ML20141C942: Difference between revisions
StriderTol (talk | contribs) (StriderTol Bot insert) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
Line 1: | Line 1: | ||
{{Adams | |||
| number = ML20141C942 | |||
| issue date = 03/18/1986 | |||
| title = Insp Rept 50-285/86-01 on 860106-10.Violation Noted:Valve W/ Radioactive Contamination Above DOT Limits Shipped as Nonradioactive Matl on 851009 & Termination Repts Not Processed within Required Time Period | |||
| author name = Chaney H, Murray B | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000285 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-285-86-01, 50-285-86-1, GL-81-38, GL-81-389, GL-85-14, IEB-79-19, IEIN-83-10, IEIN-84-14, IEIN-84-50, IEIN-85-092, IEIN-85-92, NUDOCS 8604070351 | |||
| package number = ML20141C925 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 17 | |||
}} | |||
See also: [[see also::IR 05000285/1986001]] | |||
=Text= | |||
{{#Wiki_filter:_ | |||
, .- | |||
APPENDIX | |||
U. S. NUCLEAR REGULATORY COMMISSION | |||
REGION IV | |||
NRC Inspection Report: 50-285/86-01 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, Washington County, Nebraska | |||
Inspection Conducted: January 6-10, 1986 | |||
Inspector: b ' dlbb 7)'llL4tfd/ W8h6 | |||
Date | |||
H.~Chaney,Radl5 tion /pecialist, | |||
3 Facilities Radiological Protection | |||
Section | |||
Approved: / b E 7 N /Jffh/ /[[htb | |||
Oate' | |||
B. Murray, Chi ~et, Fadilities Radiological | |||
~ | |||
Protection Section | |||
Inspection Summary | |||
Inspection Conducted January 6-10, 1986 (Recort 50-285/86-01) | |||
Areas Inspected: Routine, unannounced inspection of the licensee's radiation | |||
protection program, low-level radioactive solid waste (LLRW) program, and | |||
transportation of radioactive materials (RAM). The inspection involved | |||
- | |||
46 inspector-hours onsite and 7 inspector-hours offsite by one NRC inspector. | |||
Results: Within the areas inspected, four apparent violations (see paragraphs | |||
8, 9 and 10) and no deviations were identified. | |||
8604070351 G60327 | |||
PDR ADOCK 05000285 | |||
G PDR | |||
_ _. __ | |||
, . | |||
2 | |||
i | |||
DETAILS | |||
j 1. Persons Contacted | |||
! OPPD | |||
i *R. L. An'drews, Division Manager-Nuclear Production | |||
*W. G. Gates, Manager, Fort Calhoun Station | |||
*R. L. Jaworski, Section Manager-Technical Services | |||
*F.' F. Franco, 'Section Manager-Radiological Health and Emergency | |||
Preparedness | |||
*C. J. Brunnert, Supervisor Operations Quality Assurance (QA) | |||
~ | |||
*K. Stultz, Technical Services | |||
, *G. L. Roach, Supervisor-Chemical and Radiation Protection (CRP) | |||
' | |||
*F. K. Smith, Plant Chemist | |||
*A. Bilau, Radioactive Waste Coordinator | |||
*J. M. Mattice, Plant Health Physicist | |||
B.' Wentworth, Quality Control (QC) Inspector | |||
* | |||
J. M. Hale, CRP Technician Coordinator ' | |||
D. A. Jacobson, CRP Training Instructor | |||
J. Carlson, Administrative Clerk | |||
R. A. Cords, CRP Technician . | |||
J. J. Fisicaro, Supervisor-Nuclear Regulatory and Industry | |||
Affairs | |||
- | |||
C. R. Crawford, ALARA Coordinator | |||
, | |||
J. E. Bentzinger, General Office QA | |||
j T. J. McIvor, Supervisor Technical Services | |||
t | |||
Others | |||
: D. Whitlock, Contract CRP Technician | |||
l - | |||
P. Harrell, NRC Resident Inspector ~ | |||
[ The NRC inspector also interviewed other licensee and contractor employees | |||
including CRP, administrative, maintenance, and QA/QC personnel. | |||
i " Denotes those individuals present during the exit interview on ' | |||
January 10, 1986. | |||
2. Licensee Action on Previously Identified Inspection Findings | |||
! . (Closed) Violation (285/8010-01): Failure to Survey - This item was | |||
previously discussed in NRC Inspection Report 50-285/80-10 and involved | |||
the failure to perform a monthly radiation survey in-room 15A of the | |||
reactor auxiliary building (RAB). Selected licensee survey records for | |||
- | |||
room 15A were reviewed and it was determined that the licensee had been | |||
surveying room 15A at an adequate frequency during 1985. This item is | |||
considered closed. | |||
: | |||
4 | |||
e | |||
s | |||
- | |||
.. . | |||
3 | |||
(Closed) Open Item (285/8226-15): NUREG-0737, Item II.F.1-1, High Range | |||
Noble Gas Effluent Monitor - This item had remained open pending licensee | |||
action to complete installation and testing of the instrumentation. | |||
Radiation Monitor (RM) 063 had been installed and appears to satisfy the | |||
requirements of NUREG-0737. This item is considered closed. | |||
(Closed) Open Item (285/8226-18): NUREG-0737, Item III.D.3.4, | |||
Modifications for Control Room Habitabi1ity - This item had remained open | |||
pending the licensee's completion of modifications to satisfy NUREG-0737 | |||
requirements. The licensee had completed installation of: (1) additional | |||
radiation shielding in the west side wall adjacent to the control room, | |||
(2) iodine monitor RM-65, and (3) toxic chemical monitors. All monitors | |||
are considered operational. This item is considered closed. | |||
(Closed) Violations (285/8303-01) & (285/8502-05): Radiation Hot Spot | |||
; | |||
Posting - The NRC inspector reviewed licensee corrective actions to | |||
resolve the failures to properly post radiation hot spots. The licensee | |||
i | |||
had: (1) provided for review of procedures by HP technicians, (2) revised | |||
' | |||
health physics procedures to eliminate conflicting requirements, and | |||
(3) more clearly state hot spot posting requirements. Inspections of the | |||
i licensee's facility did not identify any problems with hot spot posting. | |||
, | |||
This item is considered closed. | |||
, | |||
I (Closed) Violation (285/8331-01): Review of Radiation Work Permits - The | |||
NRC inspector reviewed 10 radiation work permits (RWP) and found all had | |||
; been properly reviewed per procedure RPP-20 which now requires a monthly | |||
; review for certain RWPs. This item is considered closed. | |||
(Closed) Violation (285/8502-01): Radiation Protection Instructions to | |||
Workers - The licensee had issued special instructions on selected | |||
training topics concerning radiological protection for badged personnel. | |||
- The licensee's training outlines and procedures were revised also to | |||
ensure all personnel entering the protected area (i.e., restricted area) | |||
received the training required by 10 CFR Part 19.12. This item is | |||
! considered closed. | |||
I (Closed) Violation (285/8502-02): NRC Form 4 - The licensee had taken | |||
; | |||
corrective action to have all NRC Form 4s tilled out in their entirety. | |||
A review of radiation exposure records did not identify any NRC Forms not | |||
properly filled out. This item is considered closed. | |||
. . (Closed) Violation (285/8502-03): NRC Form 5 - The licensee had taken | |||
corrective action to use a form that was equivalent to the NRC Form 5 to | |||
track quarterly exposures of workers. This item is considered closed. | |||
3. Inspector Observations | |||
j | |||
The following are observations the NRC inspector discussed with the licensee | |||
; during the exit interview on January 10, 1985. These observations are | |||
! | |||
t | |||
i | |||
o . | |||
4 | |||
neither violations nor unresolved items. These items were recommended for | |||
licensee consideration for program improvement, but they have no specific | |||
regulatory requirement. The licensee did not provide any specific comment | |||
for these items, | |||
a. Supervisor Review of Work Areas - The NRC inspector noted during | |||
interviews witI workers that a general theme was expressed concerning | |||
the lack of C' supervisor tours of job site and ongoing work and | |||
conditions within the controlled areas, i.e., RAB and containment | |||
during outages. See paragraph 4. | |||
b. Release Limits for Potentially Radioactive Material - The NRC inspector | |||
noted that the licensee's orocedures could allow for the release of | |||
materials to unrestricted areas with radioactive contamination levels | |||
above those referenced in recent NRC Information Notices. See | |||
paragraph 10. | |||
c. Coordination and Documentation of Training - There appears to be a | |||
lack of general knowledge in the CRP group in regards to who is | |||
responsible for the development of training, conduct of training, and | |||
of ensuring that training records.are properly documented. See | |||
paragraph 5. | |||
4. Radwaste/ Transportation Program Organization and Management Controls | |||
