Agreement 85Kr 6.4810.30E-03 uCi/cc 5.5410.20E-03 uCi/cc Agreement 4.
Liquid (Kaste Hold-up Tank, "B", collected 16:40, May 6,1981)
Nuclide NRC Measurement Licensee Measurement Decision tritium 7.52j_0.02E-02 uCi/ml 2.1310.02E-02 uCi/ml Disagreement gross beta 1.20+0.10E-02 uCi/ml 1.10+0.003E-02 uCi/ml Agreement 89[
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5.81TO.07E-06 uCi/ml (2)
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2.23T0.07E-06 uCi/ml (2)
13b 1.5410.01E-02 uCi/ml 1.7510.02E-02 uCi/ml Agreement Xe 1311 5.9310.04E-03 uCi/ml 6.64+0.12E-03 uCi/ml Agreement 137Cs 6.9610.06E-03 uCi/ml 7.8210.16E-03uCi/ml Agreement 134Cs 4.60+0.05E-03 uti/ml 5.02+0.14E-03 uCi/ml Agreement 136 3.74TO.18E-04 uCi/ml 4.33TO.61E-04 uCi/ml Agreement Cs 54Mn 1.40T1.21E-05 uCi/ml 1.11[0.18E-05 uCi/ml Agreement
2:4110.78E-05 uCi/ml 1.5010.13E-05 uCi/ml Agreement Co
7.2810.86E-05 uCi/ml 1.0210.12E-05 uCi/ml Disagreement Co 99gg 3.8010.96E-05 uCi/ml
<6.20E-05 uCi/ml (3)
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Nuclide NRC Measurement Licensee Measurement Decision 99mTc 4.4111.12E-05 uCi/ml
<7.41E-05 uCi/ml (3)
133 7.39+1.62E-05 uCi/ml
<1.25E-04 uCi/ml 3)
131m 1.22T0.50E-03 uCi/ml
<2.97E-03 t.Ci/ml 3)
140 1.5710.88E-05uCi/ml
<1.06E-05 uCi/ml 3)
La (1) Analytical results were not available-at the time of the-report due to the 4ct that the licensee negelected to send the samples to the-NRC re...
ce laboratory in Idaho Falls, Idaho, for 6 weeks after the date of the inspection.
Formal doumentation of-these analyses will appear in the next radiological inspection report.
(2) Analytical results were not available at time of report; therefore, no comparison is made.
(3) Licensee's peak.onfidence level for peak identification along with other analysis parameters have been established so as not to allow analysis of nuclides at sensitivity levels recommended for principal gamma emitters and dissolved and entrained gases in liquid waste samples as presented in the proposed standard technical specifications for pressurized water reactors or at activity levels equal to or less than 10% of the isotopic values stated in 10 CFR Part 20, Appendix B, Table II. No formal com-parison is made.
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Reactor Coolant Liquid (Collected 12:56, May 6,1981)
Nuclide NRC Measurement Licensee Measurement Decision 54Mn 1.0810.06E-03 uCi/ml 3.5010.26E-03 uCi/ml Disagreement 58Co 2.34+0.12E-03 uCi/ml 1.90+0.24E-03 uCi/ml Agreement 88Rb 1.25T0.04E+00 uCi/ml 1.01TO.04E+00 uCi/ml Agreement 131 1.3810.02E-02uCi/ml 1.4310.03E-02uCi/ml Agreement
132 3.25+0.03E-02 uCi/ml 2.94+0.21E-02 uCi/ml Agreement
1331 4.7510.02E-02 uCi/ml 4.833 06E-02 uCi/ml
. Agreement 1341 5.72+0.08E-02 uCi/ml 5.33+0.12E-02 uCi/ml Agreement 1351 4.67[0.07E-02 uCi/ml 5.4510.14E-02 uCi/ml Agreement 134Cs 1 9410.11E-03 uCi/mi 2.4210.24E-03 uCi/ml Agreement 137Cs 2.9010.12E-03 uCi/ml 3.6710.25E-03 uCi/ml Agreement 138 1.12+0.02E-01 uCi/ml 1.58+0.05E-01 uCi/ml Disagreement Cs i
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RESL Particulate Filter Standard (standardized 09:00, March 19, 1980)
Nuclide NRC Measurement Licensee Measurement Decision (Co 2.28+0.09E-02 uCi/gm 2.55+0.99E-02 uCi/gm Agreement 0o 1.73TO.07E-01 uCi/gm 1.84T0.01E-01 uCi/gm Agreement
7.5270.30E-02 uCi/gm 6.18T40.4E-02 uCi/gm Agreement 88}Sr 2.9270.12E-01 uCi/gm 2.96T1.77E-01 uCi/gm Agreement yy Sn 5.7'ilo.02E-02uCi/gm 4.0ST7.77E-02 uCi/gm(y) Disagreement 137 241 1.29+0.05E-01 uCi/gm 1.34T0.01E-01 uCi/gm Agreement Cs Am 3.1910.13E-02uCi/gm 2.62}1.44E-02uCi/gm Agreement (1) Licensee used a branching ratio of 100% in calculating the result.
