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Insp Rept 50-285/86-05 on 860304-06.Violation Noted:Failure to Include Sr-89 & Sr-90 Analysis Results in Semiannual Radioactive Effluent Release Repts for 1981,1982,1983,1984 & 1985 & Procedures Not Properly Reviewed
	ML20198D367
Person / Time
Site:	Fort Calhoun
Issue date:	04/11/1986
From:	Chaney H, Murray B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20198D185	List: ML20198D180; ML20198D355; ML20198D367;
References
	50-285-86-05, 50-285-86-5, NUDOCS 8605230228
	Download: ML20198D367 (11)
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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/86-05 -License: DPR-40

Docket: 50-285

Licensee: Omaha Public Power District (OPPD)

1623 Harney Street f.

Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station (FCS)

Inspection At: FCSSite,Washingtonbounty, Nebraska

Inspection Conducted: March 4-6, 1986

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Inspector: "r *

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H. Chadey'k Radiation Spe alist, Facilities

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Date

Radiological Protecti Section

Approved: _ g45 p;D(h

s Radiological

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B. Murray, Chief, Fac Date '

Protection Section

Inspection Summary

Inspection Conducted March 4-6, 1986 (Report 50-285/86-05)

Areas Inspected: Routine, unannounced inspection of.the radiological

environmental monitoring program.

Results: Within the areas inspected, two violations (see paragraph 10) and no

deviations were identified.

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DETAILS

1. Persons Contacted

OPPD

K. L. Belek, Supervisor, Environmental Sciences

S. A. Bobbrink, Chemist

F. Coddington, Instrument and Controls (I&C) Apprentice

-A. A. Constanzo, Analyst

C. R. Cr6wford, ALARA Coordinator

J. J. Fisicaro,-Supervisor, Nuclear Regulatory and Industry Affairs (NR&IA)

J. K. . Gasper, Manager, Administrative Services

W. G. Gates, Manager, Fort Calhoun Station

R. L. Jaworski, Section Manager, Technical Services

J. Nixan, I&C Technician

D. J. Hunderloh, Senior Engineer NR&IA

A. W. Richard, Manager, Quality Assurance

G. L. Roach, Supervisor, Chemical and Radiation Protection (CRP)

- K. Stultz, Supervisor, Radiological & Environmental Monitoring Services

M. A. Wilson, Assistant Analyst

Others

P. Harrell, NRC Resident Inspector

P. Courtney, OPPD Meteorology Consultant (telephone contact)

Denotes those individuals present during the exit interview on March 6,

1986.

- Denotes individual contacted by telephone on March 11, 1986, to discuss

inspection findings not presented at the exit meeting on March 6, 1986

2. Licensee Action on Previously Identified Inspection Finding

(Closed) Open Item (285/8504-01): Training - This item was previously

discussed in NRC Inspection Report 50-285/85-04 and concerned the lack of a

formal training program for personnel involved with the radiological

environmental monitoring program. The NRC inspector determined that the

licensee's actions were adequate to resolve the inspector's concerns in

this area. This' item is considered closed.

3. Inspector Observations

The following are observations the NRC inspector discussed with the

licensee during the exit interview on March 6, 1986. These observations

are neither violations nor unresolved items. These items were recommended

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-for licensee consideration for program improvement, but they have'no

specific regulatory requirement. The licensee indicated that these items

would be reviewed. t

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a. Tritium Lower Limits of Datection (LLD1 - Tritium LLD listed in the

Radiological Effluent TechnicaT Specifications (RETS) and Offsite Dose

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Calculation Manual (ODCM) do not agree with NUREG-0472 (see paragraph 10).

b. Independence of Audit Team Members - The licensee's April 1986 scheduled

audit of the radiological environmental monitoring program has tenta-

tively assigned audit team members that have direct responsibilities

for the functional areas being audited (see paragraph 6).

4. Environmental Protection Program Organization and Management Controls

The NRC inspector examined the organization and staffing of the licensee's

environmental organization to determine compliance with the Updated Safety

Analysis Report (USAR), Sections 2.5, 2.10, 11.1, 12.1, and 12.3 commitments;

and the requirements of the Facility Operatina License Technical

Specification (TS) 5.2.1; and the recommendations of NRC Regulatory

Guide (RG) 1.33.

The NRC inspector reviewed the licensee's offsite support organization

structure and found it to agree with USAR, Figure 12.1-2, " Production

Operations Division Organization Chart." The NRC inspector also reviewed

the licensee's procedures and directives for implementing the radiological

environmental monitUring program, offsite and onsite staff functional

ass.ignments, position descriptions, allocation of personnel resources,

personnel evaluation system, management oversight of field activities,

procedure development and approval, and staff stability. Documents and

procedures that were reviewed are listed in the Attachment to this report.

