ML20141E125

Insp Rept 50-285/85-25 on 851104-08.No Violation or Deviation Noted.Unresolved Items Identified:Lack of Documentation for Calibr of Constant Air Monitoring Instrumentation & Inoperability of Gas Stack Monitor

ML20141E125
Person / Time
Site:	Fort Calhoun
Issue date:	12/13/1985
From:	Baer R, Murray B, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141E109	List: ML20141E103 ML20141E125
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-285-85-25, NUDOCS 8601070565
Download: ML20141E125 (13)

See also: IR 05000285/1985025

Text

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APPENDIX

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1,

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/85-25 License: DPR-40

Docket: 50-285

Licensee: Omaha Public Power District (OPPD)

1623 larney Street

Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station (FCS)

Inspection At: FCS Site, Blair, Nebraska

Inspection Conducted: November 4-8, 1985

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Inspectors:

R. 4. Baer, Radiation Specialist, Facilities

/ M TA/ b ' '

! Date

Radiological Protection Section

FIN W /Z-13M

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D.B.Spitzbsrg,RadFhtfinSpecialist Date

Facilities Radiological Protection Section

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Approved: $ IM62/ / / b

[BlaineMurray,~ Chief,Fp111tiesRadiological

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Date

Protection Section

Inspection Summary

Inspection Conducted November 4-8, 1985 (Report 50-285/85-25)

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

protection program for controlling occupational exposures during a refueling

outage including advanced planning and preparation, training, external exposure

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control, internal exposure control, radwaste and contaminated materials control,

posting, labelling, worker control, and independent measurements. In addition,

the NRC inspectors reviewed the licensee's actions on three open items related

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to NUREG-0737.TMI Action Plan Requirements. The inspection involved

82 inspector-hours onsite by 2 NRC inspectors.

8601070565 851EG23

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

identified. Two unresolved items were identified in paragraph 3.

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DETAILS

1. Persons Contacted

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• W. G. Gates, Manager FCS

A. Bilau, Radwaste Coordinator

M. R. Christensen, Training Instructor

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

C. R. Crawford, ALARA Coordinator

S. Dixon, C/RP Technician

M. L. Ellis, Instrument and Control (I&C) Coordinator

• J. J. Fisicaro, Supervisor - Nuclear Regulatory and Industry Affairs

S. W. Gebers, Acting C/RP Crew Chief

J. Glantz, C/RP Technician

J. M. Hale, C/RP Specialist

D. A. Jacobson, Training Instructor

T. W. Jamieson, Acting C/RP Crew Chief

• J. M. Mattice, Plant Health Physicist

• K. J. Morris, Manager, Quality Assurance (QA)

• G. L. Roach, Supervisor C/RP

B. Schmidt, C/RP Technician

F. K. Smith, Plant Chemist

Others

G. O. Maloy, Contractor Training Instructor

• P. H. Harrell, NRC Senior Resident Inspector

The NRC inspectors also interviewed other licensee and contractor

employees including C/RP, administrative,. maintenance, and construction

personnel.

• Denotes thor >e individuals present during the exit interview cn

November 8, 1985.

2. Licensee Action on Previously Identified Open Items

(Closed) Open Item (285/8226-14): NUREG-0737, Item II.B.3, Postaccident

Sampling (PASS) Capability - This item had remained open pending the

licensee's demonstration to the NRC of the PASS to perform its designed

function. In reviewing this item, the NRC inspectors found that site

acceptance testing, development of approved operating procedures, and

operator training on the system had been found satisfactory as documented

in NRC Inspection Report 50-285/84-28. Operation of the PASS was verified

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j by the NRC resident inspector during the period July 1 through

} August 31, 1985, and was documented in NRC Inspection Report 50-285/85-15.

i The NRC inspectors also reviewed records of PASS dilution calibrations '

performed in September 1984. The licensee had not as yet performed an

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evaluation of particulate and iodine plateout in the PASS containment

atmosphere sampling line. This finding is noted as an observation in

paragraph 4 of this report.

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Open item 285/8226-14 is considered closed.

