IR 05000285/1998006

Insp Rept 50-285/98-06 on 980406-10.Violations Noted.Major Areas Inspected:Plant Support

ML20217N099
Person / Time
Site:	Fort Calhoun
Issue date:	04/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217N065	List: ML20217N061 ML20217N093 ML20217N099
References
50-285-98-06, 50-285-98-6, NUDOCS 9805050220
Download: ML20217N099 (14)

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l ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-285  ;

License No.: DPR-40 Report No.: 50-285/98-06 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: Fort Calhoun Station FC-2-4 Adm., P.O. Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates: April 6-10,1998 Inspector: Larry Ricketson, P.E., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch

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Division of Reactor Safety l

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Attachment: Supplemental information i

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9905050220 990430 PDR ADOCK 05000295 G PDR

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-2- I EXECUTIVE SUMMARY Fort Calhoun Station NRC inspection Report 50-285/98-06 This routine, announced inspection reviewed radiation protection activities in support of the 1998 refueling outage. Included in the inspection were reviews of planning and preparation, the ;

program for maintaining occupational exposures as low as is reasonably achievable (ALARA), I exposure controls, surveying and monitoring, and radiation worker practice Plant Sucoort ,

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The licensee prepared well for the refueling outage and the effects of leaking fue j Additional engineering controls were used, additional time was included in the shut down schedule, and additional radiation worker training was provided (Section R1.1). l

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Radiation protection performance was good, overal l

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A good ALARA program was implemented with isolated exceptions. Generally, planned work activities were reviewed thoroughly by ALARA personnel and dose saving i measures were integrated appropriately. ALARA prejob briefings were effective in ;

communicating potential radiological hazards and good radiation protection practices to l radiation workers (Section R1.1).

l . Isolated weak ALARA program elements, involving the evaluation of the effects of dose gradients on dosimetry location and the procedural guidance for evaluating the need for respiratory protection equipment, were noted (Section R1.2).

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Good radiation exposure controls were implemented, in most cases, and good job coverage was provided by radiation protection personnel (Section R1.3).

! . Surveying and monitoring were performed properly and effective contamination controls were used (Section R1.4).

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Declining radiation worker performance was noted. Problems involving improper entry into high radiation areas, dosimetry use, and contamination control were identified (Section R1.5).

. A noncited violation was identified when individuals entered a high radiation area improperly. Discretion was exercised in accordance with Section Vll.B.1 of the NRC Enforcement Policy. However, a violation of Technical Specification 5.11 was identified when another radiation worker entered a restricted high radiation area improperly (Section R1.5).

. A noncited violation was identified when an individual entered the reactor containment building without a thermoluminescent dosimeter. Discretion was exercised in accordance with Section Vll.B.1 of the NRC Enforcement Policy (Section R1.5).

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Contractor radiation protection technicians were qualified and properly screened (Section RS).

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. Reoort Details Summarv of Plant Status The licensee was condu: ting a refueling outage. The inspection was conducted during days 6-10 of the refueling outage. By the end of the inspection, the licensee had begun preparations for mid-loop activitie IV. Plant Sunoort R1 Radiological Protection and Chemistry Controls R Plannina and Preoaration Insoection Scooe (83729 and 83750)

The inspector interviewed licensee personnel about the actions taken in preparation for the refueling outag Observations and Findinas The licensee anticipated problems caused by leaking fuel elements. To address the airbome iodine, the licensee added charcoal filters to the auxiliary building exhaust {

ventilation and containment purge exhaust ventilation. Containment charcoal ventilation units were utilized during the operating cycle. Also in an effort to reduce the amount of radioactive gases, power was reduced in stages rather than shutting down the plant more abruptly, it was reduced to 70 percent for 3 days; then it was reduced to 30 percent for 3 days,. Appropriate time was planned in the outage schedule for a reactor coolant cleanup. The reactor building was purged periodically to reduce airborne radioactivity level Radiation protection personnel provided preoutage training to craft personnel to instruct them in problems and hazards caused by the leaking fuel. To keep radiation doses below administrative dose limits, the licensee initiated a program of planned, personnel evacuations, when noble gas levels in the containment building reached a level that could produce a dose rate of 15 millirems / hou According to radiation protection personnelinterviewed, adequate supplies of radiation detection instruments, protective clothing, and consumable items were availabl Conclusions The licensee prepared well for the refueling outage and the effects of leaking fue APitional engineering controls were used, additional time was included in the shut down scheLule, and additional radiation worker training was provide .

