IR 05000285/1993019

Insp Rept 50-285/93-19 on 930823-27.No Violations Noted. Major Areas Inspected:Radiation Protection Program,Including Audits & Appraisals,Training & Qualifications,External Exposure Controls & C/As for Previously Identified Items

ML20057A912
Person / Time
Site:	Fort Calhoun
Issue date:	09/10/1993
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20057A906	List: IR 05000285/1993019 ML20057A905
References
50-285-93-19, NUDOCS 9309160193
Download: ML20057A912 (11)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/93-19 Operating License: DPR-40 Licensee: Omaha Public Power District Fort Calhoun Station FC-2-4 Ad ' P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399  ; Facility Name: Fort Calhoun Station Ir.spection At: Blair, Nebraska Inspection Conducted: August 23-27, 1993  ! Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist Facilities Inspection Programs Section i l Approved: {{Lni Y

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L l LOC / Ef.' Hurray, Ch'ieT,' F5ciMi_ es Inspection Date bY

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Programs Section U l Inspection Summary l l Areas inspected: Routine, announced inspection of the radiation protection program, including audits and appraisals, training and qualifications, external exposure controls, internal exposure controls, controls of radioactive material and contamination, and corrective actions for previously identified violation Results: 1

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* A comprehensive quality assurance audit was performed using a technical expert from another power reactor facility (Section 2).

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* The licensee implemented the new 10 CFR Part 20 on July 1, 1993 (Section 3).      ,
* The radiation protection department had low turnover (Section 5).

• Training groups inspected were sufficiently staffed with qualified instructors (Section5).

• A very high percentage of the radiation protection technicians were registered by the National Registry of Radiation Protection Technologists (Section 5).

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* A good screening examination was used in selecting contract radiation protection technicians (Section 5).

• An " advanced" radiation worker training course was presented to maintenance workers (Section 5). ,

* A good training program had been established for supervisors and professionals within the radiation protection group (Section 5).

• A properly accredited dosimetry program which included state-of-the-art equipment was maintained (Section 6). '

* Areas within the radiological controlled area were properly posted and controlled (Section 6).

• A low person-rem exposure was maintained (Section 6).

• A good internal exposure control program was implemented (Section 7).

• Housekeeping within the radiological controlled area was adequate (Section 8).

• An excellent contamination control program was in place (Section 8).

Summary of Insoectioc Findinas: ,

* Violations 285/9232-01, 285/9232-02, 285/9232-03, 285/9232-04, 285/9232-05, 285/9232-06, and 285/9232-07 were closed (Section 10).

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* Attachment - Persons Contacted and Exit Meeting  '
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l-3-DETAILS 1 PLANT STATUS During this inspection, the plant was operating at 100 percent powe AUDITS AND APPRAISALS (83750) The inspector reviewed this portion of the licensea's program to determine compliance with Technical Specification 5.5.2.8 and Chapter 12 of the Updated Safety Analysis Repor The inspector reviewed Quality Assurance Audit Report 58, " Radiation Protection and ALARA," which was performed March 15-29, 1993. The four-member team included a member with previous radiation protection experience and a , technical expert from another power reactor facility. The audit identified five items which required corrective action reports and made five recommendations. Responses to the findings from the radiation control program were made promptl The licensee also performed an assessment of the radiation protection program effectiveness January 4-7, 1993. The assessment team included a member with expertise in radiation protection. The radiation protection program developed a number of initiatives for program improvement as a result of the assessmen The inspector reviewed radiological occurrence reports and incident reports related to the radiation protection progra Licensee personnel were knowledgeable of the two systems and properly documented and tracked occurrences and problems. The inspector determined that good reviews were made of the items, and proper corrective actions were implemente CHANGES (83750)

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The inspector reviewed this portion of the licensee's program to determine agreement with commitments in Chapter 12 of the Updated Safety Analysis Repor There were no substantive changes in the organizational structure. The licensee filled the positions of supervisors for Radiological Health and Engineering and Radioactive Waste Operation Changes were made to the radiological controlled area access control entry / exit point to enhance the traffic flow pattern The licensee implemented the new 10 CFR Part 20 changes on July 1, 199 Procedures were revised to include the changes. The inspector verified that the new procedures provided adequate guidance for the implementation of new Part 2 l __ , _ _ _ _ _ . _ _ - _ _ _ _ . . _ . _ . _ _ _ . _ . _ . _ _

