IR 05000298/1981008
| ML19350E742 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/04/1981 |
| From: | Baird J, Brown G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19350E739 | List: |
| References | |
| 50-298-81-08, 50-298-81-8, NUDOCS 8106230487 | |
| Download: ML19350E742 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
IE Inspection Report No. 50-298/81-03 License No. OPR-46 Docket No. 50-298 Licensee:
Nebraska Public Power District (NPPD)
Facility:
Cooper Nuclear Station (CNS)
Inspection at:
Cooper Nuclear Station, Nemaha County, Nebraska Inspection Conducted:
May 4-8, 1981 G; /D O e d b/2 /T/
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Inspector:
J. 8. 8aira, Raciation Specialist 0' ate
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Approved by:
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/ GlerfD. Brown, Chief, Tecnnical Inspection
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Branch Inscection Summary Insoection on May 4-8, 1981 (Report No. 50-298/81-08)
Areas Inscected:
Routine, unannounced inspection of the licensee's Radiation Protection Program during refueling operations including advanced planning, iriternal and external exposure control, training, surveys, access and contamination control, respiratory protection c.nd a tour of facilities involved-in the refueling.
The inspection invalved 11 inspector-hours by one NRC inspector.
Results:
No violations or deviations were notec.
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DETAILS 1.
Persons Contacted (NPPD)
- L. C. Lessor, Station Superintendent J. Sayer, Chemistry and Health Physics Supervisor R. Mcdonald, Health Physicist J. Warren, Chemist W. Gilbert, Education Specialist V. Wolstenholm, Quality Assurance Supervisor R. Jansky, Shift Supervisor
- Present at the exit interview.
In addition to the above personnel, discussions were held with NPPD technical personnel and contractor personnel.
2.
Inspector Followup On Previously Identified Items (0 pen) Significant Weakness - Health Physics Appraisal (Inspection Report 50-298/80-07):
No written procedures to implement Technical Specification 6.1.4 and ANSI N18.1-1971 for selection, qualification and training of health physics staff.
Initial training not set up to assure qualifications are met prior to appointment to responsible positions.
The inspector verified that Station Operating Procedure 1.5, " Selection and Training of Station Personnel," had been revised (Revision 5, 2/23/81) to provide health physics qualification and training require-ments.
Also, the health physics training program had been restructured to provide qualification training on a more timely basis and assure documentation of each phase.
The above action appeared to be as stated in the licensee's response to the Appraisal finding.
However, it was noted that Procedