IR 05000285/1982030
| ML20092F817 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/01/1983 |
| From: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Jones OMAHA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20092F824 | List: |
| References | |
| NUDOCS 8406230589 | |
| Download: ML20092F817 (2) | |
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01E-Docket: 50-285/82-30 i
Omaha Public Power District-ATTN:
W. C. Jones, Division Manager Production Operations 1623 Harney Street
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Omaha, NE 68102
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Gentlemen:
Thank you for your letter of April 15, 1983, in response to our letter and the attached Notice of Violation dated March 17, 1983.
We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation.
i We will review the implementation of these actions during a future inspection to ensure they have been effective in precluding future noncompliance.
In regard to our concern regarding your apparent lack of attention to the timely resolution of previously identified open items, you expressed concern
that we did not give sufficient credit to the progress made on some items.
We believe the report adequately reflects your progress and the timeliness of your actions. Of the original 18 items reviewed in NRC Inspection Report No. 50-285/82-30, only 7 were adequately resolved to allow closing. The majority of the 18 items were initially discussed in the 1980 NRC Inspecticn Report No. 50-285/80-16 and subsequently in other NRC reports.
It should be noted that one item has been open since 1978. -Several of the items, especially item 285/7805-03, involve basic ALARA concepts for the minimizing of personnel
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exposure. Based on a review of your response, the following coments are provided:
Item 3:
(285/8016-04), Internal Dosimetry Procedures - Our concerns regarding back-calculating MPC-hours in bioassay procedures were initially discussed in.
NRC Inspection Report No. 50-185/80-16, and should not be considered new require-ments. An adequate internal dosimetry program is necessary to demonstrate compliance with 10 CFR 20.103.
Item 6:
(285/8016-31), Testing of Auxiliary Building HEPA Filters - Your response
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does not adequately address actions to be taken to ensure that the recom-
.mendations of NRC Regulatory Guide 1.140 regarding inplace filter testing are implemented.
Item 7:
(285/8016-31), Effluent Monitor Calibrations - The NRC does not consider that your instrument sensitivity program satisfies the recommendations of NRC Regulatory Guide 1.21 or ANSI H323-1978 as they apply to calibration of radiation
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Omaha Public Power District-2-protection instrumentation. Also, your use of a single source during actual calibration (performed by the Instrument and Controls Department) does not satisfy the aforement ioned referenced documents for calibrating a system over its intended range of enerny and rate capabilities.
In addition, you do not have adequate records that relate the solid sources usec' during routine calibration to the initial talibration of the instrument.
Item 11:
(285/P128-03),EvaluationofContractHPTechnicians-ThecurrentNRC position on mditable experience for cnntract-type HP technicians is contained in NRC Staff P.uition, W. J. Morrison, NRC, subject:
" Clarification of experience requirements f ar radiation protection technicians," Task No. RS 807-5, August 26, 1980. This reference allows for utilization of Jon1 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per week of work for meeting e:<perience qualifications of ANSI N1B.T-1971 criteria.
We will review the implementation of your corrective actions for these and other referenced open items during a future inspection.
-Should you have any questions concerning the above-referenced items, we will be pleased to discuss them with you.
Sincerely,
W. C. Seidle, Chief Reactor Project Branch 2 '
cc:
W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023
. Harry H. Voight, Esq.
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LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, H.W.
Washington, D. C.
20036 bec: c/oDM8'(IE01)
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Resident Inspector-SectionChief(RPS-C)
Inspector-John T. Collins R. L. Bangart-E. Johnson RPB1 RPD2
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 402/536-4000 April
.'T, 1983 LIC-83-091 Mr. W.
C. Seidle, Chief
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Reactor Project Branch 2 I
U.
S. Nuclear Regulatory Commission Region IV
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611 Ryan Plaza Drive, Suite 1000 APR 2 I i983 i
Arlington, Texas 76011
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Docket No. 50-285
Dear Mr. Seidle:
IE Inspection Report 82-30 Please find attached the Omaha Public Power District's re-sponse to the one (1) violation and twelve (12) open items discussed in the referenced report.
The District is concerned about the statement in your March 17, 1983 letter regarding the lack of suf ficient management attention for resolution of previously identified open items.
The District believes it is unfortunate that the progress on the resolution of the open items referenced in the subject report was not reflected in that report.
The District be-lieves that timely action has been taken to resolve many of these open items, as discussed in the attached response.
