IR 05000285/1985018

Insp Rept 50-285/85-18 on 850826-30.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection Program,Including Organization & Mgt Controls,Training & Qualifications & ALARA Program

ML20133P552
Person / Time
Site:	Fort Calhoun
Issue date:	10/08/1985
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133P550	List: IR 05000285/1985018 ML20133P548
References
50-285-85-18, NUDOCS 8511010055
Download: ML20133P552 (8)

Text

{{#Wiki_filter:APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/85-18 License: DPR-40 Docket: 50-285 Licensee: Omaha Public Power District (OPPD) 1623 Harney Street Omaha, Nebraska 68102 Facility Name: Fort Calhoun Station (FCS) Inspection At: FCS Site, Blair Nebraska Inspection Conducted: August 26-30, 1985 Inspector: R.' M Baer, Radiation Specialist, Facilities

    /C Date
    /8C Radiological Protection Section Approved: i {{fC)llf/}l6Yl   lYk Y Blaine Murray; Chief,/ Facilities Radiological Dato'

Protection Section Inspection Summary Inspection Conducted August 26-30, 1985 (Report 50-285/85-18) Areas Inspected: Routine, unannounced inspection of the ifcensee's radiation protection program including organization and management controls, training and qualifications, and the ALARA program. The inspection involved 35 inspector-hours onsite by one NRC inspector and four inspector hours at the corporate offices.

Results: Within the areas inspected, no violations or deviations were identifie .

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8511010055 051021 PDR ADOCK 05000205 O PDR

  -2-DETAILS Persons Contacted OPPD
*R. L. Andrews, Olvision Manager, Nuclear Production C. L. Brunnert, Supervisor Operations Quality Assurance (QA)

A. G. Christensen, Chemistry and Radiation Protection (C/RP) Technician

*M. R. Christensen, Training Instructor R. A. Cards, C/RP Senior Technician
*F. F. Franco, Manager Radiological Health and Emergency Planning
*J. K. Gasper, Manager Administrative Services D. A. Jacobson, Training Instructor
*R. L. Jaworski, Manager Technical Services
*L. T. Kusek, Supervisor Operations (Acting Plant Manager)
*0. J. Hunderloh, Licensing Engineer A. W. Richards, Supervisor QA
* L. Roach, Supervisor C/RP
*F. A. Thurtell, Olvision Manager, QA
*C. F. Vanecek, Shift Supervisor Others G. O. Maloy, Contractor Training Instructor
*L. A. Yandell, NRC Senior Resident Inspector The NRC inspector also interviewed other Itcensee and contractor employees including C/RP, administrative, maintenance and construction personne * Denotes those individuals present during the exit interview on August 30, 1985. 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 reviewe *

Radiation Protection Manual - Section 1.0 is not consistent with the current plant organization and operatio * Radiation Protection Program PoIIcy_ Statement - The ifconsee does not have a corporate policy statement, as recommended in NUREG-0761, nor is it addressed whether the station radiation protection manager has access to corporate management to discuss radiological safety problem * Training Manual - Section 6.1.2.4 is not consistent with the classification for C/RP technicians and specialists used by the

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  -3-Itcensee, and Section 6.2 does not specify a definite retraining interval for C/RP personne * Trainino Instructor Qualification - Contractor training instructors are not required to have formal training in classroom management, presentation methods, or any instructional teaching method * System Training for ANSI Qualified Technicians - The licensee does not provide C/RP-technicians, considered qualified to ANSI N18.1-1971 criteria, with a plant systems training cours * General Employco Training - The method and sequence for the removal of protective clothing being taught by the contractor instructor was not consistent with good working practices or as recommended in the
" General Employee Training Radiation Protection Manual" student handout provided by the license * Respirator Trainina - The licensee had not maintained records to verify respirator fit test and percentage of penetration result This item had also teen previously identified in NRC Inspection Report 50-285/84-0 * ALARA - Organization and program appears weak in the areas of:

procedures, caffned responsibilities, assigned duties, authority, and management commitment.

3. Organization __and Management Controls The NRC inspector reviewed the Ifcensee's C/RP organization and management controls to determine compliance with FCS Technical Specifications (TS) Section 5.2 requirements and commitments in the updated Safety Analysis Report (USAR) Sections 12.1, 12.3, and 1 The NRC inspector verffled that the organization chart contained in the TS agreed with figure 12.1-1, dated July 1985, of the USAR. The NRC inspector observed that the licensee's Radiation Protection Manual, which includes the organization and management controls for the C/RP Group in Section 1.0, was not in agreement with the current TS, USAR, or position descriptions for C/RP first line supervisor This was brought to the attention of Ilconsee representatives who stated that Section 1.0 of the Radiation Protection Manual would be revise The NRC inspector discussed with Ilcensee representatives lines of access for the Radiation Protection Manager (RPM) to corporate management in order to discuss radiation safety problems that might not be adequately resolved at the plant leve The licensee stated that a means of communi-cation exist between the RPM and corporate management, but that it is not formally designated in writirn1 The plant organizational chart shows the RPM reporting directly to the plant manager. The inspector also discussed the lack of a written management policy statement to support the radiation protection program as recommended in NUREG-076 The NRC inspector discussed with ifconsee representatives the availability of a backup to

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j the RP The licensee stated that, at present, onsite individuals , available to backup or replace the RP do not meet published RPM i qualification criteri However, corporate level personnel are available l who are RPM qualified.

