ML20206F601
| ML20206F601 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/27/1986 |
| From: | Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206F573 | List: |
| References | |
| 50-285-86-08, 50-285-86-8, NUDOCS 8606240534 | |
| Download: ML20206F601 (10) | |
See also: IR 05000285/1986008
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-285/86-08
License:
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Docket:
50-285
Licensee:
Omaha Public Power District (OPPD)
1623 Harney Street
Omaha, Nebraska 68102
Facility Name:
Fort Calhoun Station (FCS)
Inspection At:
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Inspection Conducted:
April 7-10, 1986
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Inspector:
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R. F/ Baer, Radiation Specialist, Facilities
Ddte
Radiological Protection Section
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Approved:
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7/87/8(E
B'Murray, Chief, Faci /itiesRadiological
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Protection Section
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Inspection Summary
Inspection Conducted April 7-10, 1986 (Report 50-285/86-08)
Areas Inspected:
Routine, unannounced inspection of the licensce's radiation
protection program including:
external occupational exposure control and
personal dosimetry; internal exposure control and assessment; control of
radioactive materials and contamination, surveys and monitoring; and facilities
and equipment.
Results: Within the areas inspected, three violations were identified (see
paragraph 6).
No deviations were identified.
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8606240534 860613
ADOCK 05000285
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DETAILS
1.
Persons Contacted
- W. G. Gates, Manager, FCS
L. Cherko, Emergency Plan Technician
M. R. Core, Supervisor, Maintenance
C. R. Crawford, ALARA Coordinator
M. L. Ellis, Instrument and Control (I&C) Coordinator
- J. J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs
- J. J. Foley, Supervisor, I&C/ Electrical Maintenance
- F. F. Franco, Manager, Radiological Health and Emergency Planning
S. W. Gebers, Acting Chemistry and Radiation Protection (C/RP) Crew Chief
J. M. Hale, C/RP Specialist
M. K. Hawes, Dosimetry Specialist
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T. W. Jamieson, C/RP Technician
- J. M. Matti<e, Plant Health Physicist
- A. W. Richards, Manager, Quality Assurance
- G. L. Roach, Supervisor, C/RP
F. K. Smith, Plant Chemist
- R. K. Stultz, Supervisor, Radiological and Environmental
T. Thompson, Acting C/RP Crew Chief
L. P. Walling, Supervisor, Administrative Services
Others
G. O. Maloy, Contractor Training Instructor
- P. H. Harrell, NRC Senior Resident Inspector
The NRC inspector also interviewed several other licensee and contractor
employees including C/RP, administrative, maintenance, and contractor
personnel.
- Denotes those individuals present during the exit interview on April 10,
1986.
2.
Inspector Observations
The following are observations the NRC inspector discussed with the
licensee during the exit interview on April 10, 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 considered.
a.
Thermoluminescent Dosimetry (TLD) Program - The corporate TLD program
is audited on a 3 year frequency.
See paragraph 3 for details.
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b.
Instrument Calibration Frequency - The licensee has specified a
calibration frequency of 5 years for a condenser R-meter.
See
paragraph 3 for details,
c.
Radiological and Environmental Monitoring Services Procedures - The
licensee's procedures issued by the radiological and environmental
monitoring services section do not receive the review and approval
that would routinely be afforded to station procedures.
See
paragraph 3 for details,
d.
Radiation Survey Documentation - The licensee had not documented all
beta radiation survey data.
See paragraph 5 for details.
e.
Airborne Radiation Monitors - The licensee had an excessive quantity
of constant airborne radioactivity monitors either out-o' service or
in the alarm mode.
See paragraph 4 for details,
f.
Instrument Repair - The licensee had a large quantity of radiation
protection survey meters out-of-service.
See paragraph 5 for
details,
g.
Instrument Availability - An adequate inventory of operational
radiation survey instrumentation was not available to support daily
work evaluations.
See paragraph 5 for details.
3.
External Occupational Exposure Control & Personal Dosimetry
The NRC inspector reviewed the licensee's external exposure control and
personal dosimetry program for compliance with the requirements of 10 CFR Parts 20.101(a), 20.101(b), 20.102, 20.104(a), 20.202(a) and 20.401(a),
and the recommendations of Regulatory Guides (RGs) 8.2, 8.3, 8.4, 8.7,
8.14, and 8.28.
The NRC inspector reviewed the Nuclear Production Technical Services
Department operating procedures located at the corporate offico relating
to TLDs listed in Attachment 1.
The licensee had received certification
for their TLD program from the National Voluntary Laboratory Accreditation
Program (NVLAP) in the following categories:
II accident-high energy
photons, IV high energy photons, V beta particles, VII photons plus beta
particles, and VIII photons plus neutrons.
The licensee had not attempted
certification for the three remaining categories.
The NRC inspector noted
that the internal audit frequency for the Radiological and Environmental
Services Section located at the corporate office was based on a 3 year
frequency.
However, the recommended audit frequency in RG 1.33 and NVLAP
documents for this quality-related activity is normally annual or biennial
as a maximum.
The NRC inspector discussed with licensee representatives the 5 year
calibration frequency specified for the condenser R-meter in corporate
procedure N-TS0P-3.
The incostry standard ANSI N323-1978 recommends an
annual calibration as the maximum and more frequent depending on instrument
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usage. The licensee stated that they had also obtained a condenser
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R-meter from FCS and used both instruments when determining the source
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strength and radiation levels of the Cesium-137 TLD calibration source.
The FCS instrument had been calbrated annually.
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The NRC inspector also discussed the review and approval of written
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procedures.
The licensee's review for TLD-related procedures is presently
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limited to the supervisor radiological and environmental monitoring
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services and approval by the section manager, technical services.
The NRC
inspector noted that the TLD-related procedures are not subjected to the
same level of review and approval that is provided to station operating
procedures.
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The licensee's external occupational exposure history for the previous
5 years compared to the average exposure for all pressurized water
reactors is depicted in Table 1.
The licensee has consistently maintained
an exposure history at or below the industry average.
No violations or deviations were identified.
4.
Internal Exposure Control and Assessment
The NRC inspector reviewed the licensee's internal exposure control and
assignment program to determine compliance with 10 CFR Part 20.103 and the
recommendations of RGs 8.7, 8.8, 8.9, 8.15, and 8.26.
The NRC inspector reviewed FCS C/RP procedures listed in Attachment 2,
representative records for the airborne radioactivity sampling program,
whole body counter operational checks, and interviewed personnel to
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determine the effectiveness of the program.
The NRC inspector determined
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that the licensee's respiratory protection program including the
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associated maintenance, cleaning, and supporting air sampling program
appeared adequate and met the requirements of 10 CFR Part 20.103.
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The NRC inspector expressed concern to licensee representatives relating
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to the operation of the constant air samplers located in the auxiliary
building.
These units monitor the concentration of airborne particulates,
iodine, and noble gases (PING).
The licensee had four PING units of which
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two were found in the alarm mode (flashing light) for particulate
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concentrations and two were out-of-service.
These units had been placed
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in service in September of 1985 and had been constantly in the alarm mode.
The licensee stated that the alarm set point had been determined based on
the instrument background plus the allowed concentration.
The units use a
fixed filter and as the natural radon daughter products buildup on the
filter the units alarm.
The licensee had not established an alarm point
which accounted for this buildup unti1 equilibrium conditions existed.
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The NRC inspector stated that both C/RP personnel and station personnel
would become complaisant to the constant alarm and should the airborne
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concentration exceed regulatory requirements the licensee would not be
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aware of this condition for a prolonged length of time.
The licensee
stated that the alarm set point would be recalculated based on a 45 minute
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equilibrium period, set points re-established and all personnel advised
that the PINGS were operational and to take appropriate action should the
units alarm in the future.
The NRC inspector noted that these PING
monitors are used for trend analysis only, the official airborne
concentration determination is performed by analysis of routine grab air
samples taken in the general area of the PING.
The licensee had two PINGS
operational on April 10, 1986, and the remaining two units to be returned
to service as soon as replacement parts were available.
The NRC inspector reviewed the emergency equipment inventories performed
monthly and documented on form ST-RM-3 for the period of July 1985 through
March 1986.
The NRC inspector also inventoried the equipment located in
the operational support center.
The NRC inspector determined that all
equipment listed on the checklist was present and within calibration
requirements.
The NRC inspector discussed with licensee representatives the status of
the new fast scan whole body counting system and reviewed the latest
calibration data.
The NRC inspector noted that the licensee had not
participated in any independent laboratory intercomparison programs for
whole body counting.
The licensee stated they had performed comparison
studies with the manufacture.
No violations or deviations were identified.