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i-4-4 PLANNING AND PREPARATION (83750) The inspector reviewed this portion of the licensee's program to determine compliance with Technical Specification 5.8 and agreement with commitments in Chapter 12 of the Updated Safety Analysis Repor The licensee was scheduled to start a 56-day refueling outage on September 25, i 199 l The radiation protection program planned to supplement its permanent staff with approximately 86 additional people, including 32 contract radiation protection technician ; The licensee planned to conduct mock-up training for maintenance activities involving steam generator nozzle dam installation and letdown filter replacemen Approximately 120 to 160 radiation work permits will be required for outage work. Only a few of these had been prepared at the time of the inspectio When the inspector expressed concern with the radiation work permit preparation progress, radiation protection representatives stated that they had been involved with outage work planning and had determined that there were no new work activities to be performed during the 1993 refueling outag Therefore, since sufficient job histories were on file and ready for use in preparing the radiation work permits, radiation protection personnel would .) have sufficient time to prepare the permits by September 2 The licensee was planning for extensive use of engineering controls, such as auxiliary ventilation systems, during the outage. The inspector noted that a i good supply of ventilation units was availabl RAINING AND QUALIFICATIONS OF PERSONNEL (83723) l The inspector reviewed this portion of the licensee's program to determine compliance with 10 CFR 19.12 and Technical Specification 5.8 and agreement i with commitments in Chapter 12 of the Updated Safety Analysis Repor The inspector determined that the radiation protection organization has been very stable. Only one technician had terminated employment within the last 4 year. No senior radiation protection technicians have joined the radiation  ; protection staff since the last inspection, other than those who nave , participated in the licensee's initial radiation protection techaician I training progra The inspector interviewed representatives from the training department and determined that the radiation protection technician training group' continued to have three instructors. A new instructor with health physics experience was recently hired. Appropriate facilities for classes were availabl A suitable reference library and information distribution system were also available to the instructor l

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   -5-There was no official training coordinator within the radiation protection department; however, both radiation protection and training representatives stated that communications between the two departments were excellen Official meetings were held twice a year to discuss training need Informal discussions were commo The licensee continued to offer an initial training course for junior level technicians and cuntinuing training for senior level technicians. The licensee offered four to seven cycles of continuing training per yea The initial training course included training in reactor systems and radiological hazards associated with those systems. Continuing training included discussions on industry events and lessons learne The number of technicians registered by the National Registry of Radiation Protection Technologists was 80 to 90 percent of those eligibl The licensee had implemented a good examination program for screening potential contract radiation protection technicians. The test required a passing grade of 80 percent. Those successfully passing the examination were considered eligible for employment for a period of 2 years. Technicians registered by the National Registry of Radiation Protection Technologist were exempted from taking the tes Contractor cadiation protection technicians are given 3 days of training which includes leu ons learned, pertinent standing orders, and radiation protection procedure the job training and performance testing follow. Performance evaluation checklists are used to document the contract technicians'

successful demonstration of their knowledge of licensee procedure A course entitled, " Advanced Radiation Worker Training," was being presented by the radiation protection technician instructors to increase worker awareness of good radiation protection techniques. Mock-ups of piping and valves were used & simulate hardware in the radiological controlled area during the practical portion of the course. A simulated contaminant will be used shortly for added realism. Maintenance personnel were being presented the training first. Other groups will receive the training after maintenance perronne The licensee maintained a continuing, technical training program for radiation protection supervisors and professional staff. The training consisted of vendor training and professional meeting attendance by all professional staff member The licensee had three instructors for general employee, radiation worker, and respiratory protection training. During the past year, between 1200 and 1400 people were instructed. Training representatives predicted an increase to 1500 to 1700 this year because of the outage. The inspector discussed with training representatives topics presented during the courses and reviewed student handouts and determined that the training was comprehensiv Representatives from this area of training also stated that they had appropriate facilities and good resource . . - .

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. i-6-Evaluation forms were available to individuals who wished to provide comments on the course content and instructor presentatio i 6 EXTERNAL EXPOSURE CONTROLS (83750) The inspector reviewed this portion of the licensee's program to determine compliance with Technical Specification 5.8 and agreement with commitments in Chapter 12 of the Updated Safety Analysis Repor There were no major changes in the dosimetry program since the previous inspection of this area of the licensee's program. The licensee continued to use state-of-the-art equipment and be accredited by the National Voluntary Laboratory Accreditation Program in all eight dosimetry test categories (as defined by American National Standards Institute.N13.11).