During future inspections and exit interviews, we will attempt to make the I&E inspectors more fully aware of the District's efforts on issues such as these.
We solicit your cooperation in these matters.
Sincerely, SE b
W.
C. Jones Division Manager Production Operations WCJ/TLP:jmm M
l Attachments
cc:
LeBoeuf, Lamb, Leiby & MacRae'
Mr.
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A.
Yandell, NRC Senior Resident Inspector Mr. E. G. To gigng g gectManager
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Attachment 1 OMAHA PUBLIC POWER DISTRICT IE INSPECTION REPORT 82-30 Violation Procedural: Compliance Technical Specification 5.11, " Radiation Protection Program," states:
" Procedures for personnel radiation protection shall be prepared consistent with the re-quirements of 10 CFR 20 and shall be.
. maintained and
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adhered to.
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Radiation procedures are also addressed in your Standing Order T-1, " Radiation Protection Manual," which states:
. will abide to every provision
"All station personnel.
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of the Radiation Protection Manual.
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In addition,-Section IV.I.1, " Weekly Review of Standing R.W.P.'s," of Radiation Protection Procedure (RPP)-20,
" Radiation Work Permit," which is part of the Radiation Protection Manual states:
"All R.W.P.'s written for a period greater than five working days will be reviewed by a designated individual within the Radiation Protection Group the R.W.P. will be dated and initialed in the space
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provided."
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Contrary to the above, on November 30, 1982, the NRC in-spector determined that the licensee has not performed the
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proper weekly review of 18 Standing RWP's between November 12-November 30, 1982.
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This is a severity Level V violation.
(supplement IV)
Response
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(1)
Corrective steps which have been.taken and the results achieved.
The Radiation Work Permits (RWP) in question were re-viewed by qualified personnel within two (2) days of-discovery of the incident.
Qualified individuals to perform future RWP reviews have been designated and the Plant Health Physicist has been given the responsi-bility of.enuuring these reviews are completed as '
scheduled.
This action will result in reducing the probability of recurrence of this incident.
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Corrective steps which will be taken to avoid'further l
violations.
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The RWP review process will be closely monitored by
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responsible plant personnel to ensure the RWP review
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schedule is adhered to.
(3)
Date when full compliance will be achieved.
L The District is presently in full compliance with RWP reviews.
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Attachment 2 RESPONSE TO OPEN ITEMS IDENTIFIED i
IN IE REPORT 82-30
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1.0 open Item (285/7805-03):
Innta11ation of Remote l
Containment Air Sampler - Th;,s item was discussed in
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NRC Inspection Report Nos. 50-285/78-03, 50-285/79-14, i
50-285/81-12, and 50-285/82-04 and involved'the-licensee's use of personnel to obtain the routine weekly air sample from within the reactor containment during reactor operation.
The licensee had con-structed and tested a remote containment air sampling system; the system failed to produce representative samples and was abandoned.
The licensee plans on using, when installed, the Postaccident Sampling System (PASS) to obtain the weekly containment air samples.
This item (285/7805-03) remains open.
Response The previous plan to use the PASS to obtain the weekly con-tainment atmosphere sample has been changed because the PASS does not provide for particulate sampling.
An alternative to the weekly personnel entry of. containment to collect the.necessary gas and particulate samples is pre-sently being evaluated and may involve relocation of the sampling point or monitors.
This alternative is being developed in conjunction with.a program to test the repre-sentative sampling capability of RN-050, 051, 061, and 062 (see responsa to open' Item 285/4014-32).
This alternative will be developed by September 1, 1983 and is expected to be operational by February, 1984.
2.0 Open Item (285/8016-03):
QA/0C Proeram for Gamma, Beta'. and Neutron' Personnel Rongterthe Devices - This item was first discussed in NRC Inspection Report No.
50-285/80-16 and also again in NRC Inspection Report No. 50-285/01-24 and involved the failure of the licensee to provide full range calibration for personnel radiation esposure. monitoring-devices.
e' This portion was provLously clemed out on nopeation Report No. 50-285/01-28.
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e This portion was found to be sa e
e ory by the NRC inspector and is considered glated.
See Section 12 for details.
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Beta TLDs The licensee is still performing
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evaluations and testing of TLD's for proper' beta energy response.
This portioniot gggg item (28S/8010-03) is et111 considered 3.
See Seetion-12 for dotatis.
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Response
j The District's program for evaluating current personnel beta
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j dosimetry and beta radiation fields at the Fort Calhoun j
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Station is in progress.
