IR 05000285/1990018

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Insp Rept 50-285/90-18 on 900326-30.Licensee-identified Violation Noted Re Failure of Security Guard to Comply W/ Entry Requirements.Major Areas Inspected:Occupational Radiation Protection Program During Outage Conditions
ML20042G131
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 04/24/1990
From: Baer R, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20042G130 List:
References
50-285-90-18, NUDOCS 9005110125
Download: ML20042G131 (14)


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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-285/90-18 Operating License: DPR-40-Docket:- 50-285 l

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' Licensee: Omaha-Public Power District (0 PPD)

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444 South 16th Street Mall Omaha, Nebraska.68102-2247

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-Facility Name:

Fort-Calhoun Station (FCS)

Inspection At:

FCS site, Blair, Nebraska Inspection Conducted: March 26-30, 1990

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Inspector:

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K. E.:Baer, Radiation Specialist, Facilities Date Radiological Protection Section

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Accompanied By:

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Blaine Murray, Chief, Facilities Radiological Protection

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Section-

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. Approved:

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Nb B.'Mirrray, Chief 7 Facili s Radiological D'a te /

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Protection Section

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t Inspection Summary

' Inspection Conducted March 26-30, 1990 (Report 50-285/90-18)

Areas Inspected:

Routine, unannounced inspection of the occupational radiation

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. protection program during outage conditions.

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1Results: The licensee has developed a well qualified radiation protection and technical support-staff. Technicians are' encouraged to seek registration with the National Registry. of Radiation Protection Technicians and appropriate training has been provided. The licensee maintains an adequate supply of

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calibrated radiation detection equipment to support work activities.

A state-of-the-art thermoluminscent dosimetry system has been accredited and

placed into operation for external radiation exposure determinations.

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The licensee has provided additional work space for the radiation protection and radioactive waste activities which has increased the work effectiveness of the ~ group.-

q Management support and station personnel awareness to the. radiation protection program requirements have ' increased and work groups appear to be communicating with each other. ALARA program goals had been established and ALARA committees are active at both the station and corporate level with strong management i

support evident.

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i Quality assurance audits appear to be directed toward the identification:of.

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. progammatic weaknesses in addition to compliance with established procedures.

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- The licensee has.made a marked improvement to the radiation protection. program.

since the last refueling outage. Within the areas inspected, there was.one licensee identified violation (paragraph 13). One open item is discussed in paragraph 10. No deviations were identified.

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DETAILS

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Persons Contacted OPPD

  • W. G. Gates, Division Manager,-Nuclear Operations
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L'. Andrews, Division Manager, Nuclear Services

  • G. R. Peterson, Manager, FCS
  • J. P. Bobba, Radiation Protection Manager, FCS
  • C, J. Brunnert, Supervisor, Operational Quality Assurance-(QA)
  • M..R. Core, Supervisor, Maintenance
  • D. W, Dale,. Supervisor, Quality Control (QC)
  • F. F. Franco, Hansger, Radiological Health and Emergency Planning
  • J. K. Gasper, Manager, Training
  • S. N. Gebers, Supervisor, Radiological' Services l

L. K. Haskell, Radiological Engineering Coordinator i

R. G. Haug, Supervisor Chemical and Radiation Protection Training i

  • R. L. Jaworski, Manager,. Station Engineering

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  • J. D. Kecy, Supervisor, System Engineering
  • D. L. Lovett, Supervisor, Radiation. Protection Operations

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  • D. J. Matthews, Supervisor, Station Licensing i
  • T. J. McIvor, Manager, Nuclear Projects

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  • W. W. Orr, Manager,,QA/QC
  • R. L. Phelps,. Manager, Design Engineering
  • P. Sepcenko, Superv.isor, Outage Projects
  • R. J. Sexton, Supervisor, Radiological Health and Engineering j

L. D. Sills, Senior QA Lead Auditor

  • C, F. Simmons, Station Licensing Engineer

.K. E. Steele, Radiological Health Coordinator

P. D. Swafford, Supervisor, Radiological Waste Operations i

M. A. Tesar, Supervisor, Technical and Radiation Training i

' *T. Therkildsen,- Supervisor, Nuclear Licensing i

  • J. W.- Tills, Assistant Plant Manager, FCS

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J.'M. Uhland, Supervisor, Radiation Orientation and Emergency

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Preparedness Training i

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L. C. Wigdahl, Supervisor, Technical Training NM

  • P. Harrell, Senior Resident Inspector
  • T. Reis, Resident Inspector The inspector also interviewed several other licensee.and contractor j

employees including radiation protection, chemistry, operations,

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maintenance, administrative, and training personnel.

