IR 05000285/1990041

Insp Rept 50-285/90-41 on 901015-19.No Violations Noted. Major Areas Inspected:Liquid & Gaseous Radwaste Mgt Programs & Initial Confirmatory Dose Calculations of Offsite Doses from Radioactive Effluents Released to Environ

ML20058K417
Person / Time
Site:	Fort Calhoun
Issue date:	12/10/1990
From:	Jang J, Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058K411	List: IR 05000285/1990041 ML20058K408
References
50-285-90-41, NUDOCS 9012170224
Download: ML20058K417 (11)

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U.S. NUCLEAR REGULATORY COMMISSION'

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REGION IV-

NRC Inspection Report: 50-285/90-41 Operating License: DPR-40: q Docket: 50-285 l Licensee: Omaha Public Power District' (OPPD)

444 South 16th. Street Mall i i

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Mail.Stop 8E/EP4 Omaha, Nebraska- 68102-2247 j

Facility Name: Fort Calhoun Station (FCS) l Inspection At: FCS Site, Blair, Nebraska Inspection Conducted: October 15-19, 1990 F

Inspectors: .

k J./B. Nicholas, S6nitor Radiation Specialist u.//o/po Dat6 1 Rddiological Protection and Emergency-Preparedness Section Y

J.f.Jang, Senior'RadiationSpecialist 'Date

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abo l90 Effluents Radiation Protection Section <

Region I~

l Approved: O 0, Yl/Jihu il 8 d B.'Murra~y,Chie",RadigogicalProtectiorand- Cate

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Emergency Preparednesh Section:  !

[i Inspection Summary

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Inspection Conducted October 15-19, 1990 (Repcet 50-285/90-41)

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, Areas Inspected: Routine, unannounced inspection'of the-licensee's liquid and gaseous radioactive waste management programs.andsthe initial confirmatory dose calculations of offsite doses from radioactive' effluents' released to the i environmen L

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Results: The inspectors determined that the' licensee was implementing the radioactive waste effluent program (RWEP) in accordance with the Radiological- i Effluent Technical Specifications (RETS) and Offsite Dose Calculation

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Manual (0DCM). The quantities of radionuclides released in the radioactive 1 waste effluents were within the limits specified in the RETS. Offsite doses were calculated using methods described in the ODCM and were within Technical Specification (TS) limit Initial confirmatory dose calculations were

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performed during the inspection using the new NRC PC-DOSE computer code for offsite dose calculation The licensee's and the NRC's calculated doses from i

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radioactive noble-gas ef fluents were-identical. However, comparisons between a the licensee's calculated dose results and the NRC's calculated dose results indicated differences for the total body and critical organ doses resulting

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differences in the calculated offsite dose results are the subject of' two'.open items discussed in paragraph 7 of this repor Within the areas inspected, no violations or deviations were identified. One previously identified open item was closed, t

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DETAILS Persons Contacted 3 OPPD

• J. K. Gasper, Acting Division Manager, Nuclear Operations ,

• R. L. Andrews, Division-Manager, Nuclear Services- El

• T. L. Patterson, Manager, FCS A. W. Richard, Assistant Manager, FCS

• J. B. Biggs, Chemist'

A. D. Bilau,-Acting Radwaste Supervisor a

• J. W. Chase, Manager, Nuclear Licensing- '

• V. H. Frahm, Jr. , Supervisor, Radiochemistry '

• F. F. Franco., Manager, Radiological Services '

• A. F. .Friebe, . Chemistry Technician

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• J. M. Giantz, Chemist, Radiological Services

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

• J. G. Krist, Environmental Scientist, Radiological Service ,

• L. T. Kusek, Manager, Nuclear Safety Review

• L. Lovett, Acting Supervisor, Radiation Protection '

• B.' Pence, System Engineer, Ventilation Systems

• R. L. Phelps, Manager, Design Engineering .

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• B. A. Schmidt, Supervisor, Secondary' Chemistry-

• R. J. . Sexton, Supervisor, Radiological Health and Engineering ,

• R. W. Short, Supervisor, Special Services Engineering

• L. D. Sills, Quality Assurance (QA) Auditor i

• F. K. Smith, Supervisor, Chemistry .

• E. Spires, QA Auditor .

