ML19345E881
| ML19345E881 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/27/1980 |
| From: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Jones OMAHA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML19345E882 | List: |
| References | |
| NUDOCS 8102060339 | |
| Download: ML19345E881 (5) | |
See also: IR 05000285/1980016
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UNITED STATES
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2 7 N 1980
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Docket No. 50-285/S0-16
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Omaha Public Power District
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Attn:
W. C. Jones, Division Manager
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1623 Harney Street
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Omaha, Nebraska 08102
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Gentlemen:
Subject: Heal th Physics Appraisal
The NRC has identified a need for licensees to strengthen the health physics
programs at nuclear power plants and has undertaken a significant effort to
assure that action is taken in this regard.
As a first step in this effort,
the Office of Inspection and Enforcement is conducting special team appraisals
of the health physics programs, including the health physics aspeu.s of radio-
active waste management and onsite emergency preparedness, at all operating
power reactor sites. The objectives of these appraisals are to evalaate the
overall adequacy and effectiveness of the total health physics prcgram at each
site and to identify areas of weakness that need to be strengthened. We will
use the findings from these appraisals as a basis not only for requesting
individual licensee action to correct deficiencies and effect improvements but
also for effecting improvements in NRC requirements and guidance. This effort
was identified to you in a letter dated January 22, 1980, from
F..
Victor Stello,
Jr., Director, NRC Office of Inspection and Enforcement.
During the period of September 15-26, 1980, the NRC conducted the special
appraisal of the health physics program at the Fort Calhoun Nuclear Station.
Areas examined during this appraisal are described in the enclosed report (50-
285/80-16). Within these areas, the appraisal team reviewed selected procedures
and representative records, observed work practices, and interviewed personnel.
It :s requested that you carefully review the findings of this report for con-
sideration in effecting improvements to your health ohysics program.
The
findings af the appraisal at Fort Calhoun indicate that although your overall
health physics program is adequate for present operations, several significant
weakness,is exist.
These include the following:
(1) The organization of the plant staff is such that the health physics super-
visor does not have direct recourse to the plant manager and sufficient
independence of plant operations.
The radiation protection staff turnover
should be stabilized and increased to appropriate levels.
(2) The qualifications and training of health physics technicians was con-
sidered weak in that some technicians did not meet NRC requirements for
qualification and the training program did not contain all necessary elements.
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(3) Full and current calibrations for beta, gamma and neutron radiation and
quality control measures to evaluate external dosimetry program performance
has not been conducted.
(4)
Internal dosimetry procedures have not been developed that would provide
all the necessary elements for evaluating personnel intakes of radioactivity
and internal exposure dosimetry.
(5) The radiation surveillance program was considered weak in the areas of
instrument calibration, instrument selection, incomplete or nonrepresentative
survey information and inability to measure and comply with plant adminis-
trative limits for contamination.
These findings are discussed in more detail in Appendix A, "Significant Appraisal
Findings." We recognize that an explicit regulatory requirement pertaining to
eacn significant weakness identified in Appendix A may not currently exist. Mcw-
e;ar to determine whether adequate protection will be provided for the health
and safety of workers and the public, you are requested to submit a written
statement within twenty-five (25) days of your receipt of this letter, de;cribing
your corrective action for each significant weakness identified in Appendix A
including:
(1) steps which have been taken; (2) steps which will be taken;
and (3) a schedule for completion of action.
This request is made pursuant
to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
During this appraisal, it was also found that certain of your activities do
not appear to have been conducted in full compliance with NRC requirements.
Consequently, you are required to respond to these matters, in writing, in
accordance with the Provisions of Section 2.201 of the NN's " Rules of
Practice," Part 2, Title 10, Code of Federal Regulations. Your response shouci
be based on the specifics contained in the Notice of Violation enclosed herewith
as Appendix B.
You should be aware that the next step in the NRC affort to strengthen health
physics programs at nuclear power plants will be the imposition of a require-
rrent by the Office of Nuclear Reactor Regulation (NRR) that each licensee
develop, submit to the NRC for approval . and implement a Radiation Protection
Plan.
