IR 05000285/1986032: Difference between revisions

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{{Adams
{{Adams
| number = ML20206Q203
| number = ML20211Q118
| issue date = 04/15/1987
| issue date = 02/04/1987
| title = Ack Receipt of 870323 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/86-32
| title = Insp Rept 50-285/86-32 on 861215-19.Violation Noted: Personnel Did Not Wear Protective Clothing Specified on Radiation Work Permit RWP 86-430-1 for Entry Into Radiologically Controlled Area
| author name = Gagliardo J
| author name = Baer R, Murray B
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Andrews R
| addressee name =  
| addressee affiliation = OMAHA PUBLIC POWER DISTRICT
| addressee affiliation =  
| docket = 05000285
| docket = 05000285
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8704210363
| document report number = 50-285-86-32, TAC-64446, NUDOCS 8703030020
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| package number = ML20211Q091
| page count = 2
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 11
}}
}}


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APPENDIX B
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U.S. HUCLEAR REGULATORY COMMISSION


"
==REGION IV==
''t  APR I 5'l987 In Reply Refer To:
NRC Inspection Report: 50-285/86-32 License: DPR-40 Docket: 50-285
Docket: 50-285/86-32 Omaha Public Power District ATTN: R. L. Andrews, Division Manager-Nuclear Production 1623 Harney Street Omaha, Nebraska 68102
>
,
Licensee: OmahaPublicPowerDistrict(OPPD)
Gentlemen:
;  1623 Harney Street
Thank you for your letter of March 23, 1987, in response to our letter and Notice of Violation dated February 20, 1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
!
Omaha, Nebraska 68102 Facility Name: FortCalhounStation(FCS)
Inspection At: FCS Site, Blair, Nebraska
:'
Inspection Conducted: December 15-19, 1986 i
Inspector:
R. E. Baei, Radiation Specialist, Facilities MMf7 Date Radiological Protection Section I
Approved: / //D;c 77l/6)l(L6/  8[M/h7 Blaine Murray, Chief, F4cilities Radiological Date
,
Protection Section /
,
l Inspection Summary Inspection Conducted December 15-19, 1986 (Report 50-285/86-32)
Areas Inspected: Routine, unannounced inspection of the licensee's radiation
,
protection program including organization and management controls, training and
, qualifications, ALARA program, and a confirmatory radiation survey.
 
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Results: Within the_ areas inspected, one violation was identified (failure to follow procedures, paragraph 4).
 
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8703030020 870220 PDR ADOCK 05000285 G  PDR
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DETAILS Persons Contacted OPPD
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  *W. G. Gates, Manager, FCS A. Bilau, Radwaste Coordinator
  * J. Brunnert, Supervisor,,0perations Quality Assurance
,  R. A. Cords, Senior Technician
  *M. Core, Supervisor, Maintenance C. R. Crawford, ALARA Coordinator
;
M. L. Ellis, Instrument and Control Coordinator J. J. Fluehr, Supervisor, Station Training J. M.Gasper Hale, $eniorTechnicianManager, Administrative and Training Services D. A. Jacobson, Training Instructor L. T. Kusek, Su)ervisor, 0)erations
  *J. M. Mattice, )lant Healt1 Physicist
'
  * J. Munderloh, Senior Engineer, Nuclear Regulatory and Industrial Affairs
  * L. Roach, Supervisor, Chemistry and Radiation Protection (C/RP)
F. K. Smith, Plant Chemist J. J. Tesarek, Reactor Engineer M. W. Williams, General Employee Training Instructor
,
Others G. O. Maloy, Contractor Training Instructor
  *P. H. Harrell, NRC Senior-Resident Inspector The including NRCC insp/RP, administrative, maintenance, and training personnel.ecto
  * Denotes those individuals present during the exit interview on-December 19, 1986.
 
. Licensee Action on Previously Identified Inspection Findings (Closed) Violation (285/8502-04): Notification of Exposure to Individuals - This item involved the tailure to provide the recuired radiation exposure information within the specified time perioc to workers who had terminated employment. The licensee had sent out the required radiation exposure information and revised their notification procedure regarding radiation workers who had terminated employment. Violation (285/8502-04) is considered closed.
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Sincerely, ORIGINAL SIGNED BY: .
* .*
J. E. Gagliardo, Chief Reactor Projects Branch cc:
W. G. Gates, Manager    'l Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt, Esq.


LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW    j Washington, D. C. 20036 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director
(Closed) Violation 285/8601-02): Failure To Notify NRC and Individuals of Exposure This (item involved the tailure to provide the recuired radiation exposure information within the specified time aerioc to the NRC
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RIV:FRP C:FRPS C:R&SPE C- C:RPB REBaer/jt urray WLFisher pRHunter JEGagi [rdo i / 4 /87 /87 4 /l0/87 A /\3/87 q// '
and workers who had terminated employmen The licensee lad sent out the required radiation exposure information and revised FCS form FC-228 to include a monthly check to ensure compliance. Violation (285/8601-02) is considered close (Closed) Violation (285/8608-01): Failure to Follow Procedures - This
I      O B704210363 870415    \
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PDR ADOCK 05000285
Item involved the failure to retain the calibration data for particulate, iodine, and noble gas monitor number 21 The licensee had recalibrated the monitor in question and had retained the calibration data. Violation (285/8608-01) is considered close (Closed) Violation (285/8608-02): Failure to Submit Special Report - This item involved the failure to submit a s)ecial report to the NRC required by Technical Specifications (TS) when tie wide range noble gas stack monitors RM-063L, M, and H were not operational. The licensee submitted a special report and updated the NRC of the status of the wide range noble gas stack monitors RM-063L M, and H. The monitors had been calibrated andreturnedtooperationalstatus. Violation (285/8608-02) is considered close (Closed) Violation (285/8608-03): Failure to Develop Procedures - This item involved the failure to develop calibration procedures for portable radiation survey instruments received from a new supplier. The licensee
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had developed the required calibration procedures for the two portable


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radiation survey meters in question. Violation (285/8608-03)1s considered close . Inspector Observations The following are observations the NRC inspector called to the licensee's attention. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requiremen The licensee indicated that these items would be reviewed: Conditional Release of Radioactive Items - The licensee's procedures did not include controls for equipment / tools conditionally released from the radiologically controlled area. See paragraph 4 for additional detail Airborne Radioactivity Area Entry Logs - The licensee's procedures did not require veritication that personnel wearing respirators were authorized to use such equipment. See paragraph 4 for additional detail Protective Clothing Used for Training Purposes - The licensee had used contaminated protective clothing in the training building. See paragraph 5 for additional details.
        ,
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,,7 g Omaha Public +ower District -2-bcc'to DMB (IE06)_.


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bec distrib. by-RIV:
.RPB Resident Inspector R. D. Martin, RA-D. Weiss,LRM/ALF R&SPB
:Section Chief'(RPB/B)
MIS' System'-
RIV File DRSP
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  'RSTS Operator.
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RSB Inspector ._
4. Organization and Management Controls  ,
Section Chief
The NRC inspector reviewed the licensee's C/RP organization and management controls to determine compliance with TS, Section 5.2 requirements and for agreement with commitments in the Updated Safety Analysis Report (USAR)
.WJ'L.. Fisher
Sections 12.1, 12.3, and 1 The NRC inspector verified that the organizational chart contained in the TS agreed with Figure 12.1-1, dated July 1986, of the USAR. The NRC inspector noted that these charts varied somewhat from current personnel assignments. The licensee had supplemented the permanent staff with temporary contractor personnel consisting of four senior health physics (HP)techniciansorspecialistandtenjuniorHPtechnicians.Nineofthe junior HP positions, which were utilized for both operational radiation protection and decontamination effort, were scheduled to be terminated after January 1, 198 The NRC inspector noted that the licensee had reduced the quantity of contaminated areas within the Radiologically Controlled Area (RCA) and approximately 80 percent of the auxillary building can be accessed without protective clothing. However, the licensee plans to reduce the decontamination crew which could reverse this improvement. This concern was discussed with the licensee which stated they would establish permanent staff personnel in the capacity of decontamination worker These persons would be available from the maintenance department and trained in decontamination dutie The NRC inspector discussed with licensee representatives that after January 1,inal.1987, to be marg The the number licensee of oaerational ac(nowedged sup)inspector's the iRC ort HP technicians appeared concern and stated they would review work assignment The NRC inspector reviewed the C/RP group shift logs and observed C/RP personnel and supervisors making tours of the work areas. The NRC inspector reviewed the FCS Radiation Protection Manual, Radiation Protection Procedures, and Operating Procedures for Health Physics Personnel. Procedures and documents reviewed are listed in Attachment The NRC inspector discussed with licensee representatives the Radiation Protection Manual, Section 3, Revision 17, October 17, 198 Section 3.2.2 addresses equipment and/or tools which maybe conditionally released or authorized for long term storage in the uncontrolled area The licensee's procedures do not account for these items in long term storage and could not assure the equipment / tools would be properly controlled. The licensee stated that procedures would be revised to assure that equipment / tools were properly controlle . .
'R. L..Bangart R. E. Hall Project Inspector, RPB-'
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I.


I.
The NRC inspector also discussed Section 3.3.2.2.d wh'ich stated that airborne radioactivity area entry logs would be collected weekly for tabulation of MPC hour The NRC inspector noted that the licensee's procedures do not require verification that personnel issued respirators'
were authorized to wear such equipment. The licensee stated that the NRC inspector observation would be reviewe Technical Specification 5.8.1 reguires that written procedures be established, implemented, and maintained that meet or exceed the minimum re    Appendix A, 7.quirements of Appendix e.(1), requires A of procedures forU.S. NRC Regulatory
  " Access Guide 1.3 Control to Radiation Areas >
Including a Radiation Work Permit System." The licensee had established ProcedureRPP-20,"RadiationWorkPermits(RWP)," Revision 7, November 24, 1986, for completing, interpreting, and using a RWP. Section IV.H.1, states for protective clothing, "These are specified in the appropriate box by portion of body to be protected. All of the items listed are minimum requirements. However . . . items listed may be substituted with different items at the discretion of the Plant Health Physicist or his designated alternate so long as the substituted items provide equal or greater protection."


l l
The NRC inspector reviewed ex) ired and current RWP's and made tours of the RC On December 17, 1986, tie NRC inspector noted that RWP 86-430-1,
        \
" Routine Inspection in Auxiliary Building," specified the following protective clothing requirements: Body-Lab coat; hands-surgeon ,
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gloves cap. In/theinsert gloves; instructions area there were no entries whicu wouldand special allow a deviation from these clothing requirements. However, the NRC inspector noted that personnel were entering the RCA during the period December 1-17, 1986 under RWP 86-430-1 without compling with the clothing requirementsspecifiedontheRWP. The NRC ins]ector informed .he licensees that allowing personnel to enter the RCA without the specified protective clothing was an apparent violation (285/8632-01) ~of station procedure . Training and Qualifications The NRC inspector reviewed the licensee's training program to determine compliance with 10 CFR Part 19.12, TS Section 5.4 and agreement with commitments in Sections 12.2.2 of the USA General Employee Training The NRC ins]ector reviewed lesson plans for general employee training (GET) I, and discussed training, objectives with licensee representatives to determine agreement with FCS Training Manual, Section 2.0, " General Employee Training," Revision 12, February 4, 1985. The NRC inspector also observed selected portions of the training conducted by the licensee.
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,. Radiation Worker Training The NRC ins)ector reviewed lesson plans for Radiation Worker Training (GET II) and discussed train.ing objectives with licensee representatives. The NRC insSector noted that protective clothing used by trainee's contained t1ree hoods that had been previously used in the RCA and were indicating contamination radiation levels of about 0.2 millirem per hour. The NRC inspector brought this to the attention of a contractor instructor who removed the clothing from the training facilit Radiation Protection Staff Training The NRC inspector reviewed the C/RP group training program and discussedtrainingobjectiveswithlicenseerepresentativesto determ(ne compliance with Section 6 of the FCS Training Manua The licensee had started a systems training course for C/HP personnel. This course included the location of pipes and components for the various plant system ~'he T NRC inspector reviewed SARC Audit Report No. 8-86, " Performance, Training, and Qualification of Facility Staff," conducted during the
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period September 15-16, 198 The NRC inspector noted this audit also included as part of the checklist those observations that had been ( identified during previous NRC inspection No violations or deviations were identifie . ALARA Program
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The NRC inspector reviewed the licensee's ALARA program, selected ALARA activities reports, and audit reports to determine agreement with the recommendations of RG .
The NRC inspector verified that the ALARA program as defined in Radiation Protection Manual Section 7, " Operational ALARA Program," Revision 3,


,
March 6, 1986, was being implemente The NRC inspector discussed with licensee representatives the status of
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1986 person rem expenditure The licensee's ALARA goal for 1986 was 129 person-rem. The licensee expected to complete the year with less than 80.0 person-re ,  'The licensee reported radiation exposures for calendar year 1985 on 10 CFR Part 20.407 data was 632 person-rem. A comparison of 10 CFR Part 20.407 data for FCS and the national average for all operating pressurized water reactors as contained in NUREG 0713, " Occupational Radiation Exposure at Commerical Nuclear Power Reactors," for the period 1981-85 is tabulated in Attachment &
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 402/536 4000   - - - -
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          ' f .?,' ! . I March 23, 1987      /
LIC-87-165      l, grg p p g, il i '
l Mr. J. E. Gagliardo, Chief        !
Reactor Projects 8;anch        l U. S. Nuclear Regulatory Commission      '
Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
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References: 1. Docket No. 50-285 T
2. Letter from NRC (J. E. Gagliardo) to OPPD (R. L. Andrews)    l dated February 20, 1987


==Dear Mr. Gagliardo:==
.
SUBJECT: Inspection Report 86-32 The subject inspection report identified a viclation concerning failure to follow procedures. Pursuant to the provisions of 10'CFR 2.201, please find attached the Omaha Public Power District's response to this violation.
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Si_cerely, h]/rffpaJ R. L. Andrews Division Manager Nuclear Production RLA:rge