The licensee's environmental staff has remained stable over the past

10 years. The turnover rate has been less than 10 percent per year.

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No violations or deviations were identified. -

5. Environmental Protection Organization Staff Qualifications and Training

The NRC inspector examined the qualifications of the environmental

protection organization staff to deternine compliance with USAR,

-Sections 12.1, 12.2.2 commitments; and the requirements of 10 CFR

Part 19.12, TSs 5.3 and 5.4; ' and

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the recommendations of RG 1.8 and

NUREG-0761.

The NRC inspector reviewed procedure: vid directives concerning training

and qualification of environmental services personnel.

No violations or deviations were identified.

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6. Audits

The NRC inspector reviewed licensee's audit program for compliance with

TS 5.5.2.8.h and 10 CFR Part 50, Appendix B.

The NRC inspector determined that the licensee had not performed any audits

of the RETS program since its implementation in October 1985. The licensee

had scheduled an audit of RETS activities to be conducted in April 1986 by

the Safety Audit and Review Committee (SARC). The NRC inspector reviewed a

draft checklist and prospective audit team members. The NRC inspector

noted that the prospective audit team leader was directly responsible for

implementation of the RETS and that one other team member was closely

associated with the conduct of the RETS program. The licensee indicated

that a review would be conducted of prospective team members and any

conflicts of interest would be resuived. The NRC inspector also reviewed

audits of the analytical services vendor, FCS site meteorology system, and

the environmental monitoring program conducted in 1984.

No violations or deviations were identified.

7. Radiological Environmental Monitoring Program

The radiological environmental monitoring program was reviewed to determine

compliance with the USAR, Section 2.10.4 commitments; the requirements of

TS 3.11, and the ODCM; and the recommendations of NUREG-0742.

a. Program Changes

The licensee implemented the RETS program in October 1985. The

Semiannual Effluent Release and Environmental Monitoring Report for

July through December 1985, reflects the change over from previous

environmental requirements to the new RETS requirements and use of the

00CM for offsite dose assessment.

b. Current Program

The NRC inspector reviewed the implementation of the RETS and ODCM

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involving revised analysis sensitivities, reporting limits, sampling

locations, reports, analytical results, sampling frequencies, land use

census, surveillance tests, program operating procedures, offsite dose

results from liquid and gaseous effluents, control of vendor / contractor

activities, and calibration of equipment.

No violations or deviations were identified.

8. Meteorological Monitoring Program

The licensee's meteorological monitoring program was inspected for

compliance with USAR, Section 2.5.3, and FCS Radiological Emergency Response

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Plan Section I.2.2.4 commitments; the requirements of NUREG-0737,

Item III.A.2; and the recommendations of RGs 1.23, 1.97, and industry

standard ANSI /ANS-2.5-1984.

The NRC inspector reviewed representative records involving meteorological

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data recovery and reduction, equipment calibration and maintenance, and

equipment design specifications. The licensee's meteorological equipment

(tower, data recorders, data plotter and remote displays, and analog

readouts in the control room), procedures and provisions for backup

meteorological data resources were inspected. Discussions were held with

the licensee's meteorological consultant (via telephone) concerning

placement of the meteorological sensors for atmospheric stability on the

meteorological tower at 10 and 110 meters above ground level, when RG 1.23

and other industry standards recommend sensors heights of 10 and 60 meters.

The licensee's sensors placement was dictated by the local geological

formations and wind profiles for FCS. The licensee's program appears to be

, acceptable based on the specific meteorological conditions at FCS.

No violations or deviations were identified.

9. Facilities, Equipment, and Supplies

The NRC inspector inspected five air sampling stations, laboratory / office

facilities, laboratory equipment, analytical equipment, equipment operating

instructions, calibration records, record storage, and sampling devices.

No violations or deviations were identified.

10. Environmental Monitoring Report, Operating Manuals and Procedures

The NRC inspector reviewed reports and procedures to determine compliance

with TSs 2.9, 3.11, 3.12, 5.9.4, 5.10.1, and 5.10.2 requirements, and 10 CFR

Parts 20.106 and 20.405, 10 CFR Part 50.36.a, 10 CFR Part 50, Appendix B and I;

and the recommendations of RGs 1.21, 1.33, 4.1, 4.2, 4.6, 4.13, 4.15, and

NUREG-0472.