The purposes of the program ares
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(1) to review the current two-element TLD for its responsive-f
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ness to beta radiation; (2) to investigate improved TLD's
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using two, three, and four elements; (3) to survey the Fort
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jl Calhoun Station and determine locations and spectrum of beta l
radiation fields; and (4) to revise and update instructions l
and procedures currently in use at the Fort Calhoun Station.
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2.1 Review ~ of Two-Element ~ TLD's - The current two-element
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TLD was found to over-respond by 464 and 274,90re-
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pnctlyggy, to high energy beta sources 90Sr/
Y and i
AU*Ru/1v Rh but to under-respond by 634 for the low j'
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85 r beta source.
However, when the current
energy K
l two-element TLD was tested in the University of
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j Michigan study of TLD processors (Study No. 3), it ggssq Category No. V for exposure to beta field from
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j TvSr/y0 The effect of these test results on per-Y
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sonnel monitoring is being considered in conjunction
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with other information collected from all elements of i
I the study program.
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j 2.2 Investigation of ~ Improved TLD's - An improved four-
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element TLD has been proposed and is currently under-
going field testing and calibration.
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four-element TLD may be provided as an alternate or
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supplement to the two-element TLD.
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i 2.3 Survey of * Beta' Fields - During the recent refueling i
j outage, identification and characterisation of beta
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fields at the Fort Calhoun Station was completed.
Locations surveyed included the primary side of the-steam generators, the spent fuel pool, corridors in
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the low pressure safety injection (LPSI) pumps, and
the waste drumming station.
The only areas where any J
. measurable beta fields were identified'were the steam generator, the LPSI pumps, and the drumming station.
Nigh energy beta fields were only ' identified inside l
the priman side of the steam generator.
Energies in excess of 1 Nov with Co60 as the isotope were.identi-
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In the LPSI pump and' drumming areas, the beta j
fields were low in energy with on doses penetrating p, yond 32 mg/cmgy 15% of the New coverall
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material,'25 mg/cm or approximately~10 inches of air.
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would attenuate the beta dose from these areas to i
approsisately 15-20% of its original value.
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Additional field measurements are scheduled at the Fort Calhoun Station to check for beta fields.
To date, only the steam generator has been shown to have beta fields which allow for the possibility of any significant beta dose.
2.4 Instructions'and Procedures - Preliminary evaluation of the steam generator fields has determined that the beta dose is reduced by a factor of 1/3 of its original value by an absorber thickness of 30 mg/cm2, Workers entering the steam generator primary side have a mininum skin covering of approximately 60 mg/cm2
(one paper coverall, one cloth coverall, and one wet
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suit).
Two-element TLD's worn by the personnel enter-ing the primary side of the steam generator estimated no beta dose to the trunk of the body but some dose at the wrist and foot extremities.
Only in the case of j
one extremity dose did the extremity non-penetrating i
beta dose exceed the extremity penetrating dose.
j Personnel protective clothing was effective in mini-
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mizing or eliminating the high energy beta dose inside the steam generators.
Conclusion Our existing two-element program appears to be adequate in the only area where there is beta radiation in the plant; i.e.,
Entry to the steam generators is
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carefully controlled and protective clothing is worn which effectively eliminates beta exposures to the worker.
However, the District will continue its evaluation to
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improve its beta dosimetry program and expects to complete their evaluation by September 30, 1983.
3.0 Open Item (285/8016-04):
Internal: Dosimetry Procedures - This item was discussed in NRC Inspection
Report Nos. 50-285/80-16 and 50-285/81-28 and involved the licensee's failure to establish an internal dosimetry program that meets the recommendations of ANSI Standard N343-1978'and NRC Regulatory Guide 8.26.
The NRC inspector determined that the licensee had not, as of this inspection (50-285/82-30), provided
suitable procedures that will ensure indirect bioassay
sampling is performed properly, or provide suitable instructions for extrapolation of whole body counting data back to initial intake of radioactive materials.
See Section 11 for details.
This item (285/8016-04)
is still considered open.
Response IE Inspection Report 80-16, Open Item 04, Section 3.2.5, identified a weakness in internal dosimetry procedures and made specific recommendations for improvement as follows:
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"3.2.5 Conc 1bsions Based on-the above findings, internal' dosi-metry: procedures have not been developed
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that would contain the biological models and calculational techniques necessary to
assess the results of direct and indirect
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bioassay measurements in terms of the
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amounts and dosimetry of radioactive
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materials taken into the body.
