ML20008E858

Responds to NRC 801227 Ltr Re Violations Noted in IE Insp Rept 50-285/80-16.Corrective Actions:Organizational Change to Be Made,Addl Employees Hired,Revised Program for Technicians & Will Study Beta Dosimeters & Spectrums

ML20008E858
Person / Time
Site:	Fort Calhoun
Issue date:	01/30/1981
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20008E853	List: ML20008E854 ML20008E858 ML20008E861
References
NUDOCS 8103100091
Download: ML20008E858 (10)

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Omaha Public Power District  :

1623 MANNEY O '* , A M A . NEaraSKA 68102 TELEAMoNE 536 4000 AREA CODE do2 January 30, 1981 i

r Mr. K. V. Seyfrit, Director U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Regwn IV 611 Ryan Plaza Drive '

Suite 1000

.i Arlington, Texas 76011

Reference:

Docket No. 50-285

Dear Mr. Seyfrit:

Inspection Report 80-16 for the Fort Calhoun Station, dated Decem- '

ber 27, 1980, identified iive "significant findings" that the Commis-sion requested response to. Accordingly, Omaha Public Power District i has attached the responses to the significant findings. ,

Sincere.1v,

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W. C. Jones  :

Division Manager Production Operations ,

WCJ/KJM/TLP:jmm Attachment  ;

cc: LeBoeuf, Lamb, Leiby & MacRae  !

1333 New Hampshire Avenue, N.W.'  !

Washington, D.C. 21036 )

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I Significant Finding A ,

The health physics function is organized in a manner such that the chemistry and health physics supervisor reports to a technical service  !

supervisor. Regulatory Guide 8.' recommends that the radiatiot protec- '

tion manager have direct recourse L responsible management and be in-dependent of station divisions concerned with station operability. The present organizational structure does not provide recourse ta higher t management and independence from station operations. The number of ANSI N181.1-1971 qualified technicians is insufficient, and requires use of l technicians from outside organizations. The staff morale and expected future losses of personnel requires management attention and corrective actions. (Section 1)

Response

l (1) Steps Which Have Been Taken 'l This licensee has and will continue to place safe operation of the Fort Calhoun Station as its pr: ma ry concern. The Chemical and Radiation Supervisor (Radiation Protection Manager) at the Fort Calhoun Station, as an assigned and active member of the Plant Review Committee, has always had direct access to the Chairman of the Plant Review Committee; that is, the Manager - Fort Calhoun Station. During regular and frequent Plant Review Committee meet- [

ings, a total of seven supervisors (including the Chemical and  ;

Radiation Protection Supervisor) have direct recourse to the Man- '

ager - Fort Calhoun Station. Among these seven supervisors, three [

are the department heads of maintenance, operations, and technical i and four are supervisors who report to these department heads on

• the Fort Calhoun organizational chart. Three of these four super- >

visors are shown organizationally as reporting to the Technical i Supervisor; one of these is the Chemical and Radiation Protection Supervisor. The District believes that, with a Plant Review Com-mittee active in all matters relating to nuclear safety (including radiation safety), committee members have had and will continue to have direct access to management.

i Relative to comments pertaining to staff turnover ar.d morale in the Chemical and Radiation Protection group, District management has also been concerned. The market demand for these specially skilled and experienced personnel has hampered staffing efforts. The key positions of Plant Health Physicist and Plant Chemist had to be '

filled during 1980. Both of these positions were filled with very capable and experienced individuals during 1980 who are dedicated to resolving the morale problems. Technician turnover was also high during 1980. Already all but one of the openings has been filled by the District. The remaining replacement will be offered employment in the near future.

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Respopg (Continued)

(2) Steps khich Will Be Taken District management has approved an organizational change such that the Chemical and Radiation Protection Supervisor reports directly to the Plant Manager. This change was approved January 2, 1981 to be effective February 1, 1981, and will be submitted to the Commission by ;iarch 1, 1981, in the form of a request for license modifica-tion.

To minimize the use of contract health physics technicians for work that is normally conducted by District employees, two additional employees will be added in 1981. The additional staffing, as well as a concentrated effort by plant management, is expected to help the overall group morale and performance. Furthermore, in 1982 two technicta positions will be filled and in 1983 an additional one will be filled. This budget planning section was taken in mid-1980.