The NRC inspector reviewed radioactive effluent release and radiological

environmental monitoring reports for the years 1981 through 1985, offsite

OPPD Technical Services Section procedures for implementing the environmental

monitoring program, FCS surveillance test procedures for conducting the

periodic RETS sampling program ana ODCM evaluations, and vendor analytical

results of radiological samples.

The NRC inspector noted that the licensee's analytical analysis lower

limits of detection values (LLDs) as referenced in the ODCM, per TS 3.11

Table 3.9, Note 2, did not agree with the recommendations of NUREG-0472,

Revision 2. Differences existed in the LLDs for gross beta and tritium

measurements. The licensee's ODCM did not provide an LLD for gross beta

measurements for water samples, and the licensee's tritium LLD was 10 times

higher (20,000 versus 2000 picocuries per liter) than that recommended in

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NUREG-0472. The NRC inspector noted that the LLDs listed by the offsite

vendor that performs radiological analyses of the licensee's environmental

sample were the same as the LLDs' appearing in the RETS even though the

actual reported results were below the LLDs in NUREG-0472. The licensee

indicated they would review LLD values.

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TS 3.12, " Radiological Waste Sampling and Monitoring," requires the

licensee to sample and analyze radioactive liquid and gaseous effluents in

accordance with Tables 3.11 and 3.12. These tables include quarterly

composite sampling and analysis of liquid and gaseous effluents for

strontium 89 and 90 radionuclides. Furthermore, TS 5.9.4.a requires, in

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part, that "A report covering the operation of the Fort Calhoun Station

during the previous 6 months shall be submitted within 60 days after.

January 1 and July 1 of each year. The radioactive effluent release report

shall include a summary of the quantities of radioactive . . . effluents

. . . released from the plant as outlined in Regulatory Guide 1.21,

Revision 1."

The NRC inspector determined by review of semiannual radioactive effluent

release reports that the licensee routinely omitted quarterly strontium 89

and 90 analysis data by entering the following notation-in the reports, ,

"Results not available at time of initial report. Revision for

Strontium 89-90 results will be provided upon receipt from vendor." On

March 6,1986, the NRC inspector determined that quarterly strontium

analysis results had not been provided for the following semiannual

Radioactive Effluent Reports:

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1981 all quarters

1982 all quarters

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1983 all quarters

1984 all quarters

1985 second, third and fourth quarters

Failure to submit the required strontium 89 and 90 analysis results is an

apparent violation of TS 5.9.4.a (285/8605-01).

TS 5.8.1 requires, in part, that " Written procedures . . . shall be

, established, . . . and maintained that meet or exceed . . . Appendix A of

USNRC Regulatory Guide (RG) 1.33 . . . ." In addition, Section 8.b of

Appendix A to RG 1.33 states, in part, that " Specific procedures for

surveillance tests, . . . should be written (imphmenting procedures are

required for each surveillance test, inspection, . . . listed in the

j, technical specifications):" Furthermore, TS 5.8.2 requires, in part, that

"Each procedure . . . of 5.8.1 above, and changes thereto, shall be

reviewed by the Plant Review Committee (PRC) and approved by the Manager -

Fort Calhoun Station prior to implementation and periodically as set forth

in each document."

The NRC inspector determined on March 11, 1986, that the below listed

licensee environmental program procedure, developed and issued by the

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offsite OPPD General Office Technical Services Section, had not been

provided proper review or approval prior to implementation / issue.

OPPD Fort Calhoun Power Station, Unit No. 1 Environmental Radiological

Monitoring Procedure Manual, Revision 2, dated December 1985.

The above noted failure to provide proper review and approval is an

apparent violation of TS requirement 5.8.2 (285/8605-02). The NRC

inspector noted that the procedure noted above had evidently never been

initially reviewed or approved as required by TS 5.8.2, and that the

procedure appeared to satisfactorily implement the required surveillances.

The licensee did not consider offsite procedures, that implemented TS

related matters, to require PRC review or plant manager approval.

No deviations were identified.

11. Quality Assurance Program

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The NRC inspector reviewed quality assurance activities for the

environmental monitoring program and contracted vendor functions. These

reviews included licensee reports, QA audits, QA related training of staff

members, calculation instructions, data reduction, results of vendor

participation in the U.S. Environmental Protection Agency's laboratory

cross check program (1985), and records of reviews of environmental data.

The NRC inspector noted that, other than periodic audit activities, there

appeared to be a lack of QA Department involvement concerning oversight of

quality related activities of the environmental group especially in

procedure development, review, and approval. The licensee indicated that

the QA oversight of the environmental monitoring program was satisfied by

the biannual audit of the program by the Safety and Audit Review Committee

per TS 5.5.2.5.h.