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-5-R1.2 Maintainino Occuoational Exoosures ALARA Insoection Scoce (83729 and 83750)

The inspector interviewed ALARA representatives and reviewed the following:

. ALARA work packages

. ALARA prejob briefings Observations and Findinas ALARA personnel were provided with sufficient time to review planned work activities and incorporate dose saving measures. ALARA/ radiation work packages were completed prior to the start of the outag The inspector reviewed selected examples of ALARA work packages and concluded that thorough reviews were performed, in most cases. However, the inspector noted two areas with potential vulnerabilities. One area involved the evaluation of the effects of dose gradients on dosimetry location and the other involved procedural guidance for evaluating the need for respiratory protection equipmen An example of the first item was identified during a review of the preparation for heated thermocouple venting, performed in ac;;ordance Radiation Work Permit 98-2501,

" Reactor Head Work in High Radiation Areas." The historicalinformation in the ALARA work package alerted ALARA personnel that dosimetry worn by personnel working on the reactor head should be relocated, if necessary. This ensured measurement of the dose to the part of the who!e-body exposed to the highest dose rate. Procedure RP-201,

" Radiation Work Permits," Revision 14, provided guidance for relocating dosimetry to a specific whole-body location other than the chest when that part will consistently receive more exposure due to the worker's position or dose gradient. The surycy used during the ALARA prejob briefing indicated dose rates of 50-75 millirems / hour, however, the work area survey only provided dose rates at waist height. The ALARA planner had not sought the additional survey information necessary to thoroughly review the potential need for relocation of personnel dosimetr l

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Licensee representatives acknowledged the inspector's comment and advised workers j to relocate dosimetry devices to the lower thigh during this particular work activit l Additionally, the radiation protection technician providing job coverage for heated thermocouple venting was instructed to conduct a comprehensive radiation survey of the work area by measuring dose rates at different heights. Following the completion of ,

heated thermocouple venting, the inspector reviewed the job survey record and noted l that the dose rates at chest height and lower thigh height were not significantly different, in this case. However, the inspector concluded that the process used by ALARA personnel to evaluate the effect dose gradients on the placement of dosimetry was weak, in this exampl l l

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i-6-l l Another potential vulnerability involved the guidance provided to ALARA planners by Procedure RP-201, " Radiation Work Permits," Revision 14. The procedure provided guidance for determining if respiratory protection equipment was warranted to maintain the total effective dose equivalent low. Through the use of estimated or historical radiological data in specified equations, the ALARA planners could predict the need for respiratory protection equipment. However, the procedural guidance did not instruct ALARA planners to reevaluate the need for respiratory protection equipment when the actual radiological conditions were known. The inspector concluded that the guidance was weak because it instructed the ALARA planner how to predict the need for respiratory protection equipment but not to confirm the prediction, once actual radiological information was available. The inspector reviewed selected ALARA work packages and found that ALARA planners had used actual data when it became available despite the lack of procedural guidance. The inspector concluded that the personnelinitiative of the ALARA planners compensated for the procedural weaknes The inspector attended ALARA prejob briefings on both the day and night shifts. Overall, ALARA prejob briefings were conducted well. The meetings were free of interruptions and resulted in good exchanges of information related to the werk assignments, the potential radiological hazards in the specific work areas, and the radiation protection practices necessary to work safel Conclusions A good ALARA program was implemented with isolated exceptions. Generally, planned work activities were reviewed thoroughly by ALARA personnel and dose saving measures were integrated appropriately. ALARA prejob briefings were effective in communicating potential radiological hazards and good radiation protection practices to radiation workers. Isolated weak ALARA program elements, involving the evaluation of the effects of dose gradients on dosimetry location and the procedural guidance for evaluating the need for respiratory protection equipment, were note R1.3 Exoosure Controls Insoection Scoos (83729 and 83750)

. Radiation work permits

. Radiological area posting

. High radiation area controls

. Dosimetry use

. Radiation protection job coverage Observations and Findinas l Radiation work permits provided appropriate guidance to radiation workers. Radiological

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measurements in the containment building and confirmed that radiation area boundaries were properly located. High radiation area controls were properly maintained; however, I

