ML20150B619
| ML20150B619 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/07/1988 |
| From: | Baer R, Chaney H, Murray B, Pedersen R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20150B603 | List: |
| References | |
| 50-285-88-05, 50-285-88-5, IEB-80-10, IEC-80-14, IEC-81-07, IEC-81-7, IEIN-83-05, IEIN-83-5, IEIN-85-092, IEIN-85-92, NUDOCS 8803170080 | |
| Download: ML20150B619 (24) | |
See also: IR 05000285/1988005
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-285/88-05 Operating License: DPR-40
Docket: 50-285
Licensee: Omaha Public Power District (0 PPD)
1623 Harney Street
Omaha, Nebraska 68102
Facility Name: Fort Calhoun Station (FCS)
Inspection At: FCS Site, Blair, Nebraska
Inspection Conducted: February 1-5, 1988
Inspectors: _M7!88
R. E'. Baer, Radiation Specialist, Facilities Date '
Radiological Protection Section, Region IV
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H. D. Chaney, Radiation Specialist, Facilities Date ~ i
Radiological Protection Section, Region IV l
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_R. L. Pedersen, Health Physicist, Radiation Date
v Protection Branch, Office of Nuclear Reactor
Regulation
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Approved: i8 OMM
i Murray',~ Chief. Facili ies Radiological
8f 7/8h
Ofte/
Protection Section, R ion IV
Inspection Summary
Inspection Conducted February 1-5, 1988 (Report 285/88-05)
Areas Inspected: Special, unannounced inspection of the radiation protection
program including organization and management controls, training and
qualifications, and radiological controls.
8803170000 geo30s
PDR ADOCK 05000285
0 PDR
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Results: Within the areas inspected, six violations were identified (failure
to: provide a written policy statement for respiratory usage, maintain socked
very high radiation area door s maintain key control of very high radi'. tion
area doors, provide radiation protection technicians requalification '. raining,
and follow procedures for very high radiation area entries and posti:ig of
controlled contamination area; see paragraphs 4 and 5). Program waknesses
are also identified as open items; see paragraph 2.
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DETAILS
1. Persons Contacted
- R. L. Andrews, Division Manager, Nuclear Production
- A. D. Bilau, Acting Plant Health Physicist
- C. J. Brannert, Supervisor, Operations Quality Assurance (QA)
M. R. Core, Supervisor, Maintenance
- F. F. Franco, Kanager, Radiological Health and Emergency Planning
- J. K. Gasper, Manager, Administrative and Training Services
- W. G. Gates, Manager, Fort Calhoun Station
- W. Hansher, Licensing Engineer
- D. A. Jacobson, Supervisor, Training
W. C. Jones, Senior Vice President
- D. J. Matthews, Senior Engineer, Licensing
- K. J. Morris, Division Manager, QA and Regulatory Affairs
- C. W. Norris, Supervisor, Radiological Services
- T. L. Patterson, Supervisor, Technical
- A. W. Richards, Manager, QA
- G. L. Roauh, Supervisor, Chemistry and Radiation Protection (C/RP)
- K. E. Steele, QA Inspector
- M. A. Tesar, Supervisor, Training Services
D. Trausch, Supervisor, Operations
- S. J. Willrett, Supervisor, Administrative Services and Security
- P. H. Harrell, Senior Resident Inspector
- T. Reis, Resident Inspector
- L. A. Yandell, Chief, Radiological Protection and Safeguards Branch
The NRC inspectors also interviewed several other licensee and contracto
employees including C/RP, operations, mairtenance, administrative, and
training personnel.
- Denotes those individuals present during the exit interview on February 5,
1988.
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2. Open Items Identified During This Inspection
An open item is a matter that requires further review and evaluation by
the NRC inspectors. Open items are used to document, track, and ensure
adequate followup on matters of concern to the NRC inspectors The
following open items were identified: ,
Open Item (285/8805-07): Organization and Position Descriptions ,
- This item involves the lack of position description for certain ,
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radiation protection personnel and updating the Technical ,
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Specification organization chart (see paragraph 3).
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Open Item (285/8805-08): Radiation Protection Procedures - This item
involves the lack of organized and comprehensive radiation protection
procedures (see paragraph 3).
Open Item (285/8805-09): Audits / Evaluations - This item involves the
j lack of a comprehensive audit / evaluation program (see paragrt.ph 3).
j Open Item (285/8805-10): Training of Radiation Protection Personnel- .
4 - This item involves the lack of a systems training program for i
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radiation protection technicians (see paragraph 4).
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i Open Item (285/8805-11): Backup Radiation Protection Manager.- This
item involves the use of an unqualified individual to serve as the
acting supervisor, C/RP (radiation protection manager) at plant ,
review committee meetings (see paragraph 4). ;
Open Item (285/8805-12): Contamination Limits - This item th alv e
4 the lack of contamination limits that are cuisistent with NRC ,
guidance (see paragraph 5). ;
Open Item (285/8805-13): Respiratory Protection Program - This item f'
involves the lack of a respiratory protection program that meets the
recommendations of Regulatory Guide (RG) 8.15 and NUREG-0041 (see ;
paragraph 5). '
3. Organization and Management Controls l
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i The NRC inspectors examined the licensee's organization and staffing and ;
compared it to the requirements contained in 10 CFR 20, Section 12 of the *
j Updated Safety Analysis Report (USAR) and Section 5.3 of the Technical
Specifications (TS). The NRC inspectors noted that a recent change of '
1 personnel in the radiation protection program had been made. The former '
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Plant Health Physicist (PHP) has been reassigned to the position of ALARA
Coordinator. The PHP position is being filled temnorarily by the former i
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Radwaste Coordinator. The licensee is currently in the process of
1 . selecting a permanent PHP.