Attachment c: LeBoeuf, Lamb, Leiby & MacRae      !
The licensee had not experienced any work activities in 1986 which involved greater than 5 person rem exposures. Attachment 3 list those work activities for 1985 which involved greater than 5 person-rem exposure The NRC inspector discussed with licensee representatives the status of ALARA work packages for the refueling outage scheduled for March 198 The ALARA coordinator had not received any outage work packages at the time of this inspection. The licensee stated these work packages were in preparation and would be received by the ALARA coordinator in sufficient time to perform the necessary ALARA revie No violations or deviations were identifie . Confirmatory Radiation Survey The licensee had requested termination of license number SMC-1420 which authorized possession of natural Uranium Hexafluoride (UF ) at the FCS sit The licensee had shipped, during the period April 5-15,1986,52 cylinders containing all the UFg which had been stored in a fenced and locked area northwest of the reMctor facility. The licensee had performed a radiation survey of the storage area and taken 16 surface soil samples for laboratory analysi The NRC inspector conducted a confirmatory radiation survey of the UF storageareawithaTechnicalAssociatesmodelTBM-3Scontaminationm5ter with a lower limit of detectability of 0.01 mr/hr. The NRC inspector identified two small plastic discs, approximately 1 inch in diameter, which measured 0.3 mr/hr at contact within the storage area. The NRC inspector informed the licensee of his survey results. The licensee attempted to locate the radioactive material with a "teletector" type survey meter which was the type of instrument used for the initial survey performed by the licensee, and could not locate the material. The i
1333 New Hampshire Ave., N.W.     .
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Washington, DC 20036    -
licensee then surveyed the area using an Eberline RM-14 count rate meter with a HP-210 probe, located the radioactive material and removed it from the area. The licensee resurveyed the entire storage area with the RM-14 frisker and located one small piece of steel which read 200 counts per minute on contact and removed this item from the are The licensee performed a laboratory analysis on those items removed from the storage area and identified Uranium-235 and Thorium-234 on the plastic discs. The licensee was not able to identify the radioactive material in the small oiece of steel which appeared to be less than the minimum
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Mi . R. D. Martin, Regional Administrator Mr. W. A. Paulsen, NRC Project Manager    _
detectable activity of the laboratory instruments.
Mr. P. H. Harrell, NRC Senior Resident Inspector  " -
1Tf*'l*k#
697 os 45 5124 ag. Employmen Equal 0pportunity
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'      l 7/v    Attachment  i i .      l
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During.an NRC inspection conducted on December 15-19, 1986, a violation of NRC  ;
The NRC inspector discussed with licensee representatives the need to use sensitive instrumentation when releasing items or areas for unrestricted
< . requirements was identified. The violation involved failure to follow proce-  !
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use. The licensee is maintaining the Ut6 storage area locked until the license is officially terminate No violations or deviations were identified.
dures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1986), the violation is listed below:    .
 
$ Violation Failure to follow orocedures
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Technical Specification 5.8.1 requires that written procedures be implemented.
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Procedure RPP-20, " Radiation Work Permit (RWP)", states the RWP specifies the i minimum protective clothing that must be worn in the radiologically controlled  i areas of the plant and that any substitution must provide equal or greater l
. Exit Interview The NRC inspector met with the NRC and licensee representatives denoted in paragraph 1 at the conclusion of the inspection on December 19, 1986. The NRC inspector summarized the scope and findings of the inspection-including the apparent violation in paragra)h 4 and the observations j discussed in )aragraph 3 of this report. T1e licensee stated that the NRC inspector's oaservations would be reviewe :
; protection.
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Contrary to the above,'the NRC inspector determined on December 17, 1986, that i
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personnel were not wr.aring the protective clothing specified on RWP 86-430-1  ;
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for entry into the radiologically controlled area. This_is a Severity Level V
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violation. (Supplement IV) (285/8632-01)
 
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i T OPPD's Response l
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! 1. Reason for Violation. if Admitted Personnel were not wearing protective clothing because they were doing
;  routine inspections in the clean controlled areas under RWP-430-1.


] ~ Beginning December 1, 1986,-the Fort Calhoun Station changed the RWP format from a pre-printed form to a computer generated form. During the
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  , ATTACHMENT 1 DOCUMENTS REVIEWED Radiation Protection Manual Section 1, " Introduction," Revision 2, dated November 26, 1985
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Section 2, " Personnel Protection Control," Revision 32, dated September 24, 1985 Section 3, " Area Control " Revision 17, dated October 17, 1986 Section 4, " Radiation Monitoring," Revision 12, dated April 9, 1986 Section 6, " Radioactive Material Control " Revision 17, dated October 11, 1985 Section7,"OperationalALARAProgram,"devision3,datedMarch6,1986 Radiation Protection Procedures RPP-6 " Radiation Protection Procedure for Protective Clothing and Respiratory Equipment Cleaning," Revision 11, dated July 30, 1985 RPP-8 " Radiological Decontamination," Revision 13, dated October 8, 1986 RPP-17 " Radioactive Source Log Maintenance Use," Revision 3, dated October 8, 1986 RPP-18 " Instrument Selection," Revision 5, dated July 3, 1985 RPP-20 " Radiation Work Permits (RWP)," Revision 7, dated November 24, 1986 Operating Procedures for Health Physics Personnel HP-1A, "Whole Body Count Evaluations," Revision 1, dated October 23, 1986 HP-9, " Contamination Control," Revision 2, dated July 2. 1985 HP-11, "Whole Body Frisking," Revision 1, dated September 27, 1985 HP-13, " Continuous Air Monitoring Instrument Operation," Revision 2, dated April 24, 1986 HP-17, " Control of Personal Radiation Detection / Monitoring Devices," Revision 2, dated October 16, 1986 HP-18, " Personnel Decontamination," Revision 2, dated March 20, 1986 HP-18A " Calculation of Absorbed Dose From Skin Contamination," Revision 0, dated March 19, 1986 HP-28 July 5,"OperationoftheModel89GammaCalibratorSystem,"
1986    Revision 0, dated


