ML20141E125
| ML20141E125 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/13/1985 |
| From: | Baer R, Murray B, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20141E109 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-285-85-25, NUDOCS 8601070565 | |
| Download: ML20141E125 (13) | |
See also: IR 05000285/1985025
Text
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APPENDIX
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1,
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-285/85-25
License:
Docket:
50-285
Licensee: Omaha Public Power District (OPPD)
1623 larney Street
Omaha, Nebraska 68102
Facility Name:
Fort Calhoun Station (FCS)
Inspection At:
Inspection Conducted:
November 4-8, 1985
Inspectors:
/ M TA/ b '
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R. 4. Baer, Radiation Specialist, Facilities
Date
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Radiological Protection Section
W
/Z-13M
D.B.Spitzbsrg,RadFhtfinSpecialist
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Facilities Radiological Protection Section
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IM62/
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[BlaineMurray,~ Chief,Fp111tiesRadiological
Approved:
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Date
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Protection Section
Inspection Summary
Inspection Conducted November 4-8, 1985 (Report 50-285/85-25)
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Areas Inspected: Routine, unannounced inspection of the licensee's radiation
protection program for controlling occupational exposures during a refueling
outage including advanced planning and preparation, training, external exposure
control, internal exposure control, radwaste and contaminated materials control,
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posting, labelling, worker control, and independent measurements.
In addition,
the NRC inspectors reviewed the licensee's actions on three open items related
to NUREG-0737.TMI Action Plan Requirements. The inspection involved
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82 inspector-hours onsite by 2 NRC inspectors.
8601070565 851EG23
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Results: Within the areas inspected, no violations or deviations were
identified. Two unresolved items were identified in paragraph 3.
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DETAILS
1.
Persons Contacted
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- W. G. Gates, Manager FCS
A. Bilau, Radwaste Coordinator
M. R. Christensen, Training Instructor
R. A. Cords, Chemistry and Radiation Protection (C/RP) Senior Technician
C. R. Crawford, ALARA Coordinator
S. Dixon, C/RP Technician
M. L. Ellis, Instrument and Control (I&C) Coordinator
- J. J. Fisicaro, Supervisor - Nuclear Regulatory and Industry Affairs
S. W. Gebers, Acting C/RP Crew Chief
J. Glantz, C/RP Technician
J. M. Hale, C/RP Specialist
D. A. Jacobson, Training Instructor
T. W. Jamieson, Acting C/RP Crew Chief
- J. M. Mattice, Plant Health Physicist
- K. J. Morris, Manager, Quality Assurance (QA)
- G. L. Roach, Supervisor C/RP
B. Schmidt, C/RP Technician
F. K. Smith, Plant Chemist
Others
G. O. Maloy, Contractor Training Instructor
- P. H. Harrell, NRC Senior Resident Inspector
The NRC inspectors also interviewed other licensee and contractor
employees including C/RP, administrative,. maintenance, and construction
personnel.
- Denotes thor >e individuals present during the exit interview cn
November 8, 1985.
2.
Licensee Action on Previously Identified Open Items
(Closed) Open Item (285/8226-14): NUREG-0737, Item II.B.3, Postaccident
Sampling (PASS) Capability - This item had remained open pending the
licensee's demonstration to the NRC of the PASS to perform its designed
function.
In reviewing this item, the NRC inspectors found that site
acceptance testing, development of approved operating procedures, and
operator training on the system had been found satisfactory as documented
in NRC Inspection Report 50-285/84-28.
Operation of the PASS was verified
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by the NRC resident inspector during the period July 1 through
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August 31, 1985, and was documented in NRC Inspection Report 50-285/85-15.
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The NRC inspectors also reviewed records of PASS dilution calibrations
performed in September 1984. The licensee had not as yet performed an
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evaluation of particulate and iodine plateout in the PASS containment
atmosphere sampling line. This finding is noted as an observation in
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paragraph 4 of this report.
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Open item 285/8226-14 is considered closed.
