IR 05000285/1997005

Insp Rept 50-285/97-05 on 970714-18.No Violations Noted. Major Areas Inspected:Plant Support

ML20151M107
Person / Time
Site:	Fort Calhoun
Issue date:	08/01/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151M106	List: IR 05000285/1997005 ML20151M101
References
50-285-97-05, 50-285-97-5, NUDOCS 9708080199
Download: ML20151M107 (27)

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ENCLOSURE'

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. U.S. NUCLEAR REGULATORY COMMISSION .

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REGION IV

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) Docket No.: 50-285

License No.: DPR-40 ,

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i Report No.: 50-285/97-05 i j Licensee: Omaha Public Power District l Facility: Fort Calhoun Station

Location: Fort Calhoun Station FC-2-4 Ad l P.O. Box 399, Hwy. 75 - North of Fort Calhoun

Fort Calhoun, Nebraska l Dates: July 14-18,1997 l Inspectors: Michael P. Shannon, Radiation Specialist, Plant Support Branch i Gilbert L. Guerra, Radiation Specialist, Plant Support Branch j Michael C. Hay, Radiation Specialist, Plant Support Branch  !

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Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety '

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I ATTACHMENTS: Supplemental Information

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9708080199 970801 PDR ADOCK 05000285

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EXECUTIVE SUMMARY

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Fort Calhoun Station

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NRC inspection Report 50-285/97-05 Plant Suocort

• High radiation areas were properly posted and controlled. Radiological controlled area boundary postings were not consistent (Section R1.1).

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. Housekeeping within the radiological controlled area was fair. Nuclear equipment operators had to dress in anti-contamination clothing to perform their daily routine duties (Section R1.1).

• The radiological work planning was effectively implemented. ALARA personnel were appropriately involved in radiological work planning and scheduling ,

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• Overall, a good ALARA program was in place, with strong senior management support and plant involvement. The 1996 exrosure goals were exceeded primarily ,

due to the failed fuel problems. Exposure goals were aggressive, challenging, and {

properly monitored by responsible ALARA personnel (Section R1.3). .i

• A number of problems were identified with the hot spot reduction program. The hot

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spot reduction program did not meet management's expectation for timely l evaluation and prioritization for removal of some hot spots (Section R1.3).

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• A non-cited violation was identified for the failure to submit a permanent shielding -

request. Engineering's department review of temporary shielding installations did not meet management's 6-month expectation on a number of occasions (Section R1.3).

• A good radiological environmental monitoring program was implemented. A non-cited violation was identified regarding the failure to initiate a condition report when an environmental sample was lost (Section R1.4).

• A very good meteorological monitoring program wa3 implemented (Section R1.5).

• Environmental monitoring stations were properly maintained with operable and calibrated equipment (Sectbn R2.1).

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• The meteorological tower was maintained in excellent condition (Section R2.2).

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• . Radiological environmental monitoring program implementing procedures contained j sufficient detail (Section R3.1).

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• Licensee staff had an excellent understanding of the radiological environmental

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monitoring program, the Offsite Dose Calculation Manual, and regulatory '

requirements (Section R4.1).

• Radiation protection training instructors were well qualified to perform their tasks.

Topics for the training cycles were not identified and developed in a timely manner.

Radiation protection management was apprvpriately involved with the development of the radiation protection training program. Greater than 90 percent of the  !

radiation protection technicians were certified as National Registry of Radiation  !

Protection Technologists (Section R5.1). l l

• Personnel responsible for implementing the radiological environmental monitoring program were properly trained and qualified (Section R5.2).

• The present organization maintained an adequate staff and provided management support for implementing the radiological environmental ~ monitoring program l (Section R6.1). 1

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• Overall. a good radiation protection quality assurance program was in place.

l Quality assurance audits and surveillances were well written and provided J management with a good tool to help assess the radiation protection program. The surveillance schedule covered the appropriate program areas; however, radiation protection management was not involved during the development of the schedule (Section R7.1).

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• Thorough, comprehensive audits of the radiological environmental program were performed (Section R7.2).

• The annual radiological environmental monitoring reports were submitted in a timely j manner and contained the required information (Section R8.1). l

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REPORT DETAILS

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Summarv of Plant Status During the inspection the plant operated at 100 percent power. No ' operational events-occurred that affected the inspection activities.

IV. Plant Support

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L R1 Radiological Protection and Chemistry Controls

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R 1.1 Extemal Exoosure Controls (83750)

a. Inspection Scope

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Selected radiation workers and radiation protection personnel involved in the-l external exposure control program were interviewed. A number of tours of the l

radiological controlled area were performed. The following items were reviewed:

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• Radiological controlled area access controls

• Housekeeping within the radiological controlled area '

• Dosimetry use b.

Observations and Findinas j l

All technical specification high radiation areas were locked and properly posted. All workers observed wore their dosimetry properly and knew to contact radiation ,

protection personnel if their electronic dosimeter alarmed.

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l No problems were identified concerning required radiological postings. However, l postings that designated radiological controlled area boundaries were not consistently posted throughout the station. For example, in the radwaste. building elevation 1007 foot, both roll-up doors in the rear of the building were posted as radiological controlled area boundary, while the personnel entrance and truck bay door were not. When this observation was discussed with radiation protection management, they stated they would review their posting procedures.

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i The inspectors noted a large percentage of rooms located throughout the  !

radiological controlled area posted as contaminated areas. During discussions with i

nuclear equipment operators, the inspectors were informed that they had to dress in ,

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anti-contamination clothing a number of times a day to perform their daily routine l

! duties. The radiation protection manager informed the inspectors that his l

{ department was aware of the situation, and efforts were underway to reduce the l amount of contaminated areas.

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Housekeeping throughout the radiological controlled area was fair. However, the inspectors noted several areas, such as, rooms 16 and 21, in which tools were laying in a contaminated area and did not appear to be involved with work in progress. Additionally, in the primary sample room located on elevation 1007 foot of the auxiliary building, the inspectors noted that latex gloves and paperwork were stuffed into an I-beam support, and additional latex gloves were laying on top of a sample chiller.

c. Conclusions

All high radiation areas were properly posted and controlled. Radiological controlled area boundary postings were not consistently posted throughout the station. All workers knew the proper response to electronic dosimeter alarms. Nuclear equipment operators had to dress in anti-contamination clothing a number of times to perform their daily routines. Housekeeping within the radiological controlled area was fair.

R1.2 . Plannina and Prenaration (83750)a.

Insoection Scope Radiation protection department personnel involved in radiation protection planning i and preparation were interviewed. The following items were reviewed: I

• ALARA job planning

• Job scheduling and sequencing

• ALARA work packages

• Incorporation of lessons-learned from similar work

• Supplies of radiation protection instrumentation, protective clothing, and consumable items b.

Observations and Findinas The maintenance 4-week look ahead schedule appeared to provide the radiation protection ALARA staff an adequate amount of time to incorporate appropriate ALARA controls for scheduled work. Radiological work package tasks were well planned. Lessons-learned from past similar work were captured and incorporated in the work packages to help enhance the ALARA work performance.

No problems were identified with the adequacy of radiation protection instrumentation, protective clothing, or consumable supplies to support radiological work.

The inspectors attended both the daily radiation protection staff and supervisors meetings. Plant status, work associated problems, and scheduled work assignments were discussed, among other department and station items. Meetings

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were conducted in a relaxed professional environment, with good open .

I communication among all personnel.

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c. Conclusions

l No problems were identified during the review of radiological work planning.

l ALARA personnel were appropriately involved in radiological work planning and j scheduling. Lessons-learned from past work activities were captured and  !

incorporated into radiological work packages. Radiation protection department meetings were held in a professional manner, with good open communication among all personnel.

R 1.3 Maintainina Occupational Exoosure As low As is Reasonably Achievable (ALARA)

(83750)

a. Inspection Scope

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Radiation protection personnel involved with the ALARA program were interviewed.

The following areas were reviewed:

• ALARA committee support

• Exposure goal establishment and status

• Hot spot reduction program

• Temporary shielding program

• ALARA suggestion program - i i

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Observations and Findinas Exoosure Goals A review of the station ALARA review committee minutes from October 1996 revealed that the ALARA review committee was supported by all major station work groups. Additionally, the ALARA review committee was appropriately involved with station exposure goal setting and monitoring.

The licensee established a fuel integrity committee to review the problems and make recommendations associated with the failed fuelissue. The fuelintegrity committee recommended not to shutdown the reactor as originally scheduled and continue aggressive purification of the reactor coolant system. Using sub-rnicron filtration and a two-step reactor rampdown the licensee was able to reduce radiation exposure by approximately 36 percent. The inspectors noted that the two-step '

i reactor rampdown which was implemented to address exposure concerns delayed the start of the refueling outage by 14 days. There was strong senior management and operations department support of the fuelintegrity committee recommendations. The strong management support was noted to be a strength of j the ALARA program.

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l The 1996 station on-line exposure goal was 19 person-rem and the refueling outage exposure goal for 1996 was 119 person-rem. These goals were established in late 1995 prior to the licensee's knowledge of the full extent of the failed fuel problem.

The actual exposures for 1996 were 36 person-rem on-line, and 190 person-rem for the refueling outage. During discussions with the radiation protection ALARA staff, the inspectors were informed that the on-line person-rem goal was exceeded primarily because station management decided to perform some scheduled outage

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work while on line due to the projected increased area dose rates after the plarit shutdown.

A large contributor to the refueling outage exposure was the increased work associated with eddy current testing of the steam generators. While performing i eddy current testing, the work scope changed from 20 percent to 100 percent of the tubes to be inspected. During discussions with the radiation protection staff,

the inspectors were informed that better contingency planning for a scope increase

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could have been performed during the 1996 outage planning process. The l inspectors noted that the licensee has formed a steam generator sub-committee to review lessons-learned and enhance the ALARA performance of this task for the 1998 refueling outage.

l The 1997 exposure goal is 38 person-rem. As of July 17,1997, the exposure was '

12 person-rem. All departments were actively involved in the exposure goal setting  ;

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and development process. Exposure goals were aggressive and properly monitored i

by the radiation protection ALARA section. The inspectors concluded that the 1997 exposure goal was challenging, and that the licensee willlikely meet their exposure l l goal.

The following table shows that licensee's yearly and 3-year person-rem rolling average and the pressurized water reactor 3-year average for 1994-1996. As the table indicates, even with the failed fuel problems, the licensee has remained below

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the pressurized water reactor national average.

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1994 1995 1996

, Yearly Totals 23 139 226

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3 year Average 145 106 129 '

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PWR National 131 170 Not Available Average (Person-rem)

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Hot Spot Reduction Proaram A review of the hot spot reduction program identifieo that there were 12 hot spots presently located throughout the plant, with four hot spots that were removed in l 1997, year. Hot spot surveys were updated during the performance of routine area '

< surveys. During discussions with the radiation protection ALARA supervisor, the

{ inspectors determined that the ALARA group was responsible for oversight of the hot spot reduction program. Although the operations department helped during the removal of hot spots, they were not a primary partner of the hot spot reduction program. The inspectors commented that the involvement of the operations department as a primary partner has helped reduce the amount of hot spots at other licensed facilities. Radiation protection management stated that they would review their program to address the inspectors' comment.

During the review of the hot spot packages maintained by the licensee, the inspectors noted that 3 of the 12 hot spots were not prioritized or evaluated for removal. One of these 3 hot spots was identified on January 9,1997, while the other two were identified June 13,1997. All 3 of these hot spots were located in l

the safety injection pump room 21, an area where operations personnel were '

, required to enter at least once per shift. The inspectors noted that one of these hot

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spots was reading as high as 1500 millirem on contact and 100 millirem at 30 centimeters.

Section 2.2.1 of Radiation Protection Procedure RP-306, Revision 7, " Hot Spot and ,

i Point Source Identification and Tracking" states that, the ALARA supervisor is responsible for prioritizing hot spots for immediate actions if they become major dose contributors. Section 7.3 of the same procedure states that, every new hot l

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spot will be evaluated for removal, and the results documented on the hot spot identification form.

During discussions with the licensee at the exit meeting on July 18,1997, the

inspectors were informed by the plant manager, that although he agreed that the precedure was not followed, there was no time requirement to accomplish the above listed steps of the procedure, and it was management's expectation that the evaluation and prioritization should be completed within 30 days of a hot spot being identified.

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( however, this did not relieve the licensee from the procedural requirement to l evaluate and prioritize the removal of hot spots in a timely manner to reduce l individual and station radiation exposures.

ALARA Suaaestion Proaram No problems were noted during the review of the ALARA suggestion program. In

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1996, there were 58 ALARA suggestions submitted,17 of these remain open as of l

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July 16,1997. Additionally,12 ALARA suggestions for 1997, have been submitted as of July 16,1997,10 remain open. The inspectors commented that timely evaluation of ALARA suggestions helped keep worker interest. The l Inspectors were informed that the ALARA review committee recently expressed additional interest in the status of ALARA suggestions, and this should help reduce the amount of open ALARA suggestions.

Temporary Shieldina Proaram l Three temporary shielding installations were in place as of July 17,1997. One temporary shielding request, TSR 90-15, which covered two installations, one in each of the safety injection pump rooms, was installed on July 26,1990, another temporary shielding installation, TSR 95-33, was installed on July 5,1995, and the last temporary shielding installation, TSR 97-10, was installed June 25,1997.

A review of the temporary shielding packages identified that:

(1) Packages were not organized; however, most survey / engineering evaluations were in the package, but i difficult for personnel to locate.

(2) Management's expectation for engineering review of the temporary shielding installation every 6-months was missed for both i the 1990 and 1995 installations on a mber of occasions, and in some cases was not reviewed for as long as 12-months.

(3) An engineering assistance request was submitted for the 1990 temporary shielding installation in 1990, but it was lost in the system. A second engineering assistance request was submitted in June of 1991, however, engineering did not respond to this request until March 30,1992, denying the engineering assistance request and recommending the request be submitted as a modification. No actions were taken by the licensee until July 3, 1997, wl- e 9 engineering change notice was submitted. This engineering change notice wN oemg evaluated by the erigineering division as of . July 17,1997.

The review of the temporary shielding packages also identified that a request for permanent shielding was not written for the 1995 temporary shielding installation, until July 3,1997, approximately 2 years after it was originally installed. Section 7.4.17 of Radiation Protection Procedure RP-307, Revision 6a, "Use and Control of Temporary Lead Shielding," states, in part, if it is known that a temporary shielding installat;on will not be removed prior to the expiration of the initial authorization per.od, initiate action to provide a permanent installation. The inspectors noted that the initial authorization period for temporary shielding installation, TSR 95-33 was 6-months.

Technical Specification 5.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33. Section 7.e.9 of Appendix A requires procedures for the implementation of the ALARA program. The inspectors identified the failure to submit a request for permanent shielding as required by Section 7.4.17 of Radiation Protection Procedure RP-307, as a violation of Technical Specification 5.8.1. The

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I inspectors identified no actual radiological safety consequence associated with this item. This failure constitutes a violation of minor significance and is being treated as a non-cited violation, consistent with Section IV of the NRC Enforcement Policy (50-285/9705-01).

c. Conclusions

The ALARA review committee was appropriately involved with station exposure goal setting and monitoring and supported by all major station work groups. Senior i management demonstrated strong support of the ALARA program by approving the recommendations of the fuel integrity committee. The station's 1996 on-line and refueling outage exposure goals were exceeded primarily due to the failed fuel problems. All station departments were actively involved in the station exposure goal setting and development process. Station exposure goals were aggressive, challenging, and properly monitored by the radiation protection ALARA section. The hot spot reduction program did not meet management's expectation for timely evaluation and prioritization for the removal of some hot spots. Engineering review of temporary shielding installations exceeded management's 6-month expectation on a number of occasions. A non-cited violation was identified for the failure to submit a permanent shielding request as required by radiation protection procedures.

R1.4 Radioloaical Environmental Monitorina Proaram (84750)a.

Insoection Scope The inspector reviewed the radiological environmental monitoring program to determine compliance with the requirements in the Offsite Dose Calculation Manual.

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Observations and Findinas The inspector noted that four missed samples were reported in the 1996 annual radiological environmental operating report. Three of the missed samples were associated with an air sample pump failure which was not replaced until two more sample periods were missed. Because, prompt action was not taken, two more  !

environmental samples were missed. Although, procedures were followed, the current process did not prevent the additional missed samples. The inspector i commented that it is atypical where more than one sample is missed due to purnp l

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failure, and the program should have ensured prompt sample pump replacement l before the collection of the next sample. The inspector discussed this issue with I instruments and controls, and chemistry staff and noted that actions were being  ;

I taken to address this issue and prevent recurrence.

The fourth sample was missed due to windy conditions, when an environmental particulate sample filter was blown away while the technician was changing the sample media. The inspector noted that no condition report was initiated in I

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i accordance with Section 2.2 of Standing Order Procedure, SO-R-2, " Condition Reporting and Corrective Action," Revision 4. Section 2.2 states that, "this procedure applies to, and requires origination of a Condition Report for... equipment ,

re!ated events, documentation deficiencies, non-routine outside agency I notifications, operational events, testing deficiencies, security infractions, human  !

performance crrors, personnel safety issues, radiological occurrences, or other circumstances which impact or potentially impact safe and/or reliable operation of Fort Calhoun Station, or events identified which are, or are suspected of being, adverse to quality."

The inspector noted that this incident was recorded in the proper sampling logs and j in the annual radiological anvironmental operating report. However, a condition '

report was not initiated to address this issue. It was noted that a corsdition report was initiated during the inspection. Technical Specification 5.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33. Section 1.d of Appendix A requires procedures for procedure adherence and temporary chanc,e method. The inspector identified the failure to initiate a condition report when in environmental sample was lost as a violation of Technical Specification 5.8.1. The inspector identified no actual safety consequences associated with this item. This failure constitutes a violation of minor significance and is being treated as a non-cited violation, consistent with section IV of the NRC Enforcement Policy.

(50-285/9705-02)

Overall, the inspector found that licensee staffing was adequate and management controls were appropriate. Except for the reported missed samples, the collection, processing, and analyses of radiological environmental media samples were conducted in accordance with station procedures and the offsite dose calculation manual. Sample analyses were performed by an outside vendor. The biennial land use census was performed as required. The annual radiological environmental operating reports were written and submitted to the NRC as required.

c. Conclusions

A good radiological environmental monitoring program was implemented in accordance with Offsite Dose Calculation Manual requirements. A non-cited violation was identified for the failure to initiate a condition report for a lost environmental sample.

R1.5 Meteoroloaical Monitorina Proaram (84750)i j

a. Inspection Scope

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The inspector reviewed the meteorological monitoring program to determine agreement with the recommendations in NRC Regulatory Guide 1.23 and compliance with the commitments in the Updated Final Safety Analysis Report.

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Also, the inspector reviewed data collection and review procedures, and discussed -

the data results with licensee personnel.

b. Observations and Findinas i

The guidance in Regulatory Guide 1.23 was utilized for implementing the licensee's I meteorological program. The meteorological tower system provided good monitoring redundancy by providing dual instrumentation at the required monitoring levels. Signals from the meteorological monitoring instrumentation were collected by the plant computer and displays of meteorological data were available to the operations staff and at the emergency facilities.

The inspector identified two areas in which program enhancements could be made.

Chemistry technicians responsible for validating the meteorological data and compiling the data for the annual repcrts were not noting or flagging in their data base when the meteorological tower was down for calibration. The inspector commented that this is important so valid meteorological data can be obtained from another source. This is because the meteorological tower continues to log data during calibration, however the tower is not in its normal configuration. The I,icensee stated that they plan to review their method of recording data while the system is being calibrated.

Regulatory Guide 1.23, " Meteorological Measurement Program for Nuclear Power Plants," suggests that calibrations on the meteorological instrementation should be conducted a least semi-annually. The inspector noted that the last two calibrations, prior to the one conducted during this inspection exceeded the 6-month calibration frequency by more than  ;

25 percent. Fort Calhoun Station management acknowledged the I inspectors' comments during the exit meeting on July 18,1997.

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! Although, no operability requirements for the meteorological tower instrumentation l were contained in the Fort Calhoun Technical Specifications, the licensee ,

maintained a very good meteorological monitonng program.

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c. Conclusions

l l i A very good meteorological monitorir.g program was implemented. The inspector l determined that a proper data collection and review program was in place. In

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general, the performance of the meteorological monitoring program satisfied the commitments of the Update Final Safety Analysis Report and agreed with the guidance contained in Regulatory Guide 1.23.

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- 13-R2 Status of Radiological Protection and Chemistry Facilities and Equipment R2.1 Environmental Monitorina Eauipment and Facilities (84750)

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Insoection Scope The inspector visited selected environmental sampling stations to verify that sampling locations were properly maintained and equipment was operable and properly calibrated. Sample preparation and storage f acilities were inspected to verify that sufficient supplies and spare equipment were available.

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Observations and Findinas The inspector accompanied an environmental specialist during the collection of

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required environmental samples. Several different sampling sites were visited. The i following types of sampling locations were inspected: milk, vegetation, surface

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water, and thermoluminescent dosimeters. These sites were appropriate to the Fort )

! Calhoun Station. Good sampling techniques were observed.

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The inspector accompanied and observed an instrument and controls technician collect air particulate and charcoal cartridge samples for shipment and analysis. The instrument and controls staff was also responsible for the maintenance and calibration of the air samplers. Approved procedures were used for the air sampling

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process and sample preparation for shipment and analysis. The inspector noted j that air sampler equipment in use was properly calibrated and operational. A timing I device was used on each air sampler to track operation history.

During the inspection of the selected environmental sampling locations, the

inspector verified that the sampling locations were as described in the Offsite Dose ,

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Calculation Manual. Samples were properly prepared for shipment to a vendor j laboratory for analyses.

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The inspector observed the facilities used for environmental media sample storage and preparation. The sample preparation / storage area was equipped with the necessary spare equipment and supplies to perform the required radiological environmental monitoring program sampling activities.

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Conclusions The licensee maintained sufficient supplies and spare environmental sampling equipment to perform the activities described in the Offsite Dose Calculation Manual. Environmental monitoring stations were properly maintained with operable j and calibrated equipment.

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R2.2 Meteoroloaical Monitorina Eauioment (84750)a.

Inspection Scone The inspector observed the meteorological instrumentation at the meteorological tower and reviewed the associated calibration records to ensure that the meteorological instrumentation on the towers was operable, calibrated, and maintained in accordance with written procedures, the guidance in Regulatory Guide 1.23, and Updated Final Safety Analysis Report.

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Observations and Findinas The meteorological tower was maintained in excellent condition and provided excellent data recovery. Data recovery was 96 percent for 1996.

The inspector toured the meteorological tower with the system enginecr and instrument and controls technicians responsible for performing periodic calibrations of the monitoring equipment. The licensee maintained an excellent meteorological tower with dual monitoring instrumentation at the 10 and 60 meter levels. The instrumentation at these levels included wind speed, wind direction, and temperature sensing instrumentation. Instrumentation, including recording and transmitting equipment, was noted to be in good operating condition. During this inspection the meteorological tower monitoring equipment was being calibrated.

The inspector reviewed selected meteorological instrumentation calibration procedures and associated records. The calibrations were conducted in accordance with approved procedures. All records reviewed indicated that the meteorolog; cal monitoring instruments were being properly maintained, tested, and calibrated. The inspector noted that the instrumentation agreed with Regulatory Guide 1.23 i recommendations and the licensee's Updated Final Safety Analysis Report.

c. Conclusions

The meteorological tower was maintained in excellent condition and provided excellent data recovery.

R3 Radiological Protection and Chemistry Procedures and Documentation R3.1 Offsite Dose Calculation Manual and Radioloaical Environmental Monitorina implementina Procedures (84750)

a. Inspection Scope

The inspector reviewed the Offsite Dose Calculation Manual and implementation procedures regarding the radiological environmental monitoring program.

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b. ' Observations and Findinas The implementing procedures described the responsibilities for collection,

' documentation, and shipment of environmental media samples collected around the Fort Calhoun Station. These documents contained sufficient detail for conducting the radiological environmental monitoring program activities. The inspector determined that the requirements. of the offsite dose calculation manual were-appropriately implemented by these procedures.

Revision 7 to the Offsite Dose Calculatiorf Manual had been issued 'since the last inspection. The inspector noted that the changes did not result in a decrease of the effectiveness of the radiological environmental monitoring program.

c. Conclusions

Radiological environmental monitoring program implementing procedures contained sufficient detail.

R4 Staff Knowledge and Performance R4.1 Knowledae of Radioloaical Environmental Monitorina Proaram Reauirements (84750)a.

Insoection Scope The inspector observed and held discussions with personnel involved with the

. implementation of the radiological environmental monitoring program to determine their knowledge of environmental sampling and implementing procedures.

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Observations and Findinas Licensee staff were properly trained and qualified to perform the environmental sampling activities and were familiar with the requirements of the radiological 1

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environmental monitoring program.

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i The inspector noted that good practices were used by the environmental specialist and instrument and controls technician in maintaining sample integrity. All activities observed were cunducted in an orderly fashion. The inspector noted that the  !'

licensee's staff knowledge of sampling procedures, the Offsite Dose Calculation Manual, and NRC requirements was excellent.

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c. Conclusions

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Licensee staff had an excellent understanding of the radiological environmental monitoring program, the Offsite Dose Calculation Manual, and regulatory j requirements.

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R5 Staff Training and Qualification in Radiological Protection and Chemistry l

R5.1 Radiation Protection Staff Trainina a. Insoection Scope (83750)

Personnel involved with radiation protection technician training were interviewed.

The following items were reviewed:

• Radiation protection instructor qualifications

• Radiation protection technician training lesson plans

• Radiation protection technician on-the-job training / evaluation programs

• Radiation protection management over sight of the training program b. Observations and Findinas Both radiation protection training instructors were well qualified, and had strong operational and technical backgrounds, with a number of years of applied radiological experience. Additionally, both instructors were certified as National Registry Radiation Protection Technologist.

A radiation protection continuing training schedule was developed for 1997, which identified 4 training cycles (one per quarter). However, topics for each of the two cycles which were conducted had not been identified and developed until approximately one week before the scheduled training. Topics for the remaining 2 cycles have not been identified as of July 17,1997. This issue was identified during a training department self-assessment performed in April 1997, but no actions have been taken to correct this item. The inspectors commented that early topic identification and training lesson plan development could enhance the radiation protection training program. The licensee acknowledged the inspectors' comment.

Lesson plans were well organized, and site and industry lessons-learned were incorporated in the plans. The inspectors noted good use of course feedback and radiation protection supervisory observation forms to improve the course content.

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Radiation protection management was appropriately involved in the development of the training topics.

The on-the-job training and evaluation programs were reviewed. Tasks listed were appropriate for the duties assigned, and on-the-job training and evaluation guidelines were clearly stated. The inspectors concluded from interviews held with the training and radiation protection staff, that radiation protection management was l properly involved in the development of the on-the-job training and evaluation programs.

The inspectors noted that greater than 90 percent of the radiation protection technicians were certified as National Registry of Radiation Protection Technologists.

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c. Conclusions

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Radiation protection training instructors were well qualified and had strong .

operational and technical radiation protection backgrounds. Topics for the first and  ;

second training cycles were not identified and developed until a week before the  !

scheduled start date. Topics for the last 2 quarter training cycles for 1997 have not i been identified as of July 17,1997. Course feedback and radiation protection -'

supervisory forms were appropriately used to improve the course content.

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Radiation protection management was appropriately involved with the development of the radiation protection training program. Greater than 90 percent of the radiation protection technicians were certified as National Registry of Radiation Protection Technologists.

R5.2 Trainina for Environmental Monitorina Activities (84750)

a. Inspection Scope

The training and qualification programs for the technical staff responsible for implementing the radiological environmental monitoring program were reviewed.

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Observations and Findinas A training program was maintained for instrument and control technicians who perform environmental air sample collections. The inspector noted that training had been given to the current staff of instrument and control technicians. Also, this training was incorporated into the lesson plans for future training of other instrument and control technicians, The environmental specialist and analyst had been in their positions for several years and were well qualified to perform their assigned duties. These individuals had several years of experience with Offsite Dose Calculation Manual requirements.

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c. Conclusions

Personnel responsible for implementing the radiological environmental monitoring program were properly trained and qualified.

j R6 Radiological Protection and Chemistry Organization and Administration R6.1 Environmental Monitorina (84750)a.

Insoection Scope The organization, staffing, and assignment of the radiological environmental monitoring program responsibilities were reviewed.

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b. Observations and Findings

l The chemistry department was responsible for the implementation of the radiological environmental monitoring program. An environmental specialist and an analyst in the system-chemistry group were responsible for impitmenting and  ;

maintaining all aspects of the radiological environmental monitoring program.

The inspector noted that management changes had occurred, however the staff for the radiological environmental monitoring program had remained unchanged.

c. Conclusions

The present organization maintained adequate staffing and provided management support for implementing the radiological environmental rnonitoring program.

R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Quality Assurance Audits and Surveillances. and Radiation Deoartment Self-Assessments and Radioloaical Occurrence Reoorts (83750)i a.

Insoection Scoce Selected personnel involved with the performance of quality assurance audits and surveillances, and radiation department self-assessments were interviewed. The following items were reviewed:

• Qualifications of personnel who performed quality assurance audits and surveillances

• Quality assurance audits

• Quality assurance surveillances

• Radiation protection department self-assessments

• Radiological condition reports b.

Observations and Findinas Audits and Surveillances One individual was assigned as the lead quality assurance auditor to oversee radiation protection activities. This individual had a strong auditor background and appropriate applied radiation protection experience to provide management with meaningful insight of the radiation protection program.

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The auality assurance radiation protection surveillance schedule covered the

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not involved during the development of the surveillance schedule. The inspectors commented that the involvement of radiation protection management during the planning stages of the surveillance schedule could help prioritize which surveillance would provide the station with a more timely assessment of an agreed upon weak program area. Quality assurance management stated that they would evaluate the i inspectors comment for program improvement.

I Nine quality assurance radiation protection surveillance reports written since June 1996, were reviewed. These surveillances covered a broad range of radiation protection ai .iv;&c cr.d provided management with a good tool to assess performance of the radiation protection program. During the review of the quality assurance surveillance program, the inspectors were informed, by quality assurance personnel that when a recommendation was written and documented in the commitment identification document (CID) program, the originator was required by Nuclear Operations Procedure NOD-QP-23, Revision 10, " Commitment Action Tracking System," to review and determine the adequacy of the response. On December 2,1996, quality assurance personnel documented that the schedule surveillance for radiation work permits and ALARA programs would not be performed because a thorough radiation protection self-assessment of the same areas was performed by the corporate health physit.s group in September 1996.

Thirteen commitment identification document recommendations were identified during this assessment. The inspectors noted that although the program allows quality assurance personnel to take credit for a department's self-assessments in their surveillance program, it does not involve the quality assurance department review regarding the adequacy of the responses to the recommendation because they were not the originator. The inspectors commented that this situation could circumvent the quality assurance surveillance program. Quality assurance management acknowledged the inspectors' comment and stated that they would re-evaluate their prngram.

The radiation protection program audit which was performed between March 5, and April 1,1996 was a good assessment of the radiation protection program. The audit was comprehensive and covered the major aspects of the radiation protection program. The inspectors noted that in addition to qualified Fort Calhoun staff members, the audit team was comprised of technical experts from other nuclear power stations. The audit identified 4 findings which were tracked by the licensee's condition reporting system. The condition reporting system was used by the licensee to track corrective actions. The inspectors reviewed the corrective actions pertaining to this audit and determined that they were closed in a timely manner and, in general, appeared appropriate to correct the identified deficiencies.

The inspectors noted that the radiation protection program audit frequency was once every three years, but that the quality assurance program does not require the lead auditor to assess the effectiveness of the audit findings until the next audit.

The inspectors commented that a 3-year period between problem identification and assessment of corrective actions could result in the lack of timely response. Quality j l

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assurance management stated they would review the program to address the inspectors' comment.

Self-Assessments -

No problems were identified during the review of the self-assessment program.

Eleven radiation protection department self-assessments were performed since September 1996. The self-assessments covered the appropriate areas of the radiation protection program to provide management with good oversight of program performance. Self-assessments were well written and identified a number of improvement items. Improvement items were tracked by the licensee's commitment identification document (CID) system, which was used to track recommendatians. Selected recommendation responses were reviewed by the.

inspectors and were determined to be timely and appropriate to correct the improvement item. The inspectors noted that some of the 11 self-assessments l were performed using technical experts from other nuclear power stations. The use l of technical experts from other nuclear power stations for department self- l assessments was determined to be a program strength.

j During the review of this program the inspectors noted that the lead quality assurance auditor did not receive a copy of department self-assessments and was not kept abreast of identified self-assessment improvement items. The inspectors commented that sending a copy of department self-assessments to the quality assurance lead auditor could provide an independent assessment of program areas l for improvement. Radiation protection management stated they would review the program to address the inspectors' comment.

Radioloaical Condition Reports l

No problems were identified during the review of radiological condition reports. The inspectors determined that the licensee's threshold for problem identification was appropriate. Recommendations to prevent a reoccurrence appeared to be appropriate and, in general, corrective actions were closed out in a timely manner.

• The inspectors noted that the lead quality assurance radiation protection auditor did not receive copies of radiological condition reports. The inspectors commented that informing the lead quality assurance auditor about condition reports written against their assigned program area could provide an independent assessment of program area weaknesses and enhance the program. The licensee acknowledged the inspectors' comment. No negative trends were identified during this review.

c. Conclusions

Overall, a good quality assurance program was in place. Quality assurance audits and surveillances were well written and provided management with a good tool to

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help assess the radiation protection prograrn. The effectiveness of audit findings was not required by the quality assurance program to be evaluated until the next

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] audit of a particular area. The surveillance schedule covered the appropriate

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program areas; however, radiation protection management was not involved during the development of this schedule. Technical experts from other nuclear power

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stations were used to perform quality assurance audits and radiation protection  ;

department self-assessments. No negative trends were identified during.the review

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of radiological condition reports.

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R7.2 Audits of Environmental Monitorina Activities (84750) I l

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Inspection Scoce l l Quality assurance audit reports concerning the radiological environmental monitoring and meteorological programs were reviewed.

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Observations and Findinas Good quality assurance audits and surveillances were performed. Biennial audits were conducted which adequately covered the activities of the radiological environmental monitoring program. The audit teams included specialists from other utilities. The audits identified items for improvement. Also, two surveillances for the radiological environmental monitoring program were performed per year. Also, chemistry self-assessment was performed in 1996 which reviewed radiological environmental monitoring program activities.

The inspector noted that the above audits, surveillances, and self-assessments were comprehensive, thorough, and provided management with the appropriate oversight of the radiological environmental monitoring program. Quality assurance surveillances were satisf actory to evaluate the licensee's performance and provide periodic management oversight. Audit findings were corrected in a timely manner.

The licensee used a contractor laboratory to perform radiochemistry analyses on environmental media samples. Vendor audits were performed for contractors performing ~ analysis services for the radiological environmental monitoring program.

Fort Calhoun Station lead the Nuclear Procurement issues Committee (NUPIC) audit performed in April 1997, of the vendor laboratory. These audits verified the implementation of relevant procedures for providing the radiological analyses of environmental monitoring samples in accordance with NRC Regulatory Guide 4.15.

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The contractor laboratory participated in the Environmental Protection Agency's Interlaboratory Comparison Program as required by the Technical Specifications.

The inspector reviewed the contractor laboratory's performance as reported in the Annual Radiological Environmental Operating Reports and verified that good agreement was achieved.

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Thorough, comprehensive audits were performed. The audits identified items for improvement and evaluated the performance and implementation of the radiological ,

environmental monitoring program. Audits were performed at the required frequency.

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R8 Miscellaneous Radiological Protection and Chemistry issues l l

R8.1 Annual Environmental Operatina and Effluent Release Reports (84750J l

a. Inspection Scope

The inspector reviewed the annual reports concerning radiological environmental mor.itoring program activities to determine compliance with the requirements in ,

Technical Specifications and the Offsite Dose Calculation Manual.

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Observations and Findinas Good annual radiological environmental operating and annual radioactive effluent l reports were written. The reports were submitted in a timely manner and contained '

the required information. Any discrepancies or missed samples, including the summary of the results of the biennial land use census, were reported as required.

The inspector determined that the Technical Specification required sampling, analyses, and reporting requirements were met.

The 1994 and 1995 Annual Radioactive Effluent Release Reports included required meteorological data,

c. Conclusions

l The Annual Radiological Environmental Operating and Annual Radioactive Effluent Relear,e Reports were submitted in a timely manner. The reports contained the required information.

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V. Manaaement Meetinas l

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Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at an exit meeting on July 18,1997. Regarding the hot spot issues discussed in Section R1.3, the plant manager stated, that although he agreed that the hot spot reduction procedure was not followed, there was no specific time requirement to accomplish the steps listed in the procedure. However, it was management's l

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expectation that the evaluation and prioritization should be completed within 30 days of a hot spot being identified. The licensee acknowledged the findings presented. No proprietary information was identified.

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l ATTACHMENT I

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PARTIAL LIST OF PERSONS CONTACTED Licensee W. Gates, Vice President - Nuclear R. Andrews, Division Manager, Nuclear Assessments

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J. Chase, Plant Manager ,

A. Costanzo, Environmental Specialist I T. Dukarski, Supervisor, System Chemistry J. Gasper, Manager, Nuclear Projects S. Gebers, Manager, Radiation Protection R. Haug, Corporate Health Physicist R. Hodgson, Supervisor, ALARA L. Kusek, Manager, Quality Assurance E. Matzke, Station Licensing R. Phelps, Manager, Station Engineering C. Sterba, System Engineer M. t sar, Manager, Corrective Action J. i. ._, Manayr Nuclear Licensing

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D. Trausch, Ms mager, Nuclear Safety Review M. Wilson, Environmental Analyst NRC W. Walker, Senior Resident inspector B. Murray, Chief, Plant Support Branch INSPECTION PROCEDURE USED 83750 Occupational Radiation Exposure 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF ITEMS OPENED AND CLOSED Opened 285/9305-01 NCV Failure to submit a request for permanent shielding l l l 285/9705-02 NCV Failure to initiate a Condition Report 1

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285/9705-01 NCV Failure to submit a request for permanent shielding

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285/9705-02 NCV Failure to Initiate a Condition Report i

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LIST OF

DOCUMENTS REVIEWED

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Radiation Protection Proaram

Standing Order SO-R-2, " Condition Reporting and Corrective Action," Revision 4 )

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Standing Order S0-G-111, " Performance of Self Assessments," Revision 2 l

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Radiation Protection Procedure RP-204, " Radiological Area Controls," Revision 22

Radiation Protection Procedure RP-306, " Hot Spot and Point identification and Tracking," 1

Revision 7

Radiation Protection Procedure RP-307, "Use and Control of Temporary Lead Shielding,"  !

Revision 6

Radiation Protection Procedure RP-309, " Radiation Protection Self-Assessment Program,"

Revision 5

Radiation Protection Procedure RP-AD-300, "ALARA Program," Revision 6

Nuclear Operations Division Procedure NOD-QP-23, " Commitment Action Tracking

System," Revision 10

Quality Assurance Audit Report #58, " Radiation Protection and ALARA," April 19,1996

Quality Assurance Surveillance Report H-96-2, "Use of ALARA Planning Worksheet"

Quality Assurance Surveillance Report H-96 3, "Use of ALARA Planning Worksheet"

Quality Assurance Surveillance Report H2-96-1, " Contamination Control"

Quality Assurance Surveillance Report H5-96-1, " Respiratory Protection"

Quality Assurance Surveillance Report H-3, " Work Permits - ALARA"

Quality Assurance Surveillance Report H14-96-1, "RP Refueling Activities"

Quality Assurance Surveillance Report H6-96-2, " Radiological Instruments"

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Quality Assurance Surveillance Report H1-97-1, " Radiological Operations"

Quality Assurance Surveillance Report H3-971, " Work Permits - ALARA"

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A Summary of Radiological Condition Reports Written since January 1996

Radioloaical Environmental Proaram

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Procedures:

CH-ST-RV-0001 Environmental Sample Collection-Water, Revision 2,' April 15,1997

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CH-ST-RV-0002 Environmental Sample Collection-Milk, Revision 2, December 14,1995 i

CH-ST-RV-0003 Environmental Sample Collection-Direct Radiation / Gamma Dose Quarterly

Thermoluminescent Dosimeters (TLD), Revision 1, December 14,1995

CH-ST-RV-0004 Environmental Sample Collection-Sediment, Revision 1, December 14,

1995

CH-ST-RV-0005 Environmental Sample Collection-Fish, Revision 1, December 14,1995

CH-ST-RV-0006 Environmental. Land Use Survey, Revisicn 1, December 14,1995

CH ST-RV-0007 Environmental Sample Collection-Vegetables or Food Products, Revision 1,

December 14,1995

CH-ST-RV-0008 Environmental Sample Collection-Air Monitoring, Revision 3, June 18,

1997

CH-ST-RV-0009 Environmental Sample Collection-Direct Radiation / Gamma Dose During

Site Area and General Emergencies or Annual Exchange Thermoluminescent Dosimeters

(TLD), Revision 1, December 14,1995

CH-ST-RV-0010 Environmental Monthly Progress Report Receipt, Revision 1,

December 14,1995 l

IC-ST-RM-0100 Weekly Operational Check of Environmental Monitors OAP-A-(l), OAP-B-(l),

OAP-C-(t), OAP-D-(l), OAP-E-(C), and OAP-F-(C), Channels RM-035, RM-036, RM-037, RM-

038, RM-039, and RM-040, Revision 16, June 18,1997

SO-R-2 Condition Reporting and Corrective Action, Revision 4, May 15,1997

CH-AD-0049 Annual Meteorological Data, Revision 1, April 11,1996

IC-CP-01-6289 Calibration of Meteorological Instrumentation, Revision 1,  ;

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Audits and Surveillances:

Quality Assurance Surveillance Reports

B1-95-1, Radiological Effluent Report, August 2,1995

B3-95-1 Environmental Monitoring, Augus't 2,1995

B3-96-1, Environmental Monitoring, July 1,1996

B1-96-1, Radiological Effluent Release Report, September 9,1996

B3-96-2, Environmental Monitoring, November 13,1996

Quality Assurance Audits

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63A, Radiological Effluent Technical Specifications, January 4,1995 i

63, Radiological Effluent Program, February 6,1997

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NUPIC Audit A-SE-94-07, conducted September 20-23,1994  !

NUPIC Audit 97-002, conducted April 21-24,.1997 l

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Annual Radioactive Effluent Release Report - 1995 and 1996

Annual Radiological Environmental Operating Report - 1995 and 1996

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