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R. K. Stultz, Chemistry and Environmental Supervisor, Radiological Services

• T. G. Therkildsen, Supervisor, Nuclear Licensing

• T. J. Vandervort, System Engineer, Radiation Monitoring Systems ,

• S. J. W111 rett, Manager, Nuclear Materials and Administrative Services l

NEC R. P. Mulliken, Senior Resident Inspector, FCS ,;

• T. Reis, Resident Inspector, FCS .

• J. C. Jang, Senior Radiation Specialist, Effluents Radiation Protection

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Section, Region I

• Denotes those present during the exit meeting on October 19,.199 * Followup on Previously Identified Inspection Findings (92701)  :

(0 pen) Open Item (285/8904-03): Verification of Personnel Quarterly Exposure (NRC Form 4) - This item was' identified in NRC. Inspection y Report 50-285/89-04 and involved a licensee-identified' violation concerning the failure to require personnel, employed'at-FCS with breaks-

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in their employment and/or breaks in use of personal dosimetry at FCS, to sign a written statement attesting to thei_r occupational -radiation exposure durlng-the current calendar quarter when not employed or l monitored at FCS. .The licensee had recognized this problem in their~ -!

dosimetry records and had issued a speci61 report to the NRC, dated: .,

December 19, 1988. As corrective action to-the licensee's self-identified violation of 10 CFR Part 20.101(b)(3), as described in the licensee's special report and in response to this open item, the licensee developed a -j dosimetry audit plan to review and ' upgrade- all exposure records for-personnel who had been employed at FCS. The inspectors reviewed the; j progress the licensee was making in . auditing the FCS personnel exposure L history files as described in a progress report and summary of audit  !

activities dated October 3, 1990. Phase I of the-FCS Personnel Exposure History File Review and Correction Plan had been completed on December .15, 1989. The licensee reported that 1183 files had been reviewed and .

corrected under Phase I. Phase II had. identified approximately 5800 files requiring review, which included termination files and inactive files for .

the period 1972 through 1987. The. progress report dated October 3, 1990,- '!

indicated that there were approximately 507 files remaining to be audited-to complete Phase II of the. audit. -The projected completion date for Pha:e II is December 31, 1990. The audit' appeared to be on' schedul This item will remain-open pending the licensee's completion of Phase'II of the audit and further NRC review at the completion of the au'di ,

(0 pen) Unresolved Item (285/9011-01): Radwaste Staff: Training - This ; item '

was identified in NRC Inspection Report 50-285/90-11 and involved the lack Of. completed training of the licensee's radwaste staff on the requirements '

and regulations for shipment and receipt of radioactive material and the performance of radioactive material shipment surveys. The inspectors .j reviewed the licensee's training plans for FCS staff on the requirements i and regulations for shipment of radioactive materials. The licensee had j scheduled a 4-day course on NRC and Department of Transportation (DOT) i regulations and proposed changes to .these regulations for' December 3-6, '

1990. The course is to be attended by.15 FCS staff personnel representing the departments of radwaste, radiation protection, QA, quality' control,

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and training, This training is to be conducted by a vendor. In addition, on December 7, 1990, site specific training on the lesson plans (19-23-18,

" Shipment and Receipt of Radioactive Material," and 19-24-35,

" Shipment / Receipt Surveys") is scheduled for all of the FCS radwaste staff. This training is to be' conducted by the licensee's nuclear i training department as part of the nuclear training department's Institute of Nuclear Power Operations accredited training program. This item will remain open pending the completior, of the scheduled training and review of the licensee's personnel training records during' future NRC i m pection (Closed) Open Item (285/9011-02): Vendor Audits of Radwaste Containers -

This item was identified in NRC Inspection Raoort50-285/90-11 and involved the concern that the licensee had.not performed audits of the two vendors who supplied S5 gallon drums' fabricated as' 00T Specification 17H containers and strong-tight containers for packaging dry active waste to meet the 00T Specification 7A Type A package requirements. The inspectors l

. n-5-reviewed the licensee's evaluation.of their vendor audit program which:

determined that_the 55 gallon drums and the steel boxes purchased for shipping radwaste materials were not considered _to be classified as critical quality' elements; and therefore, the suppliers and/or,

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,j manufacturers of these products were not subject to:the. licensee's vendor audit program and the licensee.had no requirement to audit'the vendors

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supplying or manufacturing the above mentioned containers _used'for radwaste packaging and shipping. The radwaste shipping. containers for dry active waste were purchased by the licensee as limited critical quality j elements and the purchasing documents required that a certificate of - o conformance to DOT: standards be supplied with each purchase: from the vendor. . The licensee had-performed a receipt-inspection ~on each purchase-- i of containers and had verified that the requirements _of the purchase; order had been met,and that a certificate'of'conformance was included with each 1, shipment. It was determined that the licensec's evaluation was adequate to resolve the NRC's concerns-in this are ~  !