The NRC inspectors examined the licensee's organization and staffing to | |||
determine compliance with the Updated Safety Analysis Report (USAR) - | |||
Sections 11 and 12; NRC Inspection and Enforcement (IE) Bulletin 79-19; | |||
10 CFR Parts 20, 50, and 71; Facility Operating License Technical | |||
Specifications (TS) 2.9.2, 5.2.2, 5.8, 5.9.4, and 5.10.1; and the | |||
recommendations of NRC Regulatory Guides (RG) 1.33, and 1.8, and NRC IE | |||
. Information Notices 83-10 and 84-50. | |||
The NRC inspector reviewed the staffing of the CRP group Radioactive Waste | |||
Coordinator (RW/C) position, compared staf fing to TS requirements and the | |||
work load involving solid RW management and transportation activities. | |||
The NRC inspector determined that the RW section was responsible for | |||
oversight of contractor solidification services, compaction of dry active | |||
waste (DAW), preparation of RAM and waste for shipment, and general RP | |||
duties associated with RW operations. | |||
, | |||
The NRC inspector reviewed the licensee's operating procedures for RW | |||
activities. The NRC inspector noted that the licensee had prepared a | |||
waste stream characterization and analysis program for compliance with | |||
~ | |||
10 CFR Part 61 requirements. The NRC inspector reviewed the procedures | |||
used by a contracted LLRW solidification service vendor and the licensee's | |||
controls over changes to those documents. The licensee's burial site | |||
contracts, DOT /NRC regulations, and package user manuals were found to be | |||
up to date. | |||
. . | |||
5 | |||
The NRC inspector reviewed QA audits and surveillances of RP, RW, and | |||
transportation ac ivities, and determined that they were carried out in | |||
accordance with Q manual requirements. The deficiencies noted in license | |||
QA audits were re olved in an effective and timely manner. The licensee's | |||
QC program for tr nsportation activities was reviewed and found to be | |||
comprehensive and well documented. | |||
During interviews with various RP and other FCS employees, it was determined | |||
that there appears to be a concern on the part of some employees that CRP | |||
group supervisory personnel were not aware of activities and employee | |||
conduct within radiologically controlled areas, and that CRP supervision | |||
did not appear to be conducting tours of radiological work areas within | |||
the RAB and reactor containment. A review of 1985 CRP supervision exposure | |||
records and access key card reader entries for accesses leading into the | |||
RAB confirmed-that only a few entries had been made via the routine RAB | |||
access door, and when added to the very little exposure being acquired by | |||
key supervisory personnel is indicative of infrequent tours of radiological | |||
work areas. This concern was brought to the attention of the licensee | |||
during the exit meeting and a subsequent telephone conversation between | |||
the NRC inspector and plant manager on February 3,1986. | |||
No violations or deviations were identified. | |||
5. Radwaste/ Transportation Organization Staff Qualifications and Training | |||
The NRC inspector examined personnel qualifications to determine compliance | |||
with NRC IE Bulletin 79-19, USAR Section 12, 10 CFR Parts 19.12 and | |||
71.105(d), and TS 5.3, 5.4, and 5.10.2; and the recommendations of RGs 1.8, | |||
8.2, 8.8, 8.27, and NUREG-0761. | |||
The NRC inspector reviewed position descriptions, training records, | |||
training outlines, special training announcements, training attendance | |||
, | |||
rosters, and discussed the qualifications and training activities of | |||
personnel performing LLRW processing and transportation activities with | |||
licensee representatives and contracted personnel. | |||
The NRC inspector determined that CRP personnel associated with LLRW | |||
activities had received periodic training by offsite vendors; however, the | |||
records of such training were found to be fragmented and difficult to | |||
retrieve. Tentatively scheduled offsite LLRW management and DOT /NRC | |||
transportation training for RW workers was also reviewed. During discus- | |||
sions with licensee personnel in the training and CRP groups, it was | |||
determined that scheduling of specialized RW training and conduct of | |||
' | |||
training was not being provided sufficient attention. The NRC inspector | |||
identified to licensee representatives at the exit meeting that RW training | |||
of CRP personnel needs additional attention to ensure that annual training | |||
commitments (licensee response to NRC IE Bulletin 79-19) are not compromised. | |||
No violations or deviations were identified. | |||
-. -. | |||
o . | |||
' | |||
6 | |||
6. Low-level Radioactive Waste Management Program | |||
The NRC inspector reviewed the licensee's program for the control, | |||
classification, characterization, and shipment of LLRW to determine | |||
compliance with the commitments contained in Section 11.1.4 of the USAR; | |||
and the requirements contained in 10 CFR Parts 20.301, 20.311, 61.55, and | |||
61.56; and TS 5.9.4; and the recommendations of NRC branch technical | |||
position (BTP) papers on LLRW classification and waste form. | |||
The NRC inspector reviewed the licensee LLRW process control program, | |||
implementing procedures, LLRW processing areas, documents on processed | |||
LLRW, and QA/QC aspects of processing LLRW. The licensee had elected not | |||
to use or make operational the permanently installed LLRW solidification | |||
system (see Section 11.1.4.1 of the USAR) in the plant, but is having wet | |||
wastes solidified / processed by a contracted service. The contracted | |||
service uses an NRC approved process. The licensee's procedures for | |||
sampling of waste streams within the plant and results of radionuclides | |||
analyses were reviewed. The NRC inspector determined that the licensee | |||
had tentatively scheduled a QA audit of the offsite laboratory that | |||
performs certain analyses to be conducted during March 1986. The | |||
licensee's scaling factors are a combination of generic Combustion | |||
Engineering factors as modified by OPPD for site-specific conditions. | |||
The NRC inspector noted that licensee scaling factors are routinely adjusted | |||
based on in-house radiochemistry analyses involving correlation factors | |||
for cesium and cobalt radioisotopes. The offsite laboratory analyses are | |||
used to verify hard to analyze radionuclides (transuranics and strontiums). | |||
LLRW shipment records contain all the information required by 10 CFR | |||
Part 20.311. | |||
The NRC inspector noted that the licensee had only been solidifying liquid | |||
waste concentrates for disposa?. Current chemistry and operational condi- | |||
- | |||
tions have sharply reduced the depletion -, demineralizer resins. Also, | |||
the licensee is currently segregating DAW and has realized a fifty percent | |||
reduction in DAW requiring disposal as LLRW. That DAW being identified as | |||
not radioactively contaminated is being controlled and not released until | |||
further radiological surveys can be performed using more sensitive analysis | |||
equipment as referenced in NRC IE Information Notice 85-92. | |||
The NRC inspectors reviewed the licensee's somiannual Radioactive Effluent | |||
Release Report, documented changes to the solid radwaste system, and PCF | |||
procedure changes submitted to the NRC per TS 5.9.4 for 1985. | |||
. - | |||
The NRC inspector reviewed the licensee's records of LLRW shipped from FCS | |||
since 1981. The following table shows the total volume for the period 1981 | |||
through 1985: | |||
J | |||
r_ . | |||
f' | |||
. . | |||
7 | |||
L | |||
Volume | |||
Year {CubicMeters) | |||
1981 253 | |||
1982 342 | |||
l - | |||
l 1983 465 | |||
1984 450 | |||
l- 1985 343 | |||
l No violations or deviations were identified. ! | |||
l | |||
7. Onsite Low-Level Radioactive Waste Storage | |||
, | |||
The licensee's onsite low-level radioactive waste storage facilir.ies were | |||
' | |||
reviewed for compliance with the guidance provided in NRC Generic Letters | |||
81-38 and 85-14; the licensee's commitments contained in Section 11.1.4.4 | |||
of the USAR: and the information contained in NRC IE Circular No. 80-18. | |||
The NRC inspector determined that the licensee had prepared interim | |||
engineering plans for using an onsite warehouse for storage of select LLRW. | |||
However, these plans are being held in abeyance until a national LLRW | |||
program is determined. | |||
i | |||
No violations or deviations were identified. | |||
Radioactive Material Transportation Program | |||
' | |||
, | |||
8. | |||
\ | |||
The NRC inspector reviewed the licensee's radioactive material transportation | |||
^ | |||
program for compliance with the requirements of TS 2.9.2 and 5.10.1.g, | |||
l 10 CFR Part 71, DOT regulations 49 CFR Parts 171 through 178, and NRC I&E | |||
, | |||
Bulletin 79-19, and the recommendations of I&E Notices 83-10, 84-14, and | |||
! 84-50, NRC Regulatory Guides (RGs) 7.1 through 7.10. | |||
The NRC inspector reviewed selected records of RAM /LLRW shipments made by | |||
l | |||
the licensee. The licensee made approximately 61 shipments during 1985. | |||
l | |||
The shipments primarily consisted of either LLRW shipped as low specific | |||
l activity (LSA) via sole use carrier or equipment and/or items shipped as I | |||
limited quantities. The NRC inspector determined that no LLRW shipped as | |||
- | |||
LSA exceeded A, quantities. The NRC inspector specifically reviewed the | |||
following areas of the RAM shipping / transportation prog,am: | |||
a. Audits and Appraisals - Onsite QA Audits, onsite surveillances, and | |||
audits conducted by the OPPD General Office Safety Audit and Review | |||
Committee (SARC) were reviewed (see the Attachment to this report on | |||
. - - _ . _ . - - - . , . _ - _ _ - . - . _ - - _ _ _ . . - _ _ - . - . - _ , - . - _ _ - _ _ . _ - _ . . - . | |||
. . | |||
8 | |||
documents reviewed) and found to be comprehensive and conducted in | |||
-accordance with FCS QA manual. Audits involved both the control over | |||
procurement and receipt inspection of packagings, and the conduct of | |||
the RAM receipt and transportation program. The last audit of RAM | |||
transportation activities was September 1984. The next audit is | |||
tentatively scheduled to be performed in 1987. Onsite QA | |||
surveillances of RAM shipping is routinely performed. | |||
b. Procedures - Licensee procedures for the preparation, inspection, ~ | |||
loading, closing, curie content determination, labeling, and | |||
preparation of shipping papers foi radioactive material were reviewed | |||
and found to be maintained current and adequate. See the Attachment | |||
to this report for procedures reviewed, | |||
c. Procurement and Reuse of Packagings - Licensee procurement prcedures, | |||
receipt inspection, and QA program for compliance with 10 CFR Part 71, | |||
Subpart H were reviewed. The licensee routinely uses QA and QC | |||
checklists for the receipt inspection and loading of packages. | |||
d. RAM Shipments - Fifteen shipments of RAM /LLRW were reviewed for | |||
compliance with the requirement of 00T and NRC for such shipments. | |||
e. Transportation Incidents - The NRC inspector determined on January 7, | |||
1986, while reviewing transporation incident reports that the licensee | |||
was notified by an offsite laboratory on or about October 14, 1985, | |||
that radicactive contamination above the DOT limits was found on a | |||
valve (MS-280) shipped on October 9, 1985. The licensee subsequently | |||
determined that the valve contained approximately 0.46 uct of loose | |||
radioactivity within the valve and about 8 uci of activated radio- | |||
activity. The shipment of the valve as non-radioactive material is | |||
an apparent violation of, 49 CFR Part 171.2(a) and 173.423 and 10 CFR | |||
Part 71.5(a) requirements (285/8601-01). | |||
f. Registration of Use of NRC Certified Packagings - The licensee was | |||
found to be a registered user of NRC certified packages used to ship | |||
RAM from FCS. Registration was being maintained on other packages | |||
not routinely used. | |||
g. Quality Assurance Program - The licensee maintains a program for | |||
ensuring that the QA program for RAM shipment packages referenced in | |||
10 CFR Part 71, Subpart H, was being complied with. | |||
. | |||
h. Preparation of Packages for Shipment - The licensee's records for | |||
shipment of RAM show that packages were inspected for quality of | |||
construction and integrity, free standing liquids, package markings / | |||
labeling, and that comprehensive radiation and contamination surveys | |||
were performed. The NRC inspector observed the preparation and | |||
packaging of a solidified liner of waste concentrates for shipment to | |||
a LLRW burial site. Independent radiation measurements of the package | |||
was made by the NRC inspector. | |||
i | |||
_ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - - _ - | |||
. .. | |||
9 | |||
i. Delivery of Completed Packages to Carriers - The NRC inspector | |||
reviewed licensee records of RAM shipments, including LSA shipments | |||
and determined that loading, bracing, use of tamperseals, placarding, | |||
advanced notification, and providing instructions on maintenance of | |||
sole use conditions was adequate. | |||
j. Periodic Maintenance of Packagings - The licensee does not routinely | |||
perform maintenance on packages, but does keep adequate records of | |||
maintenance performed by the package vendors. The NRC inspector | |||
specifically verified that annual replacement of lid seals on certain | |||
reusable packages was performed by the package vendor, | |||
k. Records and Reports - The NRC inspector reviewed general records, | |||
QA/QC records, and RAM shipment reco.rds for 1984 and 1985 and | |||
verified proper records of QA/QC activities, shipment manifests, | |||
radiation and contamination surveys, certification of compliances, | |||
semi-annual reports of transportation and LLRW activities, and | |||
evaluation of 00T specification packaging compliances. | |||
No deviations were identified. | |||
9. External Radiation Exposure Control | |||
The licensee's RP program was reviewed for compliance with the commitments | |||
contained in the USAR - Section ll, the requirements of TS 5.11, and | |||
10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203, | |||
20.205, 20.206, 20.405, 20.407, 20.408, and 20.409. | |||
The NRC. inspector reviewed licensee personnel radiation exposure records | |||
for implementation of the corrective action taken by the licensee in | |||
regards to Notice of Violation 285/8502-04, which involved the licensee's | |||
failure to notify terminated individuals of their radiation exposure | |||
- received while at FCS as required by 10 CFR Part 20.409. The NRC inspector | |||
reviewed, with the licensee during the entrance meeting of this inspection, | |||
a radiation exposure termination report sent from FCS to the NRC inspector | |||
on August 31, 1985, (OPPD Serial No. FC-C-050-85) approximately 5 months | |||
fc110 wing the inspectors last visit to FCS (March 8, 1985). On January 7, | |||
1986, the NRC inspector determined that the exposure termination report | |||
sent to the NRC inspector was not processed within the time period set | |||
forth in 10 CFR Part 20.409, which is identical to the violation referenced | |||
in NRC Inspection Report 50-285/85-02. Further investigation by the | |||
licensee determined that, additionally, termination reports for approximately | |||
. | |||
30 temporary employees had not also been processed within the required | |||
tire period. The failure to provide timely reports of radiation exposure | |||
is an apparent repeat violation of 10 CFR Part 20.409 (285/8601-02). | |||
The licensee's TS 5.11.2 requires that radiation areas above 1000 mrem /hr | |||
be controlled by posting and use of locked doors to prevent unauthorized | |||
entry into such areas. The NRC inspector determined on January 8, 1986, | |||
- - . - , . _ | |||
__ ._ _. _ . . . . - _ _ _ .. | |||
. . | |||
, | |||
l | |||
I | |||
10 | |||
l | |||
that a posted very high radiation area within Room 27 of the RAB was not | |||
being controlled by locked doors even though lockable doors were present. | |||
The licensee considered the area to be exempt from locking (per TS 5.11.2.a) | |||
, due to the additional ef fort that would be necessary to provide locking | |||
devices on the entry doors (one was a sliding door and the other was a | |||
standard door with a keyed locking mechanism) and the relative : size of the | |||
room. The NRC inspector noted to the licensee that the size of Room 27 -i | |||
' | |||
(approximately 150 square feet of accessible space) did not conpare to the | |||
example provided in the TS exemption (containment building), and that two | |||
out of three flashing lights required by the exemption were not working | |||
- | |||
and the access at the east end was not properly roped off. The general | |||
radiation levels in Room 27 were less than 1000 mrem /hr; however, waste | |||
material stored in several plastic bags within the room produced radiation | |||
