IR 05000285/1987016

Insp Rept 50-285/87-16 on 870622-26.Violations Noted.Major Areas Inspected:Radiation Protection Program,Including External Occupational Exposure Control & Personal Dosimetry & Internal Exposure Control & Assessment

ML20237K376
Person / Time
Site:	Fort Calhoun
Issue date:	08/14/1987
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237K366	List: IR 05000285/1987016 ML20237K364 ML20237K369
References
50-285-87-16, IEIN-80-22, IEIN-82-36, IEIN-82-49, IEIN-83-14, IEIN-83-49, IEIN-83-67, IEIN-84-15, IEIN-84-40, IEIN-84-59, IEIN-84-75, IEIN-85-042, IEIN-85-060, IEIN-85-42, IEIN-85-60, IEIN-86-018, IEIN-86-024, IEIN-86-042, IEIN-86-076, IEIN-86-18, IEIN-86-24, IEIN-86-42, IEIN-86-76, NUDOCS 8708190227
Download: ML20237K376 (7)

Text

{{#Wiki_filter:4 ' APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/87-16 License: DPR-40 Docket: 50-285 Licensee: Omaha Public Power District (0 PPD) 1623 Harney Street Omaha, Nebraska 68102 Facility Name: Fort Calhoun Station (FCS) Inspection At: FCS Site, Blair, Nebraska Inspection Conducted: June 22-26, 1987  ! InFpector: l ji t YN4Lt1/q ?' G/lY/#?

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R.' E. Baer, Radiation Spptialist, facilities Date RadiologicalProtectpnSection Approved: [[Ap fdddyr _k B. Murray, Chief, Facil,4f ties Radiological Date Protection Section F Inspection Summary Inspection Conducted June 22-26, 1987 (Report 50-285/87-16J Areas Inspected: Routine, unannounced inspection of the radiation protection program including: external occupational exposure control and personal l dosimetry; internal exposure control and assessment; control of radioactive j materials and contamination, surveys, and monitoring; facilities and equipment; ! and the licensee's action concerning certain NRC Inspection and Enforcement l Information Notices (IEIN). An allegation was also reviewe Results: Within the areas inspected, two apparent violations were identified (failure to follow procedures and failure to submit a special report, see paragraph 6).  ;

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DETAILS Persons Contacted OPPD

   * L. Andrews, Division Manager, Nuclear Production
   * G. Gates, FCS Plant Manager A. Bilau, Radwaste Coordinator
   * J. Brunnert, Supervisor, Operations Quality Assurance R. A. Cords, Chemistry / Radiation Protection (C/RP) Senior Technician S. Dixon, C/RP Senior Technician L. L. Gundrum, Supervisor, Nuclear Engineering
   *M. K. Hawes, Dosimetry Specialist B. P. Hearty, Dosimetry Assistant
   *K. R. Henry, Supervisor, Corporate Quality Assurance
   *R. L. Jaworski, Section Manager, Technical Services T. P. Matthews, Engineering Aide, Licensing
   *J. M. Mattice, Plant Health Physicist
   *D. J. Munderloh, Senior Engineer, Nuclear Regulatory and Industrial Affairs
   * L. Roach, Supervisor, C/RP
   * K. Stultz, Supervisor, Radiological and Environmental Monitoring Services
   * A. Tesar, Supervisor, Training Services

, T. E. Thompson, C/RP Senior Technician l T. W. Thompson, C/RP Senior Technician Others

   *P H. Harrell, NRC Senior Resident Inspector The NRC inspector also interviewed other licensee and contractor employees including C/RP, operations, administrative, maintenance, and training personne * Denotes those individuals present during the exit interview on June 26, 198 . Licensee Action on Previously Identified Inspection Findings (Closed) Violation (285/8632-01): Failure to Follow Procedures - This item involved the failure of personnel to wear the protective clothing specified on a radiation work permit for entry into the radiologically controlled area. The licensee had revised the method for designating clothing requirements and entry into the clean portion of the radiologically controlled area. Violation (285/8632-01) is considered close _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - -  --     a

