ML20127D041
| ML20127D041 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/11/1993 |
| From: | Spitzberg B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20127D018 | List: |
| References | |
| 50-285-92-32, NUDOCS 9301150070 | |
| Download: ML20127D041 (17) | |
See also: IR 05000285/1992032
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
inspention Report:
50-285/92-32
Operating License:
Licensee: Omaha Public Power District
444 South 16th Street Mall
Mail Stop 8E/EP4
Omaha, Nebraska 68102-2247
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Facility Name:
fort Calhoun Station
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inspection At:
Fort Calhoun Station, Washington County, Nebraska
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Inspection Conducted:
December 14-18, 1992
Inspector:
A. D. Gaines, Radiation Specialist
Facilities Inspection Programs Section
Approve /A BTATr~5iGTiber9, fc/
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Facilities luspection Programs Section
In_spection Summary
Ar_e_as inspected:
Routine, announced inspection of the solid radioactive waste
management and transportation of radioactive materials programs including
audits and appraisals; changes; training and qualifications of personnel;
solid radioactive waste management; radioactive waste classification, waste
characterization, and shipping requirements; transportation activities; and
internal exposure controls as they pertained to Unreso'ved item 285/9219-01.
Results:
Excellent audits s d surveillances were performed by qualified
individuals (L'>r t ior 1.1).
Audits and surveil .nces identified pertinent findings and corrective
actions for the fir aings were timely (Section 1.1).
There had been no major changes in facilities, equipment, programs, or
procedures (Section 2,1).
The radioactive waste operations department had an adequate, well
qualified staff to meet staffing requirements (Section 3.1).
9301150070 930111
{DR
ADOCK 05000285
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An excellent training program for radwaste personnel was in place
(Section 3.1).
Good implementing procedurts for the radioactive waste management
program were maintained (Section 4.1).
An excellent job of identifying and shipping radioactive waste for
burial in 1992 was performed (Section 4.1).
The low-level radioactive waste disposal program was conducted in
accordance with the requirements (Section 5.1).
Excellent implementing procedures that addressed waste classification
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and characterization, selection of packages, preparation of packages,
and delivery of the completed packages to the carrier were maintained
(Section 6.1).
Individuals responsible for transportation of radioactive waste
activities were knowledgeable of the regulatory requirements and burial
site license conditions (Section 6.1).
The review and handling of the uptake incident was excellent
(Section 7.1).
The final root cause analysis was very good and helped the licensee to
self identify the weaknesses that occurred (Section 7.1).
Corrective actions to the uptake incident were prompt and comprehensive
(Section 7.1).
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The licensee did an excellent job of confronting the transuranic issue
(Section 7.1).
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The violations that occurred do not indicate a programmatic breakdown of
the radiation protection program (Section 7.1).
Summary of Inspection Findings:
Failure to revise a radiation work permit when radiological conditions
changed (Section 7.1).
Failure to perform beta radiation dose rate measurements (Section 7.1).
Failure to count samples for gross alpha activity (Section 7.1).
Failure to review survey data for adequacy (Section 7.1).
Failure to start an air sample at the beginning of work likely to cause
airborne activity (Section 7.1)
Failure to post an Airborne Radioactivity Area (Section 7.1).
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Failure to use engineering controls to the extent practicable to limit
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airborne concentration limits (Section 7.1)
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Unresolved Item 50-285/9219-01 was closed (Section 7.1).
Inspectior. Followup Item 50-285/9207-01 was closed (Section 8.1).
Inspection Followup Item 50-285/9207-02 was closed (Section 8.2).
Inspection followup Item 50-285/9207-03 was closed (Section 8.3).
Inspection Followup Item 50-285/9207-04 was closed (Section 8.4).
Inspection Followup Item 50-285/9207-05 was closed (Section 8.5)..
Inspection Followup Item 50-285/9207-06 was closed (Section 8.6).
Attachment:
Attachment - Persons Contacted and Exit Meeting
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DETAILS
1 AUDITS AND APPRAISALS (86750)
The inspector reviewed the quality assurance audit and surveillance programs
regarding the solid radioactive waste and transportation of radioactive
materials programs to determine agreement with commitments in Chapters 12 of
the Updated Safety Analysis Report and compliance with the requirements in
Technical Specification 5.5.2.8.
1.1 Discussion
The inspector reviewed Quality Assurance Audit 63 and the qualifications of
the quality assurance auditors who performed the audit and surveillances of
the solid radioactive waste and transportation programs. Audit and
surveillance reports of quality assurance activities performed since the last
NRC inspection of the solid radioactive waste and transportation programs in
July 1991 were reviewed for scope, thoroughness of program evaluation, and
timely followup of identified deficiencies.
Quality Assurance Audit 63 was
performed in November 1991 in accordance with quality assurance procedures and
schedules. The audit was performed by qualified auditors, who were
knowledgeable in the solid radioactive waste and transportation programs, and
their applicable requirements for nuclear power facilities. The inspector
noted that the audit identified pertinent findings and that prompt corrective
actions were taken to correct the findings. The audit of the solid
radioactive waste and transportation programs was of good quality and
satisfactory to evaluate the licensee's performance in implementing the solid
radicactive waste and transportation programs.
The inspector reviewed the quality assurance surveillances performed during
the period July 1991 through Ncvember 1992 in the areas related to the
performance of the solid radioactive waste and transportation programs. The
quality assurance surveillances were of excellent quality and satisfactory to
evaluate the licensee's performance and provide periodic management oversight.
1.2 Conclusion
Excellent audits and surveillances were performed by qualified individuals.
The audits and surveillances identified pertinent findings and corrective
actions for the findings were timely.
2 CHANGES (86750)
The inspector reviewed the organization, management controls, staffing, and
the assignment of solid radioactive waste and transportation program
responsibilities for changes and to determine agreement with commitments in
Chapter 12 of the Updated Safety Analysis Report and compliance with the
requirements in Technical Specification 5.2.
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2.1 Discussion
The inspector noted that there had been no major changes since the last
inspection in facilities, equipment, programs, and procedures that would have
adversely affected the solid radioactive waste management and transportatien
of radioactive materials programs. The inspector noted that the position of
Supervisor Radwaste Operations was filled, temporarily, by the Radwaste
Operations Coordinator.
The individual who had held the position of
Supervisor Radwaste Operations was no longer employed by the licensee.
The
licensee stated that they hoped to fill the vacancy in the near future.
2.1 Conclusion
There had been no major changes in facilities, equipment, programs, or
procedures.
The position of Supervisor Radwaste Operations was temporarily
filled by the Radwaste Operations Coordinator with no apparent adverse affects
on operation of the program.
3 TRAINING AND QUALIFICATIONS (86750)
The inspector reviewed the training and qualification programs for personnel
responsible for implementing the solid radioactive waste and transportation of
radioactive materials programs to determine agreement with commitments in
Chapter 12 of the Updated Safety Analysis Report and compliance with the
requirements in lechnical Specification 5.3 and the licensee's response to NRC
3.1
Discussion
The inspector reviewed individual staff computerized training records and
qualification cards for selected individuals. The licensee's training records
indicated that a vendor radwaste training course was conducted December 1992.
Members of the radioactive waste department, quality control, and the training
department attended the vendor training.
The training included Department of
Transportation regulations,10 CFR Part 61 and 20.311, mixed waste, and
site-specific requirements for low-level waste burial sites.
It was
determined that the radioactive waste operations department had a qualified
staff to perform radioactive waste activities.
3.2 Conclusion
The radioactive waste operations department had a qualified staff to meet
staffing requirements.
The licensee had maintained an excellent training
program for radwaste personnel.
4 SOLID RADI0 ACTIVE WASTE MANAGEMENT (86750)
The inspector reviewed the licensee's solid radioactive waste management
program to determine . compliance with the requirements of Technical Specifications 2.9.2 and 3.12.2 and 10 CFR Part 61 and agreement with
commitments in Chapter 11 of the Updated Safety Analysis Report.
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4.1 Discussion
The inspector reviewed selected radioactive waste procedures that implemented
the licensee's solid radioactive waste management program.
The inspector-
noted that the procedures were adequate for the processing and disposal of
low-level radioactive waste and met the requirements of the licensee's
Technical Specifications.
The inspector reviewed the licensee's records for low-level radioactive waste
shipped since 1988.
The following tabulation shows the total volume and curie
content of the low-level radioactive waste shipped for the period 1988 through
December 11, 1992.
Year
Volume - Cubic Feet
Curie Content
1988
1,722.4
17.5
1989
6,195.0
8.8
1990
4,310.1
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1,334.5
19.7
1992
2,181.5
440.5
In 1992 approximately 439.4 curies of-the curie content that was shipped was
from the licensee's shipments of spent resins and resin filters. The licensee
did a very good. job of identifying and shipping for burial the majority of
radioactive waste on site before January 1, 1993, to preclude the
uncertainties of future burials and interim onsite storage.