(0 pen) Open Item (285/9018-01): Followup' Survey of Fuel Transfer Tute ~-

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This item was identified in NRC Inspectica Report- 50-285/90-18 and- i involved the licensee's performance of a current verification survey of the radiological conditions.in the area of,the fuel transfer tube du'in s fuel movemen The original fuel : transfer tube survey was performed in_ , '

February 1980.in response to NRC. Bulletin 78-08. The inspectors resiewed'

the results of Lthe licensee's preliminary fuel transfer tube dose . study performed at the end of the last-refueling-outage in'Ap'ril-1990. This  ;

preliminary study was performed by positioning thermoluminescent- '

dosimeters in the area of the fuel transfer tube Lto measure the radiation 4 dose while transferring spent fuel from the spent fuel . pool: to the j reactor. The_ data compiled was used to ascertain'the rise-in dose rates 1 which might be anticipated during the movement of1second or third cycle- 1 fuel from the reactor to the spent' fuel pool during. the next refuelin .i outage. The highest dose rate calculated during.the preliminary study and .;

movement of spent fuel was 4,22 millirem'per hour (mR/hr). This dose rate

. was measured in an area accessible by personnel. The results of the preliminary study of the fuel transfer tube area dose rates' during fuel transfer indicated no. substantial. increase in dose rates based on fuel i movement from the spent fuel pool to the reactor. However,_the. licensee will perform dose rate measurements in'the fuel transfer tube area during

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the removal of fuel from the reactor during the.ne't x refueling outagel.'

This item will remain open pending the licensee's completion of the fue1~ ~q transfer tube survey to be co_nducted during the next, refueling of.the-.

reacto . Open Items Identified During This Inspectio An open item is a matter that requires further review-and evaluation.by the licensee'and the inspectors. Open items are'used to document, track, and ensure adequate followup on matters of concern to the inspectors. 'The following open items were identified:

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285/9041-01 Radioactive Waste Material 4 l Shipment-Dose Rates--

285/9041-02 QA Radiological' Effluent 5 :

Surveillance Program  ;

285/9041-03 Chemistry Section Radioactive- 7 Effluent Dose Calculations 285/9041-04 Radiological Services Gr.oup 17' t Radioactive Effluent Dose ,

' Calculations Radioactive Waste Material Shipment' Dose Rates (84522)

( The inspectors reviewed the details of the licensee's violation of-the

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State of Washington's Administrative Code.and U.S. Ecology, Inc.'s, l Radioactive Materials License WN-1019-2.which. involved a discrepancy between the licensee's external. radiation reading on a single drum (No. 90-CT-0383), included ia a radwaste shipment'to Richland, Washington, on April 5, 1990,-and the burial site's~ external radiation reading _on,that

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drum during a receipt inspection of the: shipment on April,9, 1990. The licensee's external radiation' measurement of 10 mR/hr marked on thei i radwaste drum and listed-on.the;thipment manifest =was lower than the- .,

25 mR/hr external radiation measurement obtained by the State of 1 Washington's Department of Health personnel'at the burial site upon receipt of the shipment. The licensee's. response to'this 15 mR/hr ;

discrepancy between their dose rate and'the dose rate measured by the '

State of Washington-Department _of. Health was reviewed by the inspector _

Discussions held with the acting radwaste operations supervisor indicated that the licensee had implemented the corrective actions. described in.the licensee's response to-the State of Washington. These actions included the use and control of specific types of radiation _ survey-. instruments-similar to those used by the burial sites and the inspection of the radioactive material for potential in-transit shifting.within the' shipping container prior to compaction. However, the inspectors noted that the detailed corrective-actions outlined in the licensee's response.had not a'

been incorporated'into the licensee's radwaste procedures. -The licensee stated that they would incorporate their' corrective actions into the applicable radwaste procedures. This matter is considered an:open item pending further review by the inspectors. (285/9041-01)

No violations or deviations were idAntified.