These' pro-
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cedbres'need'toibe: developed'and:imple-
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i mented: to achieve: a; f ully; acceptable. pro-Gram."
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The District responded promptly and fully to this original
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finding through the initiation of a new Health Physics Pro-
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cedure, HP-10, "Whole Body Count Evaluation".
Biological models and calculational techniques for assessing internal j
deposition radiation utilizing ICRP 2, 10, and 30 method-ology were incorporated into this procedure.
The District believes its response fully addressed the elements of Open f
Item 8016-04.
The District believes the elements now identified in IE In-i i~
spection Report 82-30, which retain-8016-04 as an open item,
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are new recommendations.
I The District has or intends to take the following actions in response to the new recommendations identified in IE In-
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3.1 The District will review HP-10 and either upgrade this I
procedure or develop a new procedure to provide addi-l tional station instructions for a controlled process
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of persons referred to the UNMC/RHC for indirect bio-
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-assay evaluation.- A special review and revision of l
HP-10 will be performed by September 1,-1983.
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3.2 The District has completed the annual calibration of
the.whole body counter.
A phantom, as discussed in recommendations of ANSI N343-1978,lwas utilized for this calibration.
A review with revision improvements to Health Physics Procedure HP-10,~"Whole Body Count-ing", was issued on November 30, 1982 as part.of this
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action.
The District believes these actions' fully
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sidered closed prior to the end of;the year of 1982.-
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-5-3.3 Revised procedure HP-10 was issued on April 8, 1982 and the District believes it contains adequate in-struction to perform internal radioactivity assess-ments.
During the course of procedure review, the District intends to re-evaluate its content before September 1,1983 and provide more specific inform-I ation pertaining to the determination of MPC-hour i
intake, if determined by the review.
It should be i
noted that the District policy designates supervisory
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and more experienced HP personnel the responsibility of-assessment of special radiological incidents.
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These persons include the Supervisor - Chemistry &
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Radiation Protection, Plant Health Physicist, and lead
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HP group personnel.. Shift C/RP Technicians and other persons in the C/RP group have the responsibility to identify the incident or problem and then secure more
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technical guidance from the HP Supervisor.
As-such, l
the District believes that training of all C/RP-group
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personnel on cc.nplex internal radiation methodology is
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not advisable as it is not within their work reaponsibilities.
However, the responsible persons
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identified shall receive full training on this pro-cedure.
4.0 Open Item (285/8016-05):
Portable Instrument Cali-~
bration - This item was discussed in NRC Inspection Report Nos. 50-285/80-16 and 50-285/81-28 and involved the licensee's lack of an established calibration pro-
't gram for several types of portable-radiation monitor-ing instruments, as noted below.
l Gamma This portion!was previously closed out on NRC
Inspection Report-No.- 50-285/81-28.
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Beta:
The licensee has procured a strontium-90 beta
source of-significant activity and is in the process of obtaining National Bureau 1of Standards'(NBS) certi--
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fication for the source.
Development of station'in -
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strument calibration procedures is in progress.
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Section 13 for details.
M11s portion of open item
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(285/8016-05) is still considered open.
Neutron The licensee has implemented calibration of
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i station neutron measuring instruments by NBS using a i
moderated californium-252-source.
The licensee had not completed development of calibration contracts i
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See Section 13'for de-
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This portion of open item (285/8016-05).is-still considered open.
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-6-Instrument' Performance' Check:
The licensee has imple-
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mented a suitable preuse instrument performance check
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i program that provides for the checking of up to 3 points on an instrument and provides rejection
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j-criteria.
This portion of bben item (285/8016-05) is
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considered closed.
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Pocket?D6bineterk'(PDs):
The licensee had' procured a
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multiple PD calibrator and had located it within the auxiliary building.
The licensee had established a
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semiannual functional check procedure for PDs that meet the recommendations set forth in NRC Regulatory
Guide 8.4.
This portion of 6 pen item (285/8016-05) is
considered blosed.
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Lapel: Ait' Samplers t - The licensee had not implemented
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procedures that provide for the routine use of lapel i
samplers to substantiate MPC-hour data gathered by y
other air sampling programs, or incorporated the lapel
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air samplers into an approved maintenance and cali-
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bration program.
See Section 13 for details.
