IR 05000285/1988034

Insp Rept 50-285/88-34 on 881016-21.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program Activities Associated W/Current Refueling Outage & Allegations Re Conduct of Radiation Protection Program

ML20206L478
Person / Time
Site:	Fort Calhoun
Issue date:	11/14/1988
From:	Baer R, Chaney H, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206L476	List: IR 05000285/1988034 ML20206L471
References
50-285-88-34, NUDOCS 8811290580
Download: ML20206L478 (11)

Text

- ' '

,

's

.

'

APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/88-34 Operating License: DPR-40 Docket: 50-285 Licensee: Omaha Public Power District (OPPD)

1623 Harney Street Omaha, Nebraska 68102 Facility Name: Fort Calhoun Station (N'*)

Inspection At: FCS, Fort Calhoun, Washington County, Nebraska Inspection Conducted: October 16-21, 1988 Inspectors: Mk H. D. Chaney, Senior Radiattor. Specialist Date

'

Facilities Radiological Protection Section blau2 mow L. T. Ricketson, Radiation Specialist HMM Date '

Facilities Radiological Protection Section

,

Approved: _ blN Dhte /

'

.

M R.Protection E. Baer, Chief, SectionFacil'ities Radiological Inspection Summary

! Inspection Conducted October 16-21, 1988 (Report 50-285/88-34)

,

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program activities associated with the current refueling outag Two allegations concerning the conduct of the licensee's radiation protection program were also reviewe Results: Within the areas inspected, no violations or deviations were identifie $

t

,. - - , . . - , _ . - - _ , _ - . , , _ , - - - . . - - , ,

. '.

.

DETAILS Persons Contacted OPPD

• K. Morris, Division Manager, Nuclear Operations A. Bilau, Radioactive Waste Coordinator

• J. Bobba, Supervisor, Radiation Protection (RP)

• A. Christensen, Field Health Physicist (HP)

R. Cords, Radiation Protection Technician (RPT)

C. Crawford, Respiratory Protection Specialist

• J. Fisicaro, Supervisor, Nuclear Licensing and Regulatory Affairs

• S. Gambhir, Division Manager, Production Engineering

• Gates, Manager, FCS

• L. Gundrum, Onsite Nuclear Licensing Engineer

• D. Jacobson, Supervisor, Chemistry and Radiation Protection (CRP) Training

• A. Richard, Manager, Quality Assurance and Quality Control (QC)

B. Shubert, Systems Engineer

• C. Simmons, Onsite Nuclear Licensing Engineer

• K. Steele, Health Phytics Special Services Coordinator

• M. Tesar, Supervisor, Technical and General Employee Training C. Williams, Senior ALARA Technician Others

• P. Harrell, NOC Senior Resident Inspector

• T. Reis, NRC kssident Inspector J. Ferguson, Westinghouse Radiological Support Division, Project Coordinator

• Denotes those persons present at the exit interview on October 21, 198 In addition to the above noted individuals, the NRC inspectors contacted other licensee and contractor personnel during the inspectio . NRC Inspectors' Observation An NRC inspector's observation is a matter discussed with the licensee dur;ng the exit intervie Observations are neither violations, deviations, nor unresolved items. They have no specific regulatory requirement, but are suggestions for the licensee's consideratio Respiratoy Protection Equipment (RPE) _ Inspection - Personnel do not routinely inspect the condition of RPE at the point of issu However, the NRC inspectors noted that personnel were properly inspecting RPE prior to entering areas requiring RPE located within the radiologically controlled are J

_

,: .

. .

