ML20235T603

Insp Repts 50-285/87-21 on 870914-18.Violations Noted.Major Areas Inspected:Radiological Environ Monitoring & External Occupational Exposure Control Programs & Allegation

ML20235T603
Person / Time
Site:	Fort Calhoun
Issue date:	10/06/1987
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235T600	List: ML20235T598 ML20235T603
References
50-285-87-21, NUDOCS 8710130145
Download: ML20235T603 (6)

See also: IR 05000285/1987021

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/87-21 License: DPR-40

Docket: 50-285

Licensee: Omaha Public Power District (0 PPD)

1673 Harney Street

Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station (FCS)

Inspection At: FCS Site, Blair, Nebraska

Inspection Conducted: September 14-18, 1987

Inspector: /2#

R. E. Baer, Radiation Specialist, Facilities

1. Date/67

Radiological Protection Section

Approved: ( % h/hN){dbf

B. i4u'rray, Chief , ~Fa' cili es Radiological

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Prctection Section

Inspection Summary

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Inspection Conducted September 14-18, 1987-(Report 50-285/87-21)

Areas Inspected: Routine, unannounced inspection of the radiological

environmental monitoring and external occupational exposure control programs.

An allegation was also reviewed.

Results: Within the areas inspected, two apparent violations (failure to

control a very high radiation area door and failure to follow radiation .

protection procedures) were identified. (see paragraph 6)

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DETAILS

1. Persons Contacted

• W. G. Gates, Manager, Fort Calhoun Station

• K. L. Belek, Supervisor, Environmental Services

J. N. Borger, Equipment Operator Nuclear Auxiliary

M. E. Burns, Foreman, Electrical Maintenance

R. A. Cords, Senior Technician, Chemistry and Radiation Protection (C/RP)

A. A. Costanzo, Analyst, Environmental Services

C. R. Crawford, ALARA' Coordinator

• J. J. Fisicaro, Supervisor, Nuclear Regulatory and Industrial

Affairs (NR&IA)

J. J. Foley, Supervisor, Electrical Maintenance and Instrument and

Controls  !

• J. K. Gasper, Manager, Administrative Services

G. R. Kopecky, Inspector, Quality Assurance

• L. T. Kusek, Supervisor, Operations.

J. M. Mattice, Plant Health Physicist

J. Mixan, Technician, Instrument and Controls l

• D. J. Munderloh, Senior Engineer, NR&IA

C. W. Norris, Supervisor, Radiological Services

• A. W. Richards, Manager, Quality Assurance

• G. L. Roach, Supervisor C/RP

B. A. Schmidt, Chemist

F. K. Smith, Plant Chemist

• R. K. Stultz, Supervisor, Radiological and Environmental Monitoring

Services

M. A. Wilson, Analyst, Environmental Services

NRC

• P. H. Harrell, Senior Resident Inspector I

The NRC inspector also interviewed other licensee and contractor employees

, including C/RP, operations, administrative, maintenance, and training

l personnel.

• Denotes those individuals present during the exit interview on

September 18, 1987. j

2. Licensee Action on Previously Identified Inspection Findings )

(Closed) Open Item (285/8504-02): Audits and Reviews - This item was

previously discussed in NRC Inspection Report 50-285/85-04 and involved: '

(1) the lack of audits of the meteorological monitoring program and the

offsite vendor responsible for analysis of environmental samples, and

(2) the limited scope of the Safety Audit and Review Committee (SARC)-

audit for the environmental program. .The NRC inspector determined that

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SARC Audit Report 3-86 of the Radiological Effluent Program adequately

resolved the concerns noted above. This item is considered closed.

3. Open Items Identified During This Inspection

An open item is a matter that requires further review and ev'aluation by

the NRC inspector. Open items are used to document, track, and ensure

adequate followup on matters of concern to the NRC inspector. The

following items were identified.

Open Item (285/8721-03): Audit of Vendor Activities - This item involves

the lack of an audit of the vendor selected to perform radiological

analyses of. samples of liquid effluents and waste stream characterization

determinations.

4. Inspector Observations

The following are observations the NRC inspector discussed with the

licensee during the exit interview on September 18, 1987. These

observations are not violations, . deviations, unresolved items, or open

items. These observations were identified for licensee consideration'for

program improvement, but the observations have no specific regulatory

requirement. The licensee stated that the observations would be reviewed.

a. - Spiked Samples - The licensee does not use spiked samples to evaluate

the performance'of the vendor conducting radiological analyses on

environmental samples.

b. Sampling of Sewage Waste Lagoons - The licensee had not established a

sampling program that includes radiological analyses to. ensure that

when sludge is removed from the sewage waste lagoons the sludge does

not contain radioactive materials.