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4.2 Conclusion
The licensee had good implementing procedures for the radioactive waste
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management program.
The licensee performed an excellent job of identifying
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and shipping radioactive waste for burial in 1992.
5 RADI0 ACTIVE WASTE CLASSIF? CATION, WASTE CHARACTERIZATION, AND SHIPPING
REQUIREMENTS (86750).
The inspector reviewed the licensee's program for disposal of low-level-
radioactive waste including shipping manifests, waste classification, waste
. form and characterization, shipment labeling, tracking of- waste shipments, and
burial facility license conditions to determine compliance with the
requirements of 10 CFR 20.311, 61.55. and 61.56.
5.1 Discussion
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The inspector reviewed the licensee's radioactive waste procedures and found
the licensee's program for classification and characterization of radioactive
-waste to meet the requirements of 10 CFR Part 61.. The licensee-and a
contractor laboratory performed radiochemical analyses on samples of various
radwaste types to meet the requirements in 10 CFR 61.55 and 61.56.
The test
sample analyses results were used for determination of radwaste classification
and isotopic composition of the radwaste sources.
The licensee performed
isotopic analysis on each batch of radioactive waste packaged for shipment and'
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burial and employed correlation factors for characterization of isotopes not
directly identified.
The inspector reviewed selected radioactive waste shipment manifests and
shipping papers that accompanied the licensee's shipments of radioactive
waste.
The inspector determined that the completed manifests complied with
the requirements of 10 CFR 20.311,
5.2 Conclusion
The licensee's low-level radioactive waste disposal program was conducted in
accordance with the requirements of 10 CFR 20.311, 61.55, and 61.56.
6 TRANSPORTATION ACTIVITIES (86750)
The inspector reviewed the licensee's transportation program for shipment of
radioactive saterials and radioactive waste to determine compliance with the
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requirements of 10 CFR Parts 20, 61, and 71, and 49 CFR Parts 172-189.
6.1 Discussion
6.1.1
Quality Assurance Program
The licensee has maintained an approved Quality Assurance program in
accordance with 10 CFR Part 71, Subpart H, for the transportation of
radioactive materials (Approval 0256, Revision 3).
The approval expires
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July 31, 1994.
6.1.2 Procurement and Selection of Packages
The licensee used strong-tight containers for the shipment of radioactive
waste. Of the 81 shipments made to date in 1992, 31 were laundry shipments in
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steel containers.
Most of the other shipments were in sea and/or land
containers which contained uncompacted waste that was shipped to a vendor who
segregated and repackaged the radioactive waste.
The licensee was on the
user's list for all NRC and Department of Transportationscertified packages
used.
The licensee maintained current documentation on the manufacturer's
design testing, maintenance, and the NRC Certificate of Compliance for all
radioactive material packages used by the licensee.
6.1.3 Preparation of Packages for Shipment
The inspector verified that the licensee had procedures and checklists for the
preparation of radwaste shipments. These procedures provided for visual
inspection of the package prior to filling the container, instructions for
closing and sealing the container, marking and labeling requirements, and
determination of compliance with radiation and contamination limits. The
licensee routinely used a checklist to assure that procedures were followed
and that packages were prepared properly for shipment in accordance with NRC,
Department of Transportation, state, and burial site requirements.
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Discussions with licensee personnel indicated that the individuals involved in
the transportation of radioactive waste and/or materials possessed a working
knowledge of the licensee's procedures and NRC and Department of
Transportation regulations pertaining to the preparation of packages for
shipment.
6.1.4 Delivery of Completed Packages to Carriers
The inspector verified that the licensee's procedures included the required
NRC and Department of Transportation regulations. A review of selected
records and shipping papers for radioactive waste shipments indicated that the
licensee h4 prepared appropriate manifests and shipping papers in accordance
with approved procedures and that the shipping papers included the necessary
information to comply with regulatory requirements. The licensee only used
exclusive use carriers for all radioactive waste shipments and assured that
the following items were in accordance with NRC and Department of
Transportation regulations and station procedures:
radiation levels were
within required limits, transport vehicles were placarded properly, surface
contamination on packages did not exceed requirement levels, and blocks and/or
braces were in place to prevent damage or shifting of the load during transit.
6.1.5 Reccrds, Reports, and Notifications
The inspector reviewed selected records of 15 radioactive waste shipments made
by the licensee during 1992.
The licensee's shipments were adequately
documented to meet NRC and Department of Transportation regulations.
The
licensee maintained records of all radioactive waste and/or materials
shipments as required. The records included all shipping documentation,
radiation surveys, and required notification data.
