ML20059E198
| ML20059E198 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/26/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059E183 | List: |
| References | |
| 50-285-93-23, NUDOCS 9311030124 | |
| Download: ML20059E198 (10) | |
See also: IR 05000285/1993023
Text
.
APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-285/93-23
License: DPR-40
Licensee:
Omaha Public Power District
'
Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399, Hwy. 75 - North of Fort Calhoun
Fort Calhoun, Nebraska 68023-0399
Facility Name: Fort Calhoun Station
Inspection At:
Blair, Nebraska
Inspection Conducted: October 12-15, 1993
Inspector:
L. T. Ricketson, P.E., Senior Radiation Specialist
Facilities Inspection Programs Section
Approve :
M9
10
f./
e-8. Murray, Chief, Fhcilities Inspection
Date
Programs Section
inspection Summarv
Areas Inspected:
Routine, announced inspection of the radiation protection-
activities related to the 1993 refueling outage, including training and
qualifications, external exposure controls, internal exposure controls,
controls of radioactive material and contamination, and the program to
maintain radiation exposures as low as reasonably achievable (ALARA).
Results:
Poor planning on the part of outage management caused the chemical
volume control system to be taken out of service before it could
remove radioisotopes in solution in the reactor coolant system.
This, in turn, produced higher radiation dose rates in areas of the
plant during the early part of the outage (Section 2.1).
The radiation protection department supplemented its permanent staff
with contract personnel; however, during the early part of the
outage staffing was less than optimum, resulting in work slowdowns
(Section 2.1).
High quality ALARA work packages were produced (Section 2.1).
9311030124 931029
~
ADOCK 05000285-
O
PDR[z
,
.
b
'
-2-
A good training program for contract radiation protection personnel
was implemented (Section 2.2).
A noncited violation was identified as a result of not locking a
'
radiation area with dose rates higher than 1000 millirems per hour
(Section 2.3).
,
A violation with multiple examples was identified as a result of
radiation workers entering the radiological controlled area without
all dosimetry required by the governing radiation work permits
'
(Section 2.3).
The licensee had a strong program for the identification and
documentation of problems and violations (Section 2.3).
An excellent program for calculating internal radiation dose was
implemented (Section 2.4).
The licensee had a good program for the control of radioactive
materials and contamination (Section 2.5).
<
Summarv of Inspection Findinas:
A noncited violation was identified (Section 2.3).
Violation 285/9323-01 was identified (Section 2.3).
Attachment:
)
Persons Contacted and Exit Meeting-
e
_ _ - _ - _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - - -
.
-.
-3-
DETAILS
1 PLANT STATUS
The licensee was conducting a refueling outage which was scheduled to last
56 days. The outage started on September 25, 1993.
2 OCCUPATION RADIATION EXPOSURE CONTROL DURING EXTENDED OUTAGES (83729)
The licensee's program was inspected to determine compliance with Technical
'
Specification 5.8 and the requirements of 10 CFR Part 20, and agreement with
the commitments of Chapter 12 of the Final Safety Analysis Report.
2.1 Plannina and Preparation
During reactor coolant system cooldown, the chemical volume control system was
taken out of service before it could remove the radioisotopes left in
solution. Consequently, radiation levels in the plant rose higher than
predicted, and subsequent radiation doses for initial work activities were
higher than projected. The chemical volume control system was twice put back
into service to remove radioactivity from the reactor coolant and to bring
radiation levels to near that projected. This action was the result of an
oversight by all those reviewing the preliminary outage schedule.
The
licensee acknowledged a weakness in this aspect of outage planning and stated
that this item would be included with the outage lessons learned.
The licensee supplemented the permanent radiation protection staff with
contract technicians for the outage. During the first part of the inspection,
the inspector determined that the licensee's contract staffing was
approximately six fewer than planned. Some contract personnel had terminated
because of personal reasons, and some were terminated for disciplinary
reasons. As of October 14, 1993, the licensee had replaced these individuals
with eight other trained radiation protection technicians. Although the
shortage of radiation protection technicians resulted in work delays, the
radiation protection manager stated that it did not result in a failure to
provide radiation protection coverage for any job designated previously to
!
require such coverage.
The inspector determined through personnel interviews and observation that the
licensee had sufficient supplies of calibrated radiation survey
l
instrumentation, air samplers, portable ventilation units, and protective
clothing. However, licensee representatives stated that there were some
,
shortages of minor supplies such as sample papers, whirl packs, and clear
I
bags.
The inspector reviewed ALARA work packages and determined them to be of high
l'
quality.
Each contained historical information, survey information, and
radiation protection instructions in concise, easily understandable form. Job
reviews for all planned work had been completed by the ALARA group before the
start of the outage.
- _ - _ _ - _ - _ _ _ _ _ _ _ _ _
,_
_
._
.
_ _
.
.
-4-
Special equipment used during the outage to reduce total person-rem accrual
-
included the use of television cameras for observation and surveillance in
containment, teledose equipment for remote monitoring of some personnel
exposures, and a new type of eddy' current equipment which was easier to
install in the steam generators.
.
2.2 Trainina and Qualifications of Personnel
The inspector reviewed selected resumes of contract radiation protection
personnel and determined that they met qualification requirements.
Contract
'
radiation protection technicians interviewed commented favorably about the
licensee training program to acquaint them with the licensee's facility and
procedures.
2.3 External Exposure Control
At the start of the inspection, licensee representatives notified the
inspector that they had identified a violation of Technical Specification 5.11.2.
On October 11, 1993, a contract radiation protection technician was assigned
to chain and padlock the hatches leading to the secondary manways on "A" steam
generator. Areas with radiation dose rates of 1800 millirems per hour
(measured at 30 centimeters) were accessible through the entrance. The
technician posted the area as a Restricted High Radiation Area, chained the
east and west hatches, and secured the chains with padlocks. Another contract
radiation protection technician was on hand for the purpose of verifying that
the hatches were locked. Both technicians signed Form FC-RP-204-1,
" Restricted /Very High Radiation Area Verification Check," at S p.m.
At approximately 7:30 p.m. (also according to Form FC-RP-204-1) a licensee
'
radiation protection technician on routine tours af containment discovered
that the lock on the west hatch was unlocked. Tue licensee's subsequent
investigation determined that no entries were made into the area during the
,
time it was thought to be unlocked. The second contract radiation protection
,
technician stated that be did not physically test-the lock, but beard the-lock
make a clicking noise ar'd assumed that it was locked.
In response to the violation, the licensee implemented or committed to
implement the following corrective actions documer.ted in Incident
Report 930247:.
The contract technicians involved were terminated.
Radiation protection supervisors briefed radiation protection
j
personnel (licensee and contract) to stress management expectations,
procedural requirements, self-checking, and personal accountability.
An article was published in the Outaae Countdown as a reminder to
!
'
all station personnel of the importance of the function of second
verifications on Restricted High Radiation Area locks.
!
!
1
--
.
.
9
-5-
Licensee personnel were required to perform second person
verifications on Restricted High Radiation Area locks.
Procedure RP-204 will be revised to specifically require physical
verification of locks.
A discussion of this event and the requirements for second person
verification will be included in general employee training and
radiation protection technician training.
,
The NRC has elected to exercise discretion, in accordance with Section VII.B.2
of 10 CFR Part 2, Appendix C, and not to issue a Notice of Violation regarding
this matter. The inspector determined that the violation met the criteria for
a noncited violation prescribed in Section VII.B.2.
The inspector reviewed a number of occurrences in which radiation workers
entered into the radiological controlled area without all the dosimetry
required by the controlling radiation work permits. The events are summarized
below.
April 1,1993 - Four individuals did not sign in on the access
.
'
control computer and did not use electronic, alarming dosimeters as
required by the radiation work permit. The individuals toured the
spent fuel pool area, which was posted as a contaminated area. The
lack of alarming dosimeters was not discovered until the individuals
were removing their protective clothing. 1he individuals were
wearing thermoluminescent dosimeters. These were processed, and
they confirmed that the individuals received no significant
exposure. The occurrence was documented in Radiological Occurrence
,
Report 93-017, Incident Report 930075, and NRC Inspection
Report 50-285/93-04.
,
a
Corrective action to prevent recurrence included a design change of
the radiological controlled area access point to provide more
.q
positive control. Discretion was exercised by the NRC because the
'
criteria specified in Section VII.B.1 of the NRC Enforcement Policy
were satisfied, and a Notice of Violation was not issued. The
design change was implemented by August 15, 1993. NRC followup was
documented in NRC Inspection Report 50-285/93-16.
June 28, 1993 - An individual entered the radiological' controlled
!
area without an alarming dosimeter. The individual lost the
dosimeter on the way from the control room to the radiological
controlled area. This occurrence was documented in Radiological
Occurrence Report 93-023 and Incident Report 930158.
!
Corrective action to prevent recurrence included instructions to
training personnel to emphasize the good practice of checking
dosimetry before each entry into the radiological controlled area.