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The NRC inspectors noted that the official organization is in conformance [
with Figure 5-2 of the TS. However, the actual working organization has
been expanded beyond the organization described in the TS. Specifically, !
the existence of a special projects group and the use of "Lead Techs" as !
first line supervision for radiation protection (RP) technicians is not i
reflected in the TS organizational chart. The official organization shows i
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the PHP as the first line supervision for the RP technicians. Since th.
- TS organization was first established, the scope and complexity of the l
J PHP's responsibilities have grown such that it is now difficult for him to -
l have adequate time to supervise RP technicians. The NRC inspectors noted i
that the current working organization is similar to radiation protection i
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organizations at other power reactors. However, since the working
organization is not the official organization, no position descriptions or
titles have been developed for the lead technician positions. Areas of
responsibility and lines of authority for these positions have not been
defined.
The fact that the TS do not reflect the actual working organization and
that position descriptions have not been developed to define the
responsibilities of-the lead radiation protection technicians is a program
weakness. This is an open item pending licensee action (285/8805-07).
Interviews with the RP technical staff revealed that they do not perceive
a correlation between their performance and their opportunity for
advancement. The NRC inspectors noted that licensee management had
recently made an effort to upgrade the RP technician positions to make
them economically competitive. However, administrative difficulties
within OPPD have brought this effort to a halt. This situation has been
perceived by the staff as a complete freeze on promotions and is causing a
negative impact on morale.
The NRC inspectors noted that the plant management has limited authority
to allocate resources in the radiation protection area. Expenditure of
budgeted funds for supplies and equipment is made at the corporate level.
Although support for the program is evident by the quality of some of the
larger capital equipment (whole body counter, personnel friskers, etc.),
this arrangement has not been effective in procuring the quality and
numbers of expendable items (such as protective clothing) needed to
support the program. Comments regarding inadequate numbers of protective
clothing were noted in the licensee's QA audit (87-QA-453). The use of
double disposable booties is taught in the General Employees
Training (GET) program because the quality of the boots ava iable do not
ensure adequate protection with a single set of booties. Tois practice is
contrary to the minimization of radioactive waste policy. The Supervisor,
C/RP is aware of the situation, but has not been successful in procuring
booties of adequate quality.
The NRC inspectors found the RP procedures to be fragmented, difficult to
follow and generally not being used by plant personnel. Procedures
governing radiation protection activities are included as chapters to the
Radiation Protection Manual (RP-Manual) which is incorporated as a section
of the Plant Operating Procedures. Procedural requirements are found in
the general topic chapters of the RP-Manual as well as the chapters
dealing with radiation protection procedures, health physics procedures,
and radwaste procedures. Additional procedures were also found in Station
Standing Orders.
Some procedures were not written in enough detail to ensure that a
reasonably knowledgeable individual could follow the procedure and
complete the task correctly. In some cases, procedures for a specific
task are located in two or three different procedures.
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The NRC inspectors noted several cases where a technician performing a r
task could not identify which procedure controlled the work he was !
performing or find it in the RP-Manual. The NRC inspectors found the RP
technicians to be technically competent; however, the RP program relies
too heavily on the working experience of operators and technicians rather
than reliance on good quality procedures.
The lack of well organized and comprehensive procedures is a significant
program weakness. This is considered an open item pending licensee action
(285/8805-08).
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The NRC inspectors reviewed the licensee's audit / evaluation program. The
inspectors noted that audits had been performed; however, the inspectors
expressed concern as to why weaknesses and violations identified in this i
report were not identified by the licensee. The lack of a comprehensive
audit / evaluation program is a significant weakness. This is considered an
open item pending licensee action (285/8805-09).
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The NRC inspectors interviewed stetion personnel to determine the l
cooperation that existed between the various plant groups and the C/RP l
group. The NRC inspectors determined that while the cooperation between
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the RP technicians and other plant groups had improved in the past two
months there was still room for improvement. The NRC inspectors also :
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noted that there appeared to be a lack of cooperation between RP and other
plant groups at the supervisory level.
No violations or deviations were identified,
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4 Staff Training and Qualifications
The NRC inspectors reviewed the documents listed in Attachment 1, i
interviewed licensee personnel, and observed licensee activities to
determine whether the licensee's training and qualification program: .
meets the commitments in the USAR; satisfies the requirements in the TS '
and 10 CFR Part 19 and 20; and agrees with the recommendations and
guidance provided by ANSI /ANS N18.1-1971, 3.1-1983, RGs 1.33, 1.8, 8.15, t
8.27, 8.29, and NUREG-0041.
The NRC inspectors reviewed the training department organization,
facilities, staff qualifications, goals and cbjectives, implementing ;
procedures, lesson plans, testing material and its control, records, and
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schedules, and observed ongoing training activities. The licensee is :
- currently INPO accredited only in the area of reactor operator training, !
but expects to have the radiation protection, radiochemistry, maintenance, l
! and other remaining training programs accredit 2d in March 1988.
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1 The GET programs (GET 1, 2, and 5) for station personnei and ,
j visitors / contractors were reviewed for implementing procedures, lesson !
plan content and objectives, presentation, training facilities, practical ;
work practice demonstration, testing of employee knowledge retention, and
training oversight by the Supervisor, C/RP. The licensee's GET-1 was !
designed for personnel access into the protected area of the plant, but
not for access into radiologically controlled areas, GET-2 was designed ;
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for the qualifying of station workers to work in radiologically controlled-
areas and included respiratory protection equipment training. GET-S was
designed for the quick training of personnel that only need site-specific
training due to their having completed equivalent GET-2 (radiation worker)
at another facility. Both courses 1 and 2 are undergoing modification due
to changes in the training staff and an increase in budgeting for the GET
programs. A review of the lesson plans, handouts, and video presentations
did not reveal any problems. The licensee is constructing a new training
facility (with reactor simulator) to replace the present facilities.