6.2 Conclusion
The licensee maintained excellent implementing procedures that addressed waste
classification and characterization, selection of packages, preparation of
packages, and delivery of the completed packages to the carrier.
Individuals
responsible for transportation of radioactive waste activities were
knowledgeable of the regulatory requirements and burial site license
conditions. The licensee's shipments of radioactive waste and/or materials had
met applicable transportation requirements.
7
INTERNAL EXPOSURE CONTROL (83750)
The inspector reviewed the details concerning a licensee-identified internal
exposure intake to determine compliance with 10 CFR 20.103 requirements.
7.1 Discussion
7.1.1
Intake Incident
On April 16, 1992, during the change-out of the Reactor Letdown Filters CH-17A
and B, a radiation protection technician received an intake of airborne
radioactive material.
The radiation protection technician who received the
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intake of radioactive material was originally stationed outside Room 11 where
the reactor system letdown filters were being replaced.
His function was to
escort the scaled drums containing the used filters to a storage area.
Respiratory protection equipment was not required for this function.
Both
filter assemblies were changed out successfully, and the drums containing the
used filters were transported to storage escorted by the radiation protection
technician.
The radiation protection technician returned to Room 11 expecting
to see the maintenance personnel exiting the area.
Since the maintenance personnel were not in the process of exiting Room 11,
the radiation protection technician proceeded into Room llA to see if
assistance was needed since the process of changing out the tilters was
physically demanding and was compounded by the protective clothirl and
respiratory protection equipment requirements. When the radiation protection
technician reached the boundary of the highly contaminated area, he observed
two of the maintenance personnel in obvious physical stress and still dressed
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in protective clothing and waaring respirators.
The radiation protection
technician immediately began helping undress the stressed maintenance workers.
The highly contaminated clothing was removed, placed in a bag, and left near
the highly contaminated area boundary. The radiation protection technician
escorted the stressed workers to an area where they could rest and recover,
and he returned to Room 11 to see if further assistance was needed. The
radiation protection technician ther, assisted a second radiation protection
technician inside the highly contaminated area in transferring the highly
contaminated protective clothing across the highly contaminated area boundary.
The assisting radiation protection technician had not been required by the
radiation work permit to vere respiratory protection equipment in conjunction
with his original work assr nment. According to interviews with the two
radiation protecti.
tc+ ajans involved, the intake of radioactive material
by the assisting technician probably took place during the process of placirg
a bag of highly contaminated clothing into a clean bag for transport.
At that
time, a localized airborne radioactivity area was generated allowing the
inhalation of radioactive material by the technician not wearing respiratory
protection equipment.
The event was discovered when the radiation protect'on technician attempted to
exit the radiation controlled area and caused the personnel contamination
monitor to alarm. The radiation protection technician was placed on an
exclusion from the radiation controlled area, and in vivo and in vitro
bioassay sampling and measurements were initiated.
The radiation protection
technician showed possible internal contamination from whole-body counts and
positive nasal smears. Respirator cartridges and air sampler filters were
retained for analysis. Air sample activity was subsequently verified to be
higher than expected because of airborne alpha contamination.
7.1.2
Licensee's Exposure Determination
On April 16, 1992, the licensee started their initial investigation of- the
event.
Four urine samples and one fetal sample from the affected radiation
protection technician, one air sampler filter, and two respirator cartridges
were sent to a contractor laboratory for analyses.
Based on the initial gamma
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isotopic analysis results of the four urine samples, the licensee requested a
transuranic analysis on one of the urine samples. The initial gamma isotopic
results of the urine samples were used for preliminary dose calculations as
documented in Radiological Occurrence Report 92-030.
This report assigned
45.52 MPC-hours to the radiation protection technician as a result of his
intake of radioactive material.
Upon receipt of the results from the initial gross alpha, gross beta, and
gamma isotopic analyses of the air sampler filter, the two respirator
cartridges, and the fecal sample, the licensee requested that a transuranic
analysis of the air sampler filter be performed. The tra'scranic analysis of
the first urine sample showed a positive plutonium-238 result. On July 17,
1992, initial dose calculations were performed by the licensee using the
transuranic analysis results from the radiation protection technician's urine
sample. These dose calculations indicated a possible exposure in excess of
the 520 MPC-hour limit specified in 10 CFR 20.103.
The licensee met with the
NRC resident inspectors and informed them of the preliminary results from the
dose calculations and provided the resident inspectors with a copy of the
Radiological Occurrence Report 92-030 which contained the preliminary analysis
of the incident. The exposed radiation protection technician was also
informed of the analytical results of the bioassay samples and the preliminery
analysis of the event and associated dose commitment.