(Closed)~0 pen Item (285/8226-17): NUREG-0737, Item II.F.1 ( Attachment 3),
' Containment High Range Radiation Monitor - This item, discussed in NRC
Inspection Reports 50-285/82-26 and 50-285/83-22, was left open pending a
revision of the monitors' calibration procedures to include calibration
below 10 R/hr using a calibrated radiation source. The NRC inspectors
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reviewed containment high range radiation monitor calibration procedures
CP-RM-091 A and B and found that they had been revised on November 11,
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1984. to include radiometric calibration at 8.9 R/hr. Records showed the
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monitors to have been calibrated according to the revised procedures on
November'20, 1984. Open item 285/8226-17 is considered closed.
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3.
Unresolved Items Identified During This Inspection
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An unresolved item is a matter about which mor.e information is required in
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order to ascertain whether it is an acceptable item, an open item-,a
deviation,'or a violation.
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Unresolved I'.am (285/8525-01): Calibration of Constant Air Monitoring
Instrumentation - The licensee did not have documentation av&ilable for
review of a calibration performed on particulate, iodine, and noble gas
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(PING) monitor serial number 214 in August 1985.
See paragraph 8 for
details.
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Unresolved. Item (285/8525-02): Inoperability of Wide Range Noble Gas Stack
Monitor RM-063L.M.H - The licensee did not have documentation available
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for review of a special report on the inoperability of the wide range
noble gas stack monitor RM-063M.H beyond September 14, 1984.
See
paragraph 11 for details.
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4.
Inspectors Observations
The following are observations the NRC inspectors called to the licensee's
attention. These observations are neither violations nor unresolved
items. These items were recommended for licensee consideration for
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program improvement, but they have no specific regulatory requirement.
The licensee indicated that these items would be reviewed:
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a.
NRC Form 4 - The date the individual signed the NRC Form 4~was not
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always present and the previous exposure history units were sometimes
. missing the decimal point. See paragraph 7 for details.
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b.
Instrument Repair - The licensee had a.large quantity of. radiation
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. protection survey meters, airborne radiation monitors, and personnel
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contamination monitoring instruments out-of-service.
See paragraph 5
for details,
c.
Decontamination Personnel - The ccntractor personnel assigned to
decontamination duties in the auxiliary building were not performing
all duties in a manner considered radiologically safe.
See
paragraph 5 for details.
d.
General Employee Training Building Decontamination Showers - The
licensee had not developed procedures for controlling, sampling, and
discharging the contents from the decontamination shower holding
tank. See paragraph 9 for details,
e.
Radiographic Work - The licensee needs to exercise more control over
radiography work being performed onsite including surveys of incoming
and released vehicles and equipment.
See paragraph 10 for details.
f.
Wide Range Noble Gas Monitor (WRNG) Calibration Procedures - The
licensee's procedure for WRNG monitor calibration referenced model
numbers for the count rate meter and detector element. The recorded
data for these devises was not consistent with the procedure.
See
paragraph 11 for details.
g.
Particulate and Iodine Plateout Studies - The licensee had not
performed a plateout study for particulate and iodine on the WRNG
monitors. See paragraph 11 for details.
h.
Job Preplanning - The C/RP and ALARA groups are not involved with job
preplanning. See paragraph 5 for details.
5.
Advanced Planning and Preparation
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The NRC inspectors reviewed the C/RP. organization and determined that the
licensee had augmented the radiation protection group with contractor
technicians. The liccnsee assigned 17 senior and 8 junior technicians to
operational support, 2 senior technicians to ALARA, and 2 senior and 4
junior decontamination technicians to containment building decontamination-
work. The licensee also contracted for 10 non-nuclear trained
. housekeeping personnel for cleanup and decontamination duties in the
auxiliary building and 24 laundry workers. The licensee had established
two 10 nour shifts with staggered working hours to provide 24-hour
coverage.
The NRC inspectors reviewed the resumes and work histories of the contract
senior technicians and determined that they met the recommendations of ANSI
Standard N18.1-1971. The licensee had also evaluated the contractor
technicians and provided site specific training and individual testing in
accordance with Health Physics Procedure HP-16, " Selection of Contract
Health Physics Technicians."
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The NRC inspectors were concerned that personnel assigned to cleanup and
decontamination duties in the auxiliary building were not demonstrating
work practices which were radiologically acceptable when handling
contaminated radioactive material. The licensee stated they had initiated
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a training course to provide these individuals with a better understanding
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of radiation and precautions for handling radioactive material.
