ML20198D367
| ML20198D367 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/11/1986 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198D185 | List: |
| References | |
| 50-285-86-05, 50-285-86-5, NUDOCS 8605230228 | |
| Download: ML20198D367 (11) | |
See also: IR 05000285/1986005
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-285/86-05
-License: DPR-40
Docket:
50-285
Licensee: Omaha Public Power District (OPPD)
1623 Harney Street
f.
Omaha, Nebraska 68102
Facility Name:
Fort Calhoun Station (FCS)
Inspection At:
FCSSite,Washingtonbounty, Nebraska
Inspection Conducted: March 4-6, 1986
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Inspector:
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H. Chadey'k Radiation Spe alist, Facilities
Date
Radiological Protecti
Section
Approved:
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V////86
B. Murray, Chief, Fac
s Radiological
Date '
Protection Section
Inspection Summary
Inspection Conducted March 4-6, 1986 (Report 50-285/86-05)
Areas Inspected:
Routine, unannounced inspection of.the radiological
environmental monitoring program.
Results: Within the areas inspected, two violations (see paragraph 10) and no
deviations were identified.
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DETAILS
1.
Persons Contacted
- K. L. Belek, Supervisor, Environmental Sciences
S. A. Bobbrink, Chemist
F. Coddington, Instrument and Controls (I&C) Apprentice
-A. A. Constanzo, Analyst
C. R. Cr6wford, ALARA Coordinator
J. J. Fisicaro,-Supervisor, Nuclear Regulatory and Industry Affairs (NR&IA)
- J. K. . Gasper, Manager, Administrative Services
W. G. Gates, Manager, Fort Calhoun Station
- R. L. Jaworski, Section Manager, Technical Services
J. Nixan, I&C Technician
- D. J. Hunderloh, Senior Engineer NR&IA
- A. W. Richard, Manager, Quality Assurance
G. L. Roach, Supervisor, Chemical and Radiation Protection (CRP)
- K. Stultz, Supervisor, Radiological & Environmental Monitoring Services
M. A. Wilson, Assistant Analyst
Others
P. Harrell, NRC Resident Inspector
P. Courtney, OPPD Meteorology Consultant (telephone contact)
- Denotes those individuals present during the exit interview on March 6,
1986.
- Denotes individual contacted by telephone on March 11, 1986, to discuss
inspection findings not presented at the exit meeting on March 6, 1986
2.
Licensee Action on Previously Identified Inspection Finding
(Closed) Open Item (285/8504-01):
Training - This item was previously
discussed in NRC Inspection Report 50-285/85-04 and concerned the lack of a
formal training program for personnel involved with the radiological
environmental monitoring program.
The NRC inspector determined that the
licensee's actions were adequate to resolve the inspector's concerns in
this area. This' item is considered closed.
3.
Inspector Observations
The following are observations the NRC inspector discussed with the
licensee during the exit interview on March 6, 1986.
These observations
are neither violations nor unresolved items.
These items were recommended
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-for licensee consideration for program improvement, but they have'no
specific regulatory requirement.
The licensee indicated that these items
would be reviewed.
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a.
Tritium Lower Limits of Datection (LLD1 - Tritium LLD listed in the
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Radiological Effluent TechnicaT Specifications (RETS) and Offsite Dose
Calculation Manual (ODCM) do not agree with NUREG-0472 (see paragraph 10).
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b.
Independence of Audit Team Members - The licensee's April 1986 scheduled
audit of the radiological environmental monitoring program has tenta-
tively assigned audit team members that have direct responsibilities
for the functional areas being audited (see paragraph 6).
4.
Environmental Protection Program Organization and Management Controls
The NRC inspector examined the organization and staffing of the licensee's
environmental organization to determine compliance with the Updated Safety
Analysis Report (USAR), Sections 2.5, 2.10, 11.1, 12.1, and 12.3 commitments;
and the requirements of the Facility Operatina License Technical Specification (TS) 5.2.1; and the recommendations of NRC Regulatory
Guide (RG) 1.33.
The NRC inspector reviewed the licensee's offsite support organization
structure and found it to agree with USAR, Figure 12.1-2, " Production
Operations Division Organization Chart." The NRC inspector also reviewed
the licensee's procedures and directives for implementing the radiological
environmental monitUring program, offsite and onsite staff functional
ass.ignments, position descriptions, allocation of personnel resources,
personnel evaluation system, management oversight of field activities,
procedure development and approval, and staff stability.
Documents and
procedures that were reviewed are listed in the Attachment to this report.
The licensee's environmental staff has remained stable over the past
10 years.
The turnover rate has been less than 10 percent per year.