levels of approximately 1200 mrem /hr measured at 18 inches. The failure | |||
to properly control very high radiation areas is considered an apparent , | |||
violation of TS 5.11.2 (285/8601-03). | |||
- | |||
! | |||
; | |||
No deviations were identified. L | |||
, | |||
l 10. Control of RAM and Contamination, Surveys, and Monitoring | |||
The licensee's programs for the control of RAM and contamination, radiological | |||
surveys and monitoring were reviewed for compliance with the commitments | |||
contained in the USAR - Section 11, and the requirements in 15 5.11, | |||
10 CFR Part 19.12, and 20.4, 20.5, 20.201, 20.203, 20.205, 20.207, 20.301, | |||
20.401, and 20.402, and the recommendations in IE Information Notice 85-92. | |||
! 10 CFR Part 20.201 requires that a licensee shall make or caese to be made | |||
such surveys as may be necessary for the licensee to comply with the regu- | |||
lations in this part, which also require that surveys be conducted | |||
incident to the use, release, and disposal materials. The NR inspector | |||
determined on January 7, 1986, that on or about October 9, 1935, | |||
, | |||
. | |||
l | |||
l valve MS-280 was removed from the main steam system within Room 81 of the | |||
l plant (a normally non-radiologically controlled room) and shipped to an ' | |||
, | |||
i offsite laboratory for testing per a plant maintenance order that did not | |||
require any radiological controls. This valve is part of steam | |||
generator 8 (SGB) of the main steam system that was exposed to primary | |||
coolant radioactivity during a primary to secondary leak in 1984. The ! | |||
failure to perform proper surveys of potentially contaminated items prior ! | |||
to leaving the plant is an apparent violation of 10 CFR Part 20.201 | |||
; (285/8601-04). | |||
. | |||
! The NRC inspector noted that an internal incident report (No. 2183) was | |||
i generated on October 15, 1985, concerning the shipping of the contaminated | |||
l | |||
valve to the offsite laboratory, but at the time of this inspection | |||
' | |||
written procedures addressing radiological controls for work on the ! | |||
SG-B main steam components had not been developed. The NEC inspector | |||
pointed out tomlicensee representatives that with no established permanent | |||
corrective action, a similar situation could occur involving other | |||
systems. , | |||
! | |||
! | |||
m | |||
. . | |||
11 | |||
The NRC inspector di'scussed with licensee representatives within the CRP | |||
group and those at the exit meeting the observation that FCS procedures | |||
allow the release of materials with detectable levels of radioactive | |||
materials on them which is not in accordance with the philosophy of the | |||
NRC as expressed in NRC IE Information Notice 85-92. The NRC inspector | |||
also noted that loose surface radioactive contamination limits for | |||
materials was a factor of almost ten above the minimum sensitivity of | |||
their laboratory counters / scalers. | |||
No deviations were identified. | |||
11. Exit Meeting | |||
The inspector reviewed the scope and findings of the inspection with | |||
licensee representatives noted in paragraph 1 of this report at the | |||
conclusion of the inspection on January 10, 1986. In response to the | |||
inspector's comments the licensee agreed to implement immediate action to | |||
lock the doors to Room 27 or eliminate the source of the very high | |||
radiation. | |||
. | |||
. | |||
.. | |||
. . | |||
ATTACHMENT | |||
TO NRC INSPECTION REPORT | |||
50-205/06-01 | |||
APPENDIX B | |||
D_OCUMEf1TS__R_EV 1 EWED | |||
IIILE SEVISION DAIE | |||
Omaha Public Power (OPPD) District Quality | |||
Assurance Manual 4 11-O'-83 | |||
Fort Calhoun Station (FCS) Quality Assurance Plan | |||
Section'10.4. Deficiency Control and | |||
Corrective Action 0 09-01-84 | |||
Section 11.1. Radioactive Material Control 0 09-01-84 | |||
Section 11.2, Health Physics 0 09-01-84 | |||
Section 11.3. ALARA. Radiation Exposure | |||
Program 0 09-01-84 | |||
Section 11.5, Packaging and Transportation | |||
of Radioactive Waste 0 09-01-84 | |||
FCS Quality Assurance Department Procedure Manual (OADP) | |||
DADP-5. Internal Audit and DA Survei11ance | |||
Scheduling 3 12-03-85 | |||
OADP-6, Conduct of Audits 2 11-30-84 | |||
OADP-7, Conduct of GA Surveillances 3 07-10-85 | |||
OADP-8, Conduct of OA Inspections 1 11-30-84 | |||
DADP-10 Review of Procurement Documents 2 11-30-84 | |||
OADP-12, Material Acceptance and neceipt | |||
Inspection 2 11-30-84 | |||
,DADP-14, Deficiency Tracking and Trending 3 12-03-85 | |||
FCS DA Department and OPPD Safety Audit. Review Committer (SARC) Audits | |||
Audit No._ Cit 1e Erggu e n c ylyJ1a r s ) - Rey p_on s i b i 1 i t v | |||
13, Procurement Control 3-DA | |||
14 Control and Dualification | |||
of Vendors 2-SARC | |||
31, Storage. Shipping, ano | |||
Handling of Controlled | |||
" | |||
Ouality Equipment (COE) 3-DA | |||
56, Radioactive Material | |||
Packing and Shipping 3-DA | |||
57. Radioactive Matertal Control | |||
and Waste Management 3-DA (Requires use of | |||
Technical Specialist) | |||
63. Radiation Protection Program | |||
and Implomanting Proctriures 2-SARC | |||
, . | |||
11TL.E REVI.SIOr] De31 E | |||
DA Surveillances: | |||
tFrequency: M= monthly, O=quarteriv. | |||
S= semiannual 1y, A= annual 1y, | |||
R"r.=f uel i ng / .18 months) | |||
M-14 Plant Activities - House Keepinq | |||
0-1, COE Material Receipt / Storage /Insue | |||
0- 7, Health Physics Surveys /Reporti | |||
0-12. Radioactive Materi al / Sources | |||
.0-23, Radiation Protection | |||
1. | |||
5-3, 11aintenance Qual i ty Control | |||
S-13, Waste Solid Release | |||
A-42, Radicactive Material Shipment | |||
GA Department Internal Audit Schedule (1983 - 1986) | |||
SARC Internal Audit Schedule (1984 - 1985) | |||
NGC Ouality Assurance Program Approval tor | |||
Padioactive Material Packages No. 0256 2 07-23-04 | |||
OA/SARC Audits and Survei11ances: | |||
83-DA-185, COE Storage, Shipping and | |||
Handling, Audit P1an 31 10-31-G4 | |||
34-OA-167, Radioactive Material, Shipping. | |||
Control & Waste Management, Audit Plans | |||
56 6 57 09-05-84 | |||
- Surveillance S-13, 5/95-1 through 11/05-14 | |||
RAM Shipments | |||
OA Receipt Inspection Records | |||
Purchase Orders Material | |||
63213% Rad Waste Container 02-17-04 | |||
63222% Rad Waste Container 02-22-94 | |||
63237% Rad Waste Container 03--09-84 | |||
. 536805% Rad Waste Contatner 09-04-04 | |||
538630% Rad Waste Container 05-14-05 | |||
FCS Training Manual | |||
Gection 2.0 General Employee Trainina 10 , | |||
v?~19-05 | |||
Section 6.o. Chemistry and Radiation | |||
Pr utection Group Trainino 10 09-19 95 | |||
bection 6.2. Chemistry and Radiation | |||
Protection Group Retrainina 10 v'/ - 19 -05 | |||
k | |||
. . | |||
TITLE FEVISION DATE | |||
FCS Operating Procedure Manual | |||
Volume A. Standing Orders | |||
General (G): | |||
G-22, Storaoe of Crttical Clement and | |||
Rad 2cactive Material PacLaqino. | |||
Fire Protection Material, and | |||
Calibration Equipment 14 12-17-GS | |||
G-24, Receipt C"ntrol of CDE Material 17 12-20-94 | |||
G-25. Stores Control 14 06-25-85 | |||
G-26. Maintenance Quality Control Program to 10-16-05 | |||
G-26A. Quality Control Procram. Append 1 L. | |||
Radioactive Shipment Checklist 10 09-13-05 | |||
G-27 Training 5 0G-16-85 | |||
G-o3, Volume Reduction of Radioactive | |||
Waste O 07-39-05 | |||
Tecnnical (T): | |||
T-1. Fadiation Procedure Manual ! 03-31-01 | |||
T-4, kaste Solids Release 6 04-23-G5 | |||
T-10, Personnel E::posure Records 27 07-02-G5 | |||
T-18. Cleaning Agents for Use in the | |||
Au>:i l i ar y Bui l di ng 2 06-25-G5 | |||
Records (R): | |||
R-4 Operating Incident Reports 9 04-16-04 | |||
Volume VII, Radiation Protection Manual | |||
Section 2.0, Personnel Protection and | |||
Control 32 09-24-05 | |||
Section 2. 7, Radiation Work Permits | |||
. | |||
Section 2.0. Area Control 14 05-00-D5 | |||
Section 3.1.B. High Fadiation Area | |||
Section 3.2, Contamination Limitu | |||
Section 3.4, Access Control | |||
Section 5.0 Equipment Control 5 11-15-03 | |||
Section 5.3.2. Release to Unrestricted | |||
Area | |||
. | |||
Section 6.0, Radioactive Material Control 17 10-11-85 | |||
(RAM) | |||
Section 6.1, Receivino RAM | |||
5ecticn 6.2. Storage of RAM | |||
Section 6.2 Trancportation of RAM | |||
Section 6.4, Loading Waste Containern r.n | |||
" Sole Une" Tral 1er for Ghipment | |||
Section 6.5, Radioactive Material | |||
Shipping Papers (FC-210) | |||
3 | |||
. . | |||
TITLE h.CYItjiON DATE | |||
Sect 2on S.O. Radiation Protectino Procedur es tRPPi | |||