On July 31, 1992, the licensee informed the NRC Region IV office of the event
and the licensee's plans for a followup investigation. Arrangements were made
by the licensee with a consultant to assist in performing the MPC-hour
calculations. Additional results from the urine samples were received from
the contractor laboratory on August 7,1992, and dose calculations based on
these transuranic analytical results indicated a possible intake of
radioactive material in excess of 1800 MPC-hours. However, the consultant's
calculated MPC-hours, based primarily on the radiation protection technician's
whole-body count data, projected an MPC-hour exposure value of approximately
363 MPC-hours.
On August 20, 1992, the licensee informed the NRC Region IV office of the
projected internal exposure of 363 MPC-hours.
A second consultant was
contracted by the licensee to assist in the investigation and dose assessment.
The second consultant had submitted a draft report which indicated a
calculated upper bounds dose of 514 MPC-hours for the transuranics,1 MPC-hour
for cobalt-58 and cobalt-60, and 2 MPC-hours for the remaining activation and
fission product contribution to the total dose. Therefore, the preliminary
upper bounds dose was estimated at 517 MPC-nours.
However, the second
consultant also indicated that the most probable intake dose result would be
close to the 363 MPC-hours calculated by the first consultant and that the
value was probably conrervative.
7.1.3
NRC Assessment of the Licensee's Exposure Determination
At the time of the August 31 through September 4, 1992, NRC inspection, the
licensee had not completed their investigation of this incident and had not
made a final assignment of the internal exposure to the radiation protection
technician. The licensee had therefore, not determined whether this individual
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had exceeded the 520 MPC-hour internal exposure limit specified in
This issue was documented as an Unresolved Item in Inspection
Report 50-285/92-19 pending completion of the final MPC-hour evaluation and an
NRC review of radiological controls associated with the event. (Unresolved item
285/9219-01).
Subsequently, the licensee submitted Licensee Event Report 92-29 dated.
November 6, 1992, which documented the April 16, 1992, event.
In the Licensee
Event Report, the licensee stated that they were assigning the value of
366 MPC-hours to the individual, even though the internal dosimetry experts
were in agreement that the actual exposure was less.
The 366 MPC-hours
assigned to the individual is less than NRC's regulatory limit of
520 MPC-hours per quarter and appeared to be a conservative estimate. Just
prior to the exit meeting, the licensee had another internal dosimetry expert
review the data. This review determined that the intake may have been as low
as 19 MPC-hours.
The licensee indicated to the inspector that they would
review these findings and, if they were found to be valid, they would revise
the individuals intake results accordingly.
7.1.4
Licensee's Root Cause Analysis
The licensee had performed a root cause analysis for the uptake incident and
had their quality assurance group review the root cause analysis and the
supporting documents. The quality assurance review revealed several
nondocumented noncompliances, one of which appeared to be a repeat of a
violation identified in NRC Inspection Report 50-285/92-07.
The review also
indicated that the root cause analysis was incomplete in that it had not
addressed issues outside of the identified transuranic uptake.- Because of the-
review, the licensee performed a second in-depth root cause analysis of the
incident.
The inspector reviewed the Root Cause Analysis Report and the incident. This
second root cause-analysis was excellent and helped the licensee to self
identify ten apparent violations of procedures. The inspector did not
identify any further violations during the review of the incident and Root-
Cause Analysis Report. Through discussions with licensee personnel and an
in-depth review of the ten apparent violations that the licensee noted, .the
inspector determined that two of the apparent violations were not valid.
Also, the licensee had identified two apparent procedural violations that the
inspector determined were more appropriately cited as'one violation under
Therefore, the inspector noted that there were seven licensee
identified violations, six of which were- procedural violations, and one
violation associated with 10 CFR Part 20.
All procedural violations stemmed
from. Technical Specification 5.8.1.
Technical Specification 5.8.1 states, in part, that written procedures and
administrative policies shall be established, implemented, and maintained that
meet or exceed the minimum requirements of Sections 5.1 and 5.3 of
ANSI N18.7972 and Appendix A of Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix A, Section 7.e(l) states, in part, that access
control'to radiation ar.eas by a radiation work permit system should be covered
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by written procedures.
Radiation Protection Procedure RP-201,
Section 7.6.2.A(2), states, in part, that a radiation work permit should be
revised when radiological conditions change requiring additional controls.