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(Closed)~0 pen Item (285/8226-17)

NUREG-0737, Item II.F.1 ( Attachment 3),

' Containment High Range Radiation Monitor - This item, discussed in NRC

Inspection Reports 50-285/82-26 and 50-285/83-22, was left open pending a

revision of the monitors' calibration procedures to include calibration

below 10 R/hr using a calibrated radiation source. The NRC inspectors

i reviewed containment high range radiation monitor calibration procedures

, CP-RM-091 A and B and found that they had been revised on November 11,

i 1984. to include radiometric calibration at 8.9 R/hr. Records showed the

3 monitors to have been calibrated according to the revised procedures on

November'20, 1984. Open item 285/8226-17 is considered closed.

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3. Unresolved Items Identified During This Inspection

l An unresolved item is a matter about which mor.e information is required in

i order to ascertain whether it is an acceptable item, an open item-,a

deviation,'or a violation.

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Unresolved I'.am (285/8525-01): Calibration of Constant Air Monitoring

Instrumentation - The licensee did not have documentation av&ilable for

review of a calibration performed on particulate, iodine, and noble gas

l (PING) monitor serial number 214 in August 1985. See paragraph 8 for

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details.

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Unresolved. Item (285/8525-02): Inoperability of Wide Range Noble Gas Stack

Monitor RM-063L.M.H - The licensee did not have documentation available

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for review of a special report on the inoperability of the wide range

noble gas stack monitor RM-063M.H beyond September 14, 1984. See

paragraph 11 for details.

j 4. Inspectors Observations

The following are observations the NRC inspectors called to the licensee's

attention. These observations are neither violations nor unresolved

items. These items were recommended for licensee consideration for

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program improvement, but they have no specific regulatory requirement.

The licensee indicated that these items would be reviewed:

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a. NRC Form 4 - The date the individual signed the NRC Form 4~was not

i always present and the previous exposure history units were sometimes

. missing the decimal point. See paragraph 7 for details. i

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j b. Instrument Repair - The licensee had a.large quantity of. radiation '

i . protection survey meters, airborne radiation monitors, and personnel

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contamination monitoring instruments out-of-service. See paragraph 5

for details,

c. Decontamination Personnel - The ccntractor personnel assigned to

decontamination duties in the auxiliary building were not performing

all duties in a manner considered radiologically safe. See

paragraph 5 for details.

d. General Employee Training Building Decontamination Showers - The

licensee had not developed procedures for controlling, sampling, and

discharging the contents from the decontamination shower holding

tank. See paragraph 9 for details,

e. Radiographic Work - The licensee needs to exercise more control over

radiography work being performed onsite including surveys of incoming

and released vehicles and equipment. See paragraph 10 for details.

f. Wide Range Noble Gas Monitor (WRNG) Calibration Procedures - The

licensee's procedure for WRNG monitor calibration referenced model

numbers for the count rate meter and detector element. The recorded

data for these devises was not consistent with the procedure. See

paragraph 11 for details.

g. Particulate and Iodine Plateout Studies - The licensee had not

performed a plateout study for particulate and iodine on the WRNG

monitors. See paragraph 11 for details.

h. Job Preplanning - The C/RP and ALARA groups are not involved with job

preplanning. See paragraph 5 for details.

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5. Advanced Planning and Preparation

The NRC inspectors reviewed the C/RP. organization and determined that the

licensee had augmented the radiation protection group with contractor

technicians. The liccnsee assigned 17 senior and 8 junior technicians to

operational support, 2 senior technicians to ALARA, and 2 senior and 4

junior decontamination technicians to containment building decontamination-

work. The licensee also contracted for 10 non-nuclear trained

. housekeeping personnel for cleanup and decontamination duties in the

auxiliary building and 24 laundry workers. The licensee had established

two 10 nour shifts with staggered working hours to provide 24-hour

coverage.

The NRC inspectors reviewed the resumes and work histories of the contract

senior technicians and determined that they met the recommendations of ANSI

Standard N18.1-1971. The licensee had also evaluated the contractor

technicians and provided site specific training and individual testing in

accordance with Health Physics Procedure HP-16, " Selection of Contract

Health Physics Technicians."

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The NRC inspectors were concerned that personnel assigned to cleanup and

decontamination duties in the auxiliary building were not demonstrating

work practices which were radiologically acceptable when handling

contaminated radioactive material. The licensee stated they had initiated ,

a training course to provide these individuals with a better understanding i

of radiation and precautions for handling radioactive material.