On February 1, 1988, the NRC inspectors noted during an inspection of the
station's radiologically controlled areas that both plant' workers and RP
personnel do not follow the basic protective clothing (PC) dressing .
procedures specified in the GET practical factors class, and that the i
placement of radiological waste and used PC receptacles at an exit from a *
controlled surface contamination area (CSCA) did not comply with expected
industry radiation protection practices. RP technicians and plant workers t
were not taping PC openings and wearing the appropriate amount of PC as .
referenced in GET-2 training sessions. The NRC inspectors noted that the '
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licensee does not routinely post dressing or undressing instructions at
the exits. These observations indicate that station personnel are not j
routinely critiqued on their work practices and that RP personnel do not i
ensure that radiation protection practices covered during GET are :
implemented by plant workers. l
The implementation of the respiratory protection equipment (RPE) user l
training program was reviewed for agreement with the recommendations of ;
RG 8.15, NUREG-0041, and ANSI Z88.2. The licansee provides a i
nonradiological (ANSI Z88.2) as well as a radiological (NUREG-0041) t
respiratory protection program. The licensee is currently implementing a ,
program for the removal of asbestos insulation within the plant which ,
requires the use of RPE. The NRC inspectors determined that the training ;
program (classroom lecture and video presentation), while providing j
marginally adequate RPE training for full face air filtered !
respirators (FF-RPE), was inadequate for the training of personnel to use !'
other equipment, especially self-contained breathing apparatus (SCBA).
Interviews determined that all fire brigade personnel during the yearly [
fire fighters requalification training are required to don and use an '
SCBA. Discussions with RP personnel whom are part of the stations ;
radiological emergency plan (which provides for the use of SCBAs by !
emergency teams) determined that not all RP technicians have received SCBA
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training or have not had to requalify since initial training. The e
following observations were noted regarding RPE training. l
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Instructors providing RPE instruction have not had formal training in k
the application and use of RPE, The instructors are relying on their i
previous experience as a user of RPE and have not had sufficient i
experience in selection and use of RPE other than for airborne j
radioactive particulate protection (Section 8.1 of NUREG-0041). !
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The current GET-2 video tape for demonstrating the donning of PC and
a full-face respirator depicted an improper donning and testing of
the mask. The mask was readjusted following a successful initial
negative test of the mask without an additional negative test of the
mask.
- Training does not identify the single person assigned the
responsibility and authority at the station for the RPE program.
(Section 3.5.2 of ANSI Z88.2, and Section 12.1 of NUREG-0041).
The RPE training program does not cover the training or special
qualifications required for the use of SCBAs.
The licensee's RP technician craining program provides a structured
training program for qualifying a person with very little RP experience or
training as a fully qualified RP technician within 3 years. Formal
classroom training is supplemented by a comprehensive on-the-job
training (0JT) program (Performance Evaluation Checklist). Experienced RP
(2 to 3 years) personnel can be qualified for stand alone shift work
within 7 months depending on their experience and managements decision on
the amount of supplementary training required for a given individual. The
licensee uses oral review boards to supplement testing and OJT. The
licensee's contract RP technician selection program is documented in
procedures and requires that prospective contract radiation protection
technicians pass a screening test and have as a minimum 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> of
radiation protection experience, of which 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> (1 year) must be at
an operating power reactor, to be considered a fully qualified radiation
protection technician. The licensee screens contract technician work
history resumes for determining the appropriate amount of time that'can be
credited to any work experience before determining the contract
technician's qualification status.
Even though the licensee has excellent training program implementing
procedures for the evaluation, training, and qualification of RP
technicians, it was apparent that the amount of continuing and
requalification training for the RP technicians as a whole is fragmented
due to the fact that the majority of the training is not mandatory. The
licensee provides approximately 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> of training per year to RP
technicians. The licensee had created requalification and continued
(special/ training) training programs for RP technicians which included the
review of industry and station events for presentation during the
September through December 1987 training cycle. During this time period,
only 2 RP technicians took requalification training, out of an estimated
11 RP technicians that has not been requalified during the past 15 months.
Also during this period, only four RP technicians attended the continuing
training program on industry and plant events during which time the
licensee's problems with the locking of high radiation areas were
discussed and reviewed. The licensee indicated that the Supervisor, C/RP
had met with the RP personnel and discussed the current high radiation
area problems. Training records indicated that not all RP personnel were
in attendance at these meetings and that as of January 10, 1988, not all
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RP technicians had been officially briefed (documented) on the high
radiation area incidents either during staff meetings or by reading of the
procedural changes brought about by the incidents.
Section 12.2.2.3 of the USAR states that following the initial training,
retraining is done on a recurring basis to maintain and upgrade job
proficiency. TS 5.4.1 requires that a retraining program for the plant
staff shall be maintained and shall meet or exceed the requirements of
Section 5.5 of ANSI N18.1-1971. Section 5.5 of ANS1 18.1-1971 states that
a training program shall be established which maintains the proficiency of
the operating organization through periodic training exercises,
instruction periods, and reviews of those items and equipment which relate
to safe operation of the facility. Section 8.2.2 of the Training Program
Master Plan 14 (Revision 0, dated July 1,1987, states that the Radiation
Protection Technician will complete the minimum requalification training
requirements yearly (not to exceed 15 months) as defined for their current
job position.
The NRC inspectors determined on February 4, 1988, that the three
individuals involved in the October 14, 1987, January 25, 1988, and
February 4, 1988, high radiation area incidents were all RP technicians
working in the Radwaste Section. These RP technicians had not been
requalified as RP technicians even though they performed RP technician
duties in support of radwaste operations that involved high radiation area
surveillance, work operation radiological surveys and posting, and ensured
compliance with Radiation Work Permit (RWP) requirements. Training
records indicated that the elapse time since the last qualification for
the three technicians varied between 37, 35, and 18 months.
The failure to maintain the three RP technician's cualification up-to-date
is an apparent violation of TS 5.4.1. (285/8805-01).
The NRC inspectors also reviewed the licensee's 1988 training program
schedule for plant RP technicians. Based on a review of training records
and interviews with RP technicians and training department personnel, the
NRC inspectors determined that training on reactor plant systems is not
mandatory for RP personnel either as initial qualification training or
uograde training for RP personnel hired before the implementation of the
plant systems training program. RP technicians that stand shift alone
were not knowledgeable in the reactor plant systems to the extent of how
various system's operation can effect plant radiological conditions. A
review of training records indicated that most RP personnel had received
only plant familiarization training which for the most part involved only
the identification of which rooms of the plant contained certain systems.
The previous experience of several RP technicians were noted to only ,
involve naval nuclear power plants. The failure to provide plant reactor :
systems training for RP technicians is considered a significant program '
weakness in that the lack of such a program does not provide assurance
that a RP technician's decisions and actions during all normal and ,
abnormal conditions will be appropriate and ensure the safety of plant
personnel. ;
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The lack of a mandatory reactor plant system training program for all RP
technicians is a program weakness. This is considereo an open item
pending licensee action to provide reactor plant system training
(285/8805-10).
The NRC inspectors reviewed position descriptions, employee resumes,
qualification evaluations, and licensee' procedures governing the
evaluation of an employee's qualifications. The licensee is committed in
TS 5.3.1 to the recommendations in ANSI N18.1-1971. The licensee's RP
staff (Supervisor, RP; ALARA Coordinator; Plant HP; Radioactive Waste
Coordinator; and 24 RP technicians including 9 contract RP technicians)
appear to meet the qualification. guidance in Section 4.5.2 of
ANSI N18.1-1971. The NRC inspectors noted that the licensee gave too much
credit to personnel with U.S. Navy nuclear power, engineering laboratory
technician (ELT), experience. The NRC inspectors discussed with the
licensee that ELT experience for a standard 6-year tour of duty with the
U.S. Navy really only amounts to 4 years of experience of which
approximately 2 or more years is primarily radiochemistry work. A review
of experience evaluation forms required by Standing Order G-53, "Personnel
Certification - TS 5.3," indicated that up to 3 years.of experience had
been credited to several RP technicians due to their_ navy ELT experience.
The NRC inspectors noted that all staff personnel (except one trainee and
four junior RP technicians) met 2 year minimum experience requirement of
ANSI N18.1-1971 for the position of RP technician. Staff assignments were
appropriate for the qualifications of the RP personnel. However, it was
determined that the Plant Chemist had served as an alternate to the
Supervisor, C/RP on the Plant Review Committee (PRC). Since the
Supervisor, C/RP (Radiation Protection Manager) is expected to address
radiological protection matters during the PRC meetings, it is considered
inappropriate that a person with no technical training or professional
experience in radiological protection matters, in order to satisfy
RG 1.8-1975 criteria, represent the Supervisor, C/RP on the PRC. The use
of the Plant Chemist as a radiological protection expert at the PRC
meetings is a program weakness. This is considered an open item pending
licensee action (285/8805-11).
5. Radiological Controls
a. ALARA Program
The NRC inspectors reviewed the licensee's ALARA program including
management policies, assignment and responsibilities, procedures and
standards, employea indoctrination and instruction, reviews of design
and equipment selection, audits and appraisals, program changes,
worker awareness and involvement, goals and objectives, and results
and effectiveness to determine adherence to 10 CFR Part 20.1
requirements and guidance in RGs 8.8, 8.10, and 8.27.
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The NRC inspectors reviewed the ALARA implementing procedures ;
contained in the RP-Manual, Section_ 7, "Operational ALARA Program," l
Revision 6, dated August 28, 1987; training _ lesson plans; ALARA
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meeting minutes; ALARA policy statement, Number 9.03, dated August 1,
1984; ALARA committee staffing; ALARA' suggestion program; and ALARA'- i
design reviews.
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The NRC inspectors noted the ALARA policy statement _ contained in the --
OPPD Supervisors Manual, Number 9.03, was last. updated in August 1984 ;
and did not mention or encourage the Employee ALARA Concern Form to ;
reduce *adiation exposures. The NRC inspectors also noted the .
Employee ALARA Concern Forms receive limited use. . If individuals ;
felt strongly about a particular job where radiation exposure might ,
be reduce, they would normally discuss this with their !
supervisor / foreman. ;
-The ALARA program has not received the full support from plant i
departments. A procedure had been recommended by the ALARA .
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committee, Draft Standing Order G-59, "Operational Containment Entry
Evaluation," which required an evaluation of conditions prior to
entry into the containment building, and was sent to the Plant Review c
Committee (PRC) for approval in April 1985. This standing order had ,
not received PRC approval'as of February 1988.
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The licensee had made a long term commitment to INPO to reduce the
overall person-rem exposure by the year 1991. As part of this i
commitment, the licensee's corporate management established a station
goal of 320 person-rem for_1988. The goal for_1987.was !
34b person-rem which was exceeded by 43.5 person-rem due to i
additional maintenance work during the outage. A comparison of l
10 CFR Part 20.407 data for FCS and the national average of all ;
operating pressurized water reactors as contained in NUREG-0713,_ .
"Occupational Radiation Exposure at Commercial Nuclear power i
Reactors," for the period 1983-87 is tabulated in Attachment 2, !
Table 1. Table 2 contains a tabuiation of work functions that l
exceeded 5 person-rem in 1987. -l
No violations or deviations were identified. !
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b. Radioactive Materials and Contamination Control Practices l
The NRC inspectors reviewed the licensee's radiation and I
contamination control program and inplementing procedures for p
compliance with the requirements of TS' 5.11 and 10 CFR Part 20, ;
agreement with the commitments contained in 'JSAR; and the guidance !
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contained in RG 8.4, 8.7, 8.8, 8.10, 8.13, 8.15, 8.27, and Inspection
and Enforcement Circular (IEC) 80-14, IEC 81-07, IE
Bulletin (IEB) 80-10, IE . Interim Position on Evaluation and Controls
of 1.ow Level Radioactive Volume Contamination of Materials From
Nuclear Power Plants (dated July 17,1981), IE Information
Notice (IEIN) 83-05, and IEIN 85-92.
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The NRC inspectors reviewed the licensee's program for the control of ,
radioactive n.aterials released from the control of the licensee for
agreement with NRC guidar,0.e and reculations. The NRC has issued
several documents discussing the inadvertent contamination of a
normally nonradioactive plant system (IEC 80-14 and IEB 80-10), the
surveying and contamination limits for material to be released from
licensee control (IEC 81-07 and IEIN 85-92), and the radiological
controls to be exercised over disposal of Icw-level radioactive waste
(IEIN 83-05 and 85-92). The licensee's RP-Manual, radiation
protection prcgram implementing procedures, and RP technician
training documents provided the following information concerning
radiation and contamination limits for materials to be used or
released from the plant:
Contamination Limit Radiation Limit -
Material (loose Surface Contamination) (Fixed Contamination)
Skin Oecon none detectable As low as possible
(HP-18)
Personal clothing < 1000 dpm/100cm2 __
(RP-Manual 2.22.2)
PC reuse < 10000 dpm/ probe
(RP-Procedure 6)
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Reuse of RPE < 500 dpm/100cm2 inside < 5000 dpm total
(RP-Manual 2.28,2) fixed and loose
RPE Use
Required > 20000 dpm/100cm2
(RP-Manual 2.30.2)
Tools Released < 100 dpm/100cm2 alpha
to unrestricted < 1000 dpm/100cm2 beta / gamma < 5000 dpm total ,
area fixed and loose
(RP-Manual 3.2.1)
Waste for
Disposal in
Uncontrolled none detectable
Area
(RP-Manual 3.2.1)
i Leaking Packages
Received < 1000 dpm/100cm2
(RP-Manua 6.1.4)
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Leaking Sc urce < 0.005 uci/ swipe
(RP-Manua* 6.2.2) equivalent to 11000 dpm/ swipe
(RP-Procedure 17)
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Shipping Trailer < 2200 dpm/100cm2 beta / gamma < 0.1 mr/hr (waist
Arrival < 220 dpm/100cm2 high or contact
(RP-Manual 6.4.1) with surface
unknown)
Exterior of
RAM Shipped Same as above for Trailer Varies (10 CFR 71)
(RP-Manual 6.4.1) Arrival
Tools for use in
Aux. Controlled
Area < 2000 dpm < 2000 dpm
(RP-Procedure 8)
Segregated clean
waste (Controlled < 1000 dpm/ probe
Unconditional
Released,RW-7)
The licensee's release limits do not agree with the NRC guidance, and
overall are not consistent with preventing skin contamination at the
station. It is noted that alpha contamination limits only apply to
materials released from radiological control, but not on RPE or PC to
be reused, contamination area posting requirements, RPE use
requirements, or for the release of areas following decontamination.
The licensee's ability to evaluate surface contamination at very low
levels with existing laboratory counting equipment, the limits for
loose surface, and also fixed contamination are several .tagnitudes
too high for materials to be released for unrestricted use. The
stipulation that RPE is to be used if loose surface contamination
limits are above 20,000 dpm is not consistent with the minimization
of the use of RPE and does not allow for the practical application of
task evaluations in determining the need for RPE. The licensee's
lack of consistent and conservative limits on surface and fixed
contamination for materials to be worn /used and released by the
licensee are significant program weaknesses. This is considered an
open item pending licensee evaluation of the contamination control
limits (285/8805-12).
The NRC inspectors made several inspections of the auxiliary building
to determine the overall effectiveness of the licensee's radioactive
material and contamination control program. During these
inspections, the NRC inspectors identified several incidents which
demonstrate a lack of adherence to procedures and industry practices.
Some of the poor practices were:
Two or more workers were performing the same work function each
wearing different types of protective clothing.
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Access control points were established in a manner that requirec
contaminated protective equipment to be placed in receptacles
outside the controlled area.
Used protective clothing was laying in "clean" areas of the
radiologically controlled area.
- Frisker stations were not used to control the spread of
contamination when exiting from contaminated areas.
TS 5.11.2 requires that areas where the radiation intensity is
greater than 1000 millirem per hour (mrem /hr), a very high radiation
area, be provided with locked doors to prevent unauthorized entry
into such areas. Keys to these very high radiation areas shall be
maintained under the administrative control of the shif t supervisor
on duty and/or the PHP.
On January 25, 1988, at approximately 4:25 p.m. a licensee
representative performing a routine tour cf tha auxiliary building
found the door leading to room No. 11 from corridor 4, which housed
the liquid waste system filters, locked but not secured (1-e., the
lock was in the locked position, but the door was not completely
closed to ensure a fully locked door). At the time of discovery, no
personnel were in room No. 11.
