ML20153B405
| ML20153B405 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/06/1988 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-514, NUDOCS 8807130066 | |
| Download: ML20153B405 (14) | |
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L Omaha PutMc Power District 1623 Harney Oirena. Nebraska 68102 2247 402,536-4000 July 6, 1988 LIC-88-514 U. S. fluclear Regulatory Comnission Attn: Document Control Desk Mail Station Pl-137 Washington, DC 20555 Docket No. 50-285
References:
1.
Letter from NRC (L. J. Callan) OPPD (R. L. Andrews) dated 2.
March 8, 1988 Letter from OPPD (R. L. Andrews) to NRC (Document Control 3.
Desk) dated March 31, 1988 (LIC-88-211)
Letter from OPPD (R. L. Andrews) to NRC (Document Control 4.
Desk) dated June 15, 1988 (LIC-88-500)
SUBJECT:
Updated Status of Open items from NRC Inspection Report 50-285/88-05 Omaha Public Power District (OPPD) received and responded to NRC Inspection Report 88-05.
The attachment to this letter contains an updated status of open items and concerns identified in that report.
Revisions to OPPD's previous submittal (Reference 2) are denoted by a vertical line in the right hand margin.
The corrective actions to the violations, open items, and concerns are part of the Radiological Improvement Project (RIP).
This project includes the revision of the Radiation Protection Plan and Radiation Protection Procedures.
The next update will address the status of this project as well as the status of the attached concerns and open items.
It wili be forwarded by September 30, 1988.
This date allows for the completion of several milestones and preparation of an updated report.
Should you have any questions, do not hesitate to call us.
Sincerely,
[J. /
i Morris 8807130066 080706 PDR ADOCK 05000285 Division Manager PNU Nuclear Operations KJM/me Attachment cc: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator I
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P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector
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ATTACHMENT UPDATED RESPONSE TO OPEN ITEMS AND CONCERNS IN IR 88-05 p
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Open Item (285/8805-07): Organihtiob.)fanNositionDescriptiodt.. T @ item i
involves the lack of position descriptiori'far certain radiation prote fon p &-
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sonnel and updating the Technical Specific'ation organization chart.- ~ x
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Item Identification iT\\
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2.
Management Conttol Observations 1
i a.
The c"rrent organization doesn't agree with the organization charts.
There appears to be a void in first line supervisors.
Currently, lead I
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technicians hold a first line superviser's responsibility but do nol have the authority.
The technical staff is generally adequately trained and competent which appears te be what is holding the organization together.
b.
Since the working organization is not the official organization, no position descriptions for lead technician, no lines of authority and responsibility are outlined.
c.
The upgrade of C/RP positions is commendable, however, the discontinuation of this upgrade has lead to morale problems.
Present Status 0 PPD has submitted a Technical Specification change (LIC-88-380, dated May 23, 1988) to eliminate the organizational chart from the Technical Specificat:ons.
The organizational chart will be part of Section 12 of the Updated Safety Analysis Report (USAR). This will allow changes to be made to the organization without requiring a Technical Specification change.
Effective July 1,1988, the C/RP department was divided into two separate l
departments (Chemistry Department and Radiation Protection (RP) Department).
I Each major area of responsibility in the RP Department has a supervisor responsible for that area. These supervisors report directly to The Supervisor
- Radiation Protection.
Also, a review and revision of the Radiation Protection Manual is in progress which will better define the responsibilities of radiation protection personnel.
Open Item (285/8805-08): Radiation Protection Procedures. This item involves the lack of organized and comprehensive radiation protection procedures.
Item Identification RP procedures fragmented and confusir.g.
Technicians could not find procedures in RPM that were pertinent to work he was performing.
l Procedures rely too heavily on working experience of operators.
Present Status Implementation of the revised Radiation Protection Plan has been scheduled in the RIP Progr&m Plan and will be complete by October 15, 1988.