'

3 Followup on Previous Inspection Findings (92701)

i (Closed) Violation (285/8805-01): HP Technician Qualification - This item was previously discussed in NRC Inspection Report 50-285/88-05 and

,

involved the licensee's failure to ensure that HP technicians received ,

requalification training as required by facility procedure The NRC inspectors examined the licensee's implementation of the corrective actions committed to in their June 3,1988, response to the violatio The licensee's corrective actions, identifying and providing retraining to HP technicians with lapsed qualifications, appear to be adequat (0 pen) Open Item (285/8805-07): RP Staff Organization and Position Descriptions - This item was previously discussed in NRC i

,

Inspection Report 50-285/88-05 and involved the licensee's RP staff  :

organization, firstline supervisor authority, lack of agreement with the

'

-

organizational charts in Section 6.0 of the Technical Specifications (TS),

and the lack of accurate position descriptions for RP staff position The NRC inspectors examined the licensee's corrective actions

,

as committed to in the July 6,1988 (LIC 88-514), response to the NRC's concerns. The licensee had completed the submittal of a TS change request, creating two new departments (RP and Chemistry) and developed interdepartmental technical groups within the RP department. The NRC

, inspectors reviewed the staffing alignment of the RP department, including

,

supervisory assignments, and examined the licensee's newly developed  ;

position descriptions for each RP department position. The position  !

descriptions were found to adequately describe each staff position's responsibilities and functional responsibilities. These position descriptions were in draft form and had not been approved by OPPD management. This item will remain open pending licensee management

approval of the RP department position description ;

. l (Closed) Open Item (285/8805-10): Plant Systems Training - This item was previously discussed in NRC Inspection Report 50-285/88-05 and involved t i the licensee's lack of a formal RPT training program for plant system The ,

.

'

NRC inspectors examined the licensee's implementation of a plant systems  !

training program for RP technicians in the Master Training Plan as  !

committed to in the licensee's July 6,1988, response to this concern.

The licensee's actions adequately resolved the NRC's concerns regarding

,

this ite (0 pen) Open Item (285/8805-13): Respiratory Protection Program - This

'

item was previously discussed in NRC Inspection Report 50-285/88-05 and involved the lack of an adequate RPE training and use program. The NRC  !

d inspectors examined the licensee's new RPE training program for agreement ,

with the recommendations of NUREG-0041 and NRC Regulatory Guide (RG) 8.1 ,

4 The 1RC inspectors noted that RP and Training Department personnel had  !

been provided special training in respiratory protection practices ,

including applicable regulations. The NRC inspectors also verified that i the licensee had designated a person to be responsible for the FCS .

! respiratory protection program and had developed a written policy I 1  !

,

e e-- -

- - - - - , , - ,,,,,.,r ,,v,-,m, m,--,,,-,,,---,wmar-=w

-

~ ~ ~ ~ ~ =

. .

. .

'

statement regarding RPE usage (Standing Order T-11). This item will remain open pending licensee completion and implementation of procedures addressing repair and maintenance of RPE, inventory and issuance of RPE, and overall consolidation and upgrading RP program procedure . Occupational Exposure During Extended Outage (83729) Advance Planning and Preparations The NRC inspectors examined the licensee's preparations for the 1988 refueling outage. Licensee planning activities for this refueling outage was also discussed in NRC Inspection Report 50-285/88-30. The outage began on September 27, 1988, and is expected to last 77 day The NRC inspectors were specifically interested in jobs that involved RP activities such as auxiliary building and reactor containment decontamination, high radiation area and hot spot identification and elimination, primary side steam generator breaching and nozzle dam installation, secondary s'de steam generator sludge removal and inspection, removal and shipment of two reactor coolant pump electric motors, and reactor vessel head removal. The NRC inspectors held diccussions with containment outage coordinators and HP personnel implementing the ALARA program. Scheduling of work activities for the 77-day outage were also reviewed. The NRC inspectors attended licensee meetings for scheduling and planning of work activitie All departments were well represented at the twice daily meeting Due to security badging limitations for vital area access, the licensee was unable to supplement the RP department staff with the incended number of contract RPTs and radwaste support personne All station organizations are being affected by the access badging limitation Howeser, the licensee appeared to have a sufficient staff to support the work schedule Currently the RP staff, including contractors, are working 12-hour days to support the outage. Scheduled days off for personnel will be used to comply with TS 5.2.f requirements on maximum hours of work for personnel performing safety-related function No violations or deviations were identifie Staffing, Qualifications, and Training The licensee's staffing, qualifications, and training programs were inspected for compliance with the requirements of TS 5.3.1 and 5.4; and the recommendations of Industry Standard ANSI N18.1-197 The NRC inspectors discussed with the licensee the current status of staffing for the support of the RP department and the hiring of a permanent RP Supervisor. These matters were previously discussed in NRC Inspection Report 50-285/88-3 _

. _ _ _ . - _ _ _ . - _ . _ . ___ - _ - -

.