September 1, 1993 - A vendor representative entered the radiological
controlled area to work on counting room equipment without a
-
.
-6-
thermoluminescent dosimeter. The individual and his escort did not
follow the normal personnel flowpath into the radiological
controlled area. To save time, the escort had the radiation
protection shift technician log the two on the access control
computer.
By doing this, the two bypassed the normal access control
personnel and did not request a thermoluminescent dosimeter which,
for visitors, was kept at the access control point. Tne vendor
representative later identified the problem and reported it to
radiation protection personnel. The individual had sinned in on the
radiation work permit and access control computer. Thi.s occurrence
-
was documented in Radiological Occurrence Report 93-033 and Incident
Report 930200.
Corrective action to prevent recurrence included the removal of the
access computer terminal from the radiation protection shift
technician'" vfice to ensure that all personnel entering the
radiologic l controlled area followed a single pathway.
September 20, 1993 - A contract worker exited the radiological
controlled area, and access control personnel noted that he did not
have his alarming dosimeter. The individual spoke to radiation
protection representatives regarding the situation; however, there
was evidently a communication problem, and the individual was
allowed to re-enter the radiological controlled area without another
alarming dosimeter to retrieve the one he had lost.
This occurrence
was documented in Radiological Occurrence Report 0 -035 and Incident
Report 930214.
Corrective action to prevent recurrence consisted of a special
briefing for contract personnel to emphasize compliance with the
instruction of radiation protection personnel and the stationing of
a technician at the door to check dosimetry.
October 6, 1993 - An individual entered into the radiological
controlled area without carrying an alarming dosimeter, signing the
radiation work permit, or talking to the shift radiological
protection technician. The technician assigned to check dosimetry
did not prevent entry. This occurrence was documented in
Radiological Occurrence Report 93-043 and Incident Report 930236.
Corrective action to prevent recurrence included disciplinary
actions, reassignment of duties, and additional training to
emphasize the authority of access control personnel reviewing
radiation worker compliance with radiation work permit _ instructions
regarding dosimetry.
In each of the above cases, there was a failure to follow the instructions of
the respective radiation work permit in effect. All radiation work permits
involved (93-0102, 93-0004,.93-0103, 93-1197, and 93-1137, respectively)
contained a section setting forth the dosimetry requirements, which included
the use of both thermoluminescent dosimeters and alarming dosimeters.
However, in each case, the persons involved had one form of dosimetry, and no
.
._-
l
l
1
-7-
!
significant exposures were received. Each was identified by the licensee and
documented on a radiological occurrence report and later on an incident
"
report.
,
Procedure RP-AD-200, " Radiation Protection Surveillance Program Administrative
Procedure," states, in part, in Section 4.12.2 that personnel signed in on a
i
radiation work permit are responsible or adhering to the requirements and
r
,
instructions listed on the radiation work permit. Section 5.3.2.A states, in
l
part, that personnel entering the radiological controlled area are required to
wear approved personnel monitoring equipment. The examples of failure to wear ~
the required dosimetry into the radiological controlled area were identified
as a violation of Technical Specification 5.8.1 which requires that certain
procedures be established, implemented, and maintained (285/9323-01).
Because
of the similarity of the occurrences and Decause the corrective actions taken
after each were not sufficient to prevent successive occurrence, the criteria
specified in Section VII.B.2 of the NRC Enforcement Policy for the exercise of
discretion were not satisfied.
During tours of the radiological controlled area and the containment building,
the inspector reviewed area posting and controls, performed independent
radiation measurements, and observed radiation protection personnel's support
of outage work. No problems were identified.
The inspector attended prejob briefings given by ALARA personnel and noted
'
that the briefings were well prepared and presented. The inspector compared
computer-generated, radiological controlled area access records with ALARA
'
briefing attendance lists and confirmed that individuals had attended
i
mandatory briefir.gs.
!
l
2.4 Internal Exposure Control
The inspector reviewed the licensee's internal dose assessment program with a
representative of the dosimetry group and determined that the individual had
an excellent knowledge of the new 10 CFR Part 20 requirements.
In response to
hypothetical internal exposure situations proposed by the inspector, the
representative performed manual calculations and demonstrated the use of a
i
computer program in determining the committed dose equivalent and committed
effective dose equivalent. The licensee's dose results agreed with those of
the NRC.
-
i
The inspector also reviewed the use of engineering controls, air sampling
results, and derived air concentration - hour tracking results and determined
that these items combined to form a good internal exposure control and
monitoring program.