Implementing procedures *11 be developed and issued ever a 2-3 year period and completed by October 31, 1991. 1
a Open Item (285/8805-09): Audits / Evaluations. This item involves the lack of a comprehensive audit /cvaluation program.
Item Identificatj.o_r1 Inspector expressed concern as to why weaknesses and violations identified were not identified by the Licensee.
Present Statni Quality Assurance has taken sevual actions to provide more comprehensive audits and surveillances of the health physics program.
Several new surveillances have recently been implemented to observe and evaluate health physics practices to include; HP instrumentation use and selection, performance of surveys, radiation controlled area work practices (RWP use, respiratory protection, radioactive material labeling and bag-ging, and area control), contamination control, health physics counting, instrumentation operation, dose calculations, personnel contamination, and the selection process for contract HP technicians.
Audit teams on audits of health _ physics have been and will continue to be suppl.mented with appropriate technical expertise.
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The scope of the audit for health physics is being reviewed to ensure it cover.c ihe program in adequate detail during the next audit.
In addition to improving Quality Assurance's audit and surveillance programs for ths Fort Calhoun Station, other evaluation program improvements have been made.
The Radiation Improvement Project (RIP) has been given a high priority by Company management.
The Manager - Emergency Planning is currently designa-ted as tne project leader. He has people from both the corporate and plant radiological groups reporting to him to develop, implement and enhance the radiological functions. This project team is also a management oversight to evaluate H. P. program effectiveness. An outside consultant is also being uti'17ad to supplement the project technically and to add an industry-wide perspective to the project.
The Excellence in Operations assessment idekcified that offsite corporate per-sonnel with HP experience needed to devote time to evaluations and r.onsultant tasks. The Manager - Emergency Planning, the Supervisor - Radiological and Environmental Monitoring Services, and the Supervisor-Radiological Services are presently desigr-to assist the plant radiation protection group.
.g.
I Open Item (285/8805-10): Training of Radiation Protection Personnel. This Item involves the lack of a system training program for radiation protection technicians.
11m_Jdenti fication Training and Performance Observations Technical Training - Reactor Systems training is neglected. Therc are no particular requirements of systems knowledge for initial qualification or promotion.
There are too many exemptions from training because people have worked at the plant; this is no guarantee that they know systems.
Present Status System kr.owledge requiroments for initial qualification and requalification have been developed and will be upgraded in the Training Program Master Plan by September 1, 1988, 1.
Approval of plant systems lesson plans has been completed.
2.
A trafning schedule has been developed and training resources are being provided to accomplish scheduled and ongoing training.
3.
Required reactor system requalification training on selected systems for RP technicians is in progress.
4.
Reactor system training for OPPD RP technicians is in progress.
5.
RP technicians not in initial training will complete 1988 requalification in compliance with Training Program Master Plan requirements by March 1, 1989.
Open Iter (285/8805-11): Backup Radiation Protection Manager. This item in-volves the use of an unqualified individual to serve as the acting supervisor, C/RP (Radiation Protection Manager) at Plant Review Committee meetings.
Item Identification Management Control Observations The Plant Chemist is not qualified as backup to the C/RP Supervisor.
He has no technical training or professional experience in raalological protection in order to satisfy RG 1.8-1975.
Present Status Two qualified individuals (one from Chemistry and one from Radiation Protec-tion) are now required to serve as the alternate to the C/RP Supervisor.
Qu-':rication requirements have been established for chemical and radiation i
protection personnel who simultaneously serve as alternates to the C/RP Supervisor.
Standing Order G-5 was changed to include this requirement on March 21, 1988.
Effective July 1, 1988 there is a Supervisor - Radiation Protection and a Chemist:y Department supervised by the Plant Chemist. Both of these positions report directly to the Plant Manager.
Each will have an individual qualified to serve as their alternato. l
Open Item (285/8805-12): Contamination Limits. This item involves the lack of contamination limits that are consistent with NRC guidance.