The licensee identified that on April 16, 1992, radiological conditions had
changed during the change-out of the letdown purification filters, and the
contract radiation protection technician did not stop the job and have the
radiation work permit revised.
Specifically, the letdown filters were found
to be drier than usual and caused more of an airborne radioactivity problem
than was anticipated.
Therefore, this was identified as a violation of
Technical Specification 5.8.1 (285/9232-01).
Regulatory Guide 1.33, Appendix A, Section 7.e(2) states, in part, that
radiation surveys should be covered by written procedures.
Radiation
Protection Procedure RP-202, Section 7.1.1.B(1)(a), states, in part, that beta
radiation dose rates shall initially be measured at contact when internal
surfaces of primary or radwaste systems are accessible and worked on. The
licensee identified that on April 16, 1992, when the letdown purification
filters of the Chemical and Volume Control System were changed out, beta
radiation dose rates were not measured.
Therefore, this was identified as a
violation of Technical Specification 5.8.1 (285/9232-02).
Regulatory Guide 1.33, Appendix A, Section 7 e(2) states, in part, that
radiation surveys hould be covered by written procedures.
Radiation
Protection Procedure RP-202, Section 7.1.2.C(1), states, in part, that loose
surface contamination samples taken d.ging breach of primary systems are to be
counted for gross alpha activity.
The licensee identified that the loose
surface contamination samples taken on April 16, 1992, during the breach of
the Chemical and Volume Control System to change the letdown filters, were not
counted for gross alpha activity.
Therefore, this was identified as a
violation of Technical Specification 5.8.1 (285/9232-03).
Regulatory Guide 1.33, Appendix A, Section 7.e(2) states, in part, that
radiation surveys should be covered by written procedures.
Radiation
Protection Procedure RP-202, Section 7.5.2 states, in part, that the
Radiological Operation Coordinator, or his designee, shall review all surveys.
Section 7.5.4.A, staten in part, that the review shall address the adequacy
of survey data with respect to the reason for performing the surve.
The
licensee identified that reviews of the surveys performed on April 16, 1992,
in support of the letdown filter change-out, did not address the adequacy of
the survey data.
Specifically, the reviews did not detect that beta dose
rates and alpha counts should have been performed and were not.
Therefore,
this was identified as a violation of Technical Specification 5.8.1
(285/9232-04).
Regulatory Guide 1.33, Appendix A, Section 7.e(5) states, in part, that
respiratory protection should be covered by written procedures.
Radiation
Protection Procedure RP-203, Section 7.1.2.A and B, states, in part, that job
coverage air samples shall be taken as directed by the Radiation Work Permit
at the start of work likely to cause airborne activity, such as disassembly of
highly contaminated components and during work requiring respiratory
protection. .The licensee identified that on April 16, 1992, an air sample was
not taken at the start of work in Room 11 to support Radiation Work
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Permit 92-025 work which required respiratory-protection. -Specifically, one
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of the letdown filters had already been changed out before the air sample in
Room 11 was started.
Therefore, this was identified as a violation of
Technical Specification 5.8.1 (285/9232-05). The inspector noted that the
licensee had started air samples in the corridor outside' Room 11 and in an
area above Room-11 where other individuals were working before the first
filter was changed out.
The inspector determined that this violation was a
repeat violation of Violation 285/9207-04 which was for failure to perform an
air sample on a job that required respiratory protection.
The inspector noted
that the individual, who on April 16, 1992, failed to start the air sample
before the work began in Room 11, had attended a March 1992 briefing which
went over the violations that were documented in NRC Inspection Report
50-285/92-07. The briefing stressed the need to comply with the procedures
that were violated.
Regulatory Guide 1.33, Appendix A, Section 7.e(5) states, in part, that
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respiratory protection should be covered by writtJn procedures.
Radiation
Protection Procedure RP-204, Section 7.2.7, states, in part, that the licensee
post Airborne Radioactivity Areas where the concentration of airborne
radioactive materials exceed 25 percent of 1 MPC.
The licensee identified
that on April 16, 1992, Room 11 where the letdown filters were changed out was
not posted as an Airborne Radioactivity Area.
Past job evolutions indicated
that the concentration of the airborne radioactive materials in Room 11
exceeded 25 percent of 1 MPC when the filters w e changed and the
concentration exceeded 25 percent of 1 MPC on A7.il 16, 1992.
Therefore, this
was identified as a violation of Technical Specification 5.8.1 (285/9232-06).