As part of the dosimetry quality control program, on a quarterly basis, the licensee processed thermoluminescent dosimeters irradiated by the University of Michigan and compared results. On a monthly basis, the licensee processed blind spiked thermoluminescent dosimeters from a vendor. The inspector reviewed selected results from the ongoing quality assurance program and determined that the results were within industry standards for acceptabilit ' As an initiative to reduce radiation exposure, the licensee plans to replace the existing multi-pieco style of letdown filters with filters utilizing a ' one-piece element. The new filters also have a fluid flow pattern which travels from the inside out, reducing the amount of contaminated material deposited on the outside surface of the filter. The new design reduces handling time and possibility for direct contact with radioactive material The new filters will be installed during the 1993 refueling outag On tours of the radiological controlled area, the inspector observed that , posting of areas was as required. Extremely high radiation areas (greater than 1000 millirems per hour) were locked as required. The inspector made confirmatory measurements in different areas of the radiological controlled j area and did not identify areas needing additional posting or contro The licensee had not used the planned special exposure provision of the new 10 CFR Part 20 (20.1206). Total exposure accrued through the end of August was approximately 12.5 person rem INTERNAL EXPOSURE CONTROL (83725,83750) { The inspector reviewed this portion of the licensee's program to determine ,

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compliance with Technical Specification 5.8 and agreement with commitments in - Chapter 12 of the Updated Safety Analysis Repor In support of the new Part 20 implementation, the licensee issued RP-205, ,

"DAC-HOUR TRACKING." The inspector. determined that the licensee had a working !

system for the recording and tracking of derived air concentration hours for ! workers, although since its implementation there has been no need for tracking because of the lack of internal exposures. Whole-body counting confirmed that l

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! the licensee's investigative limits were not exceeded during the first eight L months of 199 l The inspector noted that Radiation Protection Procedure RP-201, " Radiation Work Permits," included instructions and a logic chart to aid radiation protection personnel in determining the need for engineering controls or respiratory protection equipmen The inspector reviewed selected aspects of the whole-body counting program and determined that a good program was maintained. The inspector reviewed the l qualifications of people in the dosimetry program and determined that all were qualified to perform whole-body counting and calibration CONTROL OF RADI0 ACTIVE MATERIALS AND CONTAMINATION, SURVEYS, AND MONITORING (83726,83750) ' The inspector reviewed this portion of the licensee's program to determine compliance with Technical Specification 5.8 and agreement with commitments in l Chapter 12 of the Updated Safety Analysis Report.

l ! The inspector reviewed examples of the licensee's surveys and determined that l they were complete and easy to interpre The inspector confirmed that a suitable supply of calibrated, response-checked, radiation survey instruments were available for immediate use. Instruments in the field, such as friskers, personnel contamination monitors, and portal monitors were response checked dail The licensee began decontaminating the auxiliary building overhead areas in May 1993 and intends to have the project completed before the start of the refueling outage. The licensee was taking this action to reduce the number of personnel contaminations occurring when work is done in these areas during the outag Housekeeping within the radiological controlled area was good in some areas; in other areas it was not. The inspector noted the presence of sand in Room 59, presumably brought into the area on scaffolding sections. At the end of some work days, the inspector noted that tools were scattered in several areas. Licensee representatives acknowledged that this had been a problem and stated that they were attempting to correct the situation. The inspector stated at the exit meeting that this was not a criticism of the radiation protection department, but a general observation of conditions within the radiological controlled rre The inspector noted a race shield hanging on the wall within in the tool decontamination area and another on the floor in the east safety injection pump room (Room 22). Both areas were controlled as contaminated. The inspector pointed out that the inner surfaces of the face shields could become contaminated and spread the contamination to personnel if stored in this j manner and then reused. The 'icensee took immediate action to remove the 4 faceshields and search for others. Radiation protection representatives stated that they would review the situation to determine if additiorw.1 worker ___ _____-___- _ -__________ -__ - ________--_______ - - - _ _ _ _ _ _ _ -

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   -8-guidance was needed. The licensee also used disposable face shields for some work activitie Despite the last two observations, the licensee had few personnel contamination events. Through August 31, 1993, the licensee recorded 10 skin coatamination CONCLUSIONS A comprehensive quality assurance audit was performed using a technical expert from another power reactor facilit The radiation protection department had a stable work force with very little staffing turnove Training groups inspected were sufficiently staffed with qualified instructors. A very high percentage of the radiation protection technicians were registered by the National Registry of Radiation Protection Technologists, indicating licensee attention to promoting the professional develooment of the technicians. The licensee used a good screening examination as a tool in selecting contract radiation protaction technician Presentation of an " advanced" radiation worker training course to maintenance workers indicated an increased desire to prevent contamination event A good training course for supervisors and professionals within the radiation <

protection group was maintained.