The licensee had obtained additional portable s.urvey instruments,
personnel contamination monitors, and constant air sampling equipment
prior to the refueling outage. The NRC inspectors expressed concern
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regarding the inoperability of a large quantity of dose rate survey
instruments and personnel monitoring equipment. Although this
inoperability of equipment created an inconvenience, the health and safety
of personnel was not compromised.
The licensee stated that an additional
I&C technician had been assigned to radiological instrument repair and
calibration and that should rectify this concern.
The NRC inspectors expressed concern that the C/RP and ALARA groups were
not involved with job preplanning in the early development phase.
The
C/RP and ALARA groups were using daily briefings to update work on progress
and delays in the outage schedule. Licensee representatives stated that on
occasion, work was delayed because either ALARA reviews or radiation
surveys were needed prior to starting work and that radiation work permits
(RWPs) had been prepared for scheduled work that were not used.
No violations or deviations were identified.
6.
Training and Qualifications
The NRC inspectors reviewed the routine and specialized training programs
associated with the outage with emphasis on that training provided to
contractor personnel.
The NRC inspectors determined that the requirements
of 10 CFR Part 19.12 were being met.
The NRC inspectors noted that the licensee had received a full size
mock-up of the bottom portion of a steam generator, including the tube
plate, for training. The licensee nad used the mock-up to train personnel
for eddy current testing and tube repair work.
No violations or deviations were identified.
7.
External Exposure Control
The NRC inspectors reviewed the licensee's program for external radiation
exposure control to determine compliance with the requirements of
10 CFR Parts 20.101, 20.102, and 20.202.
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The NRC inspectors determined that all personnel entering the radiation
controlled area (RCA) were issued a thermoluminescent dosimeter (TLD)
which are processed monthly. The individual entering the RCA also wear
direct-reading dosimeters (DRD) as required by the RWP.
The licensee uses
the DRD results for tracking personnel exposures with dose totals updates
being made once per shift.
The NRC inspe'ctors reviewed selected personnel exposure history files to
determine that current NRC Form 4 and previous exposure histories were
available prior to exceeding the 1250 mrem quarterly exposure limit.
The
NRC inspectors determined that individuals were not always dating the NRC
Form 4 and that when previous radiation exposures were entered on the form
the decimal point used to denote rem was not always in place.
The
licensee stated they had placed additional emphasis on these areas of the
form.
The NRC inspectors reviewed selected records of work functions performed
by the licensee and contractors that required other than routine radiation
exposure monitoring, such as multibadging or extremity badging with TLDs.
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The licensee program for recording other than routine exposures appeared
to be adequate.
No violations or deviations were identified.
8.
Internal Exposure Control
The NRC inspectors reviewed the licensee's internal exposure control
program to determine compliance with the requirements of 10 CFR 20.103,
and the recommendations of Regulatory Guide (RG) 8.15, and NUREG-0041.
The NRC inspectors inspected the reactor auxiliary and containment
buildings on several occasions during the inspection to observe internal
exposure control practices.
Procedures and associated records were also
reviewed and discussions were held with licensee and contractor employees
to determine if internal exposures during the outage were being controlled.
The NRC inspectors reviewed a representative sample of the active and
inactive RWPs posted for the outage and records associated with their
implementation. This review verified that the permit process had been
effective during the outage at disseminating the proper internal exposure
control methods to be implemented by individuals for each task.
The NRC
inspectors observed the acquisition of area grab air samples and reviewed
nonroutine breathing zone sample results used to track maximum permissible
concentration-hours (MPC-hr) personnel exposures.
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The NRC inspectors observed during a facility inspection on November 6,
1985, that a particulate, iodine, noble gas (PING) monitor in room 69 of
the auxiliary building was alarming at the high level for the iodine
channel. The sarae afternoon, one of the containment building PINGS was in
alert level while the other was in high level alarm for the iodine channel.
Action taken by the licensee in response to the alarms was to order
special grab fr samples to assess the airborne concentration of iodine.
The NRC inspectors examined the PING calibration procedures and records of
the.f r calibration to ascertain the significance of the iodine alarms.
In
the course of this review it was determined that PING unit 214 located in
room 69 of the auxiliary building did not have documentation on file
showing the calibration performed on this unit on August 15, 1985. The
licensee stated that the necessary calibrations had been performed, but
the calibration records could not be located.