. .

,

.

The NRC inspectors examined the qualifications and training provided prospective contract RPTs, held discussions with HP technicians covering radiolonical work operations, and observed their work practices. All technicians appeared to be qualifiec for their functional assignment The NRC inspectors examined testing protocols for screening contract RPTs. An allegation concerning such testing is discussed in paragraph 5 of this repor No violations or deviations were identifie c. ALARA The NRC inspectors ir.spected the licensee's ALARA program to determine agreement with the recommendatien of NRC RGs 8.8 and 8.10 and adherence to FCS procedures and directive The licensee had established radiation exposure goals for the refueling outage that involved reactor coolant pump work, steam generator inspection and repair, refueling, and other work evolutions which would require significant radiation exposure to personnel. The NRC inspectors noted that the licensee had performed extensive mockup training for certain work evolutions within containment and had established mandatory prework briefings for workers and supervisor The licensee was monitoring work progression closely and would stop work and *egroup personnel when problems were encountered that could not be resdily resolve The licensee's prework briefings were well attended and included use of photographic slides for worker orientatio The licensee's use of filtered ventilation in work areas was reviewed and found to reduce the levels of airborne radioactivity in work area The licensee had established a collective personnel exposure gool of 276 person-rem for the 1988 outage. As of October 21, 1988, the licensee had expended approximately 130 person-rem (based on self-reading pocket dosimeter readings).

d. External Radiation Exposure Control The licensee's external radiation exposure control program was inspected to determine agreement with the requirements of TS 5.11; and 10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203, 20.205, 20.206, 20.405, 20.407, 20.408, and 20.40 The NRC inspectors reviewed personnel radiation exposure records that included radiation exposure history, quarterly radiation e gosure records, authorizations to exceed administrative exposurs limits, whole body counting analysis results, dosimetry diser r ncy reports, skin contamination reports and exposure analysis resu;..s, record of QC review, letters from previous employers that verify personnel

_

_ _ _ _ _ _ _ _ _ _ _ __

.. . .

. .

.

exposure status, and exposure termination reports. The NRC inspectors noted that the licensee had implemented tighter controls over the personnel exposure extension authorizations than were practiced in the pas In lieu of a general extension for all personnel to 2400 millirem per quarter during the outage, the licensee now controls any exposure greater than 1000 millirem per quarter during the outage by supervisor / management approval of exposure extensions on a case-by-case basis. .an y extension requires a dosimetry records verification on past exposure histor The NRC inspectors also reviewed surveys of radiation and high radiation areas, issuance and placement of multiple dosimetry on personnel, extremity dosimetry use, access control over high and very high radiation areas inside and outside of the reactor containment, shielding placement and removal controls, use of alarming dosimeters for exposure control, and dose tracking and stay time controls for high dose rate work. The NRC inspectors discussed with licensee representatives the results of their evaluation involving protection factors afforded personnel by protective clothing when exposed to beta radiation inside of major plant components, and nnted that the licensee was controlling personnel stay times in the primary side of the steam generators based on the beta radiation exposure levels to personnel. The NRC inspectors also verified that the exposure controls for very high radiation areas were adequate. The licensee's use of rope barriers and flashir; ifghts for denoting very high radiation areas within containment was considered conservativ No violations or deviations were identifis e. Internal Radiation Exposure Controls ,

I

'

The licensee's program for control of internal exposure was inspected

! to determine compliance with the requirements of 10 CFR Part 20.103 l and the recommendations of RG 8.15 and NUREG-0041.