The licensee had obtained additional portable s.urvey instruments,

personnel contamination monitors, and constant air sampling equipment

prior to the refueling outage. The NRC inspectors expressed concern

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regarding the inoperability of a large quantity of dose rate survey

instruments and personnel monitoring equipment. Although this

inoperability of equipment created an inconvenience, the health and safety

of personnel was not compromised. The licensee stated that an additional

I&C technician had been assigned to radiological instrument repair and

calibration and that should rectify this concern.

The NRC inspectors expressed concern that the C/RP and ALARA groups were

not involved with job preplanning in the early development phase. The

C/RP and ALARA groups were using daily briefings to update work on progress

and delays in the outage schedule. Licensee representatives stated that on

occasion, work was delayed because either ALARA reviews or radiation

surveys were needed prior to starting work and that radiation work permits

(RWPs) had been prepared for scheduled work that were not used.

No violations or deviations were identified.

6. Training and Qualifications

The NRC inspectors reviewed the routine and specialized training programs

associated with the outage with emphasis on that training provided to

contractor personnel. The NRC inspectors determined that the requirements

of 10 CFR Part 19.12 were being met.

The NRC inspectors noted that the licensee had received a full size

mock-up of the bottom portion of a steam generator, including the tube

plate, for training. The licensee nad used the mock-up to train personnel

for eddy current testing and tube repair work.

No violations or deviations were identified.

7. External Exposure Control

The NRC inspectors reviewed the licensee's program for external radiation

exposure control to determine compliance with the requirements of

10 CFR Parts 20.101, 20.102, and 20.202.

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The NRC inspectors determined that all personnel entering the radiation

controlled area (RCA) were issued a thermoluminescent dosimeter (TLD)

which are processed monthly. The individual entering the RCA also wear

direct-reading dosimeters (DRD) as required by the RWP. The licensee uses

the DRD results for tracking personnel exposures with dose totals updates

being made once per shift.

The NRC inspe'ctors reviewed selected personnel exposure history files to

determine that current NRC Form 4 and previous exposure histories were

available prior to exceeding the 1250 mrem quarterly exposure limit. The

NRC inspectors determined that individuals were not always dating the NRC

Form 4 and that when previous radiation exposures were entered on the form

the decimal point used to denote rem was not always in place. The

licensee stated they had placed additional emphasis on these areas of the

form.

The NRC inspectors reviewed selected records of work functions performed

by the licensee and contractors that required other than routine radiation

exposure monitoring, such as multibadging or extremity badging with TLDs.

! The licensee program for recording other than routine exposures appeared

to be adequate.

No violations or deviations were identified.

8. Internal Exposure Control

The NRC inspectors reviewed the licensee's internal exposure control

program to determine compliance with the requirements of 10 CFR 20.103,

and the recommendations of Regulatory Guide (RG) 8.15, and NUREG-0041.

The NRC inspectors inspected the reactor auxiliary and containment

buildings on several occasions during the inspection to observe internal

exposure control practices. Procedures and associated records were also

reviewed and discussions were held with licensee and contractor employees

to determine if internal exposures during the outage were being controlled.

The NRC inspectors reviewed a representative sample of the active and

inactive RWPs posted for the outage and records associated with their

implementation. This review verified that the permit process had been

effective during the outage at disseminating the proper internal exposure

control methods to be implemented by individuals for each task. The NRC

inspectors observed the acquisition of area grab air samples and reviewed

nonroutine breathing zone sample results used to track maximum permissible

concentration-hours (MPC-hr) personnel exposures.

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The NRC inspectors observed during a facility inspection on November 6,

1985, that a particulate, iodine, noble gas (PING) monitor in room 69 of

the auxiliary building was alarming at the high level for the iodine

channel. The sarae afternoon, one of the containment building PINGS was in

alert level while the other was in high level alarm for the iodine channel.

Action taken by the licensee in response to the alarms was to order

special grab fr samples to assess the airborne concentration of iodine.