This was identified as an
unresolved item (285/8525-01) pending the licensee's search for this
record.
The NRC inspectors examined the post alarm grab air samples in addition to
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the routine air samples and found that while iodine concentrations had
showed an increase during the outage, measured levels had not exceeded
10 percent of MPC in ary of the sample results reviewed.
Special whole
body counting resul s performed during the outage also provided verification
of the absence of a significant iodine problem with the highest body
burden showing 50 nanocuries (7.1 percent of ICRP maximum permissible body
burden). Air sample results showed other isotopes to be near or below the
lower limit of detection (LLD).
The NRC_ inspectors reviewed the licensee's use of respiratory protection
equipment and verified that all users including outage contractor personnel
had completed the licensee's qualification program.
The NRC inspectors
observed the cleaning of used respirators and reviewed the records of
surveys of respirators prior to bagging and reissuance and found this to
have been performed in accordance with Procedure RPP-6.
No violations or deviations were identified.
9.
Radioactive and Contaminated Materials Control
The NRC inspectors observed the efforts being implemented during the
outage to control contamination and radwaste in the RCA.
The NRC inspectors
observed instances of poor radiation safety practices among a few of the
auxiliary building decontamination teams in the packaging of used protective
clothing (PC) and improper controls at step off pad control points.
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The NRC inspectors observed that worke'rs. sere properly suited out in PC'
for the areas in which they were worJ'nq and that removal of PC and step
off pad procedures were being.f llowe'bf All personnel exiting the RCA
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were required to monitor themselves in o'ne of four gas proportional
personnel contamination monitors.
The NRC inspectors observed that
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articles which had been carried into the RCA were being surveyed prior to
removal.
The NRC inspectors reviewed changes to facilitids which had occurred since~
the last radiation protection program inspection. The NRC inspectors
discussed with licensee representatives the status and basic design for
the shower facilities in the general employee training building. The
licensee stated that the effluent is collecy.ed in a 1000 gallon retention
tank, fitted with a high level alarm, and has the ability to be discharged
to either the sanitary sewer system or an external vessel.
The NRC
inspectors expressed concern that the licensee had not developed
procedures to prohibit the discharge of potentially contaminated effluents
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via an unmonitored pathway.
The licensee needs to:
(1) determine the
level the high alarm is activated, (2) provide for positive controls on
the valve connecting the retention tank to the sanitary sewer line, and
(3) develop a procedure which would address the isolation of the tank,
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collection of a repretentative sample from the tank, and an approved
discharge or disposal torm. -
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No violations or deviations were, identified.
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10.
Posting, l.abelling, and Worker Control
The NRC inspectors verified that the radiologically controlled areas were
properly posted and they appeared to be in compliance with 10 CFR 20.203.
A temporary storage area for pack, aged radwaste awaiting shipment had been
roped off and posted outside of the fuel building.
The NRC inspectors
made independent exposure rate' surveys and found them to be in agreement ,
with licensee surveys ar.a area postings.
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The NRC inspectors reviewed RWPs to ensure that station and contractor
personnel were following approved instructions in radiologically controlled
areas. - Specified RWP approved procedures appeared to have been followed
in each case, and sign-in logs and dispensation of expired RWPs were found
to be in order.
Ok November 6,1985, the NRC inspectors observed that a byproduct material
user licensed by the State of Nebraska had been on site to perform
radiography in non-radiologically controlled areas.
The NRC inspectors
noted that no procedures had been established for controlling this type of
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work although station health physics personnel had monitored the radiographic
activities. The licensee was in agreement that more control over such
activities in the future should be exercised to monitor radiographers
entering the site protected area.
No violations or deviations were identified.
11. Wide Range Noble Gas Stack Monitor
The NRC inspectors reviewed the licensee's progress to resolve open item
(285/8226-15) NUREG-0737, Item II.F.1 (Attachment 1), Noble Gas Effluent
Monitor. The licensee had completed calibration of the low range
channel of the wide range noble gas (WRNG) stack monitor RM-063L.M.H.
The midrange and high range channels had not been calibrated.
The NRC
inspectors reviewed the calibration for the low range channel of the WRNG
monitor.