This
portion of opeh item (285/8016-05) is still considered ll M'
Response i
4.1 Portable' Instthment: Calibiatibn' and' Buta: Radihtion J;
Calibration:Proeram - A Strontium-90 beta source has l
been procured and certification of source strength has J
been received'from NBS.
A procedure for calibration j
of portable beta instruments is in the draft stage of
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development.
Full range calibration of beta instru-
ments will not be possible until.an additional higher range source is acquired.
Final approval of.the cali-
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bration procedure is expected to be completed by i
June 1, 1983.
Procurement and use of a new source-is j
expected to be completed by January 1,1984.
I 4.2 Neutron' Shrvey* Inkkruheht Cillibratich'- A neutron sur-
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voy instrument has been calabrated by NBS using a j-
' moderated ~ Californium-252. source with certification on file at the Fort Calhoun station., Procedures con-
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i trolling the method of assuring timely calibration will be completed by July.1, 1983.
Investigation into
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the availability and procurement of a moderated.
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californium-252-source is presently scheduled to be
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'Skeathihe'8bheftLape13fAik'Shapitts - The Port Calhoun station respiratory protection program was developed-
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under the criteria of NURBG-0041.
Review of the air sampling program has resulted in draf t revisions to i
Section 2 of the: Radiation' Protection Nanual and pro-
'cedure NP-5, "Co11ection'and Analysis of Air' Samples"..
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Use of lapel air samplers is addressed in these changes.
Purchase of improved lapel air sanplers in being pursued.
On receipt of these units, procedures for their care, maintenance and calibration will be completed.
Completion date is expected to be December 1, 1983.
5.0 Open Item (285/8016-18):
Documentat16n'of' Air Quality - This item was discussed in NRC Inspection Report Nos. 50-285/80-16 and 50-285/81-21 and involved the failure of the licensee to establish a program to verify both station-supplied and vendor-supplied breathing air met NUREG-0041 recommendation for Grado D breathing air.
The licensee still had not fully im-plemented a satisfactory quality control program for breathing air that satisfies NUREG-0041 critoria.
The licensee is currently procuring analytical standardu and developing procedures for the breathing air QA pro-gram.
This item (285/8016-18) is still considered open.
Respohhh l
All elements of a program meeting NUREG-0041 recommendations
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for confirmation of Grade D breathing air are complete ex-l cept for the receipt of a carbon monoxide (CO) analyzer from the vendor, the calibration and use procedures for the analyzers, and final Plant Review Committee approval of the program.
The program is expected to be in full compliance two months after receipt of the CO analyzer.
The Districh has received verbal confirmation of a shipping date of May 15, 1983 from the vendor.
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6.0 Open Item (285/8016-31):
Testiho' 6f' Abkillark' Bu118-
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Ing' HEPA' Filters - This item was discussed in NRC
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Inspection Report Nos. 50-285/80-16 and 50-285/81-21 and involved the licensee failure to implement sur-veillance, maintenance, and testing programs for the auxiliary building filtered ventilation system in order to satisfy the recommendations of NRC Regulatory Guide 1.140.
The licensco had only partially imple-mented the aforementioned NRC recommendations.
See Section 15 for details.
This item (285/8016-31) is still considered 6 ben.
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The Distict has evaluated the curront surveillance program for the auxiliary building HEPA filters and the following actions are being or will be taken in order to satisfy the recommendations of Regulatory Guide 1.140:
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l 4.1 The difforential pressure gauges for HEPA filters will E
I normally be calibrated every 18 monthm + 154 in j
accordance with Standing Order M-28.
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6.2 The MEPA f11ters will be replaced when the dif-i
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forential pressure across the filter bank exceeds 4
l inches of water.
l 6.3 Replacement HEPA f11ters are procured in accordance i
with the industry standards referenced in Regulatory Guide 1.140.
4.4 A procedure will be developed for the replacement of
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HRPA f11ters.
This procedure will include, among
other things, the visual examination to assure proper installation and quality control steps.
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6.5 A visual examination of the NRPA filters will be made during each refueling outage to ensure that leakage paths do not exist.
Items (1) and (3) are presently being utilised.
Items (2),
(4), and (5) will be implemented by August 31, 1983.