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  • Denotes those individuals present during the exit interview on March 30,

1990.

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Licensee Event Report (LER) Followup (92700)

(Closed) LER.(285/89-023): On December 11, 1989, a security guard performing an hourly fire watch patrol entered into Room 7, a posted high radiation area,- without a continuously indicating radiation dose rate meter, integrated dose meter, or an individual qualified in radiation protection procedures. This event was discussed in NRC Inspection P.eport 50-285/89-50. The inspector reviewed the licensee's investigation of the incident and the implementation of corrective actions committed to in the LER.

The licensee's root cause analysis appeared to be adequate and the incident was evidently a result of lack of. attention and compliance by a single individual. The licensee took adequate corrective-actions that should prevent a reoccurrence.

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Open Item An open item-is a matter that requires review and evaluation by the inspector, including on item pending specific action by the licensee and a previously identified violation, deviation, unresolved item, and programmatic weakness. Open items are used to document, track, and ensure adequate followup by the inspector.

Open Item Title Paragraph 285/9019-01 Followup Survey of Fuel Transfer Tube

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Inspector's-Observations The following are observations the inspector discussed with the licensee during the exit interview.

Inspector observations are not violations, deviations, unresolved items, or open'1tems. These observations were identified for licensee consideration for program improvement, but have no specific regulatory-requirements.

Department supervisors and foremen-need to increase their efforts to ensure that workers comply with proper work practices (see paragraph 6).

  • Some workers do not receive a termination whole body count (see paragraph 9).

5.

Planning and Preparation The inspector reviewed representative records and discussed outage planning with licensee representatives and observed activities to verify that the necessary planning and preparations, including management support, were being implemented.

The licensee.had sufficient supplies of protective clothing, respiratory protection equipment, radiological survey instrumentation, temporary shielding, and portable ventilation equipment to support outage

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l-5-activities. A health physics (HP) coordinator was assigned to the outage management group to coordinate work activities and ensure that HP personnel were available to support scheduled work.

The radiation protection manager was also assigned as one of the shift outage coordinators.

No violations or deviations were identified.

6.

Organization and Management Controls The inspector reviewed the licensee's organization and management controls to determine compliance with Technical Specification (TS) 5.2 and agreement with the commitments with Chapter 12 of the Updated Safety Analysis Report (USAR).

Organization Significant improvements have been made in the Radiation Protection (RP)

Department during 1988-1990. The staffing level had increased from 22 in 1988 to 55 in 1990.

In addition to the 55 permanent positions, 10 contract decontamination technicians are also included in the RP organization under a long-term contract. The present RP organization has 39 technicians reporting to 12 coordinators that report to 3 rupervisors who in turn report to the supervisor, radiation protection (radiation protection manager). The licensee had established an adequate permanent staff to handle routine plant operations-and, except for decontamination and laundry activities, only relies on contractor support during major outages. The licensee had hired three individuals in 1989 to fill the supervisor positions.

Each of these individuals has a Masters degree in health physics or nuclear engineering along with several years of RP experience at power reartors. The turnover rate within the department had been low; only two individuals had left the department since 1988.

The RP program. received strong management support. This support had been demonstrated by the increase in staffing positions, the purchase of new state-of-the-art instruments and equipment, and the construction of new RP office and work facilities. Good working conditions exist between the RP department and other departments such as operations, maintenance, engineering, and training. The Rp department had taken the lead to establish good lines of communication with other departments. The RP department plays an active role in the review of planned plant activities.

For example, during the 1990 refueling outage, the supervisor, radiation protection filled one of the shift outage coordinator positions.

Management Controls Audits and Appraisals The. inspector reviewed audits and appraisals related to the RP program.

The inspector examined audits and surveillances performed by the Nuclear Services Division during 1987-1990, the 1988 and 1989 external I

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-6-evaluations, and a special audit conducted by a consultant in 1989. The specific documents reviewed are listed in the Attachment to this report.

i The inspector also reviewed audit plans and checklists used by the Nuclear Service Division in preparation for audits of Rp activities.

The Nuclear. Services Division had performed comprehensive, performance

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based audits.. In 1989, the division hired an auditor with about 8 years of health physics experience in order to improve their technical expertise in the RP area.