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ATTACHMENT 2
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  ' transition, a statement previously included on the pre-printed RWP, which
FCS Annual Person-Rem Versus
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directed that protective clothing was not required in clean controlled ,_ .. l
PWR National Average Year 1981 1982 1983 1984 1985 PWR Average 652 578 592 556 422 FCS 458 217 433 563 632 s
 
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s ATTACHMENT 3 1985 Jobs Over 5 person-rems i  = Job Description    Person-Rem
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-( areas, was omitted from the new form. This change led to personnel who i
3-  Decontamination in Containment    26.102 Delta T Process Loop Modifications    24.542 Health Physics Coverage in Containment    23.250 Inservice Inspection Weld Inspection    19.338
 
were accustomed to the pre-printed RWP continuing in the practice of not  i wearing protective clothing in clean controlled areas. This was consis-  !
tent with Radiation Protection Manual- allowances- for clean controlled  i areas, but was inconsistent with the RWP. This discrepancy posed no  '
i  radiological concerns.
 
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  , 2. Corrective Steos Which Have Been Taken and the Results' Achieved l
Nozzle Dam Installation    16.957 Plu      14.698
  ; 'When this item was brought to OPPD's attentien, action was taken to I
  !. Edd SteamGenerator(/GS/G)
; correct affected RWP's by upgrading those RWP's to include the statement, l j
Current Testing S  Tubes 10.827
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,  Rep ace Polar Crane Feedrail~    9.001
  " Protective clothing should not be worn in clean controlled areas." The
  ' Eddy Current Testing CEA's     7.324 Remote Reactor Vessel Stud Plugs    7.195 Vent Header Replacement    6.241 c Refueling Head Work    5.463 i
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computer program which generates the RWP form was changed to include the direction for non-use of protective clothing in clean controlled areas-which formerly_ appeared on the pre-printed RWP.  .
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3. Corrective Steos Which Nill Be Taken to Avoid Further Violations 1 The corrective steps taken have been effective, and no further action is.
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4. Date When Full Comoliance Will Be Achieved
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; OPPD .is presently in full compliance.
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Latest revision as of 23:32, 18 December 2021

Insp Rept 50-285/86-32 on 861215-19.Violation Noted: Personnel Did Not Wear Protective Clothing Specified on Radiation Work Permit RWP 86-430-1 for Entry Into Radiologically Controlled Area
ML20211Q118
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 02/04/1987
From: Baer R, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211Q091 List:
References
50-285-86-32, TAC-64446, NUDOCS 8703030020
Download: ML20211Q118 (11)
v • d • e


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APPENDIX B

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U.S. HUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/86-32 License: DPR-40 Docket: 50-285

>

Licensee: OmahaPublicPowerDistrict(OPPD)

1623 Harney Street

!

Omaha, Nebraska 68102 Facility Name: FortCalhounStation(FCS)

Inspection At: FCS Site, Blair, Nebraska

'

Inspection Conducted: December 15-19, 1986 i

Inspector:

R. E. Baei, Radiation Specialist, Facilities MMf7 Date Radiological Protection Section I

Approved: / //D;c 77l/6)l(L6/ 8[M/h7 Blaine Murray, Chief, F4cilities Radiological Date

,

Protection Section /

,

l Inspection Summary Inspection Conducted December 15-19, 1986 (Report 50-285/86-32)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation

,

protection program including organization and management controls, training and

, qualifications, ALARA program, and a confirmatory radiation survey.

!

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Results: Within the_ areas inspected, one violation was identified (failure to follow procedures, paragraph 4).