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o 5. QA Program- (84750) *

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The inspectors reviewed the licensee's QA surveillance an'd audit programs; regarding liquid and gaseous radioactive waste effluent releases to the environment to. determine agreement with commitments _.in Chapter'12 of.the-Updated Safety Analysis Report'(USAR) and compliance with the: requirements :

in Section 5.5 of the-T ]

The inspectors reviewed the surveillance and audit schedules for 1988,. I 1989, and 1990. It was noted that the last Safety Auditland-Review Committee (SARC) audit of the radiological effluent program,~ SARC j

y Audit No. 8-88, was performed during the period-October,31 through 1 November 10,-1988. This audit was reviewed during:the. previous NR inspection of This -area conducted in February 1989'. 'The next biennial 1 SARC audit of the licensee's radiological: effluent _' program is scheduled ~

for November 1990. QA Surveillance Report B1-89-1,." Radiological Effluen )

Release Survey," conducted July 18 and 20,1989, wastreviewed and found to I be comprehensive in monitoring the licensee's liquid landigaseous-effluent-release activities. The inspectors noted that thellicensee was no' longer ,

performing semiannual QA surveillances of liquid and gaseous. radiological l effluent releases as in1 years previous to'1989. This reduction in QA~' l surveillance activity of the~1iquid and gaseous radiological' effluents'was-discussed with the licensee:during the-exit meeting onL0ctober'19, 1990'

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The licensee stated that this reduction'in QA' surveillance frequency of J this area would be evaluated. This matter;is considered an open item l pending further review by the' inspectors. (285/9041-02)

No violations or deviations were identified, i

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6. Radioactive Liquid and Gaseous Effluent Systems (84750)_

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The inspectors reviewed the licensee's liquid and gaseous radioactive- q waste effluent programs including: radwaste sampling and analyses, 1 procedures for operation = of radioactie waste effluent systems _ and performance of releases to the environment, surveillance tests' and- ,

process and effluent radiation monitor tests and calibrations to determine agreement with commitments in Chapters 4, 6, 9, and 11:of the USAR and compliance with the requirements in Sections 2.9, 3.12, and 5.8 of the T ;

The inspectors reviewed the licensee's implementation of the RETS and 00CM to ensure compliance with sampling and analyses requ'irements, analytical sensitivities, reporting limits, surveillance requirements, RWEP procedures, offsite dose results from radiological effluents, and functional check and calibration requirements of radiation monitors and

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equipment associated with the RWE r The inspectors reviewed current approved revisions of FCS standing orders and procedures governing the release-of liquid and~ gaseous radioactive waste. Selected liquid and gaseous release permits for batch liquid <

effluent releases from the liquid radwaste monitor tanks and batch releases from radioactive waste gas decay tanks and containment were i

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-8-reviewed for the period January 1989 through September 1990. It was determined that the processing, sampling and analyses, and_ approvals and l'

performance of the radioacti_ve waste effluent releases were conducted in a accordance with FCS procedures.' Quantities of. radionuclides released.in-

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q the liquid and gaseous effluents were determined to be within the limits- o specified in the RETS. Surveillance test analyses required by the RETS for monitor tanks, steam generator blowdown.. waste gas decay tanks, containment vents / purges, and unit vent continuous-gaseous releases were j verified to be completed and documented in accordance with FC i surveillance procedures.for the period January 1989_through .