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-7-there were examples of radiation workers entering high radiation areas and restricted high radiation areas improperly. These examples are discussed in Section R Radiation workers wore dosimetry properly, with one exception. This example is also discussed in Section R Radiation protection coverage of work activities within the cor.tainment building was good; however, the inspector noted that radiation protection technicians were not always conspicuous. It was only when they were carrying radiation detection instruments that they were distinguishable from the other radiation workers in ant-contamination clothin The licensee acknowledged the inspector's comment but made no commitment The presence of leaking fuel caused additional challenges that had to be addressed by the radiation protection organization. The electronic, alarming dosimeters used by the licensee were not capable of measuring the radiation doses caused by noble gas because they resulted from low energy radiation. In order to update radiation worker dose information when noble gas was present in significant concentrations, radiation protection personnel had to take compensatory actions. Radiation protection personnel calculated the deep dose equivalent resulting from noble gasec, read and recorded the deep dose measured by the electronic alarming dosimeters, turned off the electronic, alarming dosimeters manually, added the deep dose to the calculated dosed, and entered the new information into the access control computer system. This process proved cumbersome because of the amount of work that had to be accomplished manually for each radiation worker. At one point on April 8,1998, radiation protection personnel were unable to keep the dose information updated. Radiation protection personnel confirmed that 43 radiation workers returned to the radiological controlled area before radiation protection personnel could complete their calculations and update the radiation workers' dose margins. The licensee documented these situations in Condition Report 19980072 Procedure SO-G-101 requires that personnel working in a radiological controlled area remain knowledgeable of their exposure and margin. In the examples in which radiation workers returned to the radiological controlled area before their dose totals were updated, they could not remain knowledgeable of their true dose margins. The failure to ,

follow the instruction in Procedure SO-G-101 was identified by the inspector as a j violation of Technical Specification 5.8.1, which requires the licensee establish, !

implement, and maintain procedures listed in Appendix A of Regulatory Guide 1.33. The inspector determined that in these cases there was no significant potential to exceed ,

regulatory dose limits. This failure constitutes a violation of minor significance and is l being treated as a noncited violation consistent with Section IV of the NRC Enforcement 1 Policy (50-285/9806-01).

c. Conclusions l

Good radiation exposure controls were implemented, in most cases, and good job coverage was provided by radiation protection personne !

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-8-R1.4 Survevina and Monitorina

Insoection Scooe (83729 and 83750)

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- Radiation area surveys 1

= Air sampling results )

Controls of radioactive material and contamination l

. Radiation detection equipment and calibration

. Whole-body counting t

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Radiation surveys were generally documented well and easily understood. One weak aspect of the radiation protection surveys, involving the documentation of radiation dose gradients, is discussed in Section R1.2. Radiation protection personnel maintained current knowledge of airbome radioactivity levels through air sampling. The results were documented properly. The radiation detection instruments observed by the inspector were response-tested properly and were used within the allowable calibration interval l The inspector observed the survey and release of items from the radiological controlled area and identified no problem Radiation protection personnel made personnel contamination log entries every time an

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individual was unable to pass personnel contamination monitors without an alarm. The l inspector noted that many of the personnel contamination log entries resulted from individuals unable to successfully pass the personnel monitors because of the presence of noble gases. The inspector asked radiation protection personnelif an attempt was made to trend the personnel contamination events that resulted from other than noble gases. The inspector commented that such information could be used to identify

[ negative radiation work practices. Licensee personnel stated that no attempt was made l

to discriminate between contamination events resulting noble gases and events occurring for other reasons, but they acknowledged the potential use of such information.

L l Conclusions Surveying and monitoring were performed properly and effective contamination controls were use R1.5 Radiation Worker Practices Insoection Scooe (83729 and 83750)

I The inspector interviewed licensee representatives and attended an all-hands briefing involving radiation worker practices. Additionally, the inspector reviewed the following:

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. Selected condition reports i

. Selected radiation work permits j

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. b. Observations and Findinas At the start of the inspection, licensee representatives informed the inspector of three examples of workers failing to meet radiation worker requirement ;