5.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring
The NRC inspector reviewed the implementation of the licensee's program
for control of radioactive materials and contamination, surveys, and
monitoring for compliance with Technical Specifications (TSs) 5.11.1 and
5.11.2 and 10 CFR Parts 20.105, 20.201, 20.203, and 20.401.
The NRC inspector reviewed selected radiation work permits, radiation and
contamination surveys, and radiological incident reports for the period
April 1, 1985 through April 8, 1986.
The NRC inspector discussed with
licensee representatives that the radiation and contamination survey
results did not always indicate that beta radiation surveys were being
routinely performed.
The licensee stated that zero readings which
indicated no detectable beta radiation were not always documented.
The NRC
inspector stated that a zero reading should be recorded the same as a
positive reading.
The licensee acknowledged the need to document all
survey results.
The NRC inspector verified by independent surveys that the radiation
levels documented on licensee radiation survey records were accurate.
The NRC inspector questioned the availability of portable radiation survey
instrumentation for C/RP personnel to perform routine and reactive
radiation surveys.
The licensee had two R0-2A ionization survey meters
and two teletector high range survey meters that were routinely response
checked daily and three additional R0-2As and one R0-7 that were in the
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C/RP equipment locker.
The NRC inspector discussed with licensee
representatives that a large amount of equipment was out-of-service and
unaccounted for.
The NRC inspector expressed concern that with the
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limited amount of equipment available and that C/RP technicians may use
instruments from the equipment locker or conceal an instrument in the
plant to support surveys or jobs under his direction and circumvent the
daily response check.
The licensee was not concerned about the limited
number of instruments available and stated that the C/RP would not use an
instrument without response testing as required.
The licensee reviewed
the out-of-service and unaccounted for instruments and initiated a program
to return additional instruments to service.
No violations or deviations were identified.
6.
Facilities and Equipment
The NRC inspector reviewed the licensee's facilities and equipment for
routine and emergency operations including equipment for compliance with
the Final Safety Analysis Report and Radiological Emergency Response Plan.
The NRC inspector noted that the licensee had upgraded their personnel
monitoring program for personnel exiting the radiologically controlled
area with the purchase of four personnel contamination monitors (PCM).
These PCMs are effective and assure consistent detection of radioactive
material below the level detectable by frisking.
Technical Specification 5.8.1 requires that " written procedures and
administrative policies shall be established, implemented and maintained
that meet or exceed the minimum requirements of Section 5.1 and 5.3 of
ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 . . . ."
This requirement is emphasized in the FCS operating manual.
Standing
Order G-1 which states:
" Strict adherence to the provisions of the
standing orders is mandatory for all personnel."
The NRC inspector reviewed the calibration records for the PING radiation
monitor unit number 214 which had been identified as unresolved
item (285/8525-01).
The licensee had not located the calibration data for
the August 15, 1985, calibration.
The NRC inspector' stated that the
failure to retain these data is an apparent violation of TS 5.8.1 and FCS
Standing Order C-2 " Fort Calhoun Station Quality Assurance (QA) Records"
which requires a 5 year record retention period (285/8608-01).
Technical Specification 2.21 requires that:
" Post-accident
instrumentation shall be operable as provided in Table 2-10.
If the
required instrumentation is not operable, then the appropriate action
specified in Table 2-10 shall be taken." Table 2-10 requires with the
vide range noble gas stack monitor RM-063M or RM-063H not operable the
licensee shall:
" Initiate the preplanned alternate method of monitoring
the appropriate parameter (s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and (1) either restore the
inoperable channel (s) to operable status within 7 days of the event, or
(2) prepare and submit a special report to the Commission pursuant to
Specification 5.9.3 within 14 days following the event outlining the
action taken, the cause of the inoperability, and the plans and schedules
for restoring the system to operable status."
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The NRC inspector had previously (see NRC Inspection Report 50-285/85-25)
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discussed with licensee representatives the status of the wide range noble
gas stack monitor RE-063L, M and H.
The midrange and high range channels
had not been calibrated.
The licensee had stated in letter LIC-84-301
dated September 5, 1984, that these monitors were expected to be
operational by September 14, 1984.
The NRC inspector determined in
NRC Inspection Report 50-285/85-25 that these monitors had not been
returned to operational status in September 1984.
The licensee stated
during the exit interview on November 8, 1985, for NRC Inspection
Report 50-285/85-25 that a second letter had been submitted to the
Commission that extended the September 14, 1984, date for operation of
RE-063M and H.