.i September 1990. RETS surveillance test analytical results were within TS 'j limits. Offsite doses to the environment :as a result of radioactive waste effluent releases had been calculated quarterly per RETS rnquirements and' J were within TS limit The inspectors reviewed functional checks, source checks, and calibration.

l procedures and records for. selected process and radioactive.' waste effluent =

radiation monitors. The records _for 1989 and 1990 indicated that the frequency of radiation monitor checks and calibrations met TS requirements. .The latest radiation monitor-calibrations.and setpoint'-

determinations were verified to have been performed according to approved *

procedures and the'.0DC No violations or deviations were identifie I i

7. Radioactive Liquid'and Gaseous Effluent Dose Calculations (84750). ,j L ,

The inspectors reviewed the licensee's radioactive waste effluent dose-calculations to determine compliance with.the: requirements in~the ODCM and i Sections 2.9.1 and 5.9.4 of the T l

The inspectors. conducted initial confirmatory calculations ~ of the offsite doses from the plant's liquid and gaseous radioactive waste effluents  !

released to the environment. Radioactive waste effluent dose calculations j were performed by the' inspectors for liquids,' noble gases, and airborne iodine and particulates using the NRC computer code, PC-DOSE, which was developed to verify the dose calculations described in the licensee's ODC ;

The licensee's chemistry staff performed. effluent dose calculations using .'

methodologies, assumptions, and equatior.s described in the ODCM and implemented by a computer code written by the licensee's chemistry staf l to determine compliance with the TS requirements. The inspectors, in '

cooperation with the chemistry staff, developed realistic test cases > based on typical effluent radionuclide concentrations and release rates for radioactive liquid and gaseous effluents. The. inspectors and the "l licensee's chemistry staff performed dose calculations using;the sam radionuclide concentrations for the liquid effluent test case. The. dose >

results from the original test for radwaste liquid effluents indicated differences between the NRC's and the licensee's dose results for the.-

adult total body and adult critical organ. The licensee's dose results I

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were greater than the NRC's dose results.for,the adultitotal body dose and the adult liver dose which had been chosen for compar.ison. After evaluation of the licensee's computer code; it was: discovered that the- 1; monitor tank.radionuclide input listing.had been altered and that the data-input table had.not been changed to correspond to the'radionuclide input listing. The result of this computer software modification caused the j(

c input data,for several radionuclides tojbe out-of-order and not correspond 1 with the correct radionuclide listed in _the' computer code thus causing =j erroneous dose results. The licensee corrected the"radionuclide data- '

input table so that it would match with the radionuclide input listing and - [

reran the test case.' The licensee's dose results for- the adult total, bodyf l and the adult. critical, organ'(liver) were inl agreement with the NRC's dose ;

results. Discussions with the licensee indicated that:radionuclide: !

modifications-had been made to the chemistry section. dose calculation ' ,

software-in-March 1990. At that time, changes had beenimade to th !

radionuclide-listing which probably were the.cause:of_the' differences between the licensee's andlthe NRC's liquid effluent dose. results. . Since, the licensee's. erroneous dose.results were conservative and no'TS limits ,

had been exceeded, it appeared that no TS-requirements'had been violated ~l or would be violated after the software corrections were made. This i matter was discussed with the licensee =during-the inspection and_at the- '

exit meeting on October 19, 1990. The_ licensee acknowledged that there -

appeared to be errors in the chemistry section's" computer software: radionuclide data input table and stated-that they;would review and-check all liquid ef fluent quarte'rly dose results for ' previous calendar quarters !

to verify dose results. The licensee:also stated that they would submit a .

supplemental report to'any semiannu'al radioactive effluent release reports that had been issued with erroneous dose results. This matter is  !'

considered an open item pending furthertreview by the inspector (285/9041-03)  !

In addition to the radioactive liquid effluent . test case,= a. test case for !

noble gas dose and a test case for airborne' iodine :and, particulate dose were run. The licensee's results for the total body _ gamma-air dose'and the= total body _ beta-air dose from-exposure to radioactive noble gases were in agreement with the NRC's calculated- doses. : The -licensee's dose' data-from airborne iodine and particulates was conservative when compared to the NRC's dose results. However, it was impossible _to compare the NRC's dose results directly with the' licensee's dose >results since the license had written their computer code to provide only the-most conservative: dose-results. These-dose results were:a combination of dose data calculated using previously selected highest dose factors for the -infant and child '

age groups. The licensee's dose results were also a combination of the inhilation, ground plain, and food ingestion-pathway The inspectors also performed confirmatory dose calculations:which were compared to the radiological effluent dose results obtained from the'-

licensee's' radiological services group. The radiological services group prepares the radioactive effluent release data for dose calculation.using the licensee's main-frame computer and approved computer codes, LADTAP for liquid ef fluents and GASPAR for airborne releases. The licensee's dose