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No violations or deviations were identified.
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5.
Environmental Protection Organization Staff Qualifications and Training
The NRC inspector examined the qualifications of the environmental
protection organization staff to deternine compliance with USAR,
-Sections 12.1, 12.2.2 commitments; and the requirements of 10 CFR Part 19.12, TSs 5.3 and 5.4; and the recommendations of RG 1.8 and
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The NRC inspector reviewed procedure: vid directives concerning training
and qualification of environmental services personnel.
No violations or deviations were identified.
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6.
Audits
The NRC inspector reviewed licensee's audit program for compliance with
TS 5.5.2.8.h and 10 CFR Part 50, Appendix B.
The NRC inspector determined that the licensee had not performed any audits
of the RETS program since its implementation in October 1985.
The licensee
had scheduled an audit of RETS activities to be conducted in April 1986 by
the Safety Audit and Review Committee (SARC).
The NRC inspector reviewed a
draft checklist and prospective audit team members.
The NRC inspector
noted that the prospective audit team leader was directly responsible for
implementation of the RETS and that one other team member was closely
associated with the conduct of the RETS program.
The licensee indicated
that a review would be conducted of prospective team members and any
conflicts of interest would be resuived.
The NRC inspector also reviewed
audits of the analytical services vendor, FCS site meteorology system, and
the environmental monitoring program conducted in 1984.
No violations or deviations were identified.
7.
Radiological Environmental Monitoring Program
The radiological environmental monitoring program was reviewed to determine
compliance with the USAR, Section 2.10.4 commitments; the requirements of
TS 3.11, and the ODCM; and the recommendations of NUREG-0742.
a.
Program Changes
The licensee implemented the RETS program in October 1985.
The
Semiannual Effluent Release and Environmental Monitoring Report for
July through December 1985, reflects the change over from previous
environmental requirements to the new RETS requirements and use of the
00CM for offsite dose assessment.
b.
Current Program
The NRC inspector reviewed the implementation of the RETS and ODCM
involving revised analysis sensitivities, reporting limits, sampling
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locations, reports, analytical results, sampling frequencies, land use
census, surveillance tests, program operating procedures, offsite dose
results from liquid and gaseous effluents, control of vendor / contractor
activities, and calibration of equipment.
No violations or deviations were identified.
8.
Meteorological Monitoring Program
The licensee's meteorological monitoring program was inspected for
compliance with USAR, Section 2.5.3, and FCS Radiological Emergency Response
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Plan Section I.2.2.4 commitments; the requirements of NUREG-0737,
Item III.A.2; and the recommendations of RGs 1.23, 1.97, and industry
standard ANSI /ANS-2.5-1984.
The NRC inspector reviewed representative records involving meteorological
data recovery and reduction, equipment calibration and maintenance, and
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equipment design specifications.
The licensee's meteorological equipment
(tower, data recorders, data plotter and remote displays, and analog
readouts in the control room), procedures and provisions for backup
meteorological data resources were inspected.
Discussions were held with
the licensee's meteorological consultant (via telephone) concerning
placement of the meteorological sensors for atmospheric stability on the
meteorological tower at 10 and 110 meters above ground level, when RG 1.23
and other industry standards recommend sensors heights of 10 and 60 meters.
The licensee's sensors placement was dictated by the local geological
formations and wind profiles for FCS.
The licensee's program appears to be
acceptable based on the specific meteorological conditions at FCS.
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No violations or deviations were identified.
9.
Facilities, Equipment, and Supplies
The NRC inspector inspected five air sampling stations, laboratory / office
facilities, laboratory equipment, analytical equipment, equipment operating
instructions, calibration records, record storage, and sampling devices.
No violations or deviations were identified.
10.
Environmental Monitoring Report, Operating Manuals and Procedures
The NRC inspector reviewed reports and procedures to determine compliance
with TSs 2.9, 3.11, 3.12, 5.9.4, 5.10.1, and 5.10.2 requirements, and 10 CFR Parts 20.106 and 20.405, 10 CFR Part 50.36.a, 10 CFR Part 50, Appendix B and I;
and the recommendations of RGs 1.21, 1.33, 4.1, 4.2, 4.6, 4.13, 4.15, and
The NRC inspector reviewed radioactive effluent release and radiological
environmental monitoring reports for the years 1981 through 1985, offsite
OPPD Technical Services Section procedures for implementing the environmental
monitoring program, FCS surveillance test procedures for conducting the
periodic RETS sampling program ana ODCM evaluations, and vendor analytical
results of radiological samples.
