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Insp Rept 50-285/86-08 on 860407-10.Violations Noted:Failure to Retain Calibr Data for Gaseous Effluent Monitor,Failure to Keep Noble Gas Stack Monitors Operable or to Submit Rept on Inoperability & Unauthorized Use of Survey Meter
	ML20206F601
Person / Time
Site:	Fort Calhoun
Issue date:	05/27/1986
From:	Baer R, Murray B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20206F573	List: ML20206F568; ML20206F579; ML20206F601;
References
	50-285-86-08, 50-285-86-8, NUDOCS 8606240534
	Download: ML20206F601 (10)
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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-285/86-08 License: DPR-40

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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

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Inspection Conducted: April 7-10, 1986 .

Inspector: 37 4

R. F/ Baer, Radiation Specialist, Facilities Ddte

Radiological Protection Section

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Approved: @ Mjk 7/87/8(E '

B'Murray, Chief, Faci /itiesRadiological Ohte

Protection Section

j Inspection Summary

Inspection Conducted April 7-10, 1986 (Report 50-285/86-08)

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

protection program including: external occupational exposure control and

personal dosimetry; internal exposure control and assessment; control of

radioactive materials and contamination, surveys and monitoring; and facilities

and equipment.

Results: Within the areas inspected, three violations were identified (see

paragraph 6). No deviations were identified.

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DETAILS

1. Persons Contacted I

OPPD

W. G. Gates, Manager, FCS

L. Cherko, Emergency Plan Technician

M. R. Core, Supervisor, Maintenance

C. R. Crawford, ALARA Coordinator

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

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

J. J. Foley, Supervisor, I&C/ Electrical Maintenance

F. F. Franco, Manager, Radiological Health and Emergency Planning

S. W. Gebers, Acting Chemistry and Radiation Protection (C/RP) Crew Chief

J. M. Hale, C/RP Specialist

M. K. Hawes, Dosimetry Specialist .

T. W. Jamieson, C/RP Technician I

J. M. Matti<e, Plant Health Physicist

A. W. Richards, Manager, Quality Assurance

G. L. Roach, Supervisor, C/RP

F. K. Smith, Plant Chemist

R. K. Stultz, Supervisor, Radiological and Environmental

T. Thompson, Acting C/RP Crew Chief

L. P. Walling, Supervisor, Administrative Services

Others

G. O. Maloy, Contractor Training Instructor

P. H. Harrell, NRC Senior Resident Inspector

The NRC inspector also interviewed several other licensee and contractor

employees including C/RP, administrative, maintenance, and contractor

personnel.

Denotes those individuals present during the exit interview on April 10,

1986.

2. Inspector Observations

The following are observations the NRC inspector discussed with the

licensee during the exit interview on April 10, 1986. These observations

are neither violations nor unresolved items. These items were recommended 1

for licensee consideration for program improvement, but they have no

specific regulatory requirement. The licensee indicated that these items

would be considered.

a. Thermoluminescent Dosimetry (TLD) Program - The corporate TLD program

is audited on a 3 year frequency. See paragraph 3 for details.

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b. Instrument Calibration Frequency - The licensee has specified a

calibration frequency of 5 years for a condenser R-meter. See

paragraph 3 for details,

c. Radiological and Environmental Monitoring Services Procedures - The

licensee's procedures issued by the radiological and environmental

monitoring services section do not receive the review and approval

that would routinely be afforded to station procedures. See

paragraph 3 for details,

d. Radiation Survey Documentation - The licensee had not documented all

beta radiation survey data. See paragraph 5 for details.

e. Airborne Radiation Monitors - The licensee had an excessive quantity

of constant airborne radioactivity monitors either out-o' service or

in the alarm mode. See paragraph 4 for details,

f. Instrument Repair - The licensee had a large quantity of radiation

protection survey meters out-of-service. See paragraph 5 for

details,

g. Instrument Availability - An adequate inventory of operational

radiation survey instrumentation was not available to support daily

work evaluations. See paragraph 5 for details.

3. External Occupational Exposure Control & Personal Dosimetry

The NRC inspector reviewed the licensee's external exposure control and

personal dosimetry program for compliance with the requirements of 10 CFR

Parts 20.101(a), 20.101(b), 20.102, 20.104(a), 20.202(a) and 20.401(a),

and the recommendations of Regulatory Guides (RGs) 8.2, 8.3, 8.4, 8.7,

8.14, and 8.28.