In addition to the new auditor with health physics experience, the licensee had also included a consultant with extensive health physics experience as a team member for-the 1990 audit of the RP program..-The licensee's audits were designed to verify that work was f

performed in accordance with approved procedures and the auolts also included comments concerning areas where program improvements could be made. The RP department had responded to the audits findings in a timely manner and their responses appeared to properly address the identified problem areas.

Radiological Occurrences / Incidents The inspector reviewed selected radiological occurrence reports and radiological incidents for 1989 and 1990 which document the identification-and resolution of radiological problems.

These problems usually involved workers that failed to follow-radiation work permit conditions, skin and-clothing contaminations events, and the feilure of workers to follow good radiclogical. work practices. The RP department had established a-

comprehensive program for the identification, tracking, and resolution of

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problem areas. The inspector noted that strong disciplinary actions had been taken with serious problems and with workers that were repeat offenders. The inspector did not consider the number of occurrences / incidents to be excessive, but noted that improvements could be made in this area. The instructions that workers received during general _ employee training (GET) Levels I, II, and III appear adequate to inform workers of proper radiological controls.

However, workers on

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occasions failed to comply with proper work practices.- The inspector observed that increased management attention appeared to be needed in the

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following areas:

(1) department supervisors and foremen (e.g.,

y maintenance, security, operations, etc.) need to increase the importance placed on their workers to follow good radiological practices, and (2) department supervisors foremen need to spend more time at the job

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site to. ensure that work is accomplished in a proper manner.

No violations or deviations were identified.

7.

Training and Qualifications The inspector reviewed the licensee's training and qualifications program to determine compliance with TS 5.3 and 5.4 and 10 CFR Part 19.12. The licensee's training documents that were reviewed are listed in the Attachment to this report. 'The inspector reviewed lesson plans and training records for training provided in the areas of general employee

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training, radiation worker training, training provided to the licensee's radiation protection staff, and the screening and training program for contractor RP technicians that were onsite to assist with the refueling outage. The review of training records and interviews with workers indicated that proper training had been-provided regarding general employee training (GET) Level I, radiation worker training (GET) Levels II and III, and training provided to the licensee's RP staff and technicians, i

The inspector reviewed qualifications of the training instructors in the Nuclear Operations Division, Technical and Radiation Training group that are responsible for presenting radiation protection training. The instructors appeared to be well qualified.

It was also noted that during-the current refueling outage, the radiation protection training instructors worked in the plant as full-time senior radiation protection technicians. The in plant work experience provides an opportunity for the instructors to keep current on working conditions at the plant and be. able to refer to actual working experiences during future training lectures.

The licensee had implemented a well defined training program for RP at the technician level. A review of selected training records indicated that the RP technicians had completed the designated training. The licensee stated that about 52 percent of RP technicians are registered (certified)

by the National Registry of Radiation Protection Technologists.

The licensee had also established a training program for RP supervisors and professionals.

During 1989, two RP supervisors attended a 3-month course specifically designed for the OPPD technical staff.

The 3-month course covered such items as reactor physics, plant systems, NRC regulations, and administrative requirements.

The RP staff also attended offsite courses and seminars-sponsored by industry groups and commercial vendors.

During 1989, 18 trips were made to attend offsite training.

The-inspector reviewed the licensee's program regarding the evaluation, screening, and training of contractor RP technicians used to supplement the permanent staff during the 1990 refueling outage.

This program involved three steps:

(1) The contractor submits resumes of its workers to the licensee for a preliminary evaluation to determine agreement with ANSI N18.1-1971 for classification as a senior or junior technician.

(2) Upon arrival at the plant, the prospective technician must take a written screening examination and pass the examination with a score of 80 percent or better before they are considered for senior technician positions..The inspector noted that there was about an 30 percent failure rate on the screening examination and that those individuals that fail the examination are not provided a second chance to take the examination. The inspector reviewed the screening examinations and found it to be appropriate for senior level positions.

(3) After passing the screening examination, the contractor attends a 1 to 2-week course on plant RP procedures which is followed by a written examination.

The inspector interviewed several HP technicians and found that they had a good understanding of the RP procedures and proper health physics practices.

No violation or deviations were identified.

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External Radiation Exposure Control The inspector reviewed the licensee's external radiation exposure control and personal dosimetry programs to determine compliance with TS 5.11 and 10 CFR-Part 20,202.