With regard to the concern on the NEPA f11ter installed on f
the compaction mact.ine, it is considered redundant and un-
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necessary to develop a testing or maintenance program as the
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discharge from this filter exhausts into the auxiliary build-ing HEPA f11ters.
l 7.0 Open Item (285/8016-32):
Etfikkhk!Nohikbf Cali-
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bratibas - This item was discussed in NNC Inspection
Report Nos. 50-285/80-14 and 50-28S/81-21 and involved
the licensee's lack of full range and energy cali-l
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brations for process and offluent monitors to satisfy
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the recommendations of ANSI Standards N323-1978 and i
N42.18-1900.
The licensee had not completed imple-
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mentation of a suitable offluent monitor calibration
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program.
See Section 14 for details.
This item a
'(24S/0014-32). is still considered M.
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M Procedures for sensitivity and alarm setpoint determinations of.RM-050, 051, 057, 0S9, 040, 061, and 062 were rewritten during the 1983 refueling outage and include provisions for determination of full range sensitivity and linearity.
Rr-OS was used for noble gas determinations, Co-137 for particulate determinations, and Ba-133 (mock iodine) for
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I-131 determinations.
All sources were presented to the
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detectors in the same geometry as the normal sample stream.
In the case of liquid process and offluent monitors (RN-0SS and RN-OSSA), sample-jlge were constreeted duplicating the physleal-shape:and materiale=of constreetton of the in-place-t
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monitor housing.
Monitors RM-050, 051, and 061 were tested through their full range.
Monitors HM-057 and 062 wore tested in all but the upper most decade of their rango duo to limited quantity of nource material.
RM-060 was tested
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in all but the two highout decados due to limited quantity of source.
Calibration of RM-1 and RM-2 through thono monitors' full rango would involve unacceptable personnot radiation exposure.
Monitors RM-052, 053, 054A, 054n, 056A, and 0568 are not controlling effluent monitors.
They woro calibrated during the 1983 refueling outago using existing calibration procedures.
However, they will be calibrated at the next scheduled f requoney (1984 refueling outage) with revised procedares similar to thone already revised.
The Dintrict believen its offluent monitor calibration program will meet the applicablo standard by July 1, 1984.
A program to test the representativo nampling capability of HM-050, 051, 061, and 062 will be devoloped by September 1, 1983 and perforned by Febtuary 1, 1984.
8.0 Open Iten (285/8016-33):
Curib' Content' br* Packhoek -
This item was discussed in itRC Innpoction Hoport tion.
50-285/80-16, 50-285/81-21, and 50-285/82-26 and in-volved the licennoo's method of determining the curio content of wasto packages.
The licenson had not com-pleted implementation of a now curio entinato pro-ceduro.
This item (285/8016-33) is still connidorud
!?P311'
Response After receipt of IE Inspection Report 80-16, the District performed a responsivo evaluation of solid radwante pro-coduros and practices.
The results, reported to the plant Review Committee on February 11, 1982 por memorandum FC-213-82, concluded that current methods, including the dotermination of radioactivity based on contact done raton, were in general industry use and adequate.
However, during
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later inspections, the NRC position was established that the method discussed in Hehlth _Phystbs, Volume 13, pages 445-450, " Determination of the Curie content of Packaged Radioactive Wastes Using Measured Dose Rates", as developed by Carolina Power & Light Company, was recommended.
Sub-sequent to receiving this article from the NMC inspector in early 1983, the District has performed preliminary reviews and calculations using the referenced guide.
The new method, including appropriate training, will be incorporated into either HP-3, " Solid Waste Shipment Procedures", or a new, separate procedure and implemented by September 1, 1983.
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9.0 Open Item (285/8016-38):
_f.oeal; Exhhus t: f6r Fume Xboa - This item was discussed in NRC Inspection Report Nos. 50-285/80-16 and 50-285/81-21 and dealt with the lack of sutficient air flow across the face of the radiochemical laboratory fume hood.
The licensee had not finalized plans or obtained necessary approvals for modifying the existing ventilation system.
This item (285/8016-38) is still considered
$28!1*
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Rbs.bnse An Engineering Evaluation Assistance Request (EEAR)
FC-80-132 to alleviate the fume hood's problems was l
initiated on November 8, 1980, aad Priority I.evel 2 was assigned to it.
The priority level was upgraded to Level 1 on March 25, 1981.
A preliminary design package was issued on June 10, 1982.
Following the resolution of comments, a I
final design package was issued on November 15, 1982.
This I
package was accepted by the plant staff on April 8, 1983.
Parts and supplies for this modification are presently in the Fort Calhoun Station Stores Warehouse.