The NRC inspector reviewed the Nuclear Production Technical Services

Department operating procedures located at the corporate offico relating

to TLDs listed in Attachment 1. The licensee had received certification

for their TLD program from the National Voluntary Laboratory Accreditation

Program (NVLAP) in the following categories: II accident-high energy

photons, IV high energy photons, V beta particles, VII photons plus beta

particles, and VIII photons plus neutrons. The licensee had not attempted

certification for the three remaining categories. The NRC inspector noted

that the internal audit frequency for the Radiological and Environmental

Services Section located at the corporate office was based on a 3 year

frequency. However, the recommended audit frequency in RG 1.33 and NVLAP

documents for this quality-related activity is normally annual or biennial

as a maximum.

The NRC inspector discussed with licensee representatives the 5 year

calibration frequency specified for the condenser R-meter in corporate

procedure N-TS0P-3. The incostry standard ANSI N323-1978 recommends an

annual calibration as the maximum and more frequent depending on instrument

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usage. The licensee stated that they had also obtained a condenser l

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R-meter from FCS and used both instruments when determining the source

strength and radiation levels of the Cesium-137 TLD calibration source.

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The FCS instrument had been calbrated annually. ;

The NRC inspector also discussed the review and approval of written i

i procedures. The licensee's review for TLD-related procedures is presently '

limited to the supervisor radiological and environmental monitoring

i services and approval by the section manager, technical services. The NRC

inspector noted that the TLD-related procedures are not subjected to the

same level of review and approval that is provided to station operating

procedures.

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The licensee's external occupational exposure history for the previous

5 years compared to the average exposure for all pressurized water

reactors is depicted in Table 1. The licensee has consistently maintained

an exposure history at or below the industry average.

No violations or deviations were identified.

4. Internal Exposure Control and Assessment

The NRC inspector reviewed the licensee's internal exposure control and

assignment program to determine compliance with 10 CFR Part 20.103 and the

recommendations of RGs 8.7, 8.8, 8.9, 8.15, and 8.26.

The NRC inspector reviewed FCS C/RP procedures listed in Attachment 2,

representative records for the airborne radioactivity sampling program,

whole body counter operational checks, and interviewed personnel to

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determine the effectiveness of the program. The NRC inspector determined

that the licensee's respiratory protection program including the

i associated maintenance, cleaning, and supporting air sampling program

appeared adequate and met the requirements of 10 CFR Part 20.103.

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The NRC inspector expressed concern to licensee representatives relating

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to the operation of the constant air samplers located in the auxiliary

building. These units monitor the concentration of airborne particulates,

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iodine, and noble gases (PING). The licensee had four PING units of which

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two were found in the alarm mode (flashing light) for particulate

concentrations and two were out-of-service. These units had been placed

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in service in September of 1985 and had been constantly in the alarm mode.

The licensee stated that the alarm set point had been determined based on

the instrument background plus the allowed concentration. The units use a

fixed filter and as the natural radon daughter products buildup on the

filter the units alarm. The licensee had not established an alarm point

which accounted for this buildup unti1 equilibrium conditions existed. l

The NRC inspector stated that both C/RP personnel and station personnel

would become complaisant to the constant alarm and should the airborne .

concentration exceed regulatory requirements the licensee would not be 'l

aware of this condition for a prolonged length of time. The licensee

stated that the alarm set point would be recalculated based on a 45 minute

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equilibrium period, set points re-established and all personnel advised

that the PINGS were operational and to take appropriate action should the

units alarm in the future. The NRC inspector noted that these PING

monitors are used for trend analysis only, the official airborne

concentration determination is performed by analysis of routine grab air

samples taken in the general area of the PING. The licensee had two PINGS

operational on April 10, 1986, and the remaining two units to be returned

to service as soon as replacement parts were available.

The NRC inspector reviewed the emergency equipment inventories performed

monthly and documented on form ST-RM-3 for the period of July 1985 through

March 1986. The NRC inspector also inventoried the equipment located in

the operational support center. The NRC inspector determined that all

equipment listed on the checklist was present and within calibration

requirements.

The NRC inspector discussed with licensee representatives the status of

the new fast scan whole body counting system and reviewed the latest

calibration data. The NRC inspector noted that the licensee had not

participated in any independent laboratory intercomparison programs for

whole body counting. The licensee stated they had performed comparison

studies with the manufacture.