Included in the reytew were changes in the dosimetry program to meet outage needs; use of dosimetry; selection and placement of dosimeters in nonuniform radiation fields; and required records, reports, and notifications.

The external radiation exposurement and control. program for the current-outage consists of whole body monitoring using thermoluminscent

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dosimeters (TLDs), self-reading dosimeters (SRDs), direct surveys, radiation work permits (RWPs), and administrative dose limits. The licensee utilizes control point' clerks to read SRDs and log individuals on the computerized RWP work tracking system. The SRD vs TLD radiation exposure results have shown good agreement within 15 percent. The SRD results are-.used for daily updating of personal exposures.

The. licensee had implemented a new TLD program in January 1990. A new automatic reader system and four chip TLD badge is now used. The licensee had received accreditation for the new TLD program by the National Voluntary Laboratory Accreditation Program (NVLAP) in all eight -test categories. The licensee is presently maintaining NVLAP accreditation on the old program as a backup.

The inspector noted.that the personal radiation exposure level among craft personnel varied significantly.

This topic was also discussed by licensee representatives during the station ALARA committee meeting on March 29, 1990. The licensee was attempting to make individual supervisors more aware of the need to even out the exposure among craft personnel and that if more individuals needed training in select areas, then the training would be provided.

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No violations or deviations were identified.

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Internal Radiation Exposure Control The inspector reviewed the licensee's internal radiation exposure control and assessment program to determine compliance with 10 CFR Part 20.103.

This review included changes to procedures; determination whether engineering controls, respiratory equipment, and assessment of individual uptakes meet regulatory requirements; and required records, reports, and notifications.

All persons involved in outage activities received a base line (incoming)

whole body count and were also requested to receive one upon termination.

The inspector observed that of the approximately 150 persons terminated, 19 did not receive a whole body count.

The inspector determined that there were no NRC regulations requiring a termination whole body count nor do the licensee's procedures require a termination count.

The licensee's normal procedure for a person who does not receive a termination whole i

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t body. count, when they determine he was no longer on site, is to send a

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letter ~to his (former) supervisor or company representative notifying them that the person did not receive a termination whole body count.

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were only 4 of the'19 persons that had returned for a termination whole body count.

The inspector cautioned the licensee that termination letters required by 10 CFR Part 19 should reflect-the lack M e a whole body counts. The inspector discussed this observation with the licensee at the exit meeting on March 30, 1990.

The program to control internal exposure during outage activities included engineering controls, airborne sampling and contamination surveillance, and use of National Institute of Occupational Safety and Health /Mine Safety and Health Administration (NIOSH/MSHA) approved respiratory devices

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in addition to protective clothing. Whole body counting is used to supplement the respiratory protection program to ensure its effectiveness.

The engineering controls include the use of portable ventilation units t

with HEPA filters-to exhaust and clean air from certain areas where it was possible for work activities to produce a-radioactive airborne problem.

The inspector noted that the licensee routinely performs tests of all

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. portable ventilation units and vacuum cleaners that use HEPA filters to ensure that there is no bypass leakage and that filters are performing their intended function properly.

The licensee's use of lapel breathing zone air monitors are limited.

In place of lapel air samplers the licensee uses low volume air samplers with

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an extended hose and the filter assembly at the end of the hose for breathing zone' air sampling. The inspector reviwed selected air sample and smear results and determined that the licensee's air sampling program

met the requirements of 10 CFR 20.103.

-i The inspector reviewed records of respirator usage, and inspected the respirator testing and maintenance areas and issue area at access control.

A listing of personnel currently qualified to wear respirators was maintained at the issue station.

Prior to issuing a respirator, the list was checked for respirator medical qualification, training, and fit test.

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The user's qualifications were checked a second time at the control point when he signed in on the RWP. After usage and decontamination, respirators were surveyed for residual fixed contamination and proper respirator operation prior to being returned to service.

Each mask had a color coded metal tag containing a unique identification number for tracking of usage and maintenance.

No major problems were noted concerning the use, 1:suance, and accountability of respirators.

No violations or deviations were identified.

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10. Control of Radioactive Materials and Contamination, Surveys, and Monitoring The inspector reviewed the licensee's program for control of radioactive materials and contamination, surveys, and monitoring for compliance with the requirements of TS'5.8.1 and 5.11, and.10 CFR Parts 19.12, 20.4, 20.5, 20,201, 20.203, 20.205, 20.207, and 20.301.