The NRC inspectors examined the PING calibration procedures and records of

the.f r calibration to ascertain the significance of the iodine alarms. In

the course of this review it was determined that PING unit 214 located in

room 69 of the auxiliary building did not have documentation on file

showing the calibration performed on this unit on August 15, 1985. The

licensee stated that the necessary calibrations had been performed, but

the calibration records could not be located. This was identified as an

unresolved item (285/8525-01) pending the licensee's search for this

record.

The NRC inspectors examined the post alarm grab air samples in addition to j

the routine air samples and found that while iodine concentrations had

showed an increase during the outage, measured levels had not exceeded

10 percent of MPC in ary of the sample results reviewed. Special whole

body counting resul s performed during the outage also provided verification

of the absence of a significant iodine problem with the highest body

burden showing 50 nanocuries (7.1 percent of ICRP maximum permissible body

burden). Air sample results showed other isotopes to be near or below the

lower limit of detection (LLD).

The NRC_ inspectors reviewed the licensee's use of respiratory protection

equipment and verified that all users including outage contractor personnel

had completed the licensee's qualification program. The NRC inspectors

observed the cleaning of used respirators and reviewed the records of

surveys of respirators prior to bagging and reissuance and found this to

have been performed in accordance with Procedure RPP-6.

No violations or deviations were identified.

9. Radioactive and Contaminated Materials Control

The NRC inspectors observed the efforts being implemented during the

outage to control contamination and radwaste in the RCA. The NRC inspectors

observed instances of poor radiation safety practices among a few of the

auxiliary building decontamination teams in the packaging of used protective

clothing (PC) and improper controls at step off pad control points.

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The NRC inspectors observed that worke'rs. sere properly suited out in PC'

for the areas in which they were worJ'nq and that removal of PC and step

off pad procedures were being.fo llowe'bf All personnel exiting the RCA -

were required to monitor themselves in o'ne of four gas proportional

personnel contamination monitors. The NRC inspectors observed that -

articles which had been carried into the RCA were being surveyed prior to

removal.

The NRC inspectors reviewed changes to facilitids which had occurred since~

the last radiation protection program inspection. The NRC inspectors

discussed with licensee representatives the status and basic design for

the shower facilities in the general employee training building. The

licensee stated that the effluent is collecy.ed in a 1000 gallon retention

tank, fitted with a high level alarm, and has the ability to be discharged

to either the sanitary sewer system or an external vessel. The NRC

inspectors expressed concern that the licensee had not developed

procedures to prohibit the discharge of potentially contaminated effluents

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via an unmonitored pathway. The licensee needs to: (1) determine the

level the high alarm is activated, (2) provide for positive controls on

the valve connecting the retention tank to the sanitary sewer line, and

(3) develop a procedure which would address the isolation of the tank, ','

collection of a repretentative sample from the tank, and an approved '

discharge or disposal torm. -

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No violations or deviations were, identified.

Posting, l.abelling, and Worker Control

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10.

The NRC inspectors verified that the radiologically controlled areas were

properly posted and they appeared to be in compliance with 10 CFR 20.203.

A temporary storage area for pack, aged radwaste awaiting shipment had been

roped off and posted outside of the fuel building. The NRC inspectors

made independent exposure rate' surveys and found them to be in agreement ,

with licensee surveys ar.a area postings. '

The NRC inspectors reviewed RWPs to ensure that station and contractor

personnel were following approved instructions in radiologically controlled

areas. - Specified RWP approved procedures appeared to have been followed

in each case, and sign-in logs and dispensation of expired RWPs were found

to be in order.

Ok November 6,1985, the NRC inspectors observed that a byproduct material

user licensed by the State of Nebraska had been on site to perform

radiography in non-radiologically controlled areas. The NRC inspectors

noted that no procedures had been established for controlling this type of

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work although station health physics personnel had monitored the radiographic

activities. The licensee was in agreement that more control over such

activities in the future should be exercised to monitor radiographers

entering the site protected area.

No violations or deviations were identified.

11. Wide Range Noble Gas Stack Monitor

The NRC inspectors reviewed the licensee's progress to resolve open item

(285/8226-15) NUREG-0737, Item II.F.1 (Attachment 1), Noble Gas Effluent

Monitor. The licensee had completed calibration of the low range

channel of the wide range noble gas (WRNG) stack monitor RM-063L.M.H.