) The NRC inspector verified that position descriptions adequately defined I the responsibilities and authority for the C/RP staf There had been l 1ess than ten percent turnover in Radiation Protection personnel during i

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i the past 12-months. There appeared to be a sufficient number of health l physics personnel, nineteen including one contractor technician, to  !

! carry out the Radiation Protection Progra l t

j The NRC Inspector reviewed Safety Audit Review Committee (SARC) [ Audit No.6-84 conducted during the period December 19-29, 1984, on the ! Chemistry and Radiation Protection Program. This audit included j chemistry, radiation protection, and environmental 01cments of the , l licensee's program. Audit findings were responded to in a timely manne ) The NRC inspector reviewed those procedures listed in Attachment I which j had been issued or changed since the previous radiation protection i

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; No violations or deviations were identiffe i (      r 4. Training and Qualifications    i l

The NRC inspector reviewed the licensee's training ptogram to determine l compliance with 10 CFR Part 19.12, TS-Section 5.4, and commitments in '

] Section 12.2.2 of the USA '

J Caneral Employee Trainino i l' The NRC inspector reviewed lesson plans for general employee training , l and discussed training objectives with licensee representativet, to L } determine agreement with FCS Training Manual Section 2.0 " General l l Employee Training", Revision 12, February 4,1985. The NRC inspector ,

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also observed selected portions of the training conducted by a ' i contractor instructo The NRC inspector noted that the method of ; j taping clothing seams and the sequence for removal of protective

{ clothing was not consistent with acceptable working practices or ,

1 those recommended by the licensee in their " General Employee Training l

Radiation Protection Manual" which is distributed to each student, i f The NRC inspector discussed this inconsistency with the instructor ! and ifcensee representatives. The NRC inspector also noted that the l licensee had not documented the percentage of leakage experienced

: during the respirator fit testin This item had & iso been  ,

i previously identified in NRC Inspection Report 50-285/85-0 The :

Itcensee stated that they had experienced difficulty in the [ ! operability of the respirator fit testing recorder and that a new j test booth with the associated electronic hardware was on orde ! i

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, Radiation Protection Staff Training The NRC inspector reviewed the C/RP Group Training Program and discussed training objectives with licensee representatives to j determine compliance with Section 6 of the FCS Training Manual.

) The NRC inspector determined that: (1) Section 6.1.2.4 does not , address those classifications for technicians the Ifcensee presently employs. (2) Section 6.2 does not address a frequency for retraining, j and (3) Section 6.2.2 does not address new procedures or changes to i existing procedures.

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; The NRC inspector noted that the initial C/RP Training Program for i new employees was a comprehensive course which included reactor I

systems training; however, there is no reactor system training made j available for experienced personnel who are considered ANSI N18.1-1971 f qualified.

I i The NRC inspector reviewed $ ARC Audit Number 7.84, " Performance, Training,

and Qualification " conducted during the period November 13-15, 1984, it

, was noted that the personnel conducting this audit also had difficulty retrieving information regarding C/RP personne j The NRC inspector discussed with ifconsee representatives the qualifications j of training instructor Personnel on the TCS training staff received . specialized training on methods cf instruction and presentation, but contractor personnel are not required to attend or have attended any il formal classes on these subjects. The NRC inspector noted that a contractor i instructor had difficulty in presenting his assigned lecture in an effective ! manner to new personne No violations or deviations were identifie S. Maintaintna Occupational Exposurns ALARA 1 The NRC inspector reviewed the Ilconsee's ALARA Program, selected ALARA activities reports, and audit reports.

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1 The NRC inspector verified that the ALARA Program was defined in Section 7. " Operational ALARA Program " of the Radiation Protection Manual j and incorporated the charter for the " Operational ALARA Committee," which

! included the major topics of committee function, composition, meeting i frequency, responsibilities, authority, and records. Other supporting l documents of the ALARA Program are standing order G 50 "ALARA Radiation j Exposure Program" and Corporate Policy Number 9.03 "OccupatIanal Radiatfon

Exposure ALARA." The NRC inspector noted that the ALARA committee was

! composed primarily of first-line supervisors and could not resolve ALARA { issues, but only make recommendations to the Plant Review Committee (PRC).