The licensee had initiated an investigation into this incident in
accordance with Standing Order R-4, "Operating Incident Reports."
The licensee dete. mined that a radwaste radiation protection
technician had removed some spent filters that were inside the room
at approximately 2:20 p.m. on January 25, 1988. The technician was
not aware that the door was not secured. The licensee's review of
security and other records indicated that there had not been any
entry into room No. 11 between 2:20 p.m. and 4:25 p.m. on January 25,
1988, while the door was not secured. The licensee informed the NRC
senior resident inspector and Region IV of this very high radiation ,
area door incident.
The NRC inspectors' review of this incident determined that the
closure system on the door would secure the door, if the door was
released from an open position of approximately 1 foot or greater.
The lock latch engaged the door frame plate so that the door could
not be forced open.
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The NRC inspectors reviewed radiation survey results of room No. 11.
The radiation levels inside the room, at the door were 8 mrem /hr and
approximately 100 mrem /hr at 9 feet from the door. The room
contained two filter housing assemblies. The filter housing in
service produced radiation levels of about 4000 mrem /hr in the
general area with a hot spot of 20,000 mrem /hr. The other filter
housing had general radiation levels of about 500 mrem /hr.
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The failure to control a very high radiation ' door' is considered an
apparent violation of TS 5.11.2 (285/8805-02). l
This is a similar violation regarding the failure to control very ;
high radiation areas previously identified in NRC Inspection
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Report 50-285/87-21, except in the present incident there was no j
unauthorized entry into the area.- l
The NRC inspector's review of the January 25, 1988, incident raised l
questions as to why the radwaste radiation protection technician did t
not sign out the very high radiation area key from the radiation !
prot:ction shift technician's key box. Discussions with licensee ;
repres intatives indicated that four keys, identified as key "911", a
master type key to the cuxiliary building doors had been given to {
various plant personnel during initial operation of the plant. Keys j
were recovered from the ALARA coordinator, PHP, acting radwaste +
coordinator, and a radwaste radiation prottetton technician. _These !
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keys were net issued to these specific individuals, as they were not
required to sign a key control record, but rather given to them. The ,
NRC inspectors discussed with members of the radiation protection staff t
the controls for "911" keys, and it was determined that individuals ;
acting in the capacity of shift leader during refueling / maintenance
outages had also been given these keys. The NRC inspectors asked a !
few individuals to check and see if they had a "911" key. As a !
result of these inquiries, a fif th key was returned on February 4, :
1988, that a RP technician forgot he had at home. l
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The NRC inspectors expressed concern that the licensee had not_ j
performed an in-depth investigation of keys that had been issued or >
given to personnel and had cot made a serious attempt to recover i
these keys. The NRC inspectors were informed that supervisory )
maintenance personnel also had been issued or given a master key for j
the auxiliary building doors, the NRC inspectors were not able to i
confirm this. The licensee had not determined how many "911" keys l
were initially made nor performed an investigation to determine if (
other keys were unaccounted. 1
The failure to maintain a positive administrative control for all
keys with access to very high radiation areas is considered an :
apparent violation of TS 5.11.2 (285/8805-03). l
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During an inspection of the auxiliary building with the PHP on :
February 4, 1988, the NRC inspectors noted at approximately 11 a.m. a l
RP technician had exited room 25, the railroad loading and unloading
area a posted very high radiation area, and failed to close and lock l
the door. The RP technician had travelled approximately 20 feet from j
the door when the NRC inspectors brought this situation to the j
attention of the PHP. The PHP discussed the NRC inspectors concern j
with the RP technician, in the presence of-the NRC inspectors, to j
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determine the exact status of what appeared to be an unattended,
unlocked, very high radiation area door.
The NRC inspectors determined that the RP technician had left the
door unlocked because another RP technician was still in room 25.
The PHP reminded the RP technician of the 2-man rule that had been
established for very high radiation areas and instructed the
individual to return to room 25 immediately.
TS 5.11 states that procedures for personnel radiation protection
shall be approved, maintained, and adhered to for all operations
involving personnel radiation exposure. Procedure RPM, Section 3.0,
"Area Control," Revision 20, dated January 26, 1988,
paragraph 3.1.7.2.b.1, states that with the exception of emergency
operator entry, a second person shall always accompany any entry by a
qualified RP technician into a very high radiation area. The second
person may or may not cross the very high radiation area boundary
but, in all cases, the two persons must maintain line-of-sight or
other communications while one or both persons remain within the very
high rediation area.
The failure to maintain line-of-sight or other communications with
an individual that remained in a posted very high radiation area is
considered an apparent violation of TS 5.11 (285/8805-04).
TS 5.8.1 states that written procedures and administering policies
shall be established, implemented, and maintained that meet or exceed
the minimum requiremencs of Appendix A of USNRC RG 1.33.
Section 7.e.4 of Appendix A to RG 1.33 states that radiation
protection procedures should be written to cover contamination
control. The licensee established Procedure HP-9, "Contamination
Control," Revision 2, dated July 2, 1985, and in Section C.1.c.1
requires that controlled surface contaminated areas be conspicuously
posted and an appropriate control point established if access is
required.
On February 3, 1988, the NRC inspectors noted inadequate posting of a
controlled surface contaminated area in Room 23 that contains spent
regenerate tanks and pumps. A temporary barrier rope was observed on
the floor with a posting sign lying face down. This condition was
brought to the licensees attention on February 3, 1988, at
approximately 3 p.m. The NRC inspectors observed the same condition
and brought it to the licensees attention a second time, at
approximately 9 a.m. on February 4,1998.