Upon recalculation of the spectral data using a branching ratio of 64%, which is recommended on the standard source certificate, the analysis result of 6.24E-02 uCi/gm was in agreement.
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RESL Charcoal Cartridge Homogenous Standard (standardized 09:00, March 19, 1980).
Nuclide NRC Measurement Licensee Measurement (1) Decision Co 2.28+0.09E-02 uCi/gm 1.38+0.54E-01 uCi/gm Disagreement
1.7370.07E-01 uCi/gm 1.36T0.01E-01 uCi/gm Agreement 85Sr 7.5470.30E-02 uCi/gm 5.13T33.5E-02 uCi/gm Disagreement 88lif 2.92TO.12E-01 uCi/gm 2.2171.32E-01 uCi/gm Agreement Sn 5.7570.23E-02 uCi/gm 2.0172.51E-02 uCi/gm Disagreement 137Cs 1.29T0.05E-01 uCi/gm 9.36TO.03E-02 uCi/gm Disagreement 241Am 3.1910.13E-02uCi/gm 1.4210.78E-02uCi/gm Disagreement (1) Licensee's results are based on a detector efficiency curve established using a face-loaded standard.
The standard cartridge was analyzed without flipping the cartridge at the midpoint of the 'ialysis count.
No items of violation were identified.
b.
Previous Confirmatory Measurements Confirmatory measurements were performed on a sample of gaseous waste which was a re-sample to resolve possible sample splitting problems during an inspection (Report No. 50-285/79-14) conducted in December 1978.
The following table shows the sample comparisons:
1.
Gas (Waste Gas Decay Tank, "C", collected 14:25, August 30,1979)
Nuclide NRC Measurement Licensee Measurement Decision 3Xe 3.1+0.1E-02 cCi/cc 3.9+0.07E-02 uCi/cc Agreement Kr 2.610.2E-03uCi/cc 3.0}0.30E-03uCi/cc Agreement
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No items of violation were identified.
7.
Exit Interview i
At the conclusion of the inspection on May 7, 1981,~ the inspection findings were discussed with the OPPD personnel denoted in paragraph 1.
The NRC inspectors reviewed the scope of the inspection and discussed the inspec-tion findings.
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ATTACHMENT NO.1 Criteria for Ccmoaring Analytical Measurements The folicwing is the criteria used in comparing the results of capability tests and verification measuraments.
The criteria are cased on an empirical relationship established through prior experience and this program's analyt-ical requirements.
In these criteria, the judgement limits vary in relation to the ccmparison of the resciution.
Resolution = NRC Value NRC Uncertainly Ratio = Licensee Value NRC Value Comparisons are made by first determining the resolution and then reading across the same line to the corresponding ratio.
The following table shows the acceptance values.
l RESOLUTION RATIO
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Possiole Poss1 ole Agreement Agreement A Agreement B
0.4 - 2.5 0.3 - 3.0 No ccmaarison 4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5 16 - 50 0.75 - 1.33 0.5 - 1.66 0.5 - 2.0 51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.56
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200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33 l
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"A" criteria are acclied to the following analyses:
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I Gamma 5pec:r: metry wnere princical gamma energy usec for icentification is greater tnan 250 Kev.
Tritium analyses of licuid samoles, l
- cine an acsorcers.
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'5" cr :eria are accifeo o :ne fcilewinc analvses:
d C=mma Scectrometry wnere crinci;al gamma energy used for icentificaticn is less nan 250 Kev.
39Sr and 90Sr Cetermina:icns.
l Gross Seta wnere samoles are : untec :n the same da e using the same i
reference nuclic _ _ _ _ _ _
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ATTACF14ENT N0. 2 LLDs for Nuclides on. Particulate and Charcoal Filters.
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Nuclide LLO (uCi/samole)
51 r lE-04 C
54Mn 1.5E-05 58 o 1.5E-05
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50 o 3E-05 C
55 n 3E-05 Z
39 r lE-05 S
90 r 2E-07 S
131 1
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137Cs 2E-05 140Ba 2E-05 140 a 4E-05 L
141Ce 2E-05 la4ce lE-04
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