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  -6-The NRC inspector determined that for jobs requiring the expenditure of greater than 10 man rem exposure, Section 7.5.2.4, requires that " previous ALARA techniques used in similar work and an evaluation of the effectiveness" be utilized. There is no method to effectively document previous similar work experience that has taken place prior to the implementation of the present ALARA Program or to canvas other licensee ALARA coordinators to utilize their experience The NRC inspector followed the ALARA committee's attempt to reduce entries into the containment building under reactor power conditions. The practice of routine entries to perform unnecessaiy work or verify that cartain abnormal indications were not due to equipment in the containment building were documented in November 198 The ALARA committee determined they needed to reduce the incidents of entries at power. A draft standing order G-59, " Operational Containment Entry Evaluation" which requires an adequate evaluation of the condition prior to entry into the containment building was prepared and submitted to the PRC for approval in April 198 At the time of this inspection the PRC had not taken any action to either approve or disapprove this draf t standing orde The ALARA program appears to be weak in the verification of detailed ALARA reviews of proposed design changes and station modifications. The FCS ALARA committee does not initiate or verify that adequate reviews have been performed. The committee does not appear to be involved in ongoing methods to prevent the buildup of reduction of crude concentrations within primary systems and the defining of station and corporate involvement in the ALARA program lacks guidanc The NRC inspector noted that the Ilcensee had reported 10 CFR Part 20.407 radiation exposures for the year 1984 based on direct reading dosimeter data as 544.57 man-rem, but that the thermoluminescent dostmeter value, which is the value of record, was 499.4 man rem. Attachment 2, lists work activities which involved greater than 5 man-rem exposure The NRC Inspector reviewed audit report Number 59, "ALARA Program" conducted during the period January 29 31, 1985. Three audit findings ware identified, one pertaining to the RWP ALARA work sheets not being completely filled out, two relating to whole body countinC and one relating to the processing of dostmeter badges. The licensee responded to the audit findings in a timely manne No violations or deviations were identifie . Exit Interview The NRC inspector met with the FCS NRC senior resident inspector and licensee representatives denoted in paragraph 1 at the conclusion of the inspection on August 30, 198 The NRC Nspector summarized the scopo and findings of the inspection including the observations expressed in Paragraph 2 of thfa report, the Itcensee stated that the observations would be reviewe . _ . . _ _ . . . . . . _ _ _ _ _ _ _ _ _ _ _ . _ . _ ~ - . - _ . _ . _ _ _ . _ - _ . . - - _ .

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.f ATTACHMENT 1 i i j Procedures Reviewed l j RPP-2, Radiation Protection Procedure for Control Area Injury, Revision 7 December 14, 1984

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j RPP-6, Radiation Protection Procedures for Protective Clothing and , l Respiratory Equipment Cleaning, Revision 10, June 13,1985 i j RPP-6, Small Equipment Decontamination, Revision 8. June 13, 1985 i  ;

} RPP-14 In-Plant Collection and Disposal of Radioactive Waste, Revision 2,   '

1 June 18, 1985 i

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RPP-17, Radwaste Source Log Maintenance Use, Revision 2, May 13, 1985 I

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i l i RPP-20, Radiation Work Permits (R' iip), Revision 3, February 12, 1985 l i HP-1, Whole Body Counting, Revision 6, June 19, 1985 l ] ' HP-8 Labeling and Bagging of Radioactive Materials, Revision 3, ,

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( HP-12 Outside Storage and Movement of Radioactive Waste, Revision 1,

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May 7, 1985  ; I i ! HP-18 Personnel Decontamination, Revision 1. July 1, 1985  ! J l

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i l! ATTACHMENT 2

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JOB 5 INVOLVING GREATER THAN 5 MAN-REM EXPOSURE IN 1984

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MAN-REM '

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i AFC JOB DESCRIPTION EXPOSURE

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) 63-83 Replace Spent Fuel Pool Racks 8.258

! 013-84  Refueling Head Work   5.424 ;

016-84 Reactor Coolant Pump Motor Coupling 6.026 ] 024-84 Replace Excore Cables 6.431 1 033-84 Inservice Inspection WSLD Inspection 12.908 i

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034-84 Steam Generator Eddy Current Testing 5.446 056-84 Steam Generator Rim Cut Work 8.510 066-84 Remove Reactor Vessel STUD Plugs 7.304 j 062-84 Install / Remove Steam Generator Eddy j Current Test Equipment 5.993 i ! 076 84 Steam Generator Eddy Current Testing 8.260

} 076-84 Steam Generator Leak Inspection 7.896

i 086-84 furmanite PCV103-1 8.734 l

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{ 087-84  Furmanite PCV103-1   6.088 l 018-84  Reactor Coolant Pump seal and l   Gasket Replacement   21.499 l 034-84  Steam Generator Eddy Current Testing  10.297 ;
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i ! 056-84 Steam Generator Rim Cut Work 32.722

l 087-84 "A" Steam Generator Tube Removei 17.478 i j 089-84 Repair PCV 103-1 and 2 10.147

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j 149 QC Inspection and Testing 17.046

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