10 CFR 20.103(b)(1) requires that the licensee, as a precautionary procedure,
use process or other engineering controls, to the extent practicable, to limit
concentrations of radioactive materials in air to levels below'those which
delimit an airborne radioactivity area as defined in 10-CFR 20.203(d)(1)(ii).
10 CFR 20.203(d)(1)(ii) states, in part, that an airborne radioactivity area
is any room, enclosure, or operating area in which airborne radioactive
material composed wholly or partly of licensed material exists in
concentrations which, averaged over the number of hours in any week during
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which individuals are in the area, exceed 25 percent of the amounts specified
in Appendix B, Table I, Column 1-of Part 20. Discussions with the licensee
indicated that the Radiation-Protection Supervisor had requested that a high
efficiency particulate air' filter-unit be used during the letdown filter-
change in-Room 11. The licensee stated that it would have-been-practicable to -
. use a filter, but_ the high efficiency particulate ' air filter was not.used and
this decision was not forwarded to the Radiation Protection Supervisor who.had
requested it be used.
The concentration of airborne radioactive material in
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Room 11 exceeded 25 percent of the amounts specified-in Appendix B, Table -1,
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Column 1 of Part 20.
Therefore, the licensee identified that- on April 16,
1992., engineering controls were not used to the extent: practicable to limit
concentrations of radioactive materials in air to levels below those.which
delimit an airborne radioactivity area as defined in 10 CFR 20.203(d)(1)(ii).
Therefore, this was identified as a violation of 10 CFR 20.103(b)(1)
(285/9232-07).
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A review of the incident and the Root Cause Analysis Report, combined with
interviews of individuals that were involved with the incident, indicated that
what occurred was not indicative of a programmatic breakdown of the radiation
protection program. However, the inspector indicated his concern to the
licensee because of the number of procedural violations that occurred.
The inspectors noted that the licensee's Root Cause Analysis Report contained
comprehensive corrective actions, and that the licensee had promptly proceeded
with implementation of corrective actions identified in the Root Cause
Analysis Report.
As part of their immediate corrective actions, the licensee
had completed a records review of all air sample data to determine if any
similar events had occurred.
The licensee determined that there were no
similar incidents where personnel had encountered airborne alpha contamination
without having respiratory protective equipment.
The licensee noted that an
entry underneath the reactor vessel hud taken place during the July 1992 loss
of coolant accident in which long-lived alpha contamination was later
identified. The licensee determined that the proper respiratory equipment Sad
been assigned based on expected conditions. After reviewing the license n
documentation, the inspector agreed that the conditions that ultimately were
found to have been encountered were n(
expected and that the licensee's
selection of respiratory protective equi, ment was proper at the time.
Therefore, the respirator selection for the job was not in violation of
10 CFR 20.103(3)(c).
Since the licensee has assigned the individual a conservative internal
exposure and a thorough review of the radiological controls associated with
the event has been completed, Unresolved Item 285/9219-01 is considered
closed.
7.2 Conclusion
The licensee's investigation and assessment of the uptake was excellent.
The
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final root cause analysis was very good and helped the licensee to
self-identify several violations that occurred.
The licensee's corrective
actions to the uptake incident were prompt and comprehensive. The licensee
did an excellent job of confronting the transuranic issue.
The violations
that occurred do not appear to indicate a-programmatic breakdown of the
radiation protection program.
8 FOLLOWUP (92701)
8.1
(Closed) Inspection Followup Item (285/9207-01):
Ensuring That Radiation
Work Permit Reauirements Are Complied With
This inspection followup item was identified in NRC Inspection
Report 50-285/92-07 and involved the failure of a radiation protection
technician to ensure that radiation work permit requirements were complied
with.
Specifically, the technician instructed personnel to work without
respiratory protection, even though the radiation work permit required
respiratory protection.
The inspector reviewed the licensee's corrective
actions and randomly selected radiation work permits that required respiratory
protection.
The inspector noted that respiratory protection had been used on
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the radiation work permits that required the use of respiratory protection.
The inspector determined that the licensee's corrective actions for this item
were satisfactory to close this item.
8.2
(Closed) Inspection Followup Item (285/9207-02):
Documentation of
Personnel Contaminations
This inspection followup item was identified in NRC Inspection
Report 50-285/92-07 and. involved the failure to document personnel skin and/or
clothing contamination events on Form FC-RP-207-1.
The inspector reviewed the
licensee's corrective actions and randomly selected personnel contamination
reports for review.
The inspector noted that the personnel contamination
events that were reviewed had been documented on Form FC-RP-207-1. The
inspector determined that the licensee's corrective actions for this item were
satisfactory to close this item.