No violations or deviations were identified.

5. Control of Radioactive Materials and Contamination, Surveys, and Monitoring

The NRC inspector reviewed the implementation of the licensee's program

for control of radioactive materials and contamination, surveys, and

monitoring for compliance with Technical Specifications (TSs) 5.11.1 and

5.11.2 and 10 CFR Parts 20.105, 20.201, 20.203, and 20.401.

The NRC inspector reviewed selected radiation work permits, radiation and

contamination surveys, and radiological incident reports for the period

April 1, 1985 through April 8, 1986. The NRC inspector discussed with

licensee representatives that the radiation and contamination survey

results did not always indicate that beta radiation surveys were being

routinely performed. The licensee stated that zero readings which

indicated no detectable beta radiation were not always documented. The NRC

inspector stated that a zero reading should be recorded the same as a

positive reading. The licensee acknowledged the need to document all

survey results. *

The NRC inspector verified by independent surveys that the radiation

levels documented on licensee radiation survey records were accurate.

The NRC inspector questioned the availability of portable radiation survey

instrumentation for C/RP personnel to perform routine and reactive

radiation surveys. The licensee had two R0-2A ionization survey meters

and two teletector high range survey meters that were routinely response I

checked daily and three additional R0-2As and one R0-7 that were in the '

C/RP equipment locker. The NRC inspector discussed with licensee

representatives that a large amount of equipment was out-of-service and

unaccounted for. The NRC inspector expressed concern that with the

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limited amount of equipment available and that C/RP technicians may use

instruments from the equipment locker or conceal an instrument in the

plant to support surveys or jobs under his direction and circumvent the

daily response check. The licensee was not concerned about the limited

number of instruments available and stated that the C/RP would not use an

instrument without response testing as required. The licensee reviewed

the out-of-service and unaccounted for instruments and initiated a program

to return additional instruments to service.

No violations or deviations were identified.

6. Facilities and Equipment

The NRC inspector reviewed the licensee's facilities and equipment for

routine and emergency operations including equipment for compliance with

the Final Safety Analysis Report and Radiological Emergency Response Plan.

The NRC inspector noted that the licensee had upgraded their personnel

monitoring program for personnel exiting the radiologically controlled

area with the purchase of four personnel contamination monitors (PCM).

These PCMs are effective and assure consistent detection of radioactive

material below the level detectable by frisking.

Technical Specification 5.8.1 requires that " written procedures and

administrative policies shall be established, implemented and maintained

that meet or exceed the minimum requirements of Section 5.1 and 5.3 of

ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 . . . ."

This requirement is emphasized in the FCS operating manual. Standing

Order G-1 which states: " Strict adherence to the provisions of the

standing orders is mandatory for all personnel."

The NRC inspector reviewed the calibration records for the PING radiation

monitor unit number 214 which had been identified as unresolved

item (285/8525-01). The licensee had not located the calibration data for

the August 15, 1985, calibration. The NRC inspector' stated that the

failure to retain these data is an apparent violation of TS 5.8.1 and FCS

Standing Order C-2 " Fort Calhoun Station Quality Assurance (QA) Records"

which requires a 5 year record retention period (285/8608-01).

Technical Specification 2.21 requires that: " Post-accident

instrumentation shall be operable as provided in Table 2-10. If the

required instrumentation is not operable, then the appropriate action

specified in Table 2-10 shall be taken." Table 2-10 requires with the

vide range noble gas stack monitor RM-063M or RM-063H not operable the

licensee shall: " Initiate the preplanned alternate method of monitoring

the appropriate parameter (s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and (1) either restore the

inoperable channel (s) to operable status within 7 days of the event, or

(2) prepare and submit a special report to the Commission pursuant to

Specification 5.9.3 within 14 days following the event outlining the

action taken, the cause of the inoperability, and the plans and schedules

for restoring the system to operable status."

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The NRC inspector had previously (see NRC Inspection Report 50-285/85-25) "

discussed with licensee representatives the status of the wide range noble

gas stack monitor RE-063L, M and H. The midrange and high range channels

had not been calibrated. The licensee had stated in letter LIC-84-301

dated September 5, 1984, that these monitors were expected to be

operational by September 14, 1984. The NRC inspector determined in

NRC Inspection Report 50-285/85-25 that these monitors had not been

returned to operational status in September 1984. The licensee stated

during the exit interview on November 8, 1985, for NRC Inspection

Report 50-285/85-25 that a second letter had been submitted to the

Commission that extended the September 14, 1984, date for operation of

RE-063M and H. However, the licensee in letter LIC-86-095, dated March 7,

1986, stated that OPPD had subsequently determined that the second letter

had not been sent to the Commission. The NRC inspector stated that failure

to provide a special report to the Commission covering the period beyond

September 14, 1984, constitutes an apparent violation of TS 2.21 (285/8608-02).

Technical Specification 5.8.1 requires that " written procedures and

administrative policies shall be established, implemented and maintained

that meet or exceed the minimum requirements of Section 5.1 and 5.3 of

ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 . . . ."

RG 1.33, Appendix A, Item 8.b.(1),(aa) addresses specific procedures for

surveillance tests, inspections, and calibrations should be written for

area, portable, and airborne radiation monitors.

The NRC inspector reviewed maintenance and calibration records for selected

portable radiation survey instruments. The licensee does not maintain a

maintenance history for portable survey instruments and consequently could

not assure that portable radiation survey equipment had been properly

calibrated after any maintenance which could effect previous calibrations.

The licensee had not developed or implemented calibration procedures for

the Bicron RS0-5 and Bicron Tech 50 portable radiation monitors. The

licensee stated that they were returning these instruments to the

manufacturer for calibration. The NRC inspector discussed with licensee

representatives the status of these portable radiation monitors and the

fact that the manufacturer was not on the qualified vendor list, no copy of

the manufacture calibration procedure was available for review, no

maintenance records could be documented, and station procedures had not

been developed for the operation and calibration of these instruments.

This was considered an apparent violation of TS 5.8.1 (285/8608-03).

7. 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 April 10, 1986. The NRC inspector summarized the scope and

findings of the inspection including the observations noted in paragraph 2 l

of this report. The licensee indicated that the NRC inspector observations

would be reviewed. 1

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TABLE 1

PERSONNEL RADIATION EXPOSURE

Year 1981 1982 1983 1984 1985

FCS Man-Rem 458 217 433 566 374

PWR (Avg.) Man-Rem 652 578 592 552 Not Available

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ATTACHMENT 1

TECHNICAL SERVICES OPERATING PROCEDURES

N-TSOP-3 Calibration of the Cesium-137 Source, Revision 2, July 1985

N-TSOP-4 Calibration of the Harshaw Model 2271 TLD Reader,

Revision 0, November 1984

N-TSOP-9 Annealing TLD Cards, Revision 1, June 24, 1985

N-TS0P-10 Source Procedures for Irradiating TLDs, Revision 2,

June 24, 1985

N-TSOP-12 Quality Control / Test Badges, Revision 1, November 1, 1984

N-TSOP-13 Resensitizing TLD Cards, Revision 1, July 3, 1985

N-TSOP-14 Dose Calculation for TLD Specials, Revision 1, June 24, 1985

N-TSOP-15 Reading TLD Cards, Revision 2, July 10, 1985

N-TSOP 16 Monthly Exposure Report, Revision 1, July 10, 1985

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i ATTACHMENT 2

RADIATION PROTECTION PROCEDURES

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RPP-6 Protective Clothing and Respiratory Equipment Cleaning, ,

Revision 11, July 30, 1985

i RPP-18 Instrument Selection, Revision 5, July 23, 1985

RPP-19 Gamma Source Exposure Rate Verification, Revision 5, May 13, 1985

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RPP-20 Radiation Work Permits (RWP), Revision 4, August 29, 1985

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HP-1 Fast Scan Whole Body Counting, Revision 6, June 19, 1985 i

HP-1A Whole Body Count Evaluation, Revision 0, August 27, 1985 l

HP-2 Respiratory Fit Test Quantitative Polydispersed Aerosol Test,

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Revision 5, November 13, 1985

HP-5 Collection and Analysis of Air Samples, Revision 6, September 19,

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HP-9 Contamination Control, Revision 2, July 2, 1985

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HP-11 Whole Body Frisking, Revision 1, September 27, 1985

HP-14 Counting Instrument Operation, Revision 4, October 31, 1985

HP-15 Portable Dose Instrument Operation, Revision 6, August 13, 1985

HP-17 Control of Personal Radiation Detection / Monitoring Devices,

Revision 1, November 18, 1985

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ML20206F601

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