The licer.see's representative stated that a RP technician had
attached the barrier rope and Dosting sign to the wall on February 3,
1988, but evidently it had come loose again. The failure to
conspicuously post a controlled surface contandnated area is an
apparent violation of TS 5.8.1 (285/8805-05).
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c. Respiratory Protection
The NRC inspectors reviewed.the licensee's management controls. !
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regarding the respiratory protection program to determine compliance t
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4 with 10 CFR P4rt 20.103 and the recommendationsiin RG 8.15 and
NUREG-0041. When respiratory protection equipment is used to limit
the inhalation of airborne radioactive material, 10 CFR 20.103(c)
requires that the licensee implement a respiratory protection ,
program. Several procedures are in place to cover the elements of a i
program; however, no overall controlling procedure has been issued. t
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The NRC inspectors noted that Standing Order T-11. "Respiratory
Protection Program," has been recently deleted and not replaced.
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10 CFR Part 20.103 requires programs-for the use of respiratory
protection equipment (RPE) to comply with certain criteria when the !
allowing credit fer the established protection factors for a given
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piece of equipment during exposure to airborne radioactive materials.
10 CFR Part 20.103(c) requires that when respiratory protective j
equipment is used to limit the inhalation of airborne radioactive
material, the licensee may make allowance for this use of respiratory ,
protective equipment in estimating exposures of individuals provided 5
that a written policy statement on respitator usage is issued.
Section C.1 of RG 8.15 recommends that a written policy statement on
respirator usage is to be issued from a high management level and ;
that. strong management backing is considered essential to an adequate l
respiratory protection program. Secticn 3.2 of NUREG-0041 states ;
that no respiratory protection program is considered adequate without i
a written policy statement on respirator usage issued from a ;
sufficiently high management level to ensure that its provisions may !
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be adequately enforced.
Contrary to the above, the NRC inspectors determined on February 4, !
1988, that the licensee had not issued a written policy for the i
respiratory protection program. The failure to issue a written
policy for the respiratory protection program is an apparent '
violation of the requirements of 10 CFR Part 20.103(c)(3) l
(285/8805-06). <
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The NRC inspectors reviewed the OPPD Supervisors Manual, Nuclear !
Production Division Policy and Procedurts, Station Standing Orders,
RPM, Job / Position descriptions, and interviewed C/RP management and I
technical staff to assess the effectiveness of management oversite in
this area. The following concerns were identified:
NUREJ-0041 recommends that one individual be vested with the
responsibility of maintaining the respiratory protection program j
required by 10 CFR 20.103(c)( 0 . This respiratory protection l
supervisor should oversee the day-to-day operation of the l
program. Interviews with the Supervisor, C/RP revealed that he '
is also the supervisor of respiratory protection. It appears l
that the duties of supervising the entire C/RP group does not l
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provide adequate time to run an effective respiratory protection
program, i
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- Respiratory protection equipment is provided on a self-serve ;
basis to workers. Particulate filter respirators as well as l
SCBA are placed in open racks at the entrance to the radiation :
l controlled area. Additional SCBA air bottles are located in an:
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adjoining rack. This self-service issuance of respiratory !
protection equipment is a poor practice since it does not '
provide adequate controls to ensure that the user is qualified :
to use the equipment or that the equipment is maintained in
proper working condition.
- The NRC inspectors noted two SCBA air bottles in the issue rack i
that should have been removed from use. One bottle was past due !
on the Department of Transportation 5 year _ bydrostatic pressure !
test requirenent. The other bottle had taken a blow to the :
outlet onzzle damaging its threads-and potentially compromising i
its structural integrity. If used in an emergency situation, i
either of these bottles could pose _a significant threat to the
user's life. Both SCBA bottles in question were eventually
removed from service by placing a red tag on each. The
procedure used to tag the bottles was Standing Order T-13,
"Quality Control Program for Chemistry and Radiation Protection
Equipment." T-13 requires that instruments without e valid
calibration sticker be red tagged. This descriptinn does not
adequately describe the damaged condition of the-two SCBA
bottles.
The person in charge (Supervisor, C/RP) of the respiratory
protection program lacks the necessary experience and technical
training as recommended in Chapter 12 of NUREG-0041.
Procedures for refilling SCBA bottles do not reference the
verification that bottles are within the hydrostatic test period
limitations prior to filling the high pressure SCBA bottles.
(49 CFR Part 173.34)
Procedures do not adequately address the respiratory protection
equipment quality control, maintenance, and hazard evaluation
programs (chemical, radiciodine, and particulate) as recommended
in Chapters 4, 9, and 10 of NUREG-0041.
Procedures do not adequately address the performance aspects of
periodic inspection for storeo respiratory protection equipment
as recommended in Chapter 10 of NUREG-0041.
The respiratory protection program does not provide for a
periodic evaluation of the effectiveness of the respiratory
protection program to ensure that all aspects are being
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conducted in accordance with industry standards and applicable
federal regulations as recommended in Chapter 12 of NUREG-0041.
The lack of a comprehensive and organized respiratory protection
program is a significant weakness. This is considered an open item
pending licensee action (285/8805-13).