RPP-14 In-Plant Collection and Disposal | |||
of Radioactive Waste 2 06-10-05 | |||
FPP-15, Veri f i cati on of Liquid Free | |||
Solidified Waste, Spent Resin Waste | |||
and Dry Compactable er Noncomnact- | |||
able Waste 4 11-13-05 | |||
HFP-20 Radiation Work Permtts 4 08-29-05 | |||
Section 9.0, Operating Procedures for Health Phycics Personnel (HP) | |||
HP-3, Solid Waste Shipment Procedure 13 07-30-85 | |||
H P -- 3 A , Operation of the Darrier 5 5 H i -- | |||
Integrity Container Overpack O 09-07-04 | |||
I tF -3D. Procedure (CNSI) 1 07-30-G5 | |||
HP-3C. Maintenance /NUS Support for Rad- | |||
Waste Solidificatien 0 10-30-b3 | |||
H -8, Labeling and Bagging of RAM 3 05-28-75 | |||
HP-17, Outside Storage and Movement of | |||
Radicactive Waste 1 05-07-85 | |||
Hf ' 16 Gelection of Contract s 'eal th | |||
F h ', s i c s Technittans 1 07-12-03 | |||
h?-19 Radioactive Waste Inventory | |||
Procedure ! Oo-10-OG | |||
HP-21. Determination of Package Curie | |||
Content 1 11-15-83 | |||
(P-21A, Determination of Waste Fcrm | |||
C1ausfication 3 10-24-85 | |||
HF -23, Restricted Area Vi si tor Tir t e f i n g O 12-01-83 | |||
HP-25. Radiation Hot Spot Verification / | |||
Update O O2-20-84 | |||
HF -2 /, Determination of Dry Active Waste , | |||
' | |||
kverage Radsonucl1de/Compoettton | |||
and Energy 1 10-31-SS | |||
Goi: t 2 an 10.0. Radialocical Incident Reports 1 12-01-04 | |||
Goc t i on 11.0, Procene Control Program 0 10-03-05 | |||
volume '/ I I I , Chemistry Manual Procedure (CMP) | |||
.%c t t on 2.0, Sample Collection | |||
LMP-2.3, 40 CFR Pert 190 Sampling 1 10-02-05 | |||
- | |||
CMP-3.5. Determinatton of Isotopic | |||
Specietc Acttvity 4 O',-19-05 | |||
Maintenance Procedures (MP) | |||
HfulUPAC-1. Loadino of Htqh Intoqrttv | |||
Containers J 07-30-US | |||
MP - HUSC AGl'- 1, Opening. l.cadino ond Clostnq | |||
' | |||
of Pact: age NUS 14-!70 f 1 - 1 i' - H b | |||
4 | |||
. ., . | |||
TITLE fiEV l G 10f! DATC | |||
FC5 Memorandum. FC-618-04, Subj: 10 CFR 61 Analvses for Waste | |||
C1assification 03-20-04 | |||
Innenendent Laboratory First Quarter 1985 Waste Stream | |||
Analvsis Hesulta 08-01-8S | |||
Solidification Service Procedures | |||
$ 5 --001, Precess Control Prooram for the | |||
NUSPAC Solidiftcation System I 00-16-85 | |||
55-019 System Set up / Removal Procedure for | |||
the System 8000 A | |||
SG-020, Operatino Instructions f ac the | |||
Gystem 8800 A 10-25-05 | |||
NU.3 Letter of Instruct 1on: 7526-003, FCS | |||
En1idiftcation Service Sampiing Methad 10-39-OS | |||
. | |||
FCS Calibration Procedures: | |||
CP-065-EC, Control Room Iodine Monitor 2 04-01-05 | |||
FC3 Surveillance Frocedt.re: | |||
ST -RM -2. F. 5, Process Monitor Electronic | |||
and Secondarv Calibrations 37 11-12-05 | |||
Accer,s Logs for Aunil1ary building Controlled | |||
Doore 100715 and 100722 for the period | |||
July 1985 through Deceinber 1985 | |||
FCS Drawino 435 302-001, Steam Generator Dlowdown Processing Gvstem | |||
~ | |||
RhM Shipping Package Vendor Manuals: | |||
CurrentIv | |||
TliiE Co t C . Revj e i o.n. _lgeqi s tf y ed_t)ser_ | |||
CNSI 14-195H. USA /?O74/A G YES | |||
CNSI 21-300, USA /9096/A 2 NO | |||
CMSI 8-120 USA /6601/D i ) 20 NO | |||
HN-100 USA /9151/A 0 YES | |||
HN-68)O, USA /90GO/A l '' YES | |||
* | |||
NUPAC-!OO, USA /9000/A 12 YES | |||
NUPAC 14D-2.O. USA /907c,/4 13 YE5 | |||
NUS-9000, USA /9000/A 12 YES | |||
NUS 14-l'/, USA /9151/A O YES | |||
NUG 10-135. USA /9073/A IS NO | |||
. | |||
. . , . | |||
FC9 Semtannual Solid Radioactive Watte Disposal Report | |||
.lu l y 1904 through Deceaber 1984 | |||
January 1985 through June 1985 | |||
Ju' y 1985 through December 1985 (preliminary data) | |||
FCS Form 205, Radiation Exposure Termination Reports | |||
FLStrorm 220, NRC Form 5 Equivalent | |||
. | |||
e | |||
}} |
Latest revision as of 13:43, 18 December 2020
ML20141C942 | |
Person / Time | |
---|---|
Site: | Fort Calhoun |
Issue date: | 03/18/1986 |
From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | |
Shared Package | |
ML20141C925 | List: |
References | |
50-285-86-01, 50-285-86-1, GL-81-38, GL-81-389, GL-85-14, IEB-79-19, IEIN-83-10, IEIN-84-14, IEIN-84-50, IEIN-85-092, IEIN-85-92, NUDOCS 8604070351 | |
Download: ML20141C942 (17) | |
See also: IR 05000285/1986001
Text
{{#Wiki_filter:_
, .- APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-285/86-01 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, Washington County, Nebraska Inspection Conducted: January 6-10, 1986 Inspector: b ' dlbb 7)'llL4tfd/ W8h6 Date H.~Chaney,Radl5 tion /pecialist, 3 Facilities Radiological Protection Section Approved: / b E 7 N /Jffh/ /[[htb Oate' B. Murray, Chi ~et, Fadilities Radiological ~ Protection Section Inspection Summary Inspection Conducted January 6-10, 1986 (Recort 50-285/86-01) Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program, low-level radioactive solid waste (LLRW) program, and transportation of radioactive materials (RAM). The inspection involved - 46 inspector-hours onsite and 7 inspector-hours offsite by one NRC inspector. Results: Within the areas inspected, four apparent violations (see paragraphs 8, 9 and 10) and no deviations were identified. 8604070351 G60327 PDR ADOCK 05000285 G PDR
_ _. __ , . 2 i DETAILS
j 1. Persons Contacted ! OPPD i *R. L. An'drews, Division Manager-Nuclear Production
*W. G. Gates, Manager, Fort Calhoun Station *R. L. Jaworski, Section Manager-Technical Services *F.' F. Franco, 'Section Manager-Radiological Health and Emergency Preparedness *C. J. Brunnert, Supervisor Operations Quality Assurance (QA)
~
*K. Stultz, Technical Services
, *G. L. Roach, Supervisor-Chemical and Radiation Protection (CRP) '
*F. K. Smith, Plant Chemist *A. Bilau, Radioactive Waste Coordinator *J. M. Mattice, Plant Health Physicist B.' Wentworth, Quality Control (QC) Inspector
J. M. Hale, CRP Technician Coordinator ' D. A. Jacobson, CRP Training Instructor J. Carlson, Administrative Clerk R. A. Cords, CRP Technician . J. J. Fisicaro, Supervisor-Nuclear Regulatory and Industry Affairs
-
C. R. Crawford, ALARA Coordinator , J. E. Bentzinger, General Office QA
j T. J. McIvor, Supervisor Technical Services
t Others
- D. Whitlock, Contract CRP Technician
l -
P. Harrell, NRC Resident Inspector ~
[ The NRC inspector also interviewed other licensee and contractor employees
including CRP, administrative, maintenance, and QA/QC personnel.
i " Denotes those individuals present during the exit interview on '
January 10, 1986. 2. Licensee Action on Previously Identified Inspection Findings
! . (Closed) Violation (285/8010-01): Failure to Survey - This item was
previously discussed in NRC Inspection Report 50-285/80-10 and involved the failure to perform a monthly radiation survey in-room 15A of the reactor auxiliary building (RAB). Selected licensee survey records for
-
room 15A were reviewed and it was determined that the licensee had been surveying room 15A at an adequate frequency during 1985. This item is considered closed.
4 e s
-
.. . 3 (Closed) Open Item (285/8226-15): NUREG-0737, Item II.F.1-1, High Range Noble Gas Effluent Monitor - This item had remained open pending licensee action to complete installation and testing of the instrumentation. Radiation Monitor (RM) 063 had been installed and appears to satisfy the requirements of NUREG-0737. This item is considered closed. (Closed) Open Item (285/8226-18): NUREG-0737, Item III.D.3.4, Modifications for Control Room Habitabi1ity - This item had remained open pending the licensee's completion of modifications to satisfy NUREG-0737 requirements. The licensee had completed installation of: (1) additional radiation shielding in the west side wall adjacent to the control room, (2) iodine monitor RM-65, and (3) toxic chemical monitors. All monitors are considered operational. This item is considered closed. (Closed) Violations (285/8303-01) & (285/8502-05): Radiation Hot Spot ; Posting - The NRC inspector reviewed licensee corrective actions to resolve the failures to properly post radiation hot spots. The licensee i had: (1) provided for review of procedures by HP technicians, (2) revised
'
health physics procedures to eliminate conflicting requirements, and (3) more clearly state hot spot posting requirements. Inspections of the
i licensee's facility did not identify any problems with hot spot posting. ,
This item is considered closed.
,
I (Closed) Violation (285/8331-01): Review of Radiation Work Permits - The NRC inspector reviewed 10 radiation work permits (RWP) and found all had
- been properly reviewed per procedure RPP-20 which now requires a monthly
- review for certain RWPs. This item is considered closed.
(Closed) Violation (285/8502-01): Radiation Protection Instructions to Workers - The licensee had issued special instructions on selected training topics concerning radiological protection for badged personnel. - The licensee's training outlines and procedures were revised also to ensure all personnel entering the protected area (i.e., restricted area) received the training required by 10 CFR Part 19.12. This item is
! considered closed. I (Closed) Violation (285/8502-02): NRC Form 4 - The licensee had taken
corrective action to have all NRC Form 4s tilled out in their entirety. A review of radiation exposure records did not identify any NRC Forms not properly filled out. This item is considered closed. . . (Closed) Violation (285/8502-03): NRC Form 5 - The licensee had taken corrective action to use a form that was equivalent to the NRC Form 5 to track quarterly exposures of workers. This item is considered closed. 3. Inspector Observations
j
The following are observations the NRC inspector discussed with the licensee
- during the exit interview on January 10, 1985. These observations are
! t i
o . 4 neither violations nor unresolved items. These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requirement. The licensee did not provide any specific comment for these items, a. Supervisor Review of Work Areas - The NRC inspector noted during interviews witI workers that a general theme was expressed concerning the lack of C' supervisor tours of job site and ongoing work and conditions within the controlled areas, i.e., RAB and containment during outages. See paragraph 4. b. Release Limits for Potentially Radioactive Material - The NRC inspector noted that the licensee's orocedures could allow for the release of materials to unrestricted areas with radioactive contamination levels above those referenced in recent NRC Information Notices. See paragraph 10. c. Coordination and Documentation of Training - There appears to be a lack of general knowledge in the CRP group in regards to who is responsible for the development of training, conduct of training, and of ensuring that training records.are properly documented. See paragraph 5. 4. Radwaste/ Transportation Program Organization and Management Controls The NRC inspectors examined the licensee's organization and staffing to determine compliance with the Updated Safety Analysis Report (USAR) - Sections 11 and 12; NRC Inspection and Enforcement (IE) Bulletin 79-19; 10 CFR Parts 20, 50, and 71; Facility Operating License Technical Specifications (TS) 2.9.2, 5.2.2, 5.8, 5.9.4, and 5.10.1; and the recommendations of NRC Regulatory Guides (RG) 1.33, and 1.8, and NRC IE . Information Notices 83-10 and 84-50. The NRC inspector reviewed the staffing of the CRP group Radioactive Waste Coordinator (RW/C) position, compared staf fing to TS requirements and the work load involving solid RW management and transportation activities. The NRC inspector determined that the RW section was responsible for oversight of contractor solidification services, compaction of dry active waste (DAW), preparation of RAM and waste for shipment, and general RP duties associated with RW operations.
,
The NRC inspector reviewed the licensee's operating procedures for RW activities. The NRC inspector noted that the licensee had prepared a waste stream characterization and analysis program for compliance with ~ 10 CFR Part 61 requirements. The NRC inspector reviewed the procedures used by a contracted LLRW solidification service vendor and the licensee's controls over changes to those documents. The licensee's burial site contracts, DOT /NRC regulations, and package user manuals were found to be up to date.
. . 5 The NRC inspector reviewed QA audits and surveillances of RP, RW, and transportation ac ivities, and determined that they were carried out in accordance with Q manual requirements. The deficiencies noted in license QA audits were re olved in an effective and timely manner. The licensee's QC program for tr nsportation activities was reviewed and found to be comprehensive and well documented. During interviews with various RP and other FCS employees, it was determined that there appears to be a concern on the part of some employees that CRP group supervisory personnel were not aware of activities and employee conduct within radiologically controlled areas, and that CRP supervision did not appear to be conducting tours of radiological work areas within the RAB and reactor containment. A review of 1985 CRP supervision exposure records and access key card reader entries for accesses leading into the RAB confirmed-that only a few entries had been made via the routine RAB access door, and when added to the very little exposure being acquired by key supervisory personnel is indicative of infrequent tours of radiological work areas. This concern was brought to the attention of the licensee during the exit meeting and a subsequent telephone conversation between the NRC inspector and plant manager on February 3,1986. No violations or deviations were identified. 5. Radwaste/ Transportation Organization Staff Qualifications and Training The NRC inspector examined personnel qualifications to determine compliance with NRC IE Bulletin 79-19, USAR Section 12, 10 CFR Parts 19.12 and 71.105(d), and TS 5.3, 5.4, and 5.10.2; and the recommendations of RGs 1.8, 8.2, 8.8, 8.27, and NUREG-0761. The NRC inspector reviewed position descriptions, training records, training outlines, special training announcements, training attendance , rosters, and discussed the qualifications and training activities of personnel performing LLRW processing and transportation activities with licensee representatives and contracted personnel. The NRC inspector determined that CRP personnel associated with LLRW activities had received periodic training by offsite vendors; however, the records of such training were found to be fragmented and difficult to retrieve. Tentatively scheduled offsite LLRW management and DOT /NRC transportation training for RW workers was also reviewed. During discus- sions with licensee personnel in the training and CRP groups, it was determined that scheduling of specialized RW training and conduct of
'
training was not being provided sufficient attention. The NRC inspector identified to licensee representatives at the exit meeting that RW training of CRP personnel needs additional attention to ensure that annual training commitments (licensee response to NRC IE Bulletin 79-19) are not compromised. No violations or deviations were identified.
-. -.
o . ' 6 6. Low-level Radioactive Waste Management Program The NRC inspector reviewed the licensee's program for the control, classification, characterization, and shipment of LLRW to determine compliance with the commitments contained in Section 11.1.4 of the USAR; and the requirements contained in 10 CFR Parts 20.301, 20.311, 61.55, and 61.56; and TS 5.9.4; and the recommendations of NRC branch technical position (BTP) papers on LLRW classification and waste form. The NRC inspector reviewed the licensee LLRW process control program, implementing procedures, LLRW processing areas, documents on processed LLRW, and QA/QC aspects of processing LLRW. The licensee had elected not to use or make operational the permanently installed LLRW solidification system (see Section 11.1.4.1 of the USAR) in the plant, but is having wet wastes solidified / processed by a contracted service. The contracted service uses an NRC approved process. The licensee's procedures for sampling of waste streams within the plant and results of radionuclides analyses were reviewed. The NRC inspector determined that the licensee had tentatively scheduled a QA audit of the offsite laboratory that performs certain analyses to be conducted during March 1986. The licensee's scaling factors are a combination of generic Combustion Engineering factors as modified by OPPD for site-specific conditions. The NRC inspector noted that licensee scaling factors are routinely adjusted based on in-house radiochemistry analyses involving correlation factors for cesium and cobalt radioisotopes. The offsite laboratory analyses are used to verify hard to analyze radionuclides (transuranics and strontiums). LLRW shipment records contain all the information required by 10 CFR Part 20.311. The NRC inspector noted that the licensee had only been solidifying liquid waste concentrates for disposa?. Current chemistry and operational condi- - tions have sharply reduced the depletion -, demineralizer resins. Also, the licensee is currently segregating DAW and has realized a fifty percent reduction in DAW requiring disposal as LLRW. That DAW being identified as not radioactively contaminated is being controlled and not released until further radiological surveys can be performed using more sensitive analysis equipment as referenced in NRC IE Information Notice 85-92. The NRC inspectors reviewed the licensee's somiannual Radioactive Effluent Release Report, documented changes to the solid radwaste system, and PCF procedure changes submitted to the NRC per TS 5.9.4 for 1985. . - The NRC inspector reviewed the licensee's records of LLRW shipped from FCS since 1981. The following table shows the total volume for the period 1981 through 1985: J
r_ . f'
. . 7
L
Volume Year {CubicMeters) 1981 253 1982 342
l - l 1983 465
1984 450
l- 1985 343 l No violations or deviations were identified. ! l
7. Onsite Low-Level Radioactive Waste Storage
,
The licensee's onsite low-level radioactive waste storage facilir.ies were
'
reviewed for compliance with the guidance provided in NRC Generic Letters 81-38 and 85-14; the licensee's commitments contained in Section 11.1.4.4 of the USAR: and the information contained in NRC IE Circular No. 80-18. The NRC inspector determined that the licensee had prepared interim engineering plans for using an onsite warehouse for storage of select LLRW. However, these plans are being held in abeyance until a national LLRW program is determined.
i
No violations or deviations were identified. Radioactive Material Transportation Program '
,
8.
\
The NRC inspector reviewed the licensee's radioactive material transportation ^ program for compliance with the requirements of TS 2.9.2 and 5.10.1.g,
l 10 CFR Part 71, DOT regulations 49 CFR Parts 171 through 178, and NRC I&E ,
Bulletin 79-19, and the recommendations of I&E Notices 83-10, 84-14, and
! 84-50, NRC Regulatory Guides (RGs) 7.1 through 7.10.
The NRC inspector reviewed selected records of RAM /LLRW shipments made by
l
the licensee. The licensee made approximately 61 shipments during 1985.
l
The shipments primarily consisted of either LLRW shipped as low specific
l activity (LSA) via sole use carrier or equipment and/or items shipped as I
limited quantities. The NRC inspector determined that no LLRW shipped as - LSA exceeded A, quantities. The NRC inspector specifically reviewed the following areas of the RAM shipping / transportation prog,am: a. Audits and Appraisals - Onsite QA Audits, onsite surveillances, and audits conducted by the OPPD General Office Safety Audit and Review Committee (SARC) were reviewed (see the Attachment to this report on . - - _ . _ . - - - . , . _ - _ _ - . - . _ - - _ _ _ . . - _ _ - . - . - _ , - . - _ _ - _ _ . _ - _ . . - .