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The inspector examined select radiological surveys of direct radiation and surface contamination, and airborne radioactivity which had been performed in the radiologically controlled areas of the facility.

The inspector also performed confirmatory surveys of direct radiation levels; the results of these surveys were in agreement with the licensee's recorded values.

The inspector reviewed the results and the licensee's response to NRC Bulletin 78-08 dated June 12, 1978, which relates to the radiation exposure adjacent to.the fuel transfer tube. The licensee uses yellow and magenta barrier rope, signs, and a flashing red light to restrict entrance to the. area adjacent to the fuel transfer tube in containment during fuel transfer operations.

The inspector discussed with licensee representatives the results of the original surveys that were made in February 1980 as required by the bulletin. These surveys were made using a geiger-tube portable survey meter and TLDs during fuel transfers. Tne licensee had mehsured 78 millirem (mr) exposure per-fuel bundle. transfer and estimated the maximum radiation field of 4680 mR/hr.

The results of'the licensee's radiation surveys and access control to the potential high radiation area had been reviewed and found acceptable in Inspection' Report 50-285/82-06.

The inspector noted that since the 1980 measurements, the licensee had changed fuel design and the fuel burnup had increased.

Fuel with higher burnup rates will be removed during the next refueling cycle. The licensee acknowledged the-inspector's observation and-stated they would perform.a new verification survey of the radiological conditions during the next refueling outage' to determine if there have been.any-significant changes in 1980 radiation levels. The licensee also stated that they would evaluate the methods used to restrict access to the transfer tube area to determine if more substatial controls (e.g., wire fence) are needed. This is considered an open item pending NRC review of the followup survey of the fuel transfer tube.

(285/9018-01)

No violations or deviations were identified.

11. Changes The inspector reviewed the new HP building area which included:

locker / change rooms for both male and female station and contractor personnel; office areas for HP supervisors and technicians, ALARA personnel, HP shift lead technicians; and the entrance control point for the radiological controlled area (RCA).

The licensee had made a temporary

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-11-change to the RCA exit area to provide a better personnel flow path.

Additional changes are to be cor.pleted in the RCA exit area after the present outage is completed, inis should improve the flow path for personnel leaving the RCA, obtaining respiratory protection equipment, and picking up tools and equipment that have received unrestricted clearance from the RCA.

No violations or deviations were identified.

12, Maintaining Occupational Exposure ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA to determine compliance with the requirements of 10 CFR Part 20.1(c); and the recommendations of NRC Regulatory Guides 8.8, 8.10, and 8.27.

The inspector reviewed the station ALARA committee and executive ALARA committee meeting minutes which established the 1990 annual _ goals for the station. Goals-were established for the areas of total station exposure; contamination events, both clothing and skin; total-gaseous effluents; total liquid tritium effluents; solid radioactive waste; nonoutage contaminated areas in the auxiliary building; and hot spot reduction.

These goals, where applicable, were further broken down to the individual department goal.

The executive ALARA committee is chaired by the senior vice president and includes among others, managers from various divisions, the FCS plant manager, and the radiation protection manager as members.

The executive ALARA committee appeared to be actively involved with the_ station's ALARA-program progress and_the efforts being made not to exceed the established goals in addition to providing the resources necessary to handle special problems that may occur.

The inspector attended the station ALARA committee meeting-held on March 29, 1990.

During this meeting, discussions were held regarding lifetime exposure recommendations, 1990 goal status, hot spot reductions, and personnel contamination ever.ts.

In the area of hot spot reductions, the licensee had identified the reactor coolant drain tank (RCDT) which had a hot spot of 580 roentgens per hour as the first of several that would be attempted this, year.

The ALARA coordinator presented various methods that could be employed and the advantages and disadvantages of each method.

It was decided that the tank would be drained into shield containers. The inspector was informed on April 4, 1990, that this hot spot had successfully been removed. Additional discussions were held regarding personnel contamination events (PCEs). The 1990 goal was 150 PCEs of which 23 were skin contamination.

The station had exceeded the skin contaminatim goal; there had been 36 events recorded as of March 28, 1990.

Durir,g the ALARA meeting, the licensee discussed what could be done to make personnel more aware of the need to prevent these occurrences.

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The ALARA group had purchased five video cameras and two video recorders to videotape various work functions.