Item Identification Contamination Cortrol Procedures a.
Release limits do not agree with NRC guidance, b.
No alpha contamination limits on RPE or PC to be r!used, contamination areas posting requirements or release of decontamiaated area.
c.
The 20,000 dpm limit for requiring respiratory protection without using case by case review causes unnecessary use of re:piratory protection equipment, d.
Ability to evaluate surface contamination at lor limits, loose surface limits, fixed contamination inadequate, i.e. too high for materials released to unrestricted use.
Present Status 0 PPD is conducting an in-depth review of health physics policies, procedures and practices with the objective of defining differences between the current
'*ddiation pr9tection program and an excellent radiation protection program. A
.thorcugh reevaluation of all health physics limits is an important part of this review.
On completion of the reevaluation, any inconsistencies between limits or non-conservative practices will be eliminated via the procedure change process.
The Company, with technical assistance from a consultant, is evaluating an interim position on contamination until the in-depth review is completed. The Company is also reviewing the limits for release to an unrestric:ed area for materials with the technical consultant.
An interim program defining contaminatica and release limits has been completed and implemented.
The Interim Program addresses release limits, alpha limits, taspiratory limits, fixed contamination limits and loose contamination limits.
A long term action plan dealing with contamination limits will be completed and implementec into the upgraded RPM by October 31, 1991.
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Open Item (285/8805-13):
Respiratory Protection Program. This item involves the lack of a respiratory protection program that meets the recommendations of Regulatory Guide (RG) 8.15 and NUREG-0041.
Item Identification Management Control Observation Item E:
Respiratory protection practices do not appear to meet industry standards.
Present Status i
An evaluation of the respiratory protection program has been conducted by 0 PPD personnel with vendor assistance.
This evaluation will be reviewed by 0 PPD ranagement and appropriate actions takeo to implement the necessary improve-ments.
Improvement items thus far identified are:
1.
A written policy statement for respiratory usage has been completed.
?.. A person with a vested responsibility for the respirator program has been designated.
3.
Improved maintenance and repair procedures for respirators, including hydrostatic pressure checks, and performance aspects for stored respirators is scheduled for completion by July 31, 1989.
4.
Consolidation of procedures concerning respiratory protection is scheduled for completion by July 31, 1989.
5.
Improvement of inventory and issuance procedures and controls is scheduled for completion by July 31, 1989.
6.
Better correlation between different aspects of this prograr, (i.e. Whole Body Counts, Air Sampling, Respiratory Protection Requirements and Airborne Radioactivity Entry Logs) is scheduled for completion by July 31, 1989.
7.
Evaluation of respirators per Regulatory Guide 8.15 and NUREG-0041 to determine effectiveness against chemicals, radiciodine and particulate, scheduled for completion by July 1,1989.
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Oraanization & Manaaement Concern NRC Docket 50-285/88-05, page 5, regarding purchasing authority of plant.
Jtem Identification a.
The NRC inspectors noted that the plant management has limited authority to allocate resources in the radiation protection area.
b.
Corperate not effective in procuring the quality and numbers of expandable items (such as protective clothing) needed to support the program.
See license QA audit (87-QA-453).
c.
The use of double disposable booties is taught in the GET program because the quality of the boots available do not ensure adequate protection with a single set of booties. This is contrary to mini-mization of radioactive waste.
Present Status The RP department _is working with the stores group to determine specifically which anti-contamination materials have quality and availability problems as they have in the past and will choose alternate suppliers.
The RP department will develop minimum acceptable standards for items of protective clothing which will be incorporated in purchasing specifications.
Scheduled con:pletion is August 31, 1988.
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Oraanization & Manaaement Cortedtra NRC Docket 50-285/88-05, page 6.
Item Identification The cooperation between the RP technicians and other plant groups has improved in the past two months. There was still room for improvement.
The NRC also noted that there rppered to be a lack of cooperation between RP and other plant groups at tae supervisory level.
Present Status The recently noted improvements in cooperation between groups is the result of two diily metings with maintenance and operation orientation held at 7:45 a.n. crd 3:45 p.m.
These meetings are increasing the group's ability e
to communicate, to identify and to coordinate common needs.
In addition, plant department heads are meeting each morning on administrative matters.
These three meetings were initiated in the late fall of 1987 and will continue.
The Company has devoted more resources to teaching team work, emphasizing the importance of each individual, and teaching managers and supervisors more refined people skills.
Examples of Company programs that emphasize people skills are Resource Management and Performance 100%.
In addition, Nuclear Production Division within OPPD has utilized a local professional to teach team building skills to management personnel.
Management has carried the;e skills to department supervisors, foreman and craftsman, professional people, and administrative people in sessions geared to build team work and cooperation.
Scme groups at the plant have worked directly with the team building 3rofessionals. These programs will continue as long as they are
)eneficial.
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3 Staff Trainina & Oualification Concern NRC Docket 50-285/88-05, page 7, regarding GET training.
Item Identification a.
Plant workers and RP personnel do not follow the basic protective clothing dressing procedures specified in the GET practical factors class.
b.
Placement of radiological waste and used PC receptacles at an exit from a controlled surface contamination area did not comply with expected industry radiation protection practices.
c.
The licensee does not routinely post dre: sing v. undressing instructions at the exits.
d.
RP personnel do not ensure that radiation protection practices coveted during GET are implemented by plant workers.
Present Status Procedure HP-9, Contamination Control, was revised July 1, 1988. The revision includes requirements for the placement of radiological waste and used protective clothing (Item b). The proceduralized guidance specifies protective clothing dressing and undressing procedures, posting of dressing requirements and standardization of radiation protection practices.
General Employee Training will teach pertinent aspects of the new procedure.
Training of personnel on requirements will resolve Items a, c and d.,
Staff Trainino and Qualifications Observations NRC Docket 50-85/88-05, page 7 and 8, regarding Respirator Protective Equipment training.
Item Identification Instructors providing RPE instructions have not had formal training in a.
the application and use of RPE.
The instructors are relying on their previous experience as a user of RPE and have not had sufficient exper-ience in selection and use of RPE other than for airborne radioactive particulate protection (Section 8.1 of NUREG-0041).
b.
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 responsibil-c.
ity and authority at the station for the RPE program.
(Section 3.5.2 of ANSI Z88.2, and Section 12.1 of NUREG-0041),
d.
The RPE training program does not cover the training or special quali-fications required for the use of SCBA's Discussion with RP personnel who are part of the station's Radiolog-e.
ical Emergency Plan (which provide for tile use of SCBA's by emergency teams) determined that not all RP technicians have received SCBA train-ing or have not had to requalify since initial training.
Present Status Item has been corrected by providing formal RPE training to a.
instructors, b.
The training video tape has been corrected, c.
Item c tas been addressed.
Standing Order T-11 identifies the person responsible for the respiratory protection program.
Currently, the ALARA Coordinator formalizes appropriate aspects of the respiratory protectiori program including qualification of instructors, review and approval of training materials on RPE and scope of the training program.
The Respiratory Protection Specialist will assume this responsibility after completion of the reorganization and apprcpriate training.
d.
The Training department is currently conducting training on the use of SCBA's for "mask qualified" individuals as part of the annual requal
- program, RP technicians will be trained as part of the ar.nual requalification e.
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J Staff Trainina and Oualifications Concern NRC Docket 50-285/88-05, page 10, regardinc credit for Navy ELT.
Item Identification The NRC inspectors believed that the licensee gave too much credit to per-sonnel with the U.S. Navy nuclear power, Engineering Laboratory Tech-nician (ELT) experience. The NRC inspectors discussed with the licensee that ELT experience for a standard six year tour of duty with the Navy really only amounts to four years experience of which approximately two or more years is primarily radiochemistry work.