. . 8 documents reviewed) and found to be comprehensive and conducted in -accordance with FCS QA manual. Audits involved both the control over procurement and receipt inspection of packagings, and the conduct of the RAM receipt and transportation program. The last audit of RAM transportation activities was September 1984. The next audit is tentatively scheduled to be performed in 1987. Onsite QA surveillances of RAM shipping is routinely performed. b. Procedures - Licensee procedures for the preparation, inspection, ~ loading, closing, curie content determination, labeling, and preparation of shipping papers foi radioactive material were reviewed and found to be maintained current and adequate. See the Attachment to this report for procedures reviewed, c. Procurement and Reuse of Packagings - Licensee procurement prcedures, receipt inspection, and QA program for compliance with 10 CFR Part 71, Subpart H were reviewed. The licensee routinely uses QA and QC checklists for the receipt inspection and loading of packages. d. RAM Shipments - Fifteen shipments of RAM /LLRW were reviewed for compliance with the requirement of 00T and NRC for such shipments. e. Transportation Incidents - The NRC inspector determined on January 7, 1986, while reviewing transporation incident reports that the licensee was notified by an offsite laboratory on or about October 14, 1985, that radicactive contamination above the DOT limits was found on a valve (MS-280) shipped on October 9, 1985. The licensee subsequently determined that the valve contained approximately 0.46 uct of loose radioactivity within the valve and about 8 uci of activated radio- activity. The shipment of the valve as non-radioactive material is an apparent violation of, 49 CFR Part 171.2(a) and 173.423 and 10 CFR Part 71.5(a) requirements (285/8601-01). f. Registration of Use of NRC Certified Packagings - The licensee was found to be a registered user of NRC certified packages used to ship RAM from FCS. Registration was being maintained on other packages not routinely used. g. Quality Assurance Program - The licensee maintains a program for ensuring that the QA program for RAM shipment packages referenced in 10 CFR Part 71, Subpart H, was being complied with. . h. Preparation of Packages for Shipment - The licensee's records for shipment of RAM show that packages were inspected for quality of construction and integrity, free standing liquids, package markings / labeling, and that comprehensive radiation and contamination surveys were performed. The NRC inspector observed the preparation and packaging of a solidified liner of waste concentrates for shipment to a LLRW burial site. Independent radiation measurements of the package was made by the NRC inspector.
i
_ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - - _ -
. .. 9 i. Delivery of Completed Packages to Carriers - The NRC inspector reviewed licensee records of RAM shipments, including LSA shipments and determined that loading, bracing, use of tamperseals, placarding, advanced notification, and providing instructions on maintenance of sole use conditions was adequate. j. Periodic Maintenance of Packagings - The licensee does not routinely perform maintenance on packages, but does keep adequate records of maintenance performed by the package vendors. The NRC inspector specifically verified that annual replacement of lid seals on certain reusable packages was performed by the package vendor, k. Records and Reports - The NRC inspector reviewed general records, QA/QC records, and RAM shipment reco.rds for 1984 and 1985 and verified proper records of QA/QC activities, shipment manifests, radiation and contamination surveys, certification of compliances, semi-annual reports of transportation and LLRW activities, and evaluation of 00T specification packaging compliances. No deviations were identified. 9. External Radiation Exposure Control The licensee's RP program was reviewed for compliance with the commitments contained in the USAR - Section ll, the requirements of TS 5.11, and 10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203, 20.205, 20.206, 20.405, 20.407, 20.408, and 20.409. The NRC. inspector reviewed licensee personnel radiation exposure records for implementation of the corrective action taken by the licensee in regards to Notice of Violation 285/8502-04, which involved the licensee's failure to notify terminated individuals of their radiation exposure - received while at FCS as required by 10 CFR Part 20.409. The NRC inspector reviewed, with the licensee during the entrance meeting of this inspection, a radiation exposure termination report sent from FCS to the NRC inspector on August 31, 1985, (OPPD Serial No. FC-C-050-85) approximately 5 months fc110 wing the inspectors last visit to FCS (March 8, 1985). On January 7, 1986, the NRC inspector determined that the exposure termination report sent to the NRC inspector was not processed within the time period set forth in 10 CFR Part 20.409, which is identical to the violation referenced in NRC Inspection Report 50-285/85-02. Further investigation by the licensee determined that, additionally, termination reports for approximately
.
30 temporary employees had not also been processed within the required tire period. The failure to provide timely reports of radiation exposure is an apparent repeat violation of 10 CFR Part 20.409 (285/8601-02). The licensee's TS 5.11.2 requires that radiation areas above 1000 mrem /hr be controlled by posting and use of locked doors to prevent unauthorized entry into such areas. The NRC inspector determined on January 8, 1986, - - . - , . _
__ ._ _. _ . . . . - _ _ _ .. . . , l I 10
l
that a posted very high radiation area within Room 27 of the RAB was not being controlled by locked doors even though lockable doors were present. The licensee considered the area to be exempt from locking (per TS 5.11.2.a)
, due to the additional ef fort that would be necessary to provide locking
devices on the entry doors (one was a sliding door and the other was a standard door with a keyed locking mechanism) and the relative : size of the room. The NRC inspector noted to the licensee that the size of Room 27 -i
'
(approximately 150 square feet of accessible space) did not conpare to the example provided in the TS exemption (containment building), and that two out of three flashing lights required by the exemption were not working - and the access at the east end was not properly roped off. The general radiation levels in Room 27 were less than 1000 mrem /hr; however, waste material stored in several plastic bags within the room produced radiation levels of approximately 1200 mrem /hr measured at 18 inches. The failure to properly control very high radiation areas is considered an apparent , violation of TS 5.11.2 (285/8601-03). -
!
No deviations were identified. L ,
l 10. Control of RAM and Contamination, Surveys, and Monitoring
The licensee's programs for the control of RAM and contamination, radiological surveys and monitoring were reviewed for compliance with the commitments contained in the USAR - Section 11, and the requirements in 15 5.11, 10 CFR Part 19.12, and 20.4, 20.5, 20.201, 20.203, 20.205, 20.207, 20.301, 20.401, and 20.402, and the recommendations in IE Information Notice 85-92.
! 10 CFR Part 20.201 requires that a licensee shall make or caese to be made
such surveys as may be necessary for the licensee to comply with the regu- lations in this part, which also require that surveys be conducted incident to the use, release, and disposal materials. The NR inspector determined on January 7, 1986, that on or about October 9, 1935,
,
.
l l valve MS-280 was removed from the main steam system within Room 81 of the l plant (a normally non-radiologically controlled room) and shipped to an '
,
i offsite laboratory for testing per a plant maintenance order that did not
require any radiological controls. This valve is part of steam generator 8 (SGB) of the main steam system that was exposed to primary coolant radioactivity during a primary to secondary leak in 1984. The ! failure to perform proper surveys of potentially contaminated items prior ! to leaving the plant is an apparent violation of 10 CFR Part 20.201
- (285/8601-04).
.
! The NRC inspector noted that an internal incident report (No. 2183) was i generated on October 15, 1985, concerning the shipping of the contaminated l
valve to the offsite laboratory, but at the time of this inspection
'
written procedures addressing radiological controls for work on the ! SG-B main steam components had not been developed. The NEC inspector pointed out tomlicensee representatives that with no established permanent corrective action, a similar situation could occur involving other systems. ,
! !
m
. . 11 The NRC inspector di'scussed with licensee representatives within the CRP group and those at the exit meeting the observation that FCS procedures allow the release of materials with detectable levels of radioactive materials on them which is not in accordance with the philosophy of the NRC as expressed in NRC IE Information Notice 85-92. The NRC inspector also noted that loose surface radioactive contamination limits for materials was a factor of almost ten above the minimum sensitivity of their laboratory counters / scalers. No deviations were identified. 11. Exit Meeting The inspector reviewed the scope and findings of the inspection with licensee representatives noted in paragraph 1 of this report at the conclusion of the inspection on January 10, 1986. In response to the inspector's comments the licensee agreed to implement immediate action to lock the doors to Room 27 or eliminate the source of the very high radiation. . .
..