6. Exit Interview
The NRC inspectors met with the licensee representatives denoted in
paragraph 1 at the conclusion of the inspection of February 5, 1988. The
NRC inspectors summarized the scope of the inspection and discussed the
inspection findings,
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DOCUMENTS REVIEWED DURING
NRC INSPECTION 50-285/88-05
TITLE REVISION DATED
Nuclear Production Division Organization Chart 0 01/01/88
Chemistry and Radiation Protection Group
Position Descriptions (25)
Chemistry and Radiation Protection Group -
Employment Resumes (25)
HP Departmental Meeting Minutes for 10/13/87
meeting 10/27/87
HP Departmental Meeting Minutes for 10/16/87
meeting 10/27/87
ALARA Committee Meeting Minutes for 1/7/88
meeting 01/12/88
Radiation Work Permit 88-033-4 01/18/88
FCS Standing Orders
G-5, Plant Review Committee 41 10/19/87
G-31, Posting of Notice to Workers 2 10/19/87
G-53, Personnel Certification Technical
Specification 5.3 2 02/06/86
G-57, Installation of Temporary Lead Shielding 4 09/02/87
G-64, Medical Examination Program for Worker
Qualification 10 09/04/87
G-69, FCS Asbestos Abatement 2 03/25/87
0-26, Plant Keys 14 08/24/87
T-1, Radiation Protection Manual 3 03/31/81
R-4, Operating Incident Reports 12 08/04/87
FCS Radiation Protection Manual
Sections 1 thru 11 f
RPP-1, RP Procedure for Radioactive spills
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8 08/20/87
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RPP-2, RP Procedure for Control Area Injury 7 12/18/84 ,
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RPP-3, RP Procedure for Control Area Fire 6 10/19/77
RPP-4, RP Procedure for Possible Inhalation or
Ingestion Hazards (Airborne Radioactivity) 6 10/19/77
RPP-5, RP Procedure for High Radiation Area
Alarm 6 10/19/77
RPP-6, RP Procedure for Protective Clothing and
Respiratory Equipment Cleaning 12 12/22/86
RPP-6c, Respirator Washer and Dryer 0 08/24/87
RPP-8, Radiological Decontamination 14 03/25/87 ;
RPP-13. Recharging SCBA Cylinders 1 09/18/79 [
RPP-17, Radioactive Source Log Maintenance Use 3 10/08/86 !
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RPP-20, Radiation Work Permits (PWP) 8 07/13/87 j
RPP-22, Controlled Use of Respiratory Equipment 1 02/23/87
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HP-2, Respirator Fit Test Quantitative !
Polydispersed Aerosol Test 6 08/10/87 !
HP-4, Radioactive Source Control 2 09/23/83 ;
HP-7, Annual Review of Personnel Authorized to '
Wear Respirators 6 07/02/87
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HP-9, Contamination Control 2 07/02/85
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HP-11, Whole Body Frisking 1 09/27/85 l
HP-16, Selection of Contract HP Technicians 1 07/13/83 l
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HP-18, Personnel Decontamination 2 03/20/86 I
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HP-20, Compressed Breathing Air Quality t
Surveillance 1 02/28/84 i
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RW-7, In-Plant Collection and Disposal of ,
Radioactive Waste 2 03/12/87 l
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Nuclear Training Department Procedures / Documents ,
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TOP-1, Qualification aad Certification of
Instructura1 Staff 2 05/01/87
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TAP-1 CRPI, Qualification and Certification of
Chemistry and Radiation Protection Instructor 2 04/30/87 l
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- TAP-1 GETI, Qualification and Certification of ,
i General Employee Training Instructor 2 04/30/87 l
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TAP-2, Training Program Requirements: I
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Identification, Analysis, Approval, and
Authorization 2 10/29/87
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TAP-6, Evaluation of Training Program
- Effectiveness 2 10/26/87
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a TAP-8, Examination Control and Administration 3 05/28/87
! GAP-9 Maintenance of Training Records 2 04/28/86
TAP-10, lessons Learned - Inputs to Training f
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Programs - Required Reading Program 3 05/15/87
TAP-12, Conduct of On-the-Job Training 2 10/26/87
{
TAP-17, Review of Training Programs 2 10/23/87
TAP-27, Evaluation of Instructor Effectiveness
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General Employee Training Level I Handout 1 01/20/87
3 f
General Employee Training Level II Handout 4 10/19/87 ;
General Employee Training level S Handout 1 10/15/87
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Memorandum, FC-T-934-87, D. Jacobson to G. Roach, [
Subj: Identification of Short and Long Term I
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Training Goals for Radiation Protection Based i
on the Incumbent Matrix Exam, dated !
November 19, 1987. ;
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Memorandum, FC-T-058-88, D. Jacobson to !
G. Roach, Subj: 1938 C/RP Training Schedule, '
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dated January 21, 1988 ,
17 Lesson Plans for GET, Radiation workers and
HP Technician Training [
Internal Audit Report #58, Health Physics and .
ALARA 12/02/87 !
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TABLE 1
COMPARISCN OF FORT CALHOUN STATION'S ANNUAL PERSON-REM
EXPENDITURE TO NATIONAL SINGLE REACTOR PERFORMANCE
Year 1983 1984 1985 1986 1987
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PWR Average 592 556 427 392 :
Fort Calhoun 433 563 632 74 338,5
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TABLE 2
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WORK FUNCTIONS THAT EXCEEDED
- 5 PERSON-REM IN 1987
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Job Description Person-Rem
Steam Generator (5/G) Eddy Current Testing 5.945
Install S/G Nozzle Dams 14.804 *
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Remove Reactor Vessel Stud Plugs 5.307
Remove / Replace Reactor Coolant Root Valves 21.508
Decontaminate Upper and Lower Cavity 12.295 i
j Fuel Transfer in Containment and Fuel Pool 5.872
Routine Health Physics Coverage in Containment
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30.486 ,
Pressurizer Spray Valve Upgrade 11.599 ;
Remove / Replace Insulation for ISI Inspection 12.218 i
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Radwaste Preparation and Shipment 14.978
S/G Blowdown Line Insp., Annulus Insp., Sludge Lance 20.638
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