Each licensee will be expected to include in the Radiation Proection
Plan sufficient measures to provide las:ing corrective action for signiif cant
weaknesses identified during the special appraisal of the current health pc" sic;
program. Guidance for the development of this plan will incorporate pertinent
findings from the special appraisals and will be issued for public coment.
In accordance with Section 2.790 of the NRC's " Rules o
-ractice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and the en-
closures will be placed in the NRC's Public Document Room.
If this material
contains any 11fomation that you believe to be proprietary, it is necessary
that you make a written application within 20 days to this office to withhold
such informativa form public disclosure. Any such application mst be accom-
panied by an affidavit executed by the owner of the information, which
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.0maha Public Power District
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identifies the document or part sought to be withheld, and which contains a
statement of reasons which addresses with specificity the items which will be
considered by the Comission as listed in Subparagraph (B)(4) of Section 2.790.
The information sought to be withheld shall be incorporated cs far as possible
into a separate part of the affidavit.
If we do not hear from you in this
regard within the specified period, this letter and the enclosures will be
placed in the Public Document Room.
Should you have any questions concerning this appraisal, we will be pleased
to discuss them with you.
Sincerely,
/ff k b
Karl V. Seyfr'
Director
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Encicsures:
1.
Appendix A, Significant Appraisal
Findings
2.
Appendix 3, Notice of Violation
3.
Office of Inspection and Enforcement
Inspection Report No. 50-285/80-16
cc w/ enclosures:
S. C. Stevens
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Station Panager
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P. O. Box 98
Fort Calhoun, Nebraska 68102
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APPENDIX A
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SIGNIFICANT APPRAISAL FINDINGS
Jmaha Public Power District
Docket No. 50-285
Fort Calhoun Nuclea. Station
Based upon the results of the NRC Health Physics Appraisal conducted September
15-26, 1980, it appears that several significant weaknesses exist in the health
physics program as indicated below.
(P.eferences are to sections of the appraisal
report).
A.
The health physics runction is organized in a manner such that the chemistry
and health physics supervisor reports to a technical service supervisor.
Regulatory Guide 8.8 recomaends that the radiation protection manager have
direct recourse to responsible management and be incependent of station
divisicas concerned with station operability.
The present organizational
structure does not provide recourse to higher management and independence
from station cperations.
The number of ANSI N181.1-1971 qualified tech-
nicians is insufficient, and requires use of technicians from outside
organizations.
The staff morale and expected future losses of personnel
requires management attention and corrective actions.
(Section 1)
B.
The training program for health physics technicians was found to be weak
in that all elements specified in the training manual had not been com-
pleted, no systems training and no re-training has been conducted.
Written
selection criteria for technicians has not been establisned.
Documents
certaining to technician qualifications indicated some do not meet ex-
perience recJirecents specified in ANSI N18.1-1971.
At least one tech-
nician was identified as not meeting ANSI NIS.1-1971 criteria for ex-
perience.
(See Appendix B for non-compliance items) (Section 2)
C.
Full and current calibrations for beta, gamma and neutron radiation have
not been conducted.
Quality control measures in the external dosimetry
program such as TLD-Pocket Chamber comparisons and analysis of test and
control badges to evaluate program performance have not been performed.
(Section 3.1)
D.
Internal dosimetry procedures have not been developed that would centain
tne biological models and calculational technioues necessary to assess the
results of direct and indirect bioassay measurements in terms of tne
amounts and dosimetry of radioactive material taken into the body.
(Section
3.2)
E.
Portable instrument calibrations and check source response practices were
not performed as recommended in ANSI N323-1973.
Survey procedures do not
speak to instrument selection when non-routine surveys such as beta dose
rate and alpha contamination are performed.
SurveiMance for alpha
activity in plant environs and teta dose rate on certain jobs should be
increesed.
In addition, the exclusive use of high volume samplers in
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making airborne activity surveys brings into question the representa-
tiveness of measurements to actual worker exposure and the plant's
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inventory of portal monitors, friskers and hand and foot monitors,
cannot, using present techniques, measure contamination on personnel,
clothing and laundry at the limits established by plant procedures.
(Section 4)
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