The midrange and high range channels had not been calibrated. The NRC

inspectors reviewed the calibration for the low range channel of the WRNG

monitor. The NRC inspectors noted that this calibration procedure

i referenced count rate meter and detector model numbers that were not the

same as those recorded during performance of the calibration. The NRC

inspectors discussed with licensee representatives this inconsistency in

equipment data and determined that the recorded data more accurately

identified the count rate meter and detector. The licensee agreed that

the calibration procedure needed to be revised to include. consistent model

numbers.

The NRC inspectors discussed with licensee representatives the status of

the midrange and high range detector systems and FCS TS section 2.21

requirements. Table 2-10 requires that when less than the minimum number

of channels are operable, alternate methods for monitoring be initiated

and if the channels are not returned to operating status within 7 days a

special report shall be submitted within 14 days to the Commission

containing plans and schedules for returning the monitors to operable

status. The licensee provided a copy of a letter LIC-84-301 dated

September 5, 1984, which stated the monitors were expected to be operable

by September 14, 1984.

The licensee stated that a second letter was written after September 5,

1984, which extended the date of expected operability for the mon! tors.

However, the licensee was not able to locate a copy of the second letter.

The NRC inspectors stated this is considered an unresolved item

.(295/8525-02) pending resolution of the notification to the Commission and

expected operability of the monitors.

The NRC inspectors discussed with licensee representatives the status of

particulate and iodine plateout studies for the WRNG monitors. The

licensee-had not performed any calculations using ANSI Standard 13.1-1969

as a guide. The licensee stated that they expect to start the plateout

studies during calendar year 1986.

No violations or deviations were identified.

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12. ALARA Program

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The NRC inspectors reviewed the licensee's ALARA program to determine

compliance with the requirement bf 10 CFR Part 20.1 and the recommendations

of Regulatory Guides 8.8 and 8.10.

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l The NRC inspectors determined that the licensee had established a goal of

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491 manrem for the year 1985 and had expended 224 manrem as of November 6,

~1985. The licensee projected that less than 400 manrem would be expended

for the year. The licensee stated that the lower ~ exposure was due to less

steam generator work and decontamination efforts prior to working in the

RCA.

No violations or deviations were identified.

13. Surveys

.The NRC inspectors reviewed the licensee's program for implementing and

performing radiation, contamination,- and airborne radioactivity surveys

to determine ccmpliance with the requirements of 10 CFR Parts 20.103,

20.201, and 20.401. '

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The licensee's survey program appeared to be adequate for contamination

and radiation surveys for prework evaluations and RWP generation. The

NRC inspectors noted the licensee routinely collected an airborne

radioactivity sample for particulate and radiotodine analysis from the

auxiliary building once each day and from the containment building once

each work shift. The NRC inspectors determined that the licensee

performed other airborne surveys on an as needed basis when conditions

warranted. ,

At various times during the inspection period, the NRC inspectors

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conducted independent surveys of the containment and auxiliary buildings

to verify that radiological. conditions were as recorded on radiation

, survey logs and depicted on station area maps. The NRC inspectors also

observed housekeeping and temporary radioactive waste storage areas. All

areas observed appeared to be acceptable.

No violations or deviations were identified.

14. Notifications and Reports

The NRC inspectors-reviewed selected reports to determine compliance with

10 CFR Parts 19.13, 20.407, 20.405, and 20.409.

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The NRC inspectors' review, in addition to radiological worker training,

respiratory fit training, radiation exposure history, and radiation

exposure data, included the radiation protection shift turnover log,

radiological incident reports, and personnel contamination reports. The

NRC inspectors noted the licensee had revised the criteria used for

i documenting personnel contamination incidents and now records all

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incidents where contamination is detected on an individual. This

procedure sho'uld allow the licensee to track contamination incidents

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by craft, area of contamination, work function, repeat incidents, and

determine the root cause and prescribe corrective action to prevent

reoccurrence.

No violations or deviations were identified.

> 15. Exit Interview

The NRC inspectors met with the_FCS NRC senior resident inspector and

licensee representatives denoted in paragraph 1 at the conclusion of the

inspection on November 8, 1985. The NRC inspectors summarized the scope

and findings of the inspection including the unresolved items identified

in paragraph 3, and the observations noted in paragraph 4 of this report.

The licensee stated that these items and observations would be reviewed.

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