l The NRC inspectors reviewed RPE maintenance, cleaning, decontamination, inspection, issuance, and return activitie The licensee's u*e of continuous air monitors and grab air samplers l l was reviewet The licensee's use of administrative limits for l controlling personnel exposure to airbornt radioactive materials, methods for collecting and analyzing air samples, tracking personnel exposures, and filtered exhaust ventilation systems was also reviewed. The NRC inspectors noted that the licensee frequently utilized lapel type breathing zone air samplers for evaluation of airborne exposures by personnel. The NRC 1aspectors also reviewed whole body counting results for personnel suspected of having incurred an uptake of radioactivity. The NRC inspectors noted that the licensee was effectively controlling airborne radioactivity to ALARA level _-

. .

. ,

'

The NRC inspectors examined the circumstances surrounding the removal of a contract boiler maker from the site by ambulance at approximately 9:30 p.m., on September 20, 1988, following his completion of work installing nozzle dams in the prim.ry side of Steam Generator B. The worker had been wearing an air-line hood for respiratory protection and dressed in multiple la.i ers of protective clothing. Upon exiting the steam generator, the vorker exhibited disorientation and complained of chest pain.. An onsite emergency firstaid technician provided initial aid to the worker and requested he be sent immediately to a hospita The licensee declared a

"Notice of Unusual Event" per the Radiological Emergency Plan and transporteo the worker to the emergency plan designated hospita Radiological controls were implemented by FCS and the Omaha, Neb-aska, hospital to protect ambulance and emergency medical personnel due to the worker being transported in his inner cloth protective clothing

which normally contains low levels of fixed residual contaminatio l The licensee's radiological controls were sufficient to preclude the spreading of radioactive contamination or radiation exposure to personnel during the transport and care at the Omaha, Nebraska, hospital. The worker's condition was stabilized and he was held for

, further observation. The NRC inspectors examined the licensee's records concerning the medical physical given the subject worker

prior to allowing him to train, test, and qualify for respiratory

. protection use. The worker had praviously worked at FCS and other facilities, and was a frequent user of RPE. The licensee's physical j examination program and protocol for approving personnel to use RPE

,

appears to follow the recommended guidance of Section 7.4 of

NUREG-0041.

The NRC inspectors also reviewed the circumstances surrounding two personnel involved in a heat stress incident at FCS on September 27,

,

'

1988, while working in full face air purifying respirators and plastic protective clothin The workers had overworked themselves l without regard to the high temperatures of the work area (estimated i to be between 95-130*F). The workers were overcome by heat stress

! less than an hour after leaving the work area and were transported to

! the Blair, Neoraska, hospital for observatio The NRC inspector; i noted that the licensee had implemented actions to bring to the

attention of workers, at prework briefings, the necassity to be aware

of possible heat ; tress situations and had obtained special cooling l vest The licensee is also developing a more comt rehensive heat stress awareness and control progra No violations or deviations were identified.

, f. Posting, Labeling, and Worker Controls l The licensee's program for control of workers, radiological posting

! of areas, and the labeling of radioactive materials (RAM) was

'

inspected for compliance with the requirements of TS 5.11 and 10 CFR l Parts 19.12, 20.203, 20.205, 20.207, and 20.301.

a

. ..

,

.