Construction is i
expected to begin in May, 1983 and completion is expected by l
June 30, 1983.
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10.0 Open item (285/8128-01):
ALAkA' Prout am - This item j
was discussed in NMC Inspection Report Nos.
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50-285/80-16 and 50-285/81-38 and involved the licensee's failure to establish an ALARA program.
The
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licensee had established an ALARA programs however, l
the program is considered inadequate in several areas.
See Section 9 for details.
This item (285/8128-01) is considered gy)_!1 l
k...on..
Omaha Public Power District implemented a formal upgraded ALARA program on June 1, 1982, as documented in the Dis-trict's letter LIC-82-222.
The program was designed for
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compliance to the requirements of 10 CFR 20.1, utilising guidance provided in Regulatory Gulden 8.8 and 8.10.
10.1 PrbS184: fbk' 4681thationJ6f; ah' A A8W Cberdthhtok' 1N thb Fbt t' Chhhhh:Stetter ebeth184t1M - The primary re-sponsth,11 ties of tie ALARA program are established in OPPD Policy No. 9.03 and espanded in Port Calhoun Station Standing order 0-50.
Subsequently, the addi-tional position of 'ALARA Coordinator * is established in Station Operatin Manual, Section 7, g Procedures, Radiation Protection Operational ALARA Program *.
Ry designation to the ALARA Committee, the senior C/AP Technician automatically becomes the ALARA co-ordinator, tasked with providing ALARA assistance.to
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F-11-the Supervisor - Chemistry & Radiation Protection.
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.10.2 bes14hhtb.* hh' ihaiiriabalT t6: Eill:. thb' vhbaht! ALARA' Co-ordinatbr p6sition - At the time IE Inspection Report 81-21 was in progress, Mr. Joe Mattice was the desig-nated ALARA Cocrdinator.
He was promoted to Plant Health Physicist effective January 1, 1983.
He was the ALARA Coordinator until December 16, 1982, when Mr. Craig Crawford was appointed the ALARA Coordinator by assignment as the Health Physicist on the ALARA Committee.
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10.3 Ektiblikh:~ >f66E8brbh.'thht.' pr6 Vide; f6rY {hU per16dic ana: comprb ibnsikb! mhhht ement; assbssmbht: 6fi the' ALARA progrhaf performance; anc (bb batablishmbntl 6f' ALARA gbklsi for. P6rt." Chlh6bn; Sthtion' activitleks inv61ving rh63nhetivb: Wheths',: pers6nnb1 c6nthminationsi.' bmbloyeh
[E3us:thaihti6h!bxpohbres',;rehpiratory:pt6tectibn:use freuvency, and other activities involving exposure to radioa6tive materials or control of radioactivity -
Fors'Calhodn~Sta61od'S6anding Order G-50,which is an
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administrative procedure, specifically states that an annual ALARA report, which evaluates the success and 5tatd5 of the ALARA program shall be provided.
The District notes that Regulatory Guide 8.8 states a
" data base is not available" presently and that the
" criteria for meeting 10 CPR 20.l(c) takes the form of qualitative guidance (e.g., goals, objectives, and statements of good practice).".The District issued its 1983 ALARA goals per memorandum dated December 10, 1982 (EP-82-329).
The ALARA goals pertain to indi-vidual radiation exposure reduction and collective radiation exposure as recommended by Regulatory Guide 8.8, as well as to refueling activity; radioactive gaseous, liquid and solid wastes reduction; program effectiveness; and program documentation.
The Dis-trict believes its goal. projections are commensurate to the proposed list.
The District believes its ALARA program meets es-sential requirements presently, that no open items exist, that improvements based on program experience may be adopted, and that it is currently is in full-compliance.
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11.0 Open Item (285/8128-03):
Evaluation of Contract HPl Technicians - This item wa5' discussed in NRC'In-spectiod Report No. 50-285/81-28 and' involved the licensee's' failure to establish procedures that pro-vided guidance in-evaluati g the work experience'ofL
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contract HP-technicians. :the_ licensee's procedures to resolve this item.do'not agree with the NRC staff posi
tion on accounting of hours worked for each year of x
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See Section 7 for details.
This item (285/8128-03) is still considered open.
Response In response to Open Item 285/8128-03, the District prepared and issued procedure HP-16, " Selection of Contract Health Physics Technicians", on January 14, 1982.
This action was performed in accordance with the best available information, including ANSI N18.1-1971.
The District believed this item to be closed by this timely action.
