IR 05000285/1985025: Difference between revisions

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{{Adams
{{Adams
| number = ML20141E125
| number = ML20212P974
| issue date = 12/13/1985
| issue date = 08/28/1986
| title = 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
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/85-25
| author name = Baer R, Murray B, Spitzberg D
| author name = Gagliardo J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Andrews R
| addressee affiliation =  
| addressee affiliation = OMAHA PUBLIC POWER DISTRICT
| docket = 05000285
| docket = 05000285
| license number =  
| license number =  
| contact person =  
| contact person =  
| case reference number = RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM
| document report number = NUDOCS 8609030353
| document report number = 50-285-85-25, NUDOCS 8601070565
| title reference date = 07-31-1986
| package number = ML20141E109
| package number = ML20212P977
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 13
| page count = 2
}}
}}


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=Text=
=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:
AUG 2 81986 In Reply Refer To:
R. 4. Baer, Radiation Specialist, Facilities
Docket:
          / M TA/ b ' '
50-285/85-25 Omaha Public Power District ATTN:
!          Date Radiological Protection Section FIN W    /Z-13M a
R. L. Andrews, Division Manager-Nuclear Production 1623 Harney Street Omaha, Nebraska 68102 Gentlemen:
D.B.Spitzbsrg,RadFhtfinSpecialist      Date Facilities Radiological Protection Section i
Thank you for your letter of July 31, 1986, providing an update on the status of commitments made in your letter dated July 13, 1986, that responded to NRC Inspection Report 50-285/85-25 and the Notice of Violation. We will review the implementation of your corrective actions during future inspections and after October 1, 1986, when detector RM-063H will have been calibrated.
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 inspector EG23 PDR O ADOCK 05000285
 
PDR
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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 Persons Contacted 0."D
  * 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 personne * Denotes thor >e individuals present during the exit interview cn November 8, 198 . 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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Sincerely, J. E. Gagliardo, Chief Reactor Projects Branch cc:
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W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt, Esq.
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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 '
LeBoeuf, Lamb, Leiby & MacRae
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 repor '
1333 New Hampshire Avenue, NW Washington, DC 20036 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bcc:
Open item 285/8226-14 is considered closed.
(see next page)
 
f RIV:FRPS C:FRPS f C:R&P C:R
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;  (Closed)~0 pen Item (285/8226-17): NUREG-0737, Item II.F.1 ( Attachment 3),
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  ' 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
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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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; 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
C:RPB 4 RBaer:cd BMurray WLFis DRHun er JEG lia7 o d
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details.
/86 (
 
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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, 198 See paragraph 11 for details.
 
j 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
!
program improvement, but they have no specific regulatory requirement.
:  The licensee indicated that these items would be reviewed:
! 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 detail i I
j Instrument Repair - The licensee had a.large quantity of. radiation '
i  . protection survey meters, airborne radiation monitors, and personnel r
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contamination monitoring instruments out-of-servic See paragraph 5 for details, Decontamination Personnel - The ccntractor personnel assigned to decontamination duties in the auxiliary building were not performing all duties in a manner considered radiologically saf See paragraph 5 for detail 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, 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 detail 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 detail 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 detail Job Preplanning - The C/RP and ALARA groups are not involved with job preplanning. See paragraph 5 for details.
a
 
, 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 coverag 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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ak Omaha Public Power District-2-bcc w/1tr dtd 7/31/86 from licensee:
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  ,
DMB (IE06)
a training course to provide these individuals with a better understanding i of radiation and precautions for handling radioactive materia 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
RPB Resident Inspector R. D. Martin, RA R&SPB Section Chief (RPB/B)
  .
MIS System RIV File DRSP RSTS Operator RSB DWeiss, LFMB (AR-2015)
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 concer 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 use No violations or deviations were identifie . 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 personne The NRC inspectors determined that the requirements of 10 CFR Part 19.12 were being me 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 wor No violations or deviations were identifie . 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 20.20 ;
 
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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 shif 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 limi 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 for 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 TLD !  The licensee program for recording other than routine exposures appeared to be adequat No violations or deviations were identifie . 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-004 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 controlle 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 channe Action taken by the licensee in response to the alarms was to order special grab fr samples to assess the airborne concentration of iodin The NRC inspectors examined the PING calibration procedures and records of the.f r calibration to ascertain the significance of the iodine alarm 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 recor 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- No violations or deviations were identifie . Radioactive and Contaminated Materials Control The NRC inspectors observed the efforts being implemented during the outage to control contamination and radwaste in the RC 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 monitor The NRC inspectors observed that  -
articles which had been carried into the RCA were being surveyed prior to remova 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 vesse 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, identifie Posting, l.abelling, and Worker Control
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1 The NRC inspectors verified that the radiologically controlled areas were properly posted and they appeared to be in compliance with 10 CFR 20.20 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 posting '
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 orde 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 area 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 are No violations or deviations were identifie . 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. The midrange and high range channels had not been calibrated. The NRC inspectors reviewed the calibration for the low range channel of the WRNG monito 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 number 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, 198 The licensee stated that a second letter was written after September 5, 1984, which extended the date of expected operability for the mon! tor However, the licensee was not able to locate a copy of the second lette 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 monitor 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 guid The licensee stated that they expect to start the plateout studies during calendar year 198 No violations or deviations were identifie _ _ - - _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ . _ .
 
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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 8.1 ,
l  The NRC inspectors determined that the licensee had established a goal of i
491 manrem for the year 1985 and had expended 224 manrem as of November 6,
  ~198 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 RC No violations or deviations were identifie . 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 20.40 '
i 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 warrante ,
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 acceptabl No violations or deviations were identifie . 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 reoccurrenc No violations or deviations were identifie > 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 repor The licensee stated that these items and observations would be reviewe .
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Latest revision as of 10:22, 23 May 2025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/85-25
ML20212P974
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 08/28/1986
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Andrews R
OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20212P977 List:
References
NUDOCS 8609030353
Download: ML20212P974 (2)
v • d • e


Text

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AUG 2 81986 In Reply Refer To:

Docket:

50-285/85-25 Omaha Public Power District ATTN:

R. L. Andrews, Division Manager-Nuclear Production 1623 Harney Street Omaha, Nebraska 68102 Gentlemen:

Thank you for your letter of July 31, 1986, providing an update on the status of commitments made in your letter dated July 13, 1986, that responded to NRC Inspection Report 50-285/85-25 and the Notice of Violation. We will review the implementation of your corrective actions during future inspections and after October 1, 1986, when detector RM-063H will have been calibrated.

Sincerely, J. E. Gagliardo, Chief Reactor Projects Branch cc:

W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae

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1333 New Hampshire Avenue, NW Washington, DC 20036 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bcc:

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DMB (IE06)

RPB Resident Inspector R. D. Martin, RA R&SPB Section Chief (RPB/B)

MIS System RIV File DRSP RSTS Operator RSB DWeiss, LFMB (AR-2015)

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