,

The NRC inspectors rev ewed the posting of RAM, radiation, high radiation, airborne radioactivity, and low dose rate areas. The NRC inspectors reviewed material release logs, control peint logs, and verified that control point technicians had reaoy access to radiation work permits (RWP). The NRC inspectors noted that the licensee routinely surveyed materials and spaces for alpha radioactivity as well as beta / gamma radioactivit Licensee surveys have not detected any alpha or significant hot particle Selected RWP were reviewed and work activities observed (steam generator nozzle dam installation). The NRC inspectors observed worker activities and performed confirmatory radiation level measurements of plant area No violations or devi i tions were identifie Control of RAM, Contamination, and Radiological Monitoring The licensee's programs for the control and survey / monitoring of RAM were reviewed for compliance with the requirements of TS 5.11 and 6.12; and 10 CFR Parts 19.12, 20.4, 20.5, 20.201, 20.203, 20.205, 20,207, 20.301, 20.401, and ?0.40 The NRC inspectors examined the licensee's radiological survey program involving prework/RWP review, ongoing work activities, storage areas, change rooms, lunch and meeting rooms, contractor service facilities, radiological control points, and material being released from radiologically controlled areas. The NRC inspectors i also reviewed the control exercised over RAM transferred to onsite vendor / contractor facilities for testing, decontamination, or maintenance. Temporary work areas and control points established inside reactor containment and auxiliary building were inspecte The NRC inspectors inspected radiological work controls and operations involving reactor vessel head, reactor coolant pumps, equipment decontamination, steam generator (primary side) inspection and ripair, and inspection and maintenance of the steam supply syste1. Confirmatory radiation level measurements were performed on selec;ed areas, including components of both the reactor coolant systen and steam supply system. All results agreed with documented survtys performed by the licensee. The licensee's radiological controls for work operations appear to effectively control personnel expr,sure to RAM and material removed from system '

No violations or deviations were identifie . Allegation Followup (99024) An anonymous allegation (88-A-0074) was .eceived in the NRC Region o*fice en September 24, 1988, concerning contract RPTs. The allegers concerns were:

(1) A certain group of RPTs were given approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of preparatory training prior to being given the FCS contract RPT screening exa . _ _ _ . _ _ _ . _ _ . --_ . - _ _ _ - - _ _ -

,.,

. .

_

.

. Discussion: After a group of contract RPTs (supplied by a particular vendor in August 1988) experienced a high failure rate vhen administered on RPT knowledge screening test, the licensee contracted with enother vendor to supply additional contract RPTs in order to rnet outage support requirement The licensee's testing and d'squalification of a number of the August 1988 crew of contract RPTs was the subject of an NRC Region IV Daily Staff Note, dated August 11, 1988. The NRC 4.spectors noted that the licensee's RPT screening test was typical of that found in routine use at other NRC Region IV facilitie Finding: The allegation was substantiated. The vendor did offer refresher training to those prospective RPTs that wanted it and subsequently held the training on various dates in an Omaha, Nebraska, hotel room. This refresher training was conducted prior to the licensee adrainistered testing. The licensee did not knowingly provide technical support for the refresher training or conduct it. Vendor offering of refresher training to their personnel is a common practice and does not violate any NRC regulation (2) This same group of RPTs were given specific or similar questions found in the licensee's HP knowledge screening test before the tes Discussion: Licensee representatives did not rule out the fact that previous licensee prepared contract RPT screening tests may have been obtained by the vendor. However, the licensee's training department frequently revised the RPT screening test (via substitution of different questions and a reordering and phrasing of the questions). The Itcensee also controls tests and testing materials in recordance with station procedures that are designed to protect the integrity of the test The licensee had produced approximately 10 revisions to the contract RPT knowledge screening test. These revisions were administered at various times during the period August 8 through October 3, 1988. During interviews with two of the more senior contract RPTs, the NRC inspectors determined that the contract RPTs had produced, on their own, typical RPT knowledge test questions for use during the refresher training session These questions / tests were developed by personnel experienced with developing similar tests for licensees in other NRC regions. The NRC inspectors noted that even 10 CFR Part 55 reactor operator qualification tests are publicly available for use and are used frequently by NRC licensees in preparing prospective reactor operator candidates for NRC licensin Finding: The allegation was substantiated. There does not appear to have been any improprieties committed by either the vendor or the licensee.

I

.

'

. .