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1 3. Inspector Observation q a The following are observations the NRC inspector discussed with the ) licensee during the exit interview on June 26, 1987. These observations are not violations, deviations, unresolved items, or open items. These observations were identified for licensee consideration for program improvement, but the observations have no specific regulatory requiremen J The licensee stated that the observations would be reviewe J Inspection and Enforcement Information Notice (IEIN) File For Radiation Protection Reference - A reference file of applicable IEINs had not been established to provide easy access for C/RP technicians for this type of informatio Thermoluminescent Dosimeter (TLD) System - The two element TLD used at FCS does not provide a high degree of accuracy for determining ! both shallcw dose and deep dose exposure . Program Areas Inspected The following program areas were inspected. Unless otherwise noted, the inspection was completed and revealed no violations, deviations, unresolved items, or open items. Notations after a specific inspection l item are used to identify the following: I = item not inspected or only partially inspected, V = violati]n, D = deviation, U = unresolved item, and 0 = open ite : Procedure Inspection Requirements

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83724 External Occupational Exposure Control and Personal ' Dosimetry 02.01 - Audits and Appraisals (I) 02.02 - Program Changes 02.03 - Planning and Preparation for Outages 02.04 - Personal Dosimetry (see paragraphs 7 and 8 for specific' details) 02.05 - Administrative Controls  ; 02.06 - Records, Reports, and Notifications i 83725 Internal Exposure Control and Assessment 02.01 - Audits and Appraisals (I) 02.02 - Program Changes 02.03 - Planning and Preparation for Outages 02.04 - Assessing Intakes of Radioactive Materials 02.05 - Engineering Administrative Controls 02.06 - Respiratory Protection Equipment 02.07 - Records, Reports, and Notifications

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83726 Control of Radioactive Materials and Contamination, Surveys, and Monitoring 02.01 - Audits and Appraisals (I) 02.02 - Program Changes 02.03 - Surveys and Monitoring (V - see paragraph 6) 02.04 - Radioactive Materials and Contamination Controls 83727 Facilities and Equipment 02.01 - Facility Changes 02.02 - Equipment 5. Inspection and Enforcement Information Notices (IEIN) The NRC inspector determined that the following IEINs had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planne I 86-76 86-90 The licensee did not have documentation which indicated the review and

actions taken for IEINs issued before 1980 had been completed, and that l

IEINs 86-103, 86-107, 87-03, and 87-07 wore still in the review cycl . Surveys and Monitoring i The NRC inspector reviewed selected records of radiation and contamination surveys, survey instrumentation calibration and performance tests l performed during 1987 and discussed the results with licensee l representative l Technical Specification (TS) 5.8.1 requires that " written procedures . . . be established, implemented, and maintained that meet or exceed the minimum requirements of Section 5.1 and 5.3 of ANSI N18.7-1972, and Appendix A of USNRC Regulatory Guide 1.33 . . . ." This requirement l _ ___J

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5 i is emphasized in the FCS Operating Manual, Standing Order G-1, which . states: " Strict adherence to the provisions of the Standing Orders is l l mandatory for all personnel." Standing Order T-13, " Quality Control i Program for Chemistry and Radiation Protection Equipment," establishes the minimum schedule for performing calibration and functional check Item 5.2.2(2) requires the.t a functional check of portable survey instruments and friskers be performed daily prior to us The NRC inspector determined on June 23, 1987, that the licensee was not performing a daily functional check prior to use for friskers being used to sort contaminated /non-contaminated waste and monitor tools and equipment being released from the radiologically controlled areas of the plant. The NRC inspector stated that failure to perform a daily l functional check on friskers is considered an apparent violation of } TS 5.8.1 (285/8716-01).

Functional check procedure FCP-HP-1, Radiation Detection Equipment Performance Testing, in Section IV(4)(a) states the Xetex 4158 alarming dosimeters will be performance tested at 64 mr for routine operations or 256 nr for outage / major maintenanc The licensee utilizes the Xetex 415B alarming dosimeters to ensure that personnel do not exceed the daily administrative exposure limits of 100 mrem for routine operations and 300 mrem during outage / major maintenance wor The NRC inspector determined the licensee had performance tested the Xetex 415Bs being used for routine operations during the period June 1-20,1987, at 256 mr and not 64 tr.r as required by procedure FCP-HP-1. Failure to performance test the Xetex 415Bs at the proper exposure level is considered an apparent violation of TS 5. (285/8716-01).

Technical Specification 2.21 states that post-accident instrumentation shall be operable as provided in Table 2-10, and if the required instrumentation is not operable, then the appropriate action specified in Table 2-10 shall be taken. In Table 2-10, Item 2, the Wide Range Noble Gas Stack Monitor, RE-063L, M, and H, require a minimum of one channel for each range be operable. If the inoperable channels are not returned to operable status the licensee is to prepare and submit a special report to the Commission within 14 days outlining action taken, cause of inoperability, plans, and schedules for restoring the system to operable statu The NRC inspector determined on June 23, 1987, that the three channels of the Wide Range Noble Gas Stack Monitor, RE-063L, RE-063M, and RE-063H had been inoperable since May 15, 1987, and that a special report had not been submitted to the Commission. The NRC inspector stated that this is an apparent violation of TS 2.21 (285/8716-02).