l Descriotion of Occurrences i On April 4,1998, two contract employees were observed entering a room posted as a high radiation area. The individuals were not working in accordance with a radiation work permit that allowed entrance into a high radiation area. According to the electronic dosimeter records, the radiation dose received by each individual i was 2 millirems. The occurrence was documented in Condition Report i 199800651, On April 4,1998, an individual entered a restricted high radiation area (a high radiation area with dose rates greater than 1000 millirems / hour) to perform wor After a while, the individual's electronic, alarming dosimeter alarmed, and radiation protection personnel instructed the individual to leave the radiological controlled area. The individual had attended a prejob briefing in accordance with Radiation Work Permit 98-3512 and had been informed of the radiological conditions in the work area and the special requirements of the radiation work permit. Radiation protection personnel had provided continuous coverage, as required by the radiation work permi Licensee representatives determined that the individual entered an incorrect radiation work permit number into the access control computer. Instead of Radiation Work Permit 98-3512, the proper radiation work permit for the work activity, the individual entered Radiation Work Permit 98-101, a general radiation work permit that the individual had used previously. The occurrence might not have been identified, except that the individual's electronic, alarming dosimeter alarmed at a lower dose because the alarm set points were dictated by Radiation Work Permit 98-101, rather than 98-3512. Radiation Work Permit 98-101 did not allow entry into restricted high radiation areas and required electronic, alarming dosimeter set points of 20 millirems for dose and 80 millirems / hour for dose rat Radiation Work Permit 98-3512 allowed entry into restricted high radiation areas and required electronic alarming dosimeter set points of 200 millirems for dose and 200 millirems / hour. The individual received 21 millirems during the entry into the radiological controlled area. The occurrence was documented in Condition Report 19980065 . On April 5,1998, an individual did not wear his thermoluminescent dosimeter into a radiation area. The individual's thermoluminescent dosimeter was found attached to his security badge at the containment building access poin Licensee representatives stated that, although the individual did not wear his thermoluminescent dosimeter, he wore an electronic, alarming dosimeter. The electronic, alarming dosimeter indicated that the individual received a radiation dose of only 1 millirem before the problem was identified, and the individual was

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-10-l instructed to leave the radiological controlled area. The occurrence was l- documented in Condition Report 199800659, Licensee representatives stated that these three occurrences indicated a negative trend in radiation worker practices. As corrective action to prevent recurrence, licensee -

, management instructed radiation workers to attend an all-hands briefing to discuss the i

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occurrences and to emphasize the need to follow radiation worker requirement Briefings were conducted April 6,199 On April 7,1998, a fourth radiation worker problem occurred. In the fourth occurrence, .

licensee representatives observed an operator in a restricted high radiation area without continuous radiation protection coverage. The occurrence was documented in Condition Report 199800072 NRC Analvsis Three of the four occurrences involved personnel entry into high radiation area j Technical Specification 5.11 requires that entrance into high radiation areas be controlled by radiation work permits. It also requires that any individual or group of individuals permitted to enter such areas be provided with or accompanied by one or more of the following: A radiation device which continuously indicates the radiation dose rate in the are c A radiation device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is reached. (Entry with this

! monitoring device may be made after the dose rate level in the area has been

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established and personnel have been made knowledgeable of dem.) . i An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. (This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the radiation i

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protection manager or the radiation work permit.)

The inspector concluded that the individuals involved in the first occurrence did not comply with the requirements of Technical Specification 5.1 * The individuals were not working in accordance with a radiation work permit issued to control entry into the high radiation area. - The individuals were working in accordance with a general radiation work permit (98-101) that allowed entry into only radiation areas, contaminated areas, and airborne radioactivity areas. This is a violation of Technical Specification 5.11. The licensee excluded the individuals from the radiological controlled area and conducted an all-hands meeting to discuss the importance of meeting radiation worker requirement This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-285/9806-02)

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-11-The inspector concluded that individual involved in the second occurrence met the intent of Technical Specification 5.11. The individual attended the Wejob briefing for the correct radiation work permit. Therefore, the individual was knowledgeable of radiological conditions in the area and of the requirements of the radiation work permi The individual was provided with a radiation device which continuously integrated the radiation dose rate in the area and alarmed when a preset integrated dose was reached (a lower dose than allowed by the correct radiation work parmit) and was accompanied by an individual qualified in radiation protection procedures who was equipped with a radiation dose rate monitoring device. The only thing done incorrectly was that the proper radiation work permit number was not entered into the access control compute This was not performed in accordance with Procedure SO-G-101, " Radiation Worker Practices," Revision 9, Section 5.5.2, which requires that persons entering the radiological controlled area enter the last four digits of the radiation work permit to be used into the access control computer. Therefore, this was a violation of Technical Specification 5.8.1, which requires the licensee establish, implement, and maintain procedures listed in Appendix A of Regulatory Guide 1.33. Because the individual was properly instructed and overseen, there was no negative impact on safety. This failure constitutes a violation of minor significance and is being treated as a noncited violatio l consistent with Section IV of the NRC Enforcement Policy (50-285/9806-03). 4

The individual involved in the third occurrence violated the requirements of Procedure SO-G-101, bection 5.3.2.F which requires that personnel entering the  !

radiological controlled area be monitored for external radiation exposure by use of a thermoluminescent dosimeter and a direct reading or electronic dosimete Thermoluminescent dosimeters are used by the licensee to provide information for radiation workers official dose records. This is a violation of Technical Specification 5. which requires that procedures and administrative policies be established, implemented, and maintained that include the items in Appendix A of Regulatory Guide 1.3 The licensee excluded the individual from the radiological controlled area and conducted an all-hands meeting to discuss the importance of meeting radiation worker requiremer.'J. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-285/9806-04).

The individual involved in the fourth occurrence did not comply with the requiremeNs of Technical Specification 5.11. The individual's radiation work permit (98-0011) alloe 9d entry into restricted high radiation areas if continuous radiation protection coverage was provided. The ir,dividual did not have continuous radiation protection coverage and, therefore, aid not comply with radiation work permit requirements. The licensee's actions to prevent occurrences such as described in Occurrence No.1 were not effective. This is a violation of Technical Specification 5.11 (50-285/9806-05).

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Mditional Observations During tours of the reactor containment building, the inspector observed radiation worker pro ces. Numerous minor problems were noted as radiation workers removed

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-12-anticontamination clothing after exiting the cont ?inment building. It is likely that this situation existed because many of the radiation workers had never worked at a nuclear facility previously. Licensee representatives stated that 499 contractor employees were provided personnel monitoring. Of these,173 had not been monitored previously at the I licensee's site or others. The inspector noted that radiation protection personnel provided good oversight of undre; sing activities and were quick to coach radiation workers in the proper radiation protection technique Conclusions

, Declining radiation worker performance was noted. Problems involving improper entry into high radiation areas, desimetry use, and contamination control were identifiecl. A noncited violation was identified when an individual entered the reactor containment building without a thermoluminescent dosimeter. Discretion was exercised in accordance with Section Vll.B.1 of the NRC Enforcement Policy. A noncited violation was identified when individuals entered a high radiation area improperly. Discretion was exercised in accordance with Section Vll.B.1 of the NRC Enforcement Policy. However, a violation of Technical Specification 5.11 was identified when another radiation worker l entered a restricted high radiation area improperl R5- Staff Training and Qualification j Insoection Scoos (83729 and 83750)

-. The inspector reviewed selected resumes of cor, tractor radiation protection technicians and interviewec' the individual responsible for screening applicants. ;

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L Contractor radiation protection technicians had sufficient experience in radiation protection activities to meet the requirements of Technical Specification Conclusions l l

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Contractor radiation protection technicians were qualified and properly screene V. Management Meetings  ;

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X1 Exit Meeting Summary i

The inspector presented the inspection results to members of licensee management at an exit :

meeting on April 10,1998. The licensee acknowledged the findings presented. No proprietary information was identifie )

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ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee J. Chase, Plant Manager S. Gambhir, Engineering and Operations Division Manager G. Gates, Vice President S. Gebers, Radiation Protection Manager R. Hamilton, Chemistry Manager R. Haug, Corporate Health Physicist R. Hodgson, ALARA Supervisor T. Jamieson, Radiological Operations Supervisor C. King, Health Physicist M. Puckett, Radiologica! Operations Supervisor K. Steele, Containment Coordinator (Nights)

T. Thompson, Radiological Operations Shift Technician C. Williams, ALARA Technician

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NEG V. Gaddy, Resident inspector W Walker, Senior Resident inspector l

l INSPECTION PROCEDURES USED 83729 Occupational Exposure During Extended Outages 83750 Occupational Radiation Exposure ITEMS OPENED. CLOSED. AND DISCUS.c"S Orened 60-285/9806-01 NCV Radworkers were not knowledgeable of dose margins 50-285/9806-02 NCV Failure to comply with Technical Specification 5.11 50-285/9806-03 NCV Failure to enter correct radiation work permit number 50-285/9806-04 NCV Failure to wear thermoluminescent dosimeter 50-285/9806-05 VIO Failure to comply with Technica! Specification 5.11

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. l Closed 50-285/9806-01 NCV Radworkers were not knowledgeable of dose marginn

.50-285/9806-02 NC Failure to comply with Technical Specification 5.11 50-285/9806-03 NCV Failure to enter correct radiation work permit number 50-285/9806-04 NCV Failure to wear thermoluminescent dosimeter LIST OF DOCUMENTS REVIEWED Procedures SO-G-101 Radiation Worker Practices, Revision 9 RP-201 Radiation Work Permits, Revision 14 RP-201 Radiological Surveys, Revision 12 RP-204 Radiological Area Controls, Revision 23 RP-205 DAC-Hour Tracking, Revision 4 RP-301 ALARA Job-Reviews, Revision 13 RP-606 - Special Dosimetry Issue, Control and Use, Revision 7 RP-608 Skin Dose Calculations, Revision 7 -

Condition Reports 199800473 199800651 199800655 199800659 199800720'

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