The NRC inspector noted that the licensee's analytical analysis lower
limits of detection values (LLDs) as referenced in the ODCM, per TS 3.11
Table 3.9, Note 2, did not agree with the recommendations of NUREG-0472,
Revision 2.
Differences existed in the LLDs for gross beta and tritium
measurements.
The licensee's ODCM did not provide an LLD for gross beta
measurements for water samples, and the licensee's tritium LLD was 10 times
higher (20,000 versus 2000 picocuries per liter) than that recommended in
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The NRC inspector noted that the LLDs listed by the offsite
vendor that performs radiological analyses of the licensee's environmental
sample were the same as the LLDs' appearing in the RETS even though the
actual reported results were below the LLDs in NUREG-0472.
The licensee
indicated they would review LLD values.
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TS 3.12, " Radiological Waste Sampling and Monitoring," requires the
licensee to sample and analyze radioactive liquid and gaseous effluents in
accordance with Tables 3.11 and 3.12.
These tables include quarterly
composite sampling and analysis of liquid and gaseous effluents for
strontium 89 and 90 radionuclides.
Furthermore, TS 5.9.4.a requires, in
part, that "A report covering the operation of the Fort Calhoun Station
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during the previous 6 months shall be submitted within 60 days after.
January 1 and July 1 of each year.
The radioactive effluent release report
shall include a summary of the quantities of radioactive . . . effluents
. . . released from the plant as outlined in Regulatory Guide 1.21,
Revision 1."
The NRC inspector determined by review of semiannual radioactive effluent
release reports that the licensee routinely omitted quarterly strontium 89
and 90 analysis data by entering the following notation-in the reports,
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"Results not available at time of initial report.
Revision for
Strontium 89-90 results will be provided upon receipt from vendor." On
March 6,1986, the NRC inspector determined that quarterly strontium
analysis results had not been provided for the following semiannual
Radioactive Effluent Reports:
1981 all quarters
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1982 all quarters
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1983 all quarters
1984 all quarters
1985 second, third and fourth quarters
Failure to submit the required strontium 89 and 90 analysis results is an
apparent violation of TS 5.9.4.a (285/8605-01).
TS 5.8.1 requires, in part, that " Written procedures . . . shall be
established, . . . and maintained that meet or exceed . . . Appendix A of
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USNRC Regulatory Guide (RG) 1.33 . . . ."
In addition, Section 8.b of
Appendix A to RG 1.33 states, in part, that " Specific procedures for
surveillance tests, . . . should be written (imphmenting procedures are
required for each surveillance test, inspection, . . . listed in the
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technical specifications):" Furthermore, TS 5.8.2 requires, in part, that
"Each procedure . . . of 5.8.1 above, and changes thereto, shall be
reviewed by the Plant Review Committee (PRC) and approved by the Manager -
Fort Calhoun Station prior to implementation and periodically as set forth
in each document."
The NRC inspector determined on March 11, 1986, that the below listed
licensee environmental program procedure, developed and issued by the
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offsite OPPD General Office Technical Services Section, had not been
provided proper review or approval prior to implementation / issue.
OPPD Fort Calhoun Power Station, Unit No. 1 Environmental Radiological
Monitoring Procedure Manual, Revision 2, dated December 1985.
The above noted failure to provide proper review and approval is an
apparent violation of TS requirement 5.8.2 (285/8605-02).
The NRC
inspector noted that the procedure noted above had evidently never been
initially reviewed or approved as required by TS 5.8.2, and that the
procedure appeared to satisfactorily implement the required surveillances.
The licensee did not consider offsite procedures, that implemented TS
related matters, to require PRC review or plant manager approval.
No deviations were identified.
11.
Quality Assurance Program
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The NRC inspector reviewed quality assurance activities for the
environmental monitoring program and contracted vendor functions.
These
reviews included licensee reports, QA audits, QA related training of staff
members, calculation instructions, data reduction, results of vendor
participation in the U.S. Environmental Protection Agency's laboratory
cross check program (1985), and records of reviews of environmental data.
The NRC inspector noted that, other than periodic audit activities, there
appeared to be a lack of QA Department involvement concerning oversight of
quality related activities of the environmental group especially in
procedure development, review, and approval.
The licensee indicated that
the QA oversight of the environmental monitoring program was satisfied by
the biannual audit of the program by the Safety and Audit Review Committee
per TS 5.5.2.5.h.
No violations or deviations were identified.
12.
Control of Contractor Activities
The licensee's control over contractor activities associated with the
environmental monitoring programs was reviewed.
The NRC inspector
determined that the licensee periodically audits the vendor providing
analytical services for the environmental monitoring program to assure that
analytical activities are being conducted as required by TS 3.11 and the
ODCM, and the recommendations of RG 4.15.