The NRC inspectors noted that this calibration procedure
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referenced count rate meter and detector model numbers that were not the
same as those recorded during performance of the calibration.
The NRC
inspectors discussed with licensee representatives this inconsistency in
equipment data and determined that the recorded data more accurately
identified the count rate meter and detector.
The licensee agreed that
the calibration procedure needed to be revised to include. consistent model
numbers.
The NRC inspectors discussed with licensee representatives the status of
the midrange and high range detector systems and FCS TS section 2.21
requirements. Table 2-10 requires that when less than the minimum number
of channels are operable, alternate methods for monitoring be initiated
and if the channels are not returned to operating status within 7 days a
special report shall be submitted within 14 days to the Commission
containing plans and schedules for returning the monitors to operable
status. The licensee provided a copy of a letter LIC-84-301 dated
September 5, 1984, which stated the monitors were expected to be operable
by September 14, 1984.
The licensee stated that a second letter was written after September 5,
1984, which extended the date of expected operability for the mon! tors.
However, the licensee was not able to locate a copy of the second letter.
The NRC inspectors stated this is considered an unresolved item
.(295/8525-02) pending resolution of the notification to the Commission and
expected operability of the monitors.
The NRC inspectors discussed with licensee representatives the status of
particulate and iodine plateout studies for the WRNG monitors.
The
licensee-had not performed any calculations using ANSI Standard 13.1-1969
as a guide.
The licensee stated that they expect to start the plateout
studies during calendar year 1986.
No violations or deviations were identified.
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12. ALARA Program
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The NRC inspectors reviewed the licensee's ALARA program to determine
compliance with the requirement bf 10 CFR Part 20.1 and the recommendations
of Regulatory Guides 8.8 and 8.10.
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The NRC inspectors determined that the licensee had established a goal of
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491 manrem for the year 1985 and had expended 224 manrem as of November 6,
~1985.
The licensee projected that less than 400 manrem would be expended
for the year.
The licensee stated that the lower ~ exposure was due to less
steam generator work and decontamination efforts prior to working in the
RCA.
No violations or deviations were identified.
13. Surveys
.The NRC inspectors reviewed the licensee's program for implementing and
performing radiation, contamination,- and airborne radioactivity surveys
to determine ccmpliance with the requirements of 10 CFR Parts 20.103,
20.201, and 20.401.
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The licensee's survey program appeared to be adequate for contamination
and radiation surveys for prework evaluations and RWP generation.
The
NRC inspectors noted the licensee routinely collected an airborne
radioactivity sample for particulate and radiotodine analysis from the
auxiliary building once each day and from the containment building once
each work shift.
The NRC inspectors determined that the licensee
performed other airborne surveys on an as needed basis when conditions
warranted.
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At various times during the inspection period, the NRC inspectors
conducted independent surveys of the containment and auxiliary buildings
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to verify that radiological. conditions were as recorded on radiation
survey logs and depicted on station area maps. The NRC inspectors also
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observed housekeeping and temporary radioactive waste storage areas. All
areas observed appeared to be acceptable.
No violations or deviations were identified.
14. Notifications and Reports
The NRC inspectors-reviewed selected reports to determine compliance with
10 CFR Parts 19.13, 20.407, 20.405, and 20.409.
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The NRC inspectors' review, in addition to radiological worker training,
respiratory fit training, radiation exposure history, and radiation
exposure data, included the radiation protection shift turnover log,
radiological incident reports, and personnel contamination reports. The
NRC inspectors noted the licensee had revised the criteria used for
documenting personnel contamination incidents and now records all
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incidents where contamination is detected on an individual.
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procedure sho'uld allow the licensee to track contamination incidents
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by craft, area of contamination, work function, repeat incidents, and
determine the root cause and prescribe corrective action to prevent
reoccurrence.
No violations or deviations were identified.
15. Exit Interview
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The NRC inspectors met with the_FCS NRC senior resident inspector and
licensee representatives denoted in paragraph 1 at the conclusion of the
inspection on November 8, 1985. The NRC inspectors summarized the scope
and findings of the inspection including the unresolved items identified
in paragraph 3, and the observations noted in paragraph 4 of this report.
The licensee stated that these items and observations would be reviewed.
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