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8703030020 870220 PDR ADOCK 05000285 G PDR

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DETAILS Persons Contacted OPPD

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  • W. G. Gates, Manager, FCS A. Bilau, Radwaste Coordinator
  • J. Brunnert, Supervisor,,0perations Quality Assurance

, R. A. Cords, Senior Technician

  • M. Core, Supervisor, Maintenance C. R. Crawford, ALARA Coordinator

M. L. Ellis, Instrument and Control Coordinator J. J. Fluehr, Supervisor, Station Training J. M.Gasper Hale, $eniorTechnicianManager, Administrative and Training Services D. A. Jacobson, Training Instructor L. T. Kusek, Su)ervisor, 0)erations

  • J. M. Mattice, )lant Healt1 Physicist

'

  • J. Munderloh, Senior Engineer, Nuclear Regulatory and Industrial Affairs
  • L. Roach, Supervisor, Chemistry and Radiation Protection (C/RP)

F. K. Smith, Plant Chemist J. J. Tesarek, Reactor Engineer M. W. Williams, General Employee Training Instructor

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Others G. O. Maloy, Contractor Training Instructor

  • P. H. Harrell, NRC Senior-Resident Inspector The including NRCC insp/RP, administrative, maintenance, and training personnel.ecto
  • Denotes those individuals present during the exit interview on-December 19, 1986.

. Licensee Action on Previously Identified Inspection Findings (Closed) Violation (285/8502-04): Notification of Exposure to Individuals - This item involved the tailure to provide the recuired radiation exposure information within the specified time perioc to workers who had terminated employment. The licensee had sent out the required radiation exposure information and revised their notification procedure regarding radiation workers who had terminated employment. Violation (285/8502-04) is considered closed.

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(Closed) Violation 285/8601-02): Failure To Notify NRC and Individuals of Exposure This (item involved the tailure to provide the recuired radiation exposure information within the specified time aerioc to the NRC

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and workers who had terminated employmen The licensee lad sent out the required radiation exposure information and revised FCS form FC-228 to include a monthly check to ensure compliance. Violation (285/8601-02) is considered close (Closed) Violation (285/8608-01): Failure to Follow Procedures - This

Item involved the failure to retain the calibration data for particulate, iodine, and noble gas monitor number 21 The licensee had recalibrated the monitor in question and had retained the calibration data. Violation (285/8608-01) is considered close (Closed) Violation (285/8608-02): Failure to Submit Special Report - This item involved the failure to submit a s)ecial report to the NRC required by Technical Specifications (TS) when tie wide range noble gas stack monitors RM-063L, M, and H were not operational. The licensee submitted a special report and updated the NRC of the status of the wide range noble gas stack monitors RM-063L M, and H. The monitors had been calibrated andreturnedtooperationalstatus. Violation (285/8608-02) is considered close (Closed) Violation (285/8608-03): Failure to Develop Procedures - This item involved the failure to develop calibration procedures for portable radiation survey instruments received from a new supplier. The licensee

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had developed the required calibration procedures for the two portable

radiation survey meters in question. Violation (285/8608-03)1s considered close . Inspector Observations The following are observations the NRC inspector called to the licensee's attention. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for program improvement, but they have no specific regulatory requiremen The licensee indicated that these items would be reviewed: Conditional Release of Radioactive Items - The licensee's procedures did not include controls for equipment / tools conditionally released from the radiologically controlled area. See paragraph 4 for additional detail Airborne Radioactivity Area Entry Logs - The licensee's procedures did not require veritication that personnel wearing respirators were authorized to use such equipment. See paragraph 4 for additional detail Protective Clothing Used for Training Purposes - The licensee had used contaminated protective clothing in the training building. See paragraph 5 for additional details.

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4. Organization and Management Controls ,

The NRC inspector reviewed the licensee's C/RP organization and management controls to determine compliance with TS, Section 5.2 requirements and for agreement with commitments in the Updated Safety Analysis Report (USAR)

Sections 12.1, 12.3, and 1 The NRC inspector verified that the organizational chart contained in the TS agreed with Figure 12.1-1, dated July 1986, of the USAR. The NRC inspector noted that these charts varied somewhat from current personnel assignments. The licensee had supplemented the permanent staff with temporary contractor personnel consisting of four senior health physics (HP)techniciansorspecialistandtenjuniorHPtechnicians.Nineofthe junior HP positions, which were utilized for both operational radiation protection and decontamination effort, were scheduled to be terminated after January 1, 198 The NRC inspector noted that the licensee had reduced the quantity of contaminated areas within the Radiologically Controlled Area (RCA) and approximately 80 percent of the auxillary building can be accessed without protective clothing. However, the licensee plans to reduce the decontamination crew which could reverse this improvement. This concern was discussed with the licensee which stated they would establish permanent staff personnel in the capacity of decontamination worker These persons would be available from the maintenance department and trained in decontamination dutie The NRC inspector discussed with licensee representatives that after January 1,inal.1987, to be marg The the number licensee of oaerational ac(nowedged sup)inspector's the iRC ort HP technicians appeared concern and stated they would review work assignment The NRC inspector reviewed the C/RP group shift logs and observed C/RP personnel and supervisors making tours of the work areas. The NRC inspector reviewed the FCS Radiation Protection Manual, Radiation Protection Procedures, and Operating Procedures for Health Physics Personnel. Procedures and documents reviewed are listed in Attachment The NRC inspector discussed with licensee representatives the Radiation Protection Manual, Section 3, Revision 17, October 17, 198 Section 3.2.2 addresses equipment and/or tools which maybe conditionally released or authorized for long term storage in the uncontrolled area The licensee's procedures do not account for these items in long term storage and could not assure the equipment / tools would be properly controlled. The licensee stated that procedures would be revised to assure that equipment / tools were properly controlle . .