However, the licensee in letter LIC-86-095, dated March 7,
1986, stated that OPPD had subsequently determined that the second letter
had not been sent to the Commission.
The NRC inspector stated that failure
to provide a special report to the Commission covering the period beyond
September 14, 1984, constitutes an apparent violation of TS 2.21 (285/8608-02).
Technical Specification 5.8.1 requires that " written procedures and
administrative policies shall be established, implemented and maintained
that meet or exceed the minimum requirements of Section 5.1 and 5.3 of
ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 . . . ."
RG 1.33, Appendix A, Item 8.b.(1),(aa) addresses specific procedures for
surveillance tests, inspections, and calibrations should be written for
area, portable, and airborne radiation monitors.
The NRC inspector reviewed maintenance and calibration records for selected
portable radiation survey instruments.
The licensee does not maintain a
maintenance history for portable survey instruments and consequently could
not assure that portable radiation survey equipment had been properly
calibrated after any maintenance which could effect previous calibrations.
The licensee had not developed or implemented calibration procedures for
the Bicron RS0-5 and Bicron Tech 50 portable radiation monitors.
The
licensee stated that they were returning these instruments to the
manufacturer for calibration.
The NRC inspector discussed with licensee
representatives the status of these portable radiation monitors and the
fact that the manufacturer was not on the qualified vendor list, no copy of
the manufacture calibration procedure was available for review, no
maintenance records could be documented, and station procedures had not
been developed for the operation and calibration of these instruments.
This was considered an apparent violation of TS 5.8.1 (285/8608-03).
7.
Exit Interview
The NRC inspector met with the FCS NRC senior resident inspector and
licensee representatives denoted in paragraph 1 at the conclusion of the
inspection on April 10, 1986.
The NRC inspector summarized the scope and
findings of the inspection including the observations noted in paragraph 2
of this report.
The licensee indicated that the NRC inspector observations
would be reviewed.
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TABLE 1
PERSONNEL RADIATION EXPOSURE
Year
1981
1982
1983
1984
1985
FCS Man-Rem
458
217
433
566
374
PWR (Avg.) Man-Rem 652
578
592
552
Not Available
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ATTACHMENT 1
TECHNICAL SERVICES OPERATING PROCEDURES
N-TSOP-3
Calibration of the Cesium-137 Source, Revision 2, July 1985
N-TSOP-4
Calibration of the Harshaw Model 2271 TLD Reader,
Revision 0, November 1984
N-TSOP-9
Annealing TLD Cards, Revision 1, June 24, 1985
N-TS0P-10
Source Procedures for Irradiating TLDs, Revision 2,
June 24, 1985
N-TSOP-12
Quality Control / Test Badges, Revision 1, November 1, 1984
N-TSOP-13
Resensitizing TLD Cards, Revision 1, July 3, 1985
N-TSOP-14
Dose Calculation for TLD Specials, Revision 1, June 24, 1985
N-TSOP-15
Reading TLD Cards, Revision 2, July 10, 1985
N-TSOP 16
Monthly Exposure Report, Revision 1, July 10, 1985
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ATTACHMENT 2
RADIATION PROTECTION PROCEDURES
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RPP-6
Protective Clothing and Respiratory Equipment Cleaning,
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Revision 11, July 30, 1985
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RPP-18
Instrument Selection, Revision 5, July 23, 1985
RPP-19
Gamma Source Exposure Rate Verification, Revision 5, May 13, 1985
RPP-20
Radiation Work Permits (RWP), Revision 4, August 29, 1985
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HP-1
Fast Scan Whole Body Counting, Revision 6, June 19, 1985
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HP-1A
Whole Body Count Evaluation, Revision 0, August 27, 1985
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HP-2
Respiratory Fit Test Quantitative Polydispersed Aerosol Test,
Revision 5, November 13, 1985
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HP-5
Collection and Analysis of Air Samples, Revision 6, September 19,
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1985
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HP-9
Contamination Control, Revision 2, July 2, 1985
HP-11
Whole Body Frisking, Revision 1, September 27, 1985
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HP-14
Counting Instrument Operation, Revision 4, October 31, 1985
HP-15
Portable Dose Instrument Operation, Revision 6, August 13, 1985
HP-17
Control of Personal Radiation Detection / Monitoring Devices,
Revision 1, November 18, 1985
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