IR 05000285/2004007
| ML042940445 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/19/2004 |
| From: | Shannon M Division of Reactor Safety IV |
| To: | Ridenoure R Omaha Public Power District |
| References | |
| IR-04-007 | |
| Download: ML042940445 (20) | |
Text
ber 19, 2004
SUBJECT:
FORT CALHOUN STATION - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000285/2004007
Dear Mr. Ridenoure:
On September 24, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fort Calhoun Station facility. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with Mr. Mark Frans and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:
- Radiation Monitoring Instrumentation
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
- Radioactive Material Processing and Transportation
- Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one self-revealing, noncited violation of very low safety significance (Green). However, because of its very low safety significance and because the finding was entered into your corrective action program, the NRC is treating this finding as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest this noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Fort Calhoun Station facility.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection
Omaha Public Power District -2-in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
//RA//
Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Docket: 50-285 License: DPR-40
Enclosure:
NRC Inspection Report 05000285/2004007 w/attachment: Supplemental Information
REGION IV==
Dockets: 50-285 Licenses: DPR-40 Report: 05000285/2004007 Licensee: Omaha Public Power District Facility: 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: September 20-24, 2004 Inspectors: Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Louis C. Carson II, Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Binesh Tharakan, Health Physicist, Plant Support Branch Donald Stearns, Project Engineer, Branch E, Division of Reactor Projects Approved By: Michael P. Shannon, Chief, Plant Support Branch Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000285/2004007; 09/20/2004 - 09/24/2004; Fort Calhoun Station; Radioactive Material
Control Program The report covered a one week period of inspection on site by a team of four region-based inspectors. A finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,
Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Public Radiation Safety
- Green.
The team reviewed a self-revealing, non-cited violation of Technical Specification 5.8.1 that resulted from the licensees failure to properly survey and control an item contaminated with radioactive material. Fixed contamination on a shackle released from the protected area was measured at approximately 19,000 disintegrations per minute/100 centimeters squared. The finding was entered into the licensees corrective action program as Condition Report 2003-5480.
The finding was more than minor because it was associated with the cornerstone attribute (material release) and it affected the associated cornerstone objective (to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain). The team used the Public Radiation Safety Significance Determination Process and determined that the finding was of very low safety significance because (1) the finding was a radioactive material control issue (2) it was not a transportation issue, and (3) it did not result in a dose to the public greater than 0.005 rem. This finding also had cross-cutting aspects associated with human performance in that licensee personnel failed to implement the established survey requirements designed to prevent the release of radioactive material (Section 2PS3).
REPORT DETAILS
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
a. Inspection Scope
This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment
- Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage
- Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area
- Self-assessments and audits
- Corrective action program reports since the last inspection
- Calibration expiration and source response check currency on radiation detection instruments staged for use
- The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training
- Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Licensee Event Reports
- Licensee action in cases of repetitive deficiencies or significant individual deficiencies The inspector completed 9 of the required 9 samples.
b. Findings
No findings of significance were identified.
2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01)
a. Inspection Scope
This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual (ODCM), and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- The most current radiological effluent release reports, changes to radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, self-assessments, audits, and licensee event reports
- Gaseous and liquid release system component configurations
- Routine processing, sample collection, sample analysis, and release of gaseous effluent; radioactive liquid and gaseous effluent release permits and dose projections to members of the public
- Changes made by the licensee to the ODCM, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection
- Monthly, quarterly, and annual dose calculations
- Surveillance test results involving air cleaning systems and stack or vent flow rates
- Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control
- Interlaboratory comparison program results
- Audits, self-assessments, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Abnormal releases
- Licensee event reports and special reports The inspector completed 10 of the required 10 samples.
b. Findings
No findings of significance were identified.
2PS2 Radioactive Material Processing and Transportation (71122.02)
a. Inspection Scope
This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:
- The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program
- Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges
- Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
- Shipping records for non-excepted package shipments
- Audits, state agency reports, self-assessments, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Observation of a shipment during the inspection
- Licensee event reports and special reports The inspector completed 6 of the required 6 samples.
b. Findings
No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program (71122.03)
a. Inspection Scope
This area was inspected to ensure that the REMP verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix I, the ODCM, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed
- Annual environmental monitoring reports and licensee event reports
- A sampling of five air sampling stations and eight thermoluminescence dosimeter (TLD)monitoring stations
- Collection and preparation of environmental samples
- Operability, calibration, and maintenance of meteorological instruments
- Each event documented in the Annual Environmental Monitoring Report which involved an inoperable sampler or anomalous measurement
- Significant changes made by the licensee to the ODCM as the result of changes to the land census or sampler station modifications since the last inspection
- Calibration and maintenance records for air samplers, quality control program, interlaboratory comparison program results, and vendor audits
- Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area and the methods used for control, survey, and release from these areas
- Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records
- Audits, self-assessments, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Each event documented in the Annual Environmental Monitoring Report which involved a missed sample or lost TLD
- Licensee event reports and special reports performed since the last inspection The inspector completed 10 of the required 10 samples.
b. Findings
Introduction.
The team reviewed a self-revealing, non-cited violation of Technical Specification 5.8.1 that resulted from the licensees failure to properly control radioactive material in accordance with procedural requirements. The violation was found to have very low safety significance.
Description.
On December 3, 2003, Fort Calhoun Station received a call from Wolf Creek Generating Station stating that it had received a shipment from Fort Calhoun Station of a supposedly empty, non-radioactive sea/land container. However, in the container was a radioactive material posting and shackle with fixed, radioactive contamination. The contamination level on the shackle equaled approximately 19,350 disintegrations per minute/100 centimeters squared, beta/gamma (assuming a 10 percent instrument efficiency and a 15.5 centimeters squared probe area).
Fort Calhoun Station investigated and concluded that an unconditional release survey of the sea/land container was not performed. The failure to survey the shipping container for unconditional release led to the licensees failure to identify and control the shackle. The container was subsequently released from the licensees protected area and shipped as non-radioactive material. The licensees dose calculation demonstrated that the maximum annual dose to a member was approximately 3 millirems.
Analysis.
The failure to survey and control radioactive material is a performance deficiency.
The finding was more than minor because it was associated with the cornerstone attribute (material release) and it affected the associated cornerstone objective (to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain). The team used the Public Radiation Safety Significance Determination Process and determined that the finding was of very low safety significance because
- (1) the finding was a radioactive material control issue
- (2) it was not a transportation issue, and
- (3) it did not result in a dose to the public greater than 0.005 rem. This finding also had cross-cutting aspects associated with human performance in that licensee personnel failed to implement the established survey requirements designed to prevent the release of radioactive material.
Enforcement.
Technical Specification 5.8.1.a. requires procedures listed in Regulatory Guide 1.33, Revision 2, Appendix A, 1978. Regulatory Guide 1.33, Appendix A, Section 7(e),requires procedures for radiation surveys. Procedure RP-202, Radiological Surveys, Revision 20, Section 7.2.9. requires that items be surveyed before being unconditionally released. Section 7.2.9.C. states, If any detectable radioactivity is indicated on any internal or external surface, the material or equipment shall not be unconditionally released. The licensee violated this requirement when it failed to perform a survey and subsequently unconditionally released a shackle with fixed radioactive contamination. Because this example of a failure to perform a radiological survey and control radioactive material was of very low safety significance and was entered into the licensees corrective action program (as Condition Report 2003-5480), this violation is being treated as an non-cited violation (NCV),consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000285/2004007-01, Failure to survey and control radioactive material.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
Annual Sample Review
a. Inspection Scope
The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:
- Radiation Monitoring Instrumentation (Section 2OS3)
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)
- Radioactive Material Processing and Transportation (Section 2PS2)
- Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)
b. Findings and Observations
No findings of significance were identified.
4OA4 Cross-Cutting Aspects of Findings
Section 2PS3 describes an issue with a human performance cross-cutting aspect which involved the failure of workers to follow programmatic requirements to survey and control items contaminated with radioactive material.
4OA6 Management Meetings
Exit Meeting Summary
On September 24, 2004, the team presented the inspection results to Mr. M. Frans, Assistant Plant Manager, and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- M. Anderson, Senior Technician, Radioactive Waste
- D. Bannister, Plant Manager
- M. Breuer, Senior Technician, Radioactive Waste
- D. Conn, Technician, Radioactive Waste
- A. Costanzo, Environmental Specialist, System Chemistry
- P. DeAngelis, Radiological Equipment Supervisor, Radiation Protection
- S. Dixon, Health Physicist, Radiation Protection
- D. Dryden, Specialist, Licensing
- T. Dukarski, Supervisor, System Chemistry
- S. Gebers, Corporate Health Physicist
- B. Glover, Technician, Radiation Protection
- R. Haug, Manager, Chemistry
- M. Hawes, Chemistry Technician, System Chemistry
- T. Jamieson, Supervisor, Radioactive Waste
- S. Kalra, System Engineer (Meteorological Tower), System Engineering
- T. Maine, Supervisor, Radiation Protection Operations
- T. Nguyen, System Engineer (Radiation Monitoring), Systems Engineering
- M. Puckett, Manager, Radiation Protection
- C. Sarnowski, Clerk, Radiation Protection
NRC
- J. Hanna, Senior Resident Inspector
- L. Willoughby, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE Opened and Closed During this Inspection
- 05000285/2004007-01 NCV Failure to survey and control radioactive material.
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