No violations or deviations were identified.

12. Control of Contractor Activities

The licensee's control over contractor activities associated with the

environmental monitoring programs was reviewed. The NRC inspector

determined that the licensee periodically audits the vendor providing

analytical services for the environmental monitoring program to assure that

analytical activities are being conducted as required by TS 3.11 and the

ODCM, and the recommendations of RG 4.15.

No violations or deviations were identified.

13. Reportable Occurrences

The NRC inspector determined that the licensee had no reportable

occurrences, as per TSs 5.9.3 and 5.9.4.b.2, involving the ODCM or

radiological effluent releases during 1985.

No violations or deviations were identified.

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14. Exit Interview

The NRC inspector met with the licensee's representatives identified in

paragraph 1 of this report at the conclusion of the inspection on March 6,

4 1986. The NRC inspector summarized the scope'and the results of the

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inspection.

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ATTACHMENT ,

TO NRC INSPECTION REPORT

50-285/86-05

APPENDIX 8

DOCUMENTS REVIEWED

IIILE BEVISION D81E

Omaha Public Power (OPPD) District Quality

Assurance Manual 4 11-09-83

OPPD Safety Audit Review Committee (SARC) Audits

Audit 84-13, Ser. 84-DA-144, Teledyne Isotopes Inc. 08-24-84

Audit 3-85, SARC, Site Emergency Plan and Procedures 07-18-85

Draft Audit Checklist -for RETS 1986, Audit #55

Audit #55, Ser. 94-DA-188, Environmental Program 10-04-84

SARC Internal Audit Schedule (1994 - 1985)

OPPD Nuclear Production Technical Services Section Procedures (N-TSAP)

N-TSAP-1, Preparation and Approval of

Technical Services Administrative

Procedures O O2-85

N-TSAP-8, Analysis Verification 1 05-85

N-TSAP 10, Preparation and Approval of

Technical Services Operating, Test, and

l Special Procedures O O2-85

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! N-TSAP-11, Technical Services Quality Related

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Training Program 1 05-85

N-TSAP-12, Identification, Handiing, and ,

Storage of Quality Assurance Records 2 01-86

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Radiolooical b Environmental Monitorino Services Unit Procedures

Environmental Radiological Monitoring

Procedure Manual 2 12-05

Fort Calhoun Station Emergency Radiological

Monitor Booklet (EP-82-3) O 08-82

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IIILE BEVISION D6IE .

FCS Operatino Procedure Manual

Volume A. Standino Orders

T-2, Waste Liquids Release 21 11-09-84

T-3, Waste Gas Release 20 11-09-84

+ T-15, Waste Lagoon Release 2 10-04-83

FCS Calibration Procedures

CP-6272, 110 Meter Wind Direction 9 11-12-85

CP-6273, 45 Meter Wind Direction 8 11-12-85

CP-6274, Primary 10 Meter Wind Direction 5 11-12-85

CP-6275, Secondary 10 Meter Wind Direction 8 11-11-85

CP-6276. 110 Meter Wind Speed 7 11-12-85

CP-6277, 45 Meter Wind Speed 7 11-12-85

CP-6278, Primary 10 Meter Wind Speed 7 11-12-85

CP-6279 Secondary 10 Meter Wind Speed 6 11-12-85

CP-6280, 110-1 Meter Delta Temperature 6 11-11-85

CP-6281, 110-2 Meter Delta Temperature 6 11-11-85

CP-6282, 110-3 Meter Delta Temperature 4 11-11-85

CP-6283, 10-1 Meter Amb i er.t Temperature 4 11-12-85

CP-6284, 10-2 Meter Ambient Temperature 4 11-11-85

CP-6285, 10-3 Meter Ambient Temperature 3 11-12-85

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FCS Survei11ance Procedure.

ST-ERM-1. Environmental Radiological

Monitoring (Sectons F.1 - F.5) 27 01-30-86

ST-RM-4 Environmental Monitors 17 10-16-85

FCS Chemintry Manual Procedures (CMP)

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CMP-2.0, Sampling Collection 2 01-30-85

CMP-2.3, Composite Sampling 1 10-02-85

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IIILE BEylSION D8IE

CMP-4.3, Waste Lagoon Release Permit 2 12-6-84

CMP-4.4, Waste Liquid Release Permit 4 10-02-85

CMP-4.5, Containment Purge / Vent Release Permit 5 09-30-85

CMP-4.6, Waste Gas Release Permit 5 10-02-85

CMP-6, Offsite Dnse Calculation Manual 0 10-02-85

ML20198D367

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