The NRC inspector also discussed Section 3.3.2.2.d wh'ich stated that airborne radioactivity area entry logs would be collected weekly for tabulation of MPC hour The NRC inspector noted that the licensee's procedures do not require verification that personnel issued respirators'

were authorized to wear such equipment. The licensee stated that the NRC inspector observation would be reviewe Technical Specification 5.8.1 reguires that written procedures be established, implemented, and maintained that meet or exceed the minimum re Appendix A, 7.quirements of Appendix e.(1), requires A of procedures forU.S. NRC Regulatory

" Access Guide 1.3 Control to Radiation Areas >

Including a Radiation Work Permit System." The licensee had established ProcedureRPP-20,"RadiationWorkPermits(RWP)," Revision 7, November 24, 1986, for completing, interpreting, and using a RWP.Section IV.H.1, states for protective clothing, "These are specified in the appropriate box by portion of body to be protected. All of the items listed are minimum requirements. However . . . items listed may be substituted with different items at the discretion of the Plant Health Physicist or his designated alternate so long as the substituted items provide equal or greater protection."

The NRC inspector reviewed ex) ired and current RWP's and made tours of the RC On December 17, 1986, tie NRC inspector noted that RWP 86-430-1,

" Routine Inspection in Auxiliary Building," specified the following protective clothing requirements: Body-Lab coat; hands-surgeon ,

gloves cap. In/theinsert gloves; instructions area there were no entries whicu wouldand special allow a deviation from these clothing requirements. However, the NRC inspector noted that personnel were entering the RCA during the period December 1-17, 1986 under RWP 86-430-1 without compling with the clothing requirementsspecifiedontheRWP. The NRC ins]ector informed .he licensees that allowing personnel to enter the RCA without the specified protective clothing was an apparent violation (285/8632-01) ~of station procedure . Training and Qualifications The NRC inspector reviewed the licensee's training program to determine compliance with 10 CFR Part 19.12, TS Section 5.4 and agreement with commitments in Sections 12.2.2 of the USA General Employee Training The NRC ins]ector reviewed lesson plans for general employee training (GET) I, and discussed training, objectives with licensee representatives to determine agreement with FCS Training Manual, Section 2.0, " General Employee Training," Revision 12, February 4, 1985. The NRC inspector also observed selected portions of the training conducted by the licensee.

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,. Radiation Worker Training The NRC ins)ector reviewed lesson plans for Radiation Worker Training (GET II) and discussed train.ing objectives with licensee representatives. The NRC insSector noted that protective clothing used by trainee's contained t1ree hoods that had been previously used in the RCA and were indicating contamination radiation levels of about 0.2 millirem per hour. The NRC inspector brought this to the attention of a contractor instructor who removed the clothing from the training facilit Radiation Protection Staff Training The NRC inspector reviewed the C/RP group training program and discussedtrainingobjectiveswithlicenseerepresentativesto determ(ne compliance with Section 6 of the FCS Training Manua The licensee had started a systems training course for C/HP personnel. This course included the location of pipes and components for the various plant system ~'he T NRC inspector reviewed SARC Audit Report No. 8-86, " Performance, Training, and Qualification of Facility Staff," conducted during the

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period September 15-16, 198 The NRC inspector noted this audit also included as part of the checklist those observations that had been ( identified during previous NRC inspection No violations or deviations were identifie . ALARA Program

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The NRC inspector reviewed the licensee's ALARA program, selected ALARA activities reports, and audit reports to determine agreement with the recommendations of RG .

The NRC inspector verified that the ALARA program as defined in Radiation Protection Manual Section 7, " Operational ALARA Program," Revision 3,

March 6, 1986, was being implemente The NRC inspector discussed with licensee representatives the status of

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1986 person rem expenditure The licensee's ALARA goal for 1986 was 129 person-rem. The licensee expected to complete the year with less than 80.0 person-re , 'The licensee reported radiation exposures for calendar year 1985 on 10 CFR Part 20.407 data was 632 person-rem. A comparison of 10 CFR Part 20.407 data for FCS and the national average for all operating pressurized water reactors as contained in NUREG 0713, " Occupational Radiation Exposure at Commerical Nuclear Power Reactors," for the period 1981-85 is tabulated in Attachment &