8.3
(Closed) Inspection Followup Item (285/9207-03):
Documentation of
Respiratory Protection Equipment Selection
This inspection followup item was identified in NRC Inspection
Report 50-285/92-07 and involved the failure to attach a respiratory
protection equipment selection Form FC-RP-201-6 to a radiation work permit
,
which required respiratory protection.
The inspector reviewed the licensee's
corrective-actions and randomly selected radiation work permits that required
respiratory protection.
The inspector noted that the radiation work permits
that were reviewed had Form FC-RP-201-6 attached. The inspector determined
that the licensee's corrective actions for this item were satisfactory to
close this item.
8.4
(Closed) Inspection Followup' Item (285/9207-04):
Air Sampling =
This i,nspection followup item was identified in NRC Inspection
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Report 50-285/92-07- and involved the failure to perform an air sample on a job
with radiation work permit required respiratory protection.
The inspector-
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determined that the licensee's immediate corrective actions for this item were
not sufficient in that there was a similar occurrence. This item is being
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closed, and followup of the licensee's-corrective actions will be tracked-
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under 285/9232-05.
8.5 (Closed) Inspection Followup Item (285/9207-05):
Performance of
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Whole-Body Counts for Facial Contamination
This inspection followup item was identified in NRC Inspection
Report 50-85/92-07 and involved the failure to perform a _whole-body count for
an individual who had exhibited skin contamination in the area of the mouth
and nose.
The inspector reviewed the licensee's corrective actions and-
randomly selected personnel contamination reports that involved facial
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contaminations for review. -The inspector noted that for'the contamination
reports that were reviewed, the licensee had performed whole-body counts on
individuals who had exhibited skin __ contamination in:the area of the mouth and
nose. The inspector determined that the licensee's corrective actions for
this item were satisfactory to close this item.
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8.6 (Closed) Inspection followup item (285/9207-06);
Calibration of
Airborne Radiation Monitori
This inspection followup item was identified in NRC Inspection
Report 50-285/92-07 and involved the failure to calibrate an airborne monitor
at the proper frequency. The inspector reviewed the licensee's corrective
actions and randomly selected airborne monitors while touring the
radiologically controlled area to-verify if the instruments had been
calibrated at the proper frequencies.- The inspector noted that the
instruments that were reviewed had been calibrated'at the proper frequencies.
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The inspector determined that the licensee's corrective actions for this item
were satisfactory to close this item.
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ATTACHMENT
1 PERSONS CONTACTED
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1.1
Licensee Personnel
- R. L. Andrews, Division Manager, Nuclear Services
- S. K. Gambhir, Division Manager, Production Engineering
8. H. Blome, Supervisor, Corporate Quality Assurance
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M. A. Breuer, Technician,_ Radioactive Waste Operations
- J. W. Chase, Acting Plant Manager
- G. M. Cook, Supervisor Station Licensing
- A. G. Christensen, Supervisor, Radiation Protection Operations
F. F. Franco, Manager, Radiological Services
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- W. G. Gates, Vice President, Nuclear Operations
- J. K. Gasper, Manager, Nuclear Training
S. W. Gebers, Health Physicist, Radiological Services
R. G. Haug, Supervisor, Chemistry / Radiation Protection Training
- R. L. Jaworski, Manager, Station Engineering
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C. J. King, Technician, Radiation Protection Operations
- L. T. Kusek, Manager, Nuclear Safety Review
- D. L. Lovett, Supervisor, Radiation Protection
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- J. M. Mattice, Acting Supervisor, Radioactive Waste Operations
- W. W. Orr, Manager, Quality Assurance / Quality Control
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T. L. Patterson, Plant Manager
- R. L. Phelps, Manager, Design Engineering
- H. J. Sefick, Manager, Security Services
- R. W. Short, Manager, Nuclear Licensing
L. D. Sills, Senior Quality Assurance Auditor
- C. F. Simmons, Station Licensing Engineer
K. E. Steele, Acting Supervisor, Radiological Health and Engineering
1.2 NRC Personnel
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- R. P. Mullikin, Senior Resident Inspector
- Indicates those present at the exit meeting on December 18, 1992.
2 EXIT MEETING-
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An exit meeting was conducted on December 18, 1992.
During this meeting, the
inspector reviewed the scope and findings of the report. The licensee stated
- that in January 1993, they were going to have an outside technical expert
audit their Radiation-Protection Program for indications of programmatic
problems. _The licensee did not identify as proprietary, any of the materials
provided to, or reviewed by the inspector during the inspection,
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