. . ATTACHMENT TO NRC INSPECTION REPORT 50-205/06-01 APPENDIX B D_OCUMEf1TS__R_EV 1 EWED IIILE SEVISION DAIE Omaha Public Power (OPPD) District Quality Assurance Manual 4 11-O'-83 Fort Calhoun Station (FCS) Quality Assurance Plan Section'10.4. Deficiency Control and Corrective Action 0 09-01-84 Section 11.1. Radioactive Material Control 0 09-01-84 Section 11.2, Health Physics 0 09-01-84 Section 11.3. ALARA. Radiation Exposure Program 0 09-01-84 Section 11.5, Packaging and Transportation of Radioactive Waste 0 09-01-84 FCS Quality Assurance Department Procedure Manual (OADP) DADP-5. Internal Audit and DA Survei11ance Scheduling 3 12-03-85 OADP-6, Conduct of Audits 2 11-30-84 OADP-7, Conduct of GA Surveillances 3 07-10-85 OADP-8, Conduct of OA Inspections 1 11-30-84 DADP-10 Review of Procurement Documents 2 11-30-84 OADP-12, Material Acceptance and neceipt Inspection 2 11-30-84 ,DADP-14, Deficiency Tracking and Trending 3 12-03-85 FCS DA Department and OPPD Safety Audit. Review Committer (SARC) Audits Audit No._ Cit 1e Erggu e n c ylyJ1a r s ) - Rey p_on s i b i 1 i t v 13, Procurement Control 3-DA 14 Control and Dualification of Vendors 2-SARC 31, Storage. Shipping, ano Handling of Controlled " Ouality Equipment (COE) 3-DA 56, Radioactive Material Packing and Shipping 3-DA 57. Radioactive Matertal Control and Waste Management 3-DA (Requires use of Technical Specialist) 63. Radiation Protection Program and Implomanting Proctriures 2-SARC
, . 11TL.E REVI.SIOr] De31 E DA Surveillances: tFrequency: M= monthly, O=quarteriv. S= semiannual 1y, A= annual 1y, R"r.=f uel i ng / .18 months) M-14 Plant Activities - House Keepinq 0-1, COE Material Receipt / Storage /Insue 0- 7, Health Physics Surveys /Reporti 0-12. Radioactive Materi al / Sources .0-23, Radiation Protection
1.
5-3, 11aintenance Qual i ty Control S-13, Waste Solid Release A-42, Radicactive Material Shipment GA Department Internal Audit Schedule (1983 - 1986) SARC Internal Audit Schedule (1984 - 1985) NGC Ouality Assurance Program Approval tor Padioactive Material Packages No. 0256 2 07-23-04 OA/SARC Audits and Survei11ances: 83-DA-185, COE Storage, Shipping and Handling, Audit P1an 31 10-31-G4 34-OA-167, Radioactive Material, Shipping. Control & Waste Management, Audit Plans 56 6 57 09-05-84 - Surveillance S-13, 5/95-1 through 11/05-14 RAM Shipments OA Receipt Inspection Records Purchase Orders Material 63213% Rad Waste Container 02-17-04 63222% Rad Waste Container 02-22-94 63237% Rad Waste Container 03--09-84 . 536805% Rad Waste Contatner 09-04-04 538630% Rad Waste Container 05-14-05 FCS Training Manual Gection 2.0 General Employee Trainina 10 , v?~19-05 Section 6.o. Chemistry and Radiation Pr utection Group Trainino 10 09-19 95 bection 6.2. Chemistry and Radiation Protection Group Retrainina 10 v'/ - 19 -05 k
. . TITLE FEVISION DATE FCS Operating Procedure Manual Volume A. Standing Orders General (G): G-22, Storaoe of Crttical Clement and Rad 2cactive Material PacLaqino. Fire Protection Material, and Calibration Equipment 14 12-17-GS G-24, Receipt C"ntrol of CDE Material 17 12-20-94 G-25. Stores Control 14 06-25-85 G-26. Maintenance Quality Control Program to 10-16-05 G-26A. Quality Control Procram. Append 1 L. Radioactive Shipment Checklist 10 09-13-05 G-27 Training 5 0G-16-85 G-o3, Volume Reduction of Radioactive Waste O 07-39-05 Tecnnical (T): T-1. Fadiation Procedure Manual ! 03-31-01 T-4, kaste Solids Release 6 04-23-G5 T-10, Personnel E::posure Records 27 07-02-G5 T-18. Cleaning Agents for Use in the Au>:i l i ar y Bui l di ng 2 06-25-G5 Records (R): R-4 Operating Incident Reports 9 04-16-04 Volume VII, Radiation Protection Manual Section 2.0, Personnel Protection and Control 32 09-24-05 Section 2. 7, Radiation Work Permits . Section 2.0. Area Control 14 05-00-D5 Section 3.1.B. High Fadiation Area Section 3.2, Contamination Limitu Section 3.4, Access Control Section 5.0 Equipment Control 5 11-15-03 Section 5.3.2. Release to Unrestricted Area
.
Section 6.0, Radioactive Material Control 17 10-11-85 (RAM) Section 6.1, Receivino RAM 5ecticn 6.2. Storage of RAM Section 6.2 Trancportation of RAM Section 6.4, Loading Waste Containern r.n " Sole Une" Tral 1er for Ghipment Section 6.5, Radioactive Material Shipping Papers (FC-210) 3
. . TITLE h.CYItjiON DATE Sect 2on S.O. Radiation Protectino Procedur es tRPPi RPP-14 In-Plant Collection and Disposal of Radioactive Waste 2 06-10-05 FPP-15, Veri f i cati on of Liquid Free Solidified Waste, Spent Resin Waste and Dry Compactable er Noncomnact- able Waste 4 11-13-05 HFP-20 Radiation Work Permtts 4 08-29-05 Section 9.0, Operating Procedures for Health Phycics Personnel (HP) HP-3, Solid Waste Shipment Procedure 13 07-30-85 H P -- 3 A , Operation of the Darrier 5 5 H i -- Integrity Container Overpack O 09-07-04 I tF -3D. Procedure (CNSI) 1 07-30-G5 HP-3C. Maintenance /NUS Support for Rad- Waste Solidificatien 0 10-30-b3 H -8, Labeling and Bagging of RAM 3 05-28-75 HP-17, Outside Storage and Movement of Radicactive Waste 1 05-07-85 Hf ' 16 Gelection of Contract s 'eal th F h ', s i c s Technittans 1 07-12-03 h?-19 Radioactive Waste Inventory Procedure ! Oo-10-OG HP-21. Determination of Package Curie Content 1 11-15-83 (P-21A, Determination of Waste Fcrm C1ausfication 3 10-24-85 HF -23, Restricted Area Vi si tor Tir t e f i n g O 12-01-83 HP-25. Radiation Hot Spot Verification / Update O O2-20-84 HF -2 /, Determination of Dry Active Waste , ' kverage Radsonucl1de/Compoettton and Energy 1 10-31-SS Goi: t 2 an 10.0. Radialocical Incident Reports 1 12-01-04 Goc t i on 11.0, Procene Control Program 0 10-03-05 volume '/ I I I , Chemistry Manual Procedure (CMP) .%c t t on 2.0, Sample Collection LMP-2.3, 40 CFR Pert 190 Sampling 1 10-02-05
-
CMP-3.5. Determinatton of Isotopic Specietc Acttvity 4 O',-19-05 Maintenance Procedures (MP) HfulUPAC-1. Loadino of Htqh Intoqrttv Containers J 07-30-US MP - HUSC AGl'- 1, Opening. l.cadino ond Clostnq ' of Pact: age NUS 14-!70 f 1 - 1 i' - H b 4
. ., . TITLE fiEV l G 10f! DATC FC5 Memorandum. FC-618-04, Subj: 10 CFR 61 Analvses for Waste C1assification 03-20-04 Innenendent Laboratory First Quarter 1985 Waste Stream Analvsis Hesulta 08-01-8S Solidification Service Procedures $ 5 --001, Precess Control Prooram for the NUSPAC Solidiftcation System I 00-16-85 55-019 System Set up / Removal Procedure for the System 8000 A SG-020, Operatino Instructions f ac the Gystem 8800 A 10-25-05 NU.3 Letter of Instruct 1on: 7526-003, FCS En1idiftcation Service Sampiing Methad 10-39-OS . FCS Calibration Procedures: CP-065-EC, Control Room Iodine Monitor 2 04-01-05 FC3 Surveillance Frocedt.re: ST -RM -2. F. 5, Process Monitor Electronic and Secondarv Calibrations 37 11-12-05 Accer,s Logs for Aunil1ary building Controlled Doore 100715 and 100722 for the period July 1985 through Deceinber 1985 FCS Drawino 435 302-001, Steam Generator Dlowdown Processing Gvstem ~ RhM Shipping Package Vendor Manuals: CurrentIv TliiE Co t C . Revj e i o.n. _lgeqi s tf y ed_t)ser_ CNSI 14-195H. USA /?O74/A G YES CNSI 21-300, USA /9096/A 2 NO CMSI 8-120 USA /6601/D i ) 20 NO HN-100 USA /9151/A 0 YES HN-68)O, USA /90GO/A l YES
NUPAC-!OO, USA /9000/A 12 YES NUPAC 14D-2.O. USA /907c,/4 13 YE5 NUS-9000, USA /9000/A 12 YES NUS 14-l'/, USA /9151/A O YES NUG 10-135. USA /9073/A IS NO .
. . , . FC9 Semtannual Solid Radioactive Watte Disposal Report .lu l y 1904 through Deceaber 1984 January 1985 through June 1985 Ju' y 1985 through December 1985 (preliminary data) FCS Form 205, Radiation Exposure Termination Reports FLStrorm 220, NRC Form 5 Equivalent
.
e
}}