The acquisition of 4,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> work experience within at least a 66 week period is in accordance with normal national work practices for contract personnel who generally work between 60 and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per week.
The promulgation of NRC Generic Letters 82-02 and 82-12 document an NRC position that 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> work weeks are sanctioned.
Prior to receipt of IE nspection Report 82-30 on March 23, 1983, the District was unaware that the NRC had established a new NRC position.
The District believes that it conforms to nationally accepted recommendations for selection of contract HP Technicians by the present HP-16 criteria and considers our exist ing procedures to be adequate.
12.0 Open Iten (285/8230-02):
Radiation Protection Manager (RPM) Qualifications - wit 6661didg'fr6m'public dis-closure requested by District's letter dated April 15, 1983.
Response Technical Specification 5.3.1 states:
"The SCRP shall meet the requirements set forth in Regulatory Guide 1.8 dated September, 1975 entitled
" Personnel Selection and Training."
The SCRP is considered to meet the educational and experience qualifications set forth in Regulatory Guide 1.8 with at least five years of experierce in applied radiation protection and extensive formal training in radiation protection."
The District has interpreted the first sentence to establish the documentary reference for the SCRP qualifications and the second sentence to define an acceptable criteria for application of'the Regulatory Guide.
The first evidence of a conflicting NRC position surfaced during the 82-30 NRC inspection and was followed by an unofficial' transmittal of an internal NRC document during the 83-06 radwaste inspection on March 7-11, 1983.
The District was unaware of'any conflicting NRC position on January 1,1983 ' when - the present SCRP appointment became effective.
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In addition, the District believes all official, industry-wide distribution of information pertinent to licensees should be made in sufficient time for inclusion into important affected decisions.
The District believes the appointment of its present SCRP conforms to of ficial regulatory requirements.
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s independently of the computer calculation. Documen-under which the system will N operated. These flow
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tation of the program should include a description of rate devices should be recalibrated periodically.
( 6 Guidelines for the documentation of digital computer the algorithm and a current listing of the program.
Whenever Practicable, a check source that is ac-programs are given in ANSI N413-1974 (Ref. 29).
tuated remotely should be installed for integrity
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checks of the detector and the associated electrical 7. Quality Control for Continuous Effluent system.
Monitoring Systems 8. Review, Analysis, and Reporting Data The specified frequency of calibration for a par-Procedures for review, analysis, and reporting of ticular system should be based (r. considerations of the data should include examinations for reasonableness nature and stability of that system. For nuclear power and consistency of the data and investigative and plants, specific requirements for calibrations and corrective actions to be taken under specified
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checks of particular effluent monitoring systems usu'
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c reumstances.
ally are included in the technical specifications for the plant.
9. Audits Initial calibration of each measuring system should Planned and periodic audits should be made to ver-
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be performed using one or more of the reference ify implementation of the quality assurance program.
standards that are certified by the National Bureau of The audits should be performed by qualified indi-Standards or that are calibrated by a measurement viduals who do not have direct responsibilities in the
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system * hat is traceable to that of the National Bureau areas being audited.
of Standards (Ref. 27). For nuclear power plants, Audit results should be documented and reviewed these calibrations are usually repeated at least annu.
by management having responsibility in the area au-
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ally. The radionuclide standards should permit calib-dited. Followup action, including reaudit of deficient rating the system over its intended range of energy
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areas, should be taken where indicated.
and rate capabilities. Periodic inplant calibration should be performed using a secondary source or D. IMPLEMENTATION method that has been related to the initial calibration.
I For nuclear power plants, these calibrations are usu.
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Mi ally performed at least monthly.
tion to applicants and licensees regarding the NRC staff's plans for using th,s regulatory guide.
i Periodic correlations should be made during opera-
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tion to relate monitor readings to the concentrations This guide reflects current NRC staff practice.
Q and'or release rates of radioactive material m, the PP monitored release path. These correlations should be cant or licensee proposes an acceptable alternative m
method, the staff will use the method described
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based on the results of analyses for specific radionuc-5.M %'N.
lides in grab samples from the release path.
herein in evaluating an applicant's or licensee's ca-
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pabili:y for and performance in complying with spec-
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Flow-rate measuring devices associated with the ified portions of the Commission's regulations until t.g cf system should be calibrated to determine actual flow this guide is revised as a result of suggestions from G E-m rates at the conditions of temperature and pressure the public or additional staff review.
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4.15-7
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