Respirator use has been light since the implementation of the new
10 CFR Part 20; however, the inspector reviewed. respirator issue records and
verified that the users were properly qualified and that they were issued the
correct equipment.
+
,
!
--
.
..
.
.
..
.
.
-8-
,
2.5 Control of Radioactive Materials and Contamination. Surveys. and
Monitorina
The inspector observed access control procedures and did not identify problems
such as discussed in Section 2.3 of this report. The inspector also observed-
the use of personnel contamination monitors by workers and noted that
radiation protection personnel responded quickly when personnel contamination
monitor alarms sounded.
The licensee had recorded 51 personnel skin contamination events directly
'
related to outage work.
Licensee representatives stated that this represented
1.45 skin contamination events per 1000 radiation work permit hours. Their
goal was no more than 1.5.
The inspector reviewed personnel contamination reports and noted that they
were complete. The reports indicated that radiation personnel had made the
proper responses and followed the instructions of Procedure RP-207, " Personnel
Monitoring and Decontamination."
The inspector noted that radiation survey instruments observed in use were
within their calibration intervals and had been response tested prior to use.
'
Survey records were complete and easy to read and understand.
2.6 Maintainina Occuoational Exoosures ALARA
The exposure goal for the outage was 150 person-rems.
The licensee's total
exposure (year to date) was approximately 56 person-rems, as of October 15,
1993.
,
Additional exposure was accrued because the chemical volume control system was
taken out of service. This factor was not considered when the person-rem goal
was established.
Licensee representatives stated that this overage might be
offset by the dose savings which were being achieved as a result of reduced
respirator usage and the subsequent increase in worker efficiency.
Therefore, they believed that the person-rem goal might still be obtainable.
ALARA technicians checked the dose accrual of individual jobs on a daily basis
to ensure that precautions and radiation work permit instructions were
appropriate. All technicians.but one had toured the containment building to
,
inspect outage work in progress.
2.7 Conclusions
Poor planning on the part of outage management caused the chemical volume
control system to be taken out of service before it could remove radioisotopes
.'
in solution in the reactor coolant system. This, in turn, produced higher
radiation dose rates in the early part of the outage.
The radiation protection department supplemented its permanent staff with
contract personnel; however, during the early part of the outage staffing was
less than optimum, resulting in work slowdowns.
.
.
.
-
.
9
.
'
-9-
High quality Alf.RA work' packages-were produced. A good training program for
contract radiation protection personnel was implemented.
A noncited violation was identified as a result of not locking a radiation
area with dose rates higher than 1000 millirems per hour.
-
A violation with multiple examples was identified as a result of radiation
workers entering the radiological controlled area without all dosimetry
required by the governing radiation work permit.
,
The licensee had a strong program for the identification and documentation of
problems and violations.
,
An excellent program for calculating internal radiation dose was implemented.
The licensee had a good program for the control of radioactive materials and
contamination.
,
,
d
.
'l
b
Y
- , ,
..,.
. - , . .
,
.
/
i
ATTACHMENT
1 PERSONS CONTACTED
1.1 Licensee Personnel
- R. L. Andrews, Division Manager, Nuclear Services
- G. R. Cavanaugh, Licensing Engineer
- J. W. Chase, Plant Manager
A. G. Christensen, Radiation Protection Operations
- G. M. Cook, Supervisor, Station Licensing
'
- W. G. Gates, Vice President
S. W. Gerbers, Supervisor, Radiological Health and Engineering
- D. L. Lovett, Supervisor, Radiation Protection
- W. W. Orr, Manager, Quality Assurance / Quality Control
K. E. Steele, Special Projects Coordinator
1.2 NRC Personnel
- R. V. Azua, Resident Inspector
- R. P. Mullikin, Senior Resident Inspector
- Denotes personnel that attended the exit meeting.
In addition to the
personnel listed, the inspector contacted other personnel during this
i
inspection period.
2 EXIT MEETING
An exit meeting was conducted on October 15, 1993.
During this meeting, the
inspector reviewed the scope and findings of the report. The licensee did not-
express a position on the inspection findings documented in this report;
however, the radiation protection manager offered a comment related to the
violation resulting from personnel entering the radiological controlled area
without proper dosimetry. He noted that 17,030 entries were made into the
radiological controlled area during the period of September 25 to October 14,
1993, and the portion in which personnel had improper dosimetry was minute.
The licensee did not identify as proprietary any information provided to, or
reviewed by, the inspector.
.
)