(3) The hired contract RPTs are unqualifieo for the functional positions they cccupy at FC Discussion: Approximately seven sen19r and five jur,1or contract HP technicians were interviewed and observed dcring this inspection. None were found to be unqualifiei for the functioral positions they occupie Finding: This allegation was not substantiated, b. Approximately 13 separate allegations (88-A-0076) were received from an alleger on September 29, 1988, regarding the adequacy of the RP program at FCS. Summarized, the allegations involved personnel control (esting and drinking) adjacent to radioactively contaminated areas; qualification of certain RP program personnel (two instances);

licensee coverup of situations that should be reported to the NRC; possible overexposures of personnel; contract RPT supervision; RPT contamination control practices; and OPPD's fai;ure to fulfill commitments made to the NRC and INP The NRC inspectors reviewed each of the allegor's concern Discussion: The NRC inepectors observed some of the allegers concerns such as wearing protective clothing in a clean area (one instance), eating and drinking adjacent to a contaminated area (laundered protective clothing issue and exit portal monitors),

employing a weak respirator issuance program (reported in NRC Inspection Report 50-285/88-05 a, Open Item 285/8tJ5-13), and using marginal contan'ination control practices when exiting a control are The NRC inspectors observed one instance of an RPT who passed a radiologically controlled area boundary (HP office hallway to auxiliary building Corridor 26 door way) and then reinserted one foot back into the clean area of the HP hallwa The event was also noted by other RPTs in the immediate aret and was sufficiently responded to with surveys and admonishment of the RPT. The subject RPT was noted by the NRC inspectors to have been sufficiently preoccupied with other matters that he evidently forgot that he had, even though briefly (few seconds /one step), passed the radiological control boundary. Based on several days of observation by the NRC inspectors in which there were no other such occurrences, the aforementioned examples are considered to be isolated events and are not indicative of a significant problem with the licensee's contarnination control or procedural compliance orogram The NRC inspectors could not determine that the licensee had failed to inform the NRC of reportable incidents or overexposures of personnel to radiation / radioactivit The NRC inspectors determined, from interviews with the NRC resident inspector, that the allegers concerns regarding reporting incidents and possible overexposures were not based on any definite occurrence but rather on conjecture th?t any plant that had been running as long as FCS should have experienced an overexposure. The NRC inspectors determined that the l

.s .

. . .

"

licensee had been following commitments made to the NRC regarding implementing improvements in the RP program (see NRC Inspection Report 50-285/88-30) and had been keeping the NRC sufficiently informed of the results and of any changes in the implementation of their improvement program (FCS Radiological Improvement Project)

which resulted from the inspection findings discussed in NRC Inspection Report 50-285/83-0 Finding: Three Allegations: wearing protective clothing in nonradiological controlled area, eating and drinking in the vicinity of a radioactively coc.taminated area, and lax contamination control practice by a RPT were substantiated. The NRC inspectors did not identify any licensee violations of NRC regulations or any significant breakdown in the licensee's RP program that had not already been brought to the attention of OPPD management by NRC inspectors or OPPD auditor . Radioactive Material Transportation Program (86721)

The licensee's preparations, packaging, records, loading, securing, placarding, and hbeling of two large, radioactively contaminated reactor coolant pump drive motors, which contained approximately 560 microcuries total radioactivity, for rail shipment were examined for compliance with the requirements of 10 CFR Part 71.49 and 49 CFR Parts 171 through 17 The NRC inspectors examined the licensce's shiptrent by rail (including the highway shipment to the rail head) of two reactor coolant pump motors (RCP 3C and 30) to Memphis, Tennessee (Hake Associates, Agreement State License No. R-9671J8) for refurbishment. The NRC inspectors noted that the licensee shipped the motors via sole use, low specific activity consignment with a railroad compan Review of shipment documentation (88-15, 88-16, and 88-17), visual inspection of the packaging and bracing, and confirmatory radiation and contamination measurements were conducted by the E inspectors. Radiation and loose contamination levels were in agreement with the licensee's surveys and placarding / labeling were found satisfactor No violations or deviations were identifie . Exit Interview The NRC inspectors met with licensee representatives identified in paragraph 1 at the conclusion of the inspection on October 21, 1988. The NRC inspectors summarized the scope and findings of the inspection.