These tapes will supplement the file of photographs use in ALARA planning and briefings in addition to reviewing work in progress and determining methods to reduce radiation

exposures and improve work practices.

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The ALARA coordinator estimated that 20 person-rem had been saved over the l

1988 refueling outage so far during this outage, j

No violations-or deviations were identified.

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Licensee Identified Violation The inspector examined the circumstances surrounding the licensee's self identification of an apparent TS violation.

j The incident involved the failure of-a security guard assigned to fire watch activities to comply with the entry requirements for a high radiation area (HRA) on December 11, 1989.

The security guard entered i

Room 7 within the RCA to verify that no fires were present.

The door to Room 7 was posted as a HRA and to contact HP prior.to entry. This incident was discussed in LER 89-023 and NRC Inspection Report 50-285/89-50.

TS 5.11 and Procedure RP-204, " Radiological Area Control," require that~

entry not be made into an HRA unless one of the following conditions is-met:

(1) the individual possesses a radiation menitoring device that

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continuously indicates the radiation dose rate in the area, (2) the i

individual is equipped with an alarming dosimeter that continuously

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integrates the radiation dose rate in the' area and alarms when a preset l

integrated dose is received, or (3) an individual qualified in radiation I

protection procedures, who is equipped with a dose rate instrument,

accompanies the individual. The security guard failed to meet any of the

requirements stated above when entering the HRA.

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The licensee's response to this incident and corrective actions taken included:

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A radiological survey of the part of Room 7 near the door and shield wall was performed.

The survey indicated dose rates of less than 0.4 mr per hour in those areas of the room that the security guard was present.

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- The TLD assigned to the security guard was pulled and authorization for the guard to enter the RCA was revoked. The SRD assigned to the

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guard indicated a radiation exposure of less than 5 millirem was received during the tour of the RCA, 3.

The security guard was suspended from duty pending a management investigation.

Following the investigation, the guard's employment with OPPD was terminated.

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The licensee conducted briefings on HRA entry requirements for all-personne1' assigned TLDs with access to the RCA.

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All appropriate security personnel were briefed on the event. They were reminded of procedural requirements for firewatch patrols and the additional requirements needed for entry into HRAs.

The licensee's corrective actions were reviewed by the inspector on March 29, 1990, and determined to be adequate to correct the licensee-identified violation and prevent recurrence. This incident would normally be considered a violation of TS 5.11 requirements.

However, the NRC Enforcement Policy, 10 CFR Part 2, Appendix C (1989), states that a Notice of Violation will generally not be issued for violations identified-by the licensee, if:

(1) it was identified by the licensee; (2) it fits in Severity Level IV or V; (3) it was reported, if required; (4) it was or will be corrected; and (5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective actions for a previous violation. This violation meets the criteria specified in 10 CFR Part 2, Appendix C (1989), and is considered a licensee _ identified violation and-no Notice of Violation will be issued concerning this-incident.

14. Exit Interview The inspector met with the senior resident inspector and the licensee's-representatives denoted in paragraph 1 at the conclusion of the inspection on March 30, 1990, and summarized the scope and findings of the inspection as presented in this-report.

The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspector during the inspection.

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ATTACHMENT Documents Reviewed

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t Audits and Appraisal Internal Audit Report No. 58, " Health Physics and ALARA," December 2,1987 l

Audit Report No. $8, " Radiation Protection and ALARA," April 26, 1989 l

Audit Notification - QA Audit No. 50, " Health Physics and ALARA" Audit Checklist No. 58, "Radiatier, Protection and ALARA," January 15, 1990 Quality Assurance Audit Report No. 58, " Radiation Protection and ALARA,"

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February 26, 1990

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QA Surveillance Report No. H1-89-1, " Radiation Protection Surveillance Survays " June 7, 1989 QA Surveillance Report No. H2-89-2, " Contamination Control," August 23, 1989

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Quadrex Review of Radiation Protection Enhancement Program, November 11, 1989 Industry Evaluations of Fort Calhoun Station, 1988 and 1989 Training and Qualifications H

Radiation and Protection Training Program Master Plan, Section 2.0, " Program Description," August 4, 1980 Radiation Protection Tr41 Mag Program Master Plan, Section 7.9, " Contractor Radiation Protection Technician Qualification Guide," July 20, 1990 Technical Staff Traihing Program Master Plan, " Technical Staff Training Schedule," March 23, 1990 i

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