No violations or deviations were identified.
13.
Reportable Occurrences
The NRC inspector determined that the licensee had no reportable
occurrences, as per TSs 5.9.3 and 5.9.4.b.2, involving the ODCM or
radiological effluent releases during 1985.
No violations or deviations were identified.
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14.
Exit Interview
The NRC inspector met with the licensee's representatives identified in
paragraph 1 of this report at the conclusion of the inspection on March 6,
1986.
The NRC inspector summarized the scope'and the results of the
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inspection.
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ATTACHMENT
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TO NRC INSPECTION REPORT
50-285/86-05
APPENDIX 8
DOCUMENTS REVIEWED
IIILE
BEVISION
D81E
Omaha Public Power (OPPD) District Quality
Assurance Manual
4
11-09-83
OPPD Safety Audit Review Committee (SARC) Audits
Audit 84-13, Ser. 84-DA-144, Teledyne Isotopes Inc.
08-24-84
Audit 3-85, SARC, Site Emergency Plan and Procedures
07-18-85
Draft Audit Checklist -for RETS 1986, Audit #55
Audit #55, Ser. 94-DA-188, Environmental Program
10-04-84
SARC Internal Audit Schedule (1994 - 1985)
OPPD Nuclear Production Technical Services Section Procedures (N-TSAP)
N-TSAP-1, Preparation and Approval of
Technical Services Administrative
Procedures
O
O2-85
N-TSAP-8, Analysis Verification
1
05-85
N-TSAP 10, Preparation and Approval of
Technical Services Operating, Test, and
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Special Procedures
O
O2-85
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N-TSAP-11, Technical Services Quality Related
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Training Program
1
05-85
N-TSAP-12, Identification, Handiing, and
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Storage of Quality Assurance Records
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01-86
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Radiolooical b Environmental Monitorino Services Unit Procedures
Environmental Radiological Monitoring
Procedure Manual
2
12-05
Fort Calhoun Station Emergency Radiological
Monitor Booklet (EP-82-3)
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08-82
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BEVISION
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FCS Operatino Procedure Manual
Volume A.
Standino Orders
T-2,
Waste Liquids Release
21
11-09-84
T-3,
Waste Gas Release
20
11-09-84
T-15, Waste Lagoon Release
2
10-04-83
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FCS Calibration Procedures
CP-6272, 110 Meter Wind Direction
9
11-12-85
CP-6273, 45 Meter Wind Direction
8
11-12-85
CP-6274, Primary 10 Meter Wind Direction
5
11-12-85
CP-6275, Secondary 10 Meter Wind Direction
8
11-11-85
CP-6276. 110 Meter Wind Speed
7
11-12-85
CP-6277, 45 Meter Wind Speed
7
11-12-85
CP-6278, Primary 10 Meter Wind Speed
7
11-12-85
Secondary 10 Meter Wind Speed
6
11-12-85
CP-6280, 110-1 Meter Delta Temperature
6
11-11-85
CP-6281, 110-2 Meter Delta Temperature
6
11-11-85
CP-6282, 110-3 Meter Delta Temperature
4
11-11-85
CP-6283, 10-1 Meter Amb i er.t Temperature
4
11-12-85
CP-6284, 10-2 Meter Ambient Temperature
4
11-11-85
CP-6285, 10-3 Meter Ambient Temperature
3
11-12-85
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FCS Survei11ance Procedure.
ST-ERM-1. Environmental Radiological
Monitoring (Sectons F.1 - F.5)
27
01-30-86
Environmental Monitors
17
10-16-85
FCS Chemintry Manual Procedures (CMP)
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CMP-2.0, Sampling Collection
2
01-30-85
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CMP-2.3, Composite Sampling
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10-02-85
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CMP-4.3, Waste Lagoon Release Permit
2
12-6-84
CMP-4.4, Waste Liquid Release Permit
4
10-02-85
CMP-4.5, Containment Purge / Vent Release Permit
5
09-30-85
CMP-4.6, Waste Gas Release Permit
5
10-02-85
CMP-6, Offsite Dnse Calculation Manual
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10-02-85
Other Documents
Nuclear Production Technical Services
Organization Chart
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01-86
Monthl y Progress Report to OPPD f rom
Teledyne Isotopes (January - December 1985)
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O2-04-86
Monthly Progress Report to OPPD from
Teledyne 1sotopes (January 1986)
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O2-28-86
Fort Calhoun Station Semi-Annual Effluent
Release and Environmental Monitoring Reports:
January - June 1981
July - December 1981
January - June 1982
January - June 1983
January - June 1984
July - December 1984
January - Jure 1985
July - December 1985
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