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The licensee had not experienced any work activities in 1986 which involved greater than 5 person rem exposures. Attachment 3 list those work activities for 1985 which involved greater than 5 person-rem exposure The NRC inspector discussed with licensee representatives the status of ALARA work packages for the refueling outage scheduled for March 198 The ALARA coordinator had not received any outage work packages at the time of this inspection. The licensee stated these work packages were in preparation and would be received by the ALARA coordinator in sufficient time to perform the necessary ALARA revie No violations or deviations were identifie . Confirmatory Radiation Survey The licensee had requested termination of license number SMC-1420 which authorized possession of natural Uranium Hexafluoride (UF ) at the FCS sit The licensee had shipped, during the period April 5-15,1986,52 cylinders containing all the UFg which had been stored in a fenced and locked area northwest of the reMctor facility. The licensee had performed a radiation survey of the storage area and taken 16 surface soil samples for laboratory analysi The NRC inspector conducted a confirmatory radiation survey of the UF storageareawithaTechnicalAssociatesmodelTBM-3Scontaminationm5ter with a lower limit of detectability of 0.01 mr/hr. The NRC inspector identified two small plastic discs, approximately 1 inch in diameter, which measured 0.3 mr/hr at contact within the storage area. The NRC inspector informed the licensee of his survey results. The licensee attempted to locate the radioactive material with a "teletector" type survey meter which was the type of instrument used for the initial survey performed by the licensee, and could not locate the material. The i

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licensee then surveyed the area using an Eberline RM-14 count rate meter with a HP-210 probe, located the radioactive material and removed it from the area. The licensee resurveyed the entire storage area with the RM-14 frisker and located one small piece of steel which read 200 counts per minute on contact and removed this item from the are The licensee performed a laboratory analysis on those items removed from the storage area and identified Uranium-235 and Thorium-234 on the plastic discs. The licensee was not able to identify the radioactive material in the small oiece of steel which appeared to be less than the minimum

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detectable activity of the laboratory instruments.

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The NRC inspector discussed with licensee representatives the need to use sensitive instrumentation when releasing items or areas for unrestricted

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use. The licensee is maintaining the Ut6 storage area locked until the license is officially terminate No violations or deviations were identified.

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. Exit Interview The NRC inspector met with the NRC and licensee representatives denoted in paragraph 1 at the conclusion of the inspection on December 19, 1986. The NRC inspector summarized the scope and findings of the inspection-including the apparent violation in paragra)h 4 and the observations j discussed in )aragraph 3 of this report. T1e licensee stated that the NRC inspector's oaservations would be reviewe :

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, ATTACHMENT 1 DOCUMENTS REVIEWED Radiation Protection Manual Section 1, " Introduction," Revision 2, dated November 26, 1985

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Section 2, " Personnel Protection Control," Revision 32, dated September 24, 1985 Section 3, " Area Control " Revision 17, dated October 17, 1986 Section 4, " Radiation Monitoring," Revision 12, dated April 9, 1986 Section 6, " Radioactive Material Control " Revision 17, dated October 11, 1985 Section7,"OperationalALARAProgram,"devision3,datedMarch6,1986 Radiation Protection Procedures RPP-6 " Radiation Protection Procedure for Protective Clothing and Respiratory Equipment Cleaning," Revision 11, dated July 30, 1985 RPP-8 " Radiological Decontamination," Revision 13, dated October 8, 1986 RPP-17 " Radioactive Source Log Maintenance Use," Revision 3, dated October 8, 1986 RPP-18 " Instrument Selection," Revision 5, dated July 3, 1985 RPP-20 " Radiation Work Permits (RWP)," Revision 7, dated November 24, 1986 Operating Procedures for Health Physics Personnel HP-1A, "Whole Body Count Evaluations," Revision 1, dated October 23, 1986 HP-9, " Contamination Control," Revision 2, dated July 2. 1985 HP-11, "Whole Body Frisking," Revision 1, dated September 27, 1985 HP-13, " Continuous Air Monitoring Instrument Operation," Revision 2, dated April 24, 1986 HP-17, " Control of Personal Radiation Detection / Monitoring Devices," Revision 2, dated October 16, 1986 HP-18, " Personnel Decontamination," Revision 2, dated March 20, 1986 HP-18A " Calculation of Absorbed Dose From Skin Contamination," Revision 0, dated March 19, 1986 HP-28 July 5,"OperationoftheModel89GammaCalibratorSystem,"

1986 Revision 0, dated

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ATTACHMENT 2

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FCS Annual Person-Rem Versus

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PWR National Average Year 1981 1982 1983 1984 1985 PWR Average 652 578 592 556 422 FCS 458 217 433 563 632 s

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s ATTACHMENT 3 1985 Jobs Over 5 person-rems i = Job Description Person-Rem

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3- Decontamination in Containment 26.102 Delta T Process Loop Modifications 24.542 Health Physics Coverage in Containment 23.250 Inservice Inspection Weld Inspection 19.338

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Nozzle Dam Installation 16.957 Plu 14.698

!. Edd SteamGenerator(/GS/G)

Current Testing S Tubes 10.827

, Rep ace Polar Crane Feedrail~ 9.001

' Eddy Current Testing CEA's 7.324 Remote Reactor Vessel Stud Plugs 7.195 Vent Header Replacement 6.241 c Refueling Head Work 5.463 i

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