S.0. G-53 indicated three years experience was given.
present Status The Company reviewed the qualifications for all technicians to ensure that they are qualified to perform their existing responsibilities.
It was determined that technicians meet the ANSI qualifications by satisfy-ing one or more of the following conditions:
a.
Two or more years commercial nuclear power experience as a health physics technician, b.
A six year tour as an ELT plus one or more years of commercial ex-perience.
c.
Six year tour as an ELT plus Fort Calhoun training.
Newly hired technicians, including ex-Navy ELT's are subject to the station's training program. The Training Program Master Plan provides a qualification mechanism that assures that the trainee has demonstrated proficiency in all elements of the training program. Otherwise, for most ex-ELT's the program is four to six months in duration.
5.0. G-53 changes have been completed.
9 Radioloaical Controls C)ncerns NRC Docket 50 285/88-05, page 11, regarding the ALARA program lack of support.
Item Ioentificat.imi a.
Lack of support for the ALARA program. The NRC inspectors noted the ALAP.A 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 radiation exposures.
b.
The ALARA program has not received the full support from plant de-partments.
c.
A procedure, S.O. G-59 Ooerational Containment Entry Evaluation, did not receive approval by the PRC.
Present Status The ALARA policy statement in the OPPD Supervisors Manual, Number 9.03 will be revised and will encourage uso of Employee ALARA Concern Forms. The Company recognized that the ALARA program required more management support.
The Corporate QA Plan redefined the ALARA program as per QAP 11.3.
The QA Plan was utilized to designate ALARA structure that includes responsibilities up to the Senior Vice President level, and includes the plant and offsite support group role in ALARA.
OPPD agrees that employee ALARA concern forms have not been effective and improvements are needed. The ALARA Supervisor has attended safety meetings of many different work groups to increase plant understanding of the ALARA program.
Recent changes (March 1988) to Standing Order G-50, which defines the sta-tion ALARA program, will provide additional strength in the program.
The ma,ior element in the change is the c:le/ated assignment of ALARA committee officers and members in order to attract and motivate increased participa-i tion of all station departments.
The Company's commitment is to maintain exposure to radiation as low as reasonably achievable. Under the organizational change of July 1,1988, the olant ALARA committee is composed of the following personnel:
Manager Fort Calhoun Station Chairman Supervisor - Radiation Protection Vice-Chairman Secretary
- ALARA Coordinator Member
- Manager - Emergency Planning Member
- Superv;sor Operations Member
- Supervisor Maintenance Member
- Supervisor Systen Engineering Member Foreman !&C Foreman Mechanical Craft Member Health Physics Technician l.
Member The ALARA committee will discuss the draft, Operational Containment Entry for incorporation into the RPM.
Generating Station Engineering has drafted an ALARA Design Engineering Guide to consider ALARA in more detail in the modification process.
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.o-Radioloaical Controls Concerns The NRC Docket 50-285/88-05, pages 13 and 14, regarding radioactive materials and contamination control practices outlined what the inspector discussed as poor practices, a.
Two or more workers were performing the same work function each wearing different types of clothing.
b.
Access control points were established in a manner that required contaminated protective equipment to be placed in receptacles outside the controlled area.
c.
Used protective clothing was laying in "clean" areas of the radiologically controlled area, d.
Frisker stations were not used to control the spread of contamination when exiting from the contaminated areas.
Present Statqi The specific concerns in items a, b c, and d abo'te, have been corrected.
l OPPD will continue to monitor the situation with increased walkdowns of the auxiliary building by the Plant Health Physicist.
This is an ongoing item.
Procedure HP-9 was updated July 1,1988 and addresses contamination postings and establishment cf controlled area boundaries.
It also provides specific guidance on the donning and removal of protective clothing.
Frisker stations have been establihsed to support contaminated area exit frisking. -