, The licensee had a properly accredited dosimetry program with state-of-the-art equipment. Areas within the radiological controlled area were properly posted

and controlled. A low person-rem exposure was maintained through routine operation A good internal exposure control program was implemente l ' Housekeeping within the radiological controlled area was adequate and excellent results were obtained by the licensee's program for control of j contaminatio j 10 FOLLOWUP DN CORRECTIVE ACTIONS FOR VIOLATIONS (92702)  ! 1 (Closed) Violation 285/9232-01: Failure to Revise a Radiation Work Permit On April 16, 1992, radiological conditions changed during the change-out of the. letdown filters, and the radiation protection technician did not stop the job to revise the radiation work permit. Consequently, the letdown filters became drier than usual, causing an airborne radioactivity proble The inspector determined that, to prevent recurrence of this violation, the I licensee took the following actions: I

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   -9-Procedure RP-201, " Radiation Work Permits," was revised to establish written guidance for work activities performed in high and very radiation area * Training given to new radiation protection technicians was evaluated to determine if additional training in such matters was warranted. The licensee determined that no changes were warrante * An assessment was performed to determine the effectiveness of the radiation protection program. A number of recommendations for improvement were submitted to licensee management as a result of the assessment. Mest had been implemented by the time of the inspectio * Procedure RP-218, " Primary Filter Change," was nearly ready for issu The inspector received a draft copy of the procedure which was set to go before the Plant Review Committee. The procedure addressed radiation protection personnel's responsibilities during such operations and addressed work delays such as that which contributed to the violatio * A design change of the letdown filters was approved (see Section 6).

10.2 (Closed) Violation 285/9232-02: Failure to Survey Lutdown Filters for Beta Radiation This violation occurred during the incident which resulted in the identification of Violation 285/9232-01. The corrective actions to prevent recurrence of Violation 285/9232-01 address this ite .3 (Closed) Violation 285/9232-03: Failure to Survey Letdown Filters for Alpha Activity This violation occurred during the incident which resulted in the - identification of Violation 285/9232-01. The corrective actions to prevent '

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recurrence of Violation 285/9232-01 address this ite .4 (Closed) Violation 285/9232-04: Failure to Perform Adeauate Reviews of Radiation Survey Results This violation occurred during the incident which resulted in the identification of Violation 285/9232-01. The corrective actions to prevent .

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recurrence of Violation 285/9232-01 address this ite .5 (Closed) Violation 285/9232-05: Failure to Perform Air Monitorina > This violation occurred during the incident which resulted in the identification of Violation 285/9232-01. The corrective actions to prevent recurrence of Violation 285/9232-01 address this ite . t

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   -10-10.6 1 Closed) Violation 285/9232-06: Failure to Post an Airborne Radioactivity Area This. violation occurred during the incident which resulted in the identification of Violation 285/9232-01. The corrective actions to prevent recurrence of Violation 285/9232-01 address this ite .7 (Closed) Violation 285/9232-07: Failure to Use Enaineerina Controls to the Extent Practicable This violation occurred during the incident which resulted in the identification of Violation 285/9232-01. The corrective actions to prevent recurrence of Violation 285/9232-01 address this ite ,
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1 PERSONS CONTACTED-1.1 Licensee Personnel

*R. L. Andrews, Division Manager, Nuclear Services
*G. R. Cavanaugh, Licensing Engineer   .
*J. W. Chase, Plant Manager A. G. Christensen, Radiation Protection Operations
*G. M. Cook, Supervisor, Station Licensing
*S. W. Gerbers, Supervisor, Radiological Health and Engineering R. G. Haug, Supervisor, Chemical and Radiation Protection Training
*W. C. Jones, Senior Vice President   !
*D. L. Lovett, Supervisor, Radiation President
*W. W. Orr, Manager, Quality Assurance / Quality Control L. D. Sills, Quality Assurance Specialist K. E. Steele, Special Projects Coordinator   ,

J. M. Uhland, Supervisor, Radiation Orientation 1.2 NRC Personnel

*R. V. Azua, Resident Inspector
*R. P. Mullikin, Senior Resident Inspector
* Denotes personnel that attended the exit meeting. In addition to the personnel listed, the inspector contacted other personnel during this inspection perio '

2 EXIT MEETING An exit meeting was conducted on August 27, 1993. During this meeting, the inspector reviewed the scope and findings of the report. The licensee did not identify as proprietary, any information provided to, or reviewed by the inspecto ;

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