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i 7. Personal Dosimetry The NRC inspector reviewed the licensee's TLD program. - The _ licensee caintains their own in-house system. This system is 'a Harshaw 2271 automated TLD system. The licensee uses two TLD elements, Harshaw type TLD-700 for beta and gamma radiation detection. The filtration over element one is approximately 16 milligrams'per square centimeter (mg/cm2) filtration and the second element has approximately 340 mg/cm2 filtratio Neutron dosimetry is provided using two Harshaw type TLD-600 element One element has 328 mg/cm2 of cadmium on each side to filter the thermal neutrons, the other eleme'nt will detect both thermal and fast neutron The licensee does not currently possess personnel dosimetry accreditation from the National Voluntary Laboratory Accreditation Program-(NVLAP) of the National Bureau of Standards. The licensee expects to: receive NVLAP accreditation prior to the February 1988 implementation requirements of 10 CFR Part 20.202(c).

The licensee's quality assurance / quality control program includes the use of spiked quality control badges. Each month 15 spiked badges are processed which have been exposed to beta and gamma radiations, neutron radiation, or gamma radiatio The radioactive sources used to spike these badges are Strontium-90, Cesium-137, and moderated Californium-25 The licensee had a contractor conduct an evaluation of beta personnel , dosimeters at Fort Calhoun Nuclear Generating Station in 1983. This evaluation determined that a four element dosimeter would provide better response to low-energy beta and photons than the current dosimete .] The NRC inspector discussed with licensee representatives that while the present two TLD chip dosimeter used at FCS will meet present regulatory requirements, it can not, with a high degree of accuracy, determine both gamma and beta radiation dose !

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8. Skin Contamination / Hot Particles l l l The NRC inspector reviewed the licensee's program for identifying and =  ! assessing skin dose from contamination / hot particles. Procedures RPP-6,

" Protective Clothing and Respiratory Equipment Cleaning," Revision 12, December 22,1986; HP-11, "Whole Body Frisking," Revision 1, September 27, -;

1985; HP-18, " Personnel Decontamination," Revision 2, March 20, 1986; and HP-18A, " Calculation of Absorbed Dose From Skin Contamination," 4 Revision 0, March 19,~1987, have been implemented to address the above areas, i The NRC inspector discussed with licensee representatives the information discussed in IEIN 86-23, " Excessive Skin Exposure Due to Contamination with Hot Particles." The licensee utilizes a.. personnel contamination  ; monitor (Eberline PCM-7) to monitor personnel exiting the radi.ologically i I-i f r  ! _______________J

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controlled area. The licensee's present computer program does not provide ) for a dose determination over a one cm2 area and at a depth of 7 milligrams per cm2 . The licensee has obtained the computer skin dose assessment program "VARSKIN" and is evaluating the program for implementation. The NRC inspector noted that in Procedure HP-18A the licensee does not routinely provide for a determination of skin dose from contamination unless personnel contamination is greater than 1 millirad or fixed contamination levels greater than 30,000 dpm per 100 square ! centimeters (cm2) on initial monitoring, nor are there any directions for ! the removal and identification of the contamination if it is a small l area (particle).

l ' Allegation (4-87-A-028)

The NRC received an allegation from a former licensee employee who stated l he had not received a whole body count when he was terminated from FC The NRC inspector substantiated the allegation that the individual terminated his work assignment or employment, in the fourth quarter of 1985, without receiving a whole body coun The licensee instructs personnel in the general employee training program that they should obtain a whole body count prior to working in the radiologically controlled area and when their work assignment is completed. The licensee currently has implemented a program which is not documented in station procedures whereby a letter is sent to individuals who exit without a whole body count reminding them that it is OPPD's policy to provide a whole body count and ask them to contact the plant and make arrangements to schedule on Although the NdC inspector substantiated the allegation regarding the lack of a whole body count on termination, there is no NRC regulatory requirement that whole body counts be made of personnel terminating their work assignment with a license No violations or deviations were identifie . Exit Interview The NRC inspector met with the personnel identified in paragraph 1 at the conclusion of the inspection on June 26, 1987. The NRC inspector summarized the scope and findings of the inspectio ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ }}