IR 05000285/1998026
| ML20198J215 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/17/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198J176 | List: |
| References | |
| 50-285-98-26, NUDOCS 9812300116 | |
| Download: ML20198J215 (15) | |
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
Docket No.:
50-285 l
License No.:
DPR-40 Report No.:
'50-285/98-26 Licensee:
Omaha Public Power District
i Fac;lity:
Fort Calhoun Station Location:
Fort Calhoun Station FC-2-4 Adm., P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates:
November 31 through December 4,1998 Inspector:
Michael P. Shannon, Senior Radiation Specialist Approved By:
Blaine Murray, Chief, Plant Support Branch
Attachment:
Supplemental information L
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m 9812300116 981217 PDR ADOCK 05000285 G
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-2-l EXECUTIVE SUMMARY Fort Calhoun Station NRC Inspection Report 50-285/98-26
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Plant Support Personnel exiting the radiological controlled area used contamination equipment
properly. Radiation workers wore personnel dosimetry properly. Housekeeping
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throughout the radiological controlled area was very good. Trash and laundry containers were properly maintained to limit the spread of potentially contaminated material (Section R1.1).
A good ALARA work planning program was in place. The station's scheduling program
allcwed ALARA personnel sufficient time to provide appropriate ALARA controls. Work packages incorporated site and industry lessons learned from past similar work (Section R1.2).
Overall, a good ALARA program was implemented. Experure goals were challenging.
- The use of a Sub-ALARA committee to develop the station exposure goals was a strength in accomplishing department " buy-in" to the station's goals. The licensee's projected 3-year average for 1996-1998, of 164 person-rem will probably be above the pressurized water reactor 3-year national average. The 1998 projected dose of 224 person-rem was primarily the result of elevated plant radiation levels due to leaking fuel.
The licensee implemented effective ALARA controls in response to the challengers presented by the leaking fuel. Some station departments did not attend a!! the ALARA committee meetings (Section R1.3).
A good hot spot reduction program was in place. An excellent temporary shielding
program was implemented. However, the ALARA suggestion program did not evaluate dose savings to the station, or provide timely notification that an ALARA suggestion was accepted to the originator (Section R1.3).
A good radiation protection requalification training program was in place. The
instructors assigned to provide requalification radiation protection training were qualified for their positions. Radiation protection management was appropriately involved in developing the training topics to help ensure that the practical and technical competence of the staff was maintained (Section RS.1).
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A good radiation protection department self-assessment program was implemented.
e The use of technical experts from other nuclear power stations was a program strength
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(Section R7.1).
In general, a fair quality assurance program was in place. Radiation protection
management was not involved in the development of the quality assurance surveillance schedule. Quality assurance originated condition reports were not reviewed by the quality assurance department prior to closure. Some quality assurance radiation protection surveillances were postponed without documenting a reason (Section R7.1).
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A deviation for a commitment in response to NRC Bulletin 7919 was identified involving -
the failure to perform annual audits of the solid radwaste transportation program. The licensee implemented effective' corrective actions; therefore, no response to this Notice
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of Deviation is required (Section R8.2)
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Report Details
. Summarv of Plant Status
The plant operated at 100 percent power during the inspection.
IV. Plant Support R1 Radiological Protection and Chemistry Controls
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RI.1 Control of Radioactive Materials and Contamination: Surveyina and Monitorina l
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Insoection Scoce (83750)
Areas reviewed included:
Contamination monitor use and response to alarms
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Personnel dosimetry use
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Radiological postings
Housekeeping in the radiological controlled area
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i b.
Observations and Findinas All personnel observed exiting the radiological controlled area used the personnel contamination monitors properly. Radiation protection personnel stationed at the egress point properly surveyed all items being removed from the radiological controlled area.
Radiological workers wore dosimetry properly and knew to contact radiation protection personnelif their elec'ronic dosimetry alarmed.
During tours of the radiological controlled area, the inspector noted that all radiological areas were properly posted and controlled. The inspector also noted that the r'
or of contaminated areas had been reduced approximately 10 percent since the las'
i inspection during the week of November 2,1998. For example, during the earker inspection the entire charging pump room had been posted and controlled as a contaminated area; however, during this inspection the contaminated areas in the charging pump room were controlled and posted at the charging pump bases.
Housekeeping throughout the radiological controlled area was very good. Trash and laundry containers were properly maintained to limit the spread of potentially contaminated material.
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Conclusions l
Personnel exiting the radiological controlled area used contamination equipment
properly Radiological areas were posted and controlled in accordance with station
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5-procedures. Radiation workers wore personnel dosimetry properly. Housekeeping throughout the radiological controlled area was very good. Trash and laundry
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containers were properly maintained to limit the spread of potentially contaminated
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material.
R1.2 Plannina and Preparation a.
Inspection Scoce (83750)
Radiation protection department personnel involved in radiation protection planning and preparation were interviewed. The following items were reviewed:
ALARA job planning
Job scheduling and sequencing
ALARA packages
Incorporation of lessons learned from similar work l
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Observations and Findinas
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No problems were identihed during the review of radiological work planning. Freezing the station's 7-week look-ahead schedule 2 weeks prior to the start of work provided
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ALARA personnel with sufficient time to evaluate a task and input appropriate ALARA work methods to perform the task.
A review of selected work packages identified that lessons learned from past similar site and industry work were captured and incorporated into the packages to help enhance the ALARA work performance of station workers.
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Conclusions A good ALARA work planning program was in place. The station's scheduling program allowed ALARA personnel sufficient time to provide appropriate ALARA controls. Work packages incorporated site and industry lessons learned from past similar work.
R1.3 Maintainina Occuoational Exposure As Low As is Reasonably Achievable (ALARA)
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Inspection Scoce (83750)
Radiation protection personnel involved with the ALARA program were interviewed. The
. following areas were reviewed:
ALARA committee support
Exposure goals
Hot spot reductions
Temporary shielding
ALARA suggestions
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b.
Observations and Findinas ALARA Committee Eight ALARA comn ttee meetings were held between February 1 and October 31,1998.
e From a review of the ALARA committee meeting minutes, the inspector determined that.
appropriate ALARA topics were discussed and, in general, all station departments attended these meetings. However, the inspector identified that operations,
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engineering, and maintenance departments did not attend two of the eight meetings.
While chemistry, construction, corporate health physics, and training departments did not attend one of the eight meetings. The inspector commented that full station support of the ALARA committee was needed to enhance the ALARA performance of the i
station. The ALARA Chairperson acknowledged the inspector's comment and stated
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that has implemented plans to improve ALARA committee support.
Technical Specification 5.8.1.a. requires procedures for the ALARA program.
Section 3.3.2. B. of Attachment 7.1 to Procedure RP-AD-300,"ALARA Program,"
Revision 7, requires the station ALARA committee chairperson to designate one or more alternates for committes positions. From a review of ALARA committee meeting minutes and discussions with radiation protection management, the inspector identified that alternates were not designated for 1997 and 1998. The failure to designate ALARA committee alternates is a violation of Technical Specification 5.8.1.a. From a review of the ALARA committee meeting minutes, the inspector did not identify a lack of I
consistency or a reduction in the sensitivity to ALARA program issues. Therefore, the failure to designate ALARA committee alternates in accordance with the requirements of Procedure RP-AD-300 constitutes a violation of minor significance and is not subject to formal enforcement action. On December 3,1998, radiation protection personnel wrote Condition Report 98-2108 documenting this issue.
Exoosure Goals From interviews with members of the ALARA staff and station management, the inspector determined that exposure goals were established with station managemen and department involvement. Challenging exposure goals were developed using the -
best past station performance factoring in the elevated work area dose rates due to the failed fuel problems. The inspector concluded that the use of a Sub-ALARA committee which consisted of department first level supervisory and craft level personnel to develop the station exposure goals was a strength in accomplishing department " buy-in" to the station goals. Additionally, the ALARA committee was appropriately involved in monitoring the exposure goal setting process. From discussion with radiation protection super.ision, the inspector determined that, in general, radiation levels had increased by about 15 percent throughout the radiological controlled area due to the failed fuel problems.. The inspector determined that the chemistry department was actively involved in the source term reduction program. The use of cesium specific resin appeared to be effective in the removal of cesium from the reactor coolant system.
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-7-l The following table shows the licensee's yearly and 3-year person-rem rolling averages and the nation I pressurized water reactor 3-year averages for 1996-1998.
l 1996 1997 1998 (projected)
Licensee's Yearly Totalt (Person Rem)
226
224 Licensee's 3-year Average (Person Rem)
129 135 164 National 3-year Average not (Person Rem)
145 144 available The licensee's 1998 exposure goal was 224 person rem, and as of December 3,1998, the year-to-date exposure was approximately 222 person-rem. Tne inspector determined from interviews with the maintenance, operation, and assistant plant managers that barring any operational and major equipment problems, the exposure goal was achievable.
Hot Soot Reduction Proaram No problems were identified with the hot spot reduction program. Since January 1, 1998, three hot spots were removed, and three hot spots remained throughout the radiological controlled area. From a review of information rewived from the licensee, the inspector determined that hot spots were properly tracked er.d recorded in accordance with station procedures. Hot spot packages contained appropriate survey and radiological evaluation information.
Iemporary Shieldina Proaram No problems were identified with the temporary shielding program. As of December 3, 1998, there were two temporary shielding installations in place within the radiological controlled area. During tours of the radiological controlled area, the inspector noted that both temporary shielding installations were properly tagged and posted in accordance with station procedural requirements. The inspector randomly selected for review 2 of 50 temporary shielding packages installed during 1998. Both shielding packages contained proper engineering evaluations, dose skving estimates, pre-and post-shielding surveys, drawings, and/or plctures of the shielding installation. The inspector concluded that the station had an excellent temporary shielding program in place.
ALARA Suaaestion Proaram i
During 1997 and 1998, there were 23 and 40 ALARA suggestions submitted respectively. Fifteen of the 63 ALARA suggestions still remained opened as of
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l December 3,1998. All ALARA suggestions were initially reviewed to determine the l
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-8-feasibility of the suggestion in a timely manner. However, after discussion with the radiation protection ALARA staff, the inspector determined that none of the ALARA
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suggestions were evaluated to determine if there was a dose savings to the station. For a
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example, the final disposition of ALARA Suggestion 97-05, which pertained to the use of extended life expectancy lig.ht bulbs in the spent fuel pool area stated that it would be cost prohibitive to use longer life expectancy light bulbs. However, no dose savings and cost of light bulb evaluations were performed to determine if it was ALARA to upgrade the lighting. Another example was Al. ARA Suggestion 98-39, which pertained to dim lighting in Room 13 of the auxiliary building. The final disposition of this item stated that it was cost prohibitive to increase the number of light fixtures to provide additional lighting. Again, the inspector noted that there were no dose savings and cost of fixture evaluations performed to determine if it was ALARA to improve the lighting in room 13.
The inspector also noted that 31 of the 63 ALARA suggestions were closed with no actions taken to determine the dose savings to the station. The inspector concluded that the evaluation process of the ALARA suggestion program was poor.
The inspector noted that the ALARA suggestion program was setup so that the originator of the suggestion was not notified that his/her suggestion was accepted until the suggestion was closed. The inspector determined that the average time to close an ALARA suggestion was approximately 6 months. ALARA Suggestion 96-28, which
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pertained to extending a telephone cord 15 feet to move an individual away from a hot spot, had been open since August 9,1996. The originator of this ALARA suggestion had still not been notified that his suggestion had been accepted. The inspector commented that timely notification that an ALARA suggestion has been accepted was an important part of a gocd ALARA suggestion program. The licensee acknowledged the inspector's comment. The inspector also noted that, in general, once an ALARA suggestion evaluatic ad to be performed by someone outside the radiation protection
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i department, the ALAHA technician had to E-mail the evaluator numerous times, prompting this individual that his/her evaluaticn was due. For example, ALARA Suggestion 98-39 was due to be evaluated by October 31,1998; however, it took four E-mail messages and an additional 20 days to get the suggestion closed. On December 4,1998, the licensee wrote Condition Report 98-2112 to address improvements to the ALARA suggestion program.
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Conclusions in general, a good ALARA program was implemented. Some station departments did not attend all the ALARA committee meetings. ALARA committee alternates were not designated for 1997 and 1998. Challenging exposure goals were developed using the best past station performance factoring in the elevated work area dose rates due to the failed fuel problems. The use of a Sub-ALARA committee to develop the station's expcaure goals was a strength in accomplishing department " buy-in" to the station goals. The licensee's projected 3-year average for 1996-1998, of 164 person-rem will probably be above the pressurized water reactor 3-year national average. The 1998 projected dose of 224 person-rem was primarily the result of elevated plant radiation levels due to leaky fuel. The licensee implemented effective ALARA contro's in response to the challengers presented by the leaky fuel. A good hot spot reduction program was in place. An excellent temporary shielding program was implemente.
The ALARA suggestion program did not evaluate dose savings to the station, or provide timely notification that an ALARA suggestion was accepted to the originator.
R5 Staff Training and Qualification in Radiological Protection and Chemistry R5.1 Radiation Protection Staff Trainina a.
Insoection Scope (83750)
Personnel involved with radiation protection technician requalification training were interviewed. The following items were reviewed:
Radiation protection instructor qualifications
Radiation protection technician training lesson plans
Radiation protection management over sight of the training program
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Observations and Findinas The inspector reviewed the qualifications of the two training department instructors assigned to provide requalification training to radiation protection personnel. Both instructors were registered as National Registry of Radiation Protection Technologists and qualified for their positions. Additionally, to maintain technical competence and remain current with station procedures and radiation protection practices, the two instructors worked for the radiation protection staff during outages. However, the inspector noted ttu. the training instructors did not follow up their training presentations by going into the,.; ant to evaluate the training effectiveness. The licensee acknowledged the inspector's observation.
From a review of the 1908 requalification training schedule, the inspector determined that appropriate topics were listed to help ensure that technical competence of the radiation protection staff was maintained.
No problems were noted during the review of Radiation Protection Training Advisory Committee meeting minutes. Station radiation protection personnel were appropriately involved.
Selected lesson plans for the 1998 requalification training program were reviewed. The inspector determined that the lesson plans were well written comprehensive, and included site and industry lessons learned. Radiation protection management was appropriately involved in developing the training topics to ensure that appropriate training was provided to the staff. Training feedback forms were effectively used to improve lesson plans.
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Conclusione A good radiation protection requalification training program was in place. The instructors assigned to provide requalification radiation protection training had extensive, l
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- 10-practical, and technical backgrounds in the above program area and were qualified for their positions. Lesson plans were well written, comprehensive, and included site and industry lessons learned. Radiation protection management was appropriately involved in developing the training topics to help ensure that the practical and technical competence of the staff was maintained.
R7 Quality Assurance in Radiological Piotection and Chemistry Activities R7.1 Quality Assurance Audits and Surveillances. and Radiation Departmen_t Self-Assessments and Radioloaical Occurrence Reports
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Inspection Scope (83750)
Selected personnelinvolved with the performance of quality assurance eudits and surveillances, and radiation department self-assessments were interviewed. The following items were reviewed:
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Radiation protection department self-assessments performed since July 1997
Qualifications of personnel who performed quality assurance audits and
surveillances Quality assurance audits performed since July 1997
Quality assurance surveillances performed since July 1997
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Observations and Findinas Radiation Protection Department Self-Assessments Seven radiation protection department self-assosaments were performed since July 1997. The inspector determined that the self assessments were comprehensive and identified a number of improvement items. Additionally, the self-assessments covered the appropriate areas of the radiation prcction program to provide management with a good overview of program performance. The inspector noted that a self-assessment performed during September 1998 used technical experts from other nuclear power stations. This self-assessment was a comprehensive review of a number of radiation protection program areas. Numerous program improvement items were identified during this self-assessment. The inspector selected six of these improvement items at random and determined that allitems were evaluated in a timely manner and action plans were in place to incorporate these improvement items into the radiation protection program.
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Quality Assurance Audits and Surveillances The intpector reviewed the qualifications of the lead quality assurance auditor involved in the oversight of the radiation protection program. The inspector noted that this
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individual had been a licensee employee for approximately 3 months. However, from interviews held with the quality assurance manager and the lead quality assurance radiation protection auditor, the inspector determined that the lead auditor had strong auditor and industry operational radiation protection backgrounds and was qualified to j
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i An audit of the radiation protection program was last performed in 1996. The audit frequency of the radiation protection program was 3 years, thus no radiation protection j
audits were scheduled during this assessment period.
Four quality assurance radiation protection surveillance reports were written since July 1997. These reports covered radiation work permits and ALARA, contamination
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controls, radiation protection outage activities, and the safety enhancement program (SEP) compliance. The inspector determined that the reports were well written and l
provided management with a good tool to assess the radiation protection program areas reviewed. One condition report was written during the performance of the above surveillance reports. The inspector determined that it was closed in a timely manner; i
I however, the inspector noted that the quality assurance program did not require quality assurance originated condition reports to be reviewed by the quality assurance department prior to closure. The inspector commented that this was atypical. The licensee acknowledged the inspector's comment.
From intennews with quality assurance and radiation protection management, the inspector determined that radiation protection management was not involved during quality assurance schedule development. The inspector commented that involving radiation protection management during the development of the surveillance schedule could enhance the program areas reviewed. Quality assurance management acknowledged the inspector's comment and stated that they would review the process of surveillance schedule development.
l 10 CFR Part 50, Appendix B, Criterion V, states, in part, activities affecting quality shall be prescribed by procedures. Section 3.4.2 of Procedure QAM-11," Conduct of QA Surveillances." Revision 13, states, if a scheduled surveillance is not conducted during the month scheduled, Form QAM 11.4 shall be cornpleted noting the reason the surveillance was postponed.
During the review of the 1998 surveillance schedule, the inspector identified that two of l
the six radiation protection surveillances (contamination controls and radiation i
instrumentation) were postponed from May to August and April to October, respectively,
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without noting the reason for the postponement. The failure to document the reason for the postponement of the above surveillances is identified as a Violation of 10 CFR Part 50, Appendix B, Criterion V. From a review of the radiation protection department self-assessments performed during 1998, the inspector noted that these program areas
l were reviewed by the station. Therefore, the failure to document the reason for the postponement of the above surveillances constitutes a violation of minor significance and is not subject to formal enforcement action. On December 2,1998, the licensee issued Condition Report 98-2101 documenting this issue.
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The inspector noted that as of December 3,1998, c,nly one of the six 1998 scheduled radiation protection surveillances had been conducted. The inspector was informed by the quality assurance manager that these surveillances were postooned because of a shortage of qualified radiation protection auditors, c.
Conclusions A good radiation protection department self-assessment program was implemented.
The use of technical experts from other nuclear power stations was a program strength.
Program improvement items were evaluated in a timely manner and action plans were in place to incorporate these improvement items into the radiation protection program, in general, a fair quality assurance program was in place. The lead quality assurance auditor involved in the oversight of the radiation protection program was qualified for his position. Radiation protection management was not involved in the development of the quality assurance surveillance schedule. Quality assurance originated condition reports were not reviewed by the quality assurance department prior to closure. Some quality assurance radiation protection surveillances were postponed without documenting a reason.
R8 Miscellaneous Radiological Protection and Chemistry issues R8.1 (_ Closed) Violation 50-285/9716-03: Failure to remove an uncalibrated electronic dosimeter from service and reachina across contaminated area boundary The inspector reviewed the licensee's October 29,1997, response regarding reaching across a contaminated boundary. The inspector noted that effective corrective actions were impNmented. No similar problems were identified. The second example described in violation 50 285/9716-03, pertained to the failure to remove an uncalibrated electronic dosimeter from service. The licensee had requested an extension to the commitment pertaining to upgrading the access computer system because of a computer sof tware delivery date delay. The inspector determined that the delay in the computer upgrade was reasonable, all other corrective actions were implemented.
Additionally, no similar problems were identified.
R8.2 (Closed) Unresond item 50-285/9816-02: Failure to follow a commitment related to auditina freauency The licensee responded to NRC Bulletin 79-19, on September 21,1979, stating that quality assurance audits of all transfer, packaging, and transport activities would be conducted annually. During NRC inspection 50-285/9816, the inspector noted that the licensee deviated from their original commitment. Quality assurance audits of the transfer, packaging, and transport activities were being conducted every two years rather than annually, as in the original commitment. To give the licensee adequate time to review the matter and search its files for confirmation that the NRC was notified of a change to the original commitment, this item was identified as an unresolved ite *
I-13-Licensee representatives info med the inspector that they were unable to find documentation of a change in commitment to the auditing frequency. A licensee representative stated in Memorandum 98-OA/QC-109 that audits including solid waste packaging and shipping attributes had been performed on a biennial basis since 1986.
Af ter consultation with the Office of Nuclear Reactor Regulation, the inspector identified the change from annual auditing of the transportation program to biennial auditing as a deviation in commitment (50-285/9826-01).
On August 25,1998, the licensee issued Condition Report 98-1717 documenting this issue. Corrective actions included: (1) the performance of an audit of the transfer, packaging, and solid radwaste transportation activities, (2) submit a commitment change to the NRC requesting to change the audit frequency of the transfer, packaging, and solid radwaste transportation activities from annually to once every 3 years, and (3)
incorporate the transfer, packaging, and solid radwaste transpo tation activities into the quality assurance audit schedule annually until the commitment change has been approved.
V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on December 4,1998. The licensee acknowledged the findings presented. No proprietary information was identified.
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ATTACHMENT l-PART'AL LIST OF PERSONS CONTACTED Licensee D. Bannister, Supervisor, Operations
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C. Crawford, Supervisor, Chemistry / Radiation Protection Training S. Dixon, ALARA Technician, Radiation Protection i
D. Dryden, Licensing Engineer, Licensing l
W. Gates, Vice President, Nuclear
- R. Hamilton, Manager, Chemistry
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B. Hansher, Supervisor, Licensing
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i R. Haug, Corporate Health Physics R. Hodgson, ALARA Supervisor, Radiation Protection T. Jamieson, Radiolyical Operations Supervisor, Radiation Protection D. Little, Radiation Protection Technician, Radiation Protection l
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R. Phelps, Acting Division Manager, Nuclear Engineering
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M. Puckett, Manager, Radiation Protection L. Schneider, Senior Quality Assurance Auditor C. Simons, Specialist, Nuclear Safety Review Group J. Solymossy, Plant Manager D. Spiras, Manager, Quality Assurance M. Tesar, Division Manager, Nuclear Support J. Tills, Assistant Plant Manager C. Williams, ALARA Technician, Radiation Protection NRC W. Walker, Senior Resident inspector INSPECTION PROCEDURE USED l
83750 Occupational Radiation Exposure l
LIST OF ITEMS OPENED AND CLOSED Open and Closed 285/9826-01 NOD Failure to follow a commitment related to auditing frequency
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Closed i
285/9716-03 VIO Failure to remove uncalibrated electronic dos! meter from service and reaching across contaminated area boundary 285/9816-02 URI Failure to follow a commitment related to auditing frequency
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-2-LIST OF DOCUMENTS REVIEWED l
Station Procedure RPP," Radiation Protection Plan, Revision 15 Radiation Protection Procedure RP-300, "ALARA Program," Revision 7 Radiation Protection Procedure RP-301, "ALARA Job Reviews," Revision 13 l
Radiation Protection Procedure RP-303,"ALARA Cost-Benefit Analysis," Revision 1 Radiation Protection Procedure RP-304, " Radiological Goals Program," Revision 2 Radiation Protection Procedure RP-305, "ALARA Suggestion Program," Revision 2 Radiation Protection Procedure RP-306, " Hot Spot and Point Source Identification and Tracking," Revision 8 Radiation Protection Procedure RP-307, "Use and Control of Temporary Lead Shielding,"
Pavision 6a Radiation Protection Procedure RP 309," Radiation Protection Self-Assessment Program,"
Revision 6 i