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results from the radioective liquid effluent test case were: greater.than the ,NRC's dose results and therefore conservative. :The inspectors checked the licensee's dose factors used for calculating the total body and organ doses for the adult, teen, and child age groups. . It was discovered:that the tritium dose factors for the adult age group' and for all affected ;

organs were different than the tritium dose factors found in Regulatory 1 Guide (RG) 1.109 and PC-DOSE. The adult dose factor associated with the o gastro-intestine critical organ and the strontium-90 radionuclide was also j found to be different. Further investigation by the inspectors,showed- -l that approximately.95 percent of the teen and. child dose factors i associated with the test case radionuclides and vital organs were'also- 1 different than '. hose-found in RG-1.109 and PC-DOSE. The: licensee stated L that the LADTAP computer code being used for-these dose. calculations had

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been installed and initiated for use'in 1977 when 10 CFR_Part 50, Appendix I, dose calcuhtions were first requiredito be; performed by the licensee, The licensee also: indicated that their computer codeidose

factor data base had not been altered since itscinitial installation.- The i

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licensee corrected the dese factors:for tritium and'stro'ntium-90 for th adult age group and reran the test case. To obtain the same adult _ dose i results from the radioactive liquid effluent: test case'as the NRC, the licensee eliminated the tritium radionuclide from the-test case and used a dilution factor for fish consumption of: 7;5 instead of 1.0 used by' i PC-DOSE. The inspectors reran the liquid test case eliminating tritium- ,

and using a dilution. factor for fish' consumption of 7.5. "The NRC dose results from this calculation were reducediapproximatelylby.a factor of j -

7.5 making the differences between the, licensee's and the NRC's-dose -

results even greater. Further study and research was'found to be necessary to resolve these differences in'the' radioactive liquid doses, i

The licensee's radiological services group noble gas dose results for. the '

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total body gamma-air dose and the total body beta-air, dose were in i

.' agreement with the NRC's. calculated doses. The licensee's radiological !

services gr m vose data from radioactive airborne iodineland:particulates compared exa 2 / to the NRC's dose data for the inhalation pathway'for all age groups. However, dose data for other ingestion pathways including. cow; meat, cow milk, and vegetation indicated that the licensee's dose results were nonconservative when compared-to the NRC's dose data. For example, dose data comparisons were made between the licensee's and'the NRC's dose ;

results for all age groups and critical organs for:the ingestion pathways of cow meat, cow milk, and vegetation. The results of these comparisons indicated that the licensee's calculated doses for thelbone,~ liver, kidney, lung, and total body were -approximately a factorgof 0.42 less than the corresponding NRC calculated doses and that the licensee's. calculated thyroid dose was approximately a factor of 0.93 lesslthan the NRC's calculated thyroid dose for all age groups and ingestion 1 pathways. The differences in the dose results between the-licensee's radiological

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services group and the NRC were discussed.withLthe licensee during.the inspection and at the exit meeting on October 19,:1990. This matter is ,

considered an open item pending further review by'the inspector '

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No violations or deviations were identifie :!

8. Reports of Radioactive Effluents -(84750) _

l The inspectors reviewed the licensee's reports concerning radwaste systems; l and effluent releases for compliance with the requirements of_10 CFR -1 .

Part 50.36(a)(2) and Section 5.9.4.a of the TS.= j The inspectors reviewed the semiannual radioactive: effluent release-reports for the periods January 1-through June 30,:1989; July 1'through-

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December 31, 1989; and January 1 through June 30,'1990. These' reports-were written in the format described in NRC RG 1.21 cn.1 contained the< L information required by T !

No violations or deviations were. identified.'  ;

9. Exit-Meeting ' (30703)

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j The' inspectors met with the resident inspectorsand,the: licensee-representatives identified in' paragraph 1 of thistreport-at the_ conclusion-of the inspection on October 19, -1990. . The1 inspectors summarized the -!

scope and findings of the inspection and-dis' cussed the differences between ;

the licensee's and NRC': offsite. dose results calculated dur.ing the- 4 inspection. The licensee agreed to . investigate and: evaluate their computer methodologies in an attempt to resolve the calculated dose i'

differences. The licensee did not identify as proprietary any of;the'-

materials provided to, or reviewed by, the inspectors:during the inspectio L

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