5. Program Areas Inspected

The following program areas were inspected. These program areas and

l inspection procedures are identified in NRC Manual Chapter 2500. Unless

l otherwise noted, the inspection was completed and revealed no violations,

deviations, unresolved items, or open items. Notations after a specific

inspection item are used to identify the following: I = item not

inspected or only partially inspected, V = violation, D = deviation, I

U = unresolved item, and 0 = open item. I

Procedure Inspection Requirements  ;

80521 Radiological Environmental Monitoring

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02.01 - Implementation of the Radiological

Environmental Monitoring Programs

02.02 - Implementation of.the Meteorological

Monitoring Program

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02.03 - Facilities, Equipment, and Supplies

02.04 - Documentation

02.05 - QA Program - 0 (see paragraph 3)

02.06 - Contractor Activities

80721 Radiological Environmental Monitoring

02.01 - Audits and Appraisals

02.02.- Changes

02.03 - Implementation of the Radiological

-Environmental Monitoring Program

02.04 - Implementation of the Meteorological

Monitoring Program

02.05 - QA Program

02.06 - Contractor Activities

83524 External Occupational Exposure Control and

Personal Dosimetry

02.01 - Physical Controls

02.02 - Administrative Controls - V (see paragraph 6)

02.03 - Personal Dosimetry

6. Apparent Violation (Procedure 83524, Item 02.02)

Failure to Control Very High Radiation Areas

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a.

Technical Specification (TS) 5.11.1, requires that entrance into each

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high radiation area in which the intensity of radiation is greater

than 1000 mrem /hr (very high radiation area) shall be controlled by <

the use of locked doors to prevent unauthorized entry. )

)

During a plant inspection at approximately 10:30 a.m. on September 9, j

1987, the NRC Resident Inspector found the door to the spent fuel I

storage pool heat exchanger, pump, and filter room (Room No. 5)

unlocked. Room No. 5 was posted outside the door as a very high

radiation area. At the time of discovery, no personnel were in

Room No. 5.

The NRC inspector review of this occurrence determined that the

operations auxiliary building equipment operator had entered

Room No. 5 at approximately 8:00 a.m. on September 9, 1987, to take a

reading on spent fuel pool instrumentation. The equipment operator

stated that when he exited Room No. 5, he believed he locked the

door. However, he did not verify the door was indeed locked.

The NRC inspector also reviewed the radiation surveys performed by ,

the licensee in Room No. 5 on September 7, and 16, 1987. These '

surveys indicated the highest direct radiation levels were approximately

15,000 mrem /hr.at contact with spent resin piping and general levels

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of about 4000 mrem /hr were present within the room. .The failure

to control a very high radiation area door is considered an

apparent violation of TS 5.11~.2. (285/8721-01)

This is a repeat violation regarding the failure to control very high

radiation areas as previously identified in NRC. Inspection

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Report 50-285/86-01.

b. Failure to Follow HP Procedures

Technical Specification 5.11, Radiation Protection Program, requires

that procedures for personnel radiation protection shall be prepared

consistent with the requirements of 10 CFR Part 20 and adhered to.

The FCS Radiation Protection Manual states in Section 3.1.7.2.b. that.

an individual may enter a very high radiation area pr.ovided that

continuous health physics coverage is afforded by a technician

equipped with a radiation dose rate instrument.

The NRC inspector determined that on September 9, 1987, an equipment

operator entered into Room No. 5 through a locked door to an area

designated as a very high radiation area without obtaining continuous-

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health physics coverage by a technician equipped with a radiation

dose rate instrument. Room No. 5 contains the spent fuel storage

pool heat exchanger, pump, and filters. Radiation surveys indicated

that radiation levels of 15,000 mrem /hr were present in the room on

September 9, 1987. -

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The failure to follow radiation protection procedures is an apparent

violation of TS 5.11. (285/8721-02)

7. Allegation Followup

Allegation (4-87-A-076)

This allegation relates to individuals exposure during maintenance

activities. Specifically, the allegation stated that only two of the six '

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electrical maintenance persons assigned to the FCS Electrical Maintenance

Department are qualified to add oil to reactor coolant pumps and the other

four persons should be trained and qualified. This would distribute the

radiation exposure among all workers. Also, the ALARA coordinator and

Supervisor C/RP refused to allow an unqualified individual to enter the

containment building during power operations for training purposes.

Discussion

The NRC inspector discussed the alleged circumstance with licensee

representatives and reviewed related records such as radiation work

, permits, ALARA work packages for containment entry at power, and personnel

radiation exposure records.

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The licensee representatives stated that four of the electrical.

maintenance persons, not two, are qualified to perform work such as adding

oil to reactor coolant pumps and that the remaining two individuals are

new hires and are scheduled to be qualified in this work during the next

maintenance / refueling outage. The licensee also stated that prior to

assigning an individual to perform this work, a current copy of the

radiation exposure record is obtained from the C/RP group and those

individuals with the' lowest exposures are assigned these tasks. The

September 14, 1987, Personnel Accumulative mrem Radiation Exposure Record'

indicated that the four qualified individuals had exposures of.1043 mrem,

785 mrem, 744 mrem, and 134 mrem.

The ALARA coordinator could not recall a conversation relating to.not

allowing an individual to enter the reactor containment (accompanying a

work crew) for training purposes. The Supervisor C/RP did remember such a

conversation and acknowledged that entry into the reactor containment

during power operations for training purposes would be discouraged and

would only be allowed in a last resort type situation.

Conclusion

The allegation was partially substantiated in that all persons are not

qualified to perform maintenance activities on reactor coolant pumps and

that entry into the reactor containment during power operations for

training was discouraged. No violations or deviations were identified.

8. Exit Interview

The NRC inspector met with the licensee's representatives identified in

paragraph 1 of this report at the conclusions of the inspection on

September 18, 1987. The NRC inspector summarized the scope and results of

the inspection.

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