It should be noted that during the time of this NRC audit special work was being conducted on plant piping supports. This required the use of qualified contract health physics support personnel so that District health physics personnel could continue to perform their normal and routine duties. Even though the District will add additional employees co this group in 1981, special projects and refueling outages will csntinue to require the use of qualified contract health physics asristance. The District will ensure that properly trained, experienced, and qualified contract technicians are utilized and that such use is minimized to the maximum extent practical.

(3) Schedule For Completion Of Action The schedule is provided above.

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Significant Finding 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 t completed, no systems training and no re-training has been conducted. ,

Written selection criteria for technicians has not been established.  :

Documents pertaining to technician qualifications indicated some do not [

meet experience requirements specified in ANSI N18.1-1971 criteria for [

experience. (See Appendix B for non-compliance items) (Section 2) f Respong f (1) Steps Which Have Been Taken The District commenced an evaluation of the overall health physics I training program to identify and develop needed upgrading.

(2) Steps Which Will Be Taken i i

The training program for health physics technicians is presently undergoing a complete revision. The training manual is being  ;

rewritten. It will include minimum requirements for Radiation

• Protection Technicians in the II, I and Senior Classifications.

Personnel designated as trainees will be required to complete the I entire Radiation Protection Study Guide / Record. Technicians pre- ;

sently employed will be given credit achieved under the previous [

system. The modules from the Nuclear Energy Training Course which i:

was prepared by HTS are on-site and will be utilized extensively in  ;

providing this training.  !

Selection criteria for Radiation Protection Technicians are being  ;

formulated. In addition, documentation methods will be improved which demonstrate that Raciation Protection Technicians meet ANSI N18.1-1971 qualification ,: rite ria .

i (3) Schedule For Completion Of Action The new training, retraining programs will be implemented by July 1,

1981. The selection criteria for Radiation Protection Technicians

' l will be completed by April 1, 1981.

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Significant Finding C  !

Full and current calibrations for beta, gamma and neutron radiation have not been conducted. Quality control measures in the external dosi-metry 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)

Response

Concern 1: Full And Current Calibrations For Beta Radiation Have Not Been Conducted.

(1) Steps Which Have Been Taken f The District has completed a p relimina ry review of the methods i available for beta calibrations. This review has confirmed that, as the District had recognized in the past, beta calibration using i natural uranium does not cover all intervals of beta source ener- '

gies that may be encountered at Fort Calhoun. The inability of the  ;

TLD to adequately monitor the very low beta radiation from Xe-133 '

has been recognized and an alternate method of accounting for this '

dose is currently in use. The method of beta calibration used by the District is near state-of-the-art technology. Proven techni-ques for monitoring low energy beta doses are of limited commercial  ;

i availability.

I i (2) Steps Which Will B. Taken  ;

Considering the above limitations for beta dose monitoring, the [

District will undertake an extensive study of: (a) imp 3d beta ,

dose TLD dosimeters, and (b) detailed determination of ne beta I source spectrums at Fort Calhoun. The results of the study are ex-pected to provide the necessary data and techniques to enable the District to implement an improved beta dosimetry program.

(3) Schedule For Completion Of Action

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See the attached Table C-1. '

i Concern 2: Full And Current Calibrations For Gamma Radiation Have  ;

Not Been Conducted.

(1) Steps Which Have Been Taken ,

. r The District believes the program installed at Fort Calhoun is ade- i quate. The sensitivity of the TLD to gamma dose is determined by  !

exposure to a Cs-137 (.662 Mev) source for three minutes at a dose i rate of 72.7 mrem / minute. The TLD sensitivity is then determined j by ratioing the TLD reader response to the total gamma dose. The  ;

sensitivity unit is ncoul/ mrem. The validity of this calibration j for various dose levels and energies is demonstrated by the quality  ;

control program with Battelle Northwest Laboratory and by results l of the Dosimetry Performance Pilot Study at the Unive rs ity of j

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Response (Continued)

Michigan. The Battelle tests include TLD irradiated to Cs-137 over the range of 30 to 10,000 mrem. The results of the most recent tests meet the acceptance criteria specified in the interim version of ANSI 13.11, Dosimetry Performance Testing Standard (NUREG/CR-1304 revised) . The TLD was also tested in Pilot Studies ,

1 and 2 at the University of Michigan. The gamma source was Co-60 s' (1.33 and 1.17 Mev) and the doses were in the range of 10 to 800 rad and 30 to 10,000 mrem. When the interim version of ANSI 13.11 is applied to the Pilot Studies, all tests are passed. Recent data obtained at Fort Calhoun for exposure of TLD to gamma radiation from Xe-133 (.223 Mev) decay, demonstrate agreement of TLD with a cloud dose calculation to within 157.. All comparisons were done with the same independently determined sensitivity (calibration) factor. The above data indicates the ability of the TLD to ac- -

curately monitor gamma dose over the range of energies and over the range of dose levels expected at the Fort Calhoun Station. The District believes the gamma calibrations are more than adequate for the present and far future anticipated requirements.

(2) Steps kbich Will Be Taken None.

(3) Schedule For Compi etion Of Action Not required.

Concern 3: Full And Current Calibrations For Neutron Radiation Have Not Been Conducted.

(1) Steps kbich Have Been Taken The 'District has comp)ated a preliminary review of this concern which has identified the need for further eval' at ' >n.

(2) Steps khich Will Be Taken

- The District recognizes that the current Fort Calhoun neutron cali-bration was performed some years ago and is committed to redeter-mining the neutron calibration factors for Fort Calhoun. The re-calibration will be accomplished in two parts: (a) as an interim measure, the response of currently available Fort Calhoun neutron survey instruments will be evaluated against TLD response to obtain a gross measure of the TLD performance, and to determine the need for more rigorous performance evaluations; and (b) prior to the 1982 refueling outage,the District will complete an investigation of improved methods of neutron calibration for the TLD and complete the recommended calibrations using the improved methods.

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t Response (Continued) r (3) Schedule For Completion Of Action I

See the attached Table C-1 for the completion date of the neutron ,

recalibration.

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Conce rn 4: Quali7y Control Measures In The External Dosimetry Program Such Ac TLD-Pocket Chamber Comparisons And Analysis Of Test And Control Badges To Evaluate Program Performance Have Not Been Performed,

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t (1) Steps Which Have been Taken The recommended camparison of TLD pocket chamber dose estimates has  !

,been initiated, i.nd the current monthly TLE exposure reports make a comparison between TLD and pocket dosimeter and indicate by a per- .

cent difference when the comparison exceeds the limits of the Fort Calhoun Administrative Procedure. Cases that exceed the limits are required by peacedure to be resolved, and are resolved and docu-mented by Foct Calhoun Station personnel.

The use of test badges by the Fort Calhoun Health Physics (HP) technicians is an operational check only. The testing and control program conducted with Battelle Northwest Laboratory provides the quality control program for TLD. Current District TLD sensitivity *

(calib ration) factors for gamma and beta radiation are determined independent of Battelle. The same sensitivity factors are used for the Battelle testing and the Fort Calhoun personnel radiation ex-posure monitoring. Therefore, the gamma and beta tests conducted with Battelle are a valid measure of system accuracy.

Because the District does not have a calibrated neutron source, an initial neutron calibration for quality control purposes was initi-ally performed in 1976 using Battelle determined dose and TLD ir-  ;

radiations. A review of this neutron calibration factor for the Cf-252 source was conducted in 1979. This review and statistical ,

analysis indicated that an adjustment on the neutron calibration factor would be appropriate. The 1976 calibration was dete rmined using limited data, and subsequent experience with the Cf-252

. source indicated an adjustment was needed. The adjustment was made ,

in 1979 and has not changed since that time. '

(2) Steps Which Will Be Taken P

Battelle quality control test will continue, and the results of the test will be fo rwa rded to the Fort Calhoun Health Physics staff.  ;

(3) Schedule For Ccmpletion Of Action All actions are complete.  ;

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i Significant Finding D l

l Internal dosimetry procedures have not been developed that woul<1 contain the biological models and calculational techniques necessary to assess the results of direct and indirect bioassay measurements in terms of the amounts and dosimetry of radioactive material taken into the body. .

(Section 3.2)

Response

(1) Steps Which Have Been Taken ,

As described in Section 3.2 of the Health Physics Appraisal Rer;rt, Fort Calhoun Station utilizes Helgeson Nuclear Services for broas-tmy analyses and evaluations. All whole body counting reports  ;

ilentify the critical organ, isotopic concentration and the percent L of maximum permissible body burden routinely. Helgeson Nuclear .!

Survices utilizes biological models and universally accepted calcu-lational methods based on ICRP (/2 and ICRP //10.

In addition, Fort Calhoun Station utilizes emergency services of the University of Nebraska Medical Center, Radiation Health Faci-

, lity. UNMC Standard Operating Procedures (SOP's) are included in the present Fort Calhoun Station Emergency Plan for reference and use. Pertinent methods are SOP #7, " Bioassay Methodology", and S0P ,

1. 8, " Radiometric Analysis", with part 8A, " Flow Sheet", 8B, " Gen-eral Bioassay", and 8C, " Urine Analysis".

The individual procedures are being collected and consolidated into a set of operating procedures to formalize the bioassay measure- '

ments and assessment program at Fort Calhoun Station.

(2) Steps Which Will Be Taken .

The assembled documents will be reviewed to ensure the formal pro-gram is effective. Supplemental procedures will be developed where inadequacy is identified. .

(3) Schedule For Completion Of Action ,

. The full program described will be implemented by July 1, 1981.

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+2 Significant Finding E Portable instrument calibrations and check source response prac-tices were not performed as recommended in ANSI N323-1978. Survey pro-cedures do not speak to instrument selection when non-routine surveys such as beta dose rate and alpha contamination are performed. Surveil-lance for alpha activity in plant environs and beta dose rate on certain jobs should be increased. In addition, the exclusive use of high volume samplers - in making airborne activity surveys brings into question and representativeness of measurements to actual worker exposure and the plant's inventory of portal monitors , friskers and hand and foot moni-tors, cannot, using present techniques, measure contamination on per-sonnel, clothing and laundry at the limits established by plant proce-dures. (Section 4)

Response

(1) Steps khich Have Been Taken The District has initiated a program to completely review the pro-grams for calibration and survey procedures using portable instru-ments.

(2) Steps bhich Will Be Taken Portable instrument calibrations and check source response practices were not performed as recommended in ANSI N323-1978.

Existing portable instrument ca?ibration procedures have been re-viewed against the recommendations in ANSI N323-1978. These pro-cedures are being revised in order to assure that calibration is performed at two points on each range or decade of the instrument for those ranges / decades normally used at the station. These re-vised procedures will be implemented by July 1, 1931, pro rided new calibration sources are received from the source vendor. In addi-tion, Standing Order T-13 will be revised to better define consis-tency with ANSI N323.

Existing performance test methods for portable instruments have been reviewed against ANSI N323-1978 recommendations. Methods will

~ be evaluated for providing a functional test on at least one point on each normal' used range of a portable instrument. Performance tests will be res- sd to reflect evaluation findings.

Survey procedures do not speak'to instrument selection when non-routine surveys such as beta dose rate and alpha contamination are performed.

Existing procedures will be revised and/or new procedures generated which address instrument selection for non-routine surveys.

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F Response (Continued)

Surveillance for alpha activity in plant environs and beta dose rate on certain jobs should be increased. '

A program has been initiated at the station which increases routine alpha activity surveillance. Once per week, representative smears taken as part of the plant daily radiation survey are counted for alpha activity. In addition, alpha activity determinations are made for non-routine activities such as those involving new fuel receipt and fuel transfers.

Beta dose rate determinations will be increased as necessary to as-sure that total radiation dose is accurately assessed prior to work in a radiation area. It is expected that most jobs requiring beta dose rate determinations will be conducted during refueling outages. ,

r The exclusive use of high volume samplers in making airborne acti-vity surveys brings into question the representativeness of measure-ments to actual worker exposure.

A method will be established for augmenting our existing personnel air sampling program to include the use of lapel air samplers and other low volume air samplers. "

The plant's inventory of portal monitors, friskers and hand and foot monitors, cannot, using present technia"es, measure contamination on personnel, clothing and laundrv of the limits established by plant procedures.

An evaluation will be conducted to investigate the effectiveness of portal monitors, friskers and hand and foot monitors in detecting station con'tamination limits. Calibration methods of existing  ;

equipment, state-of-the-art detection equipment, and existing ad-ministrative limits will be reviewed along with the recommendations of ANSI N13.12. '

(3) Schedule For Completion Of Action

_ All actions identified above will be completed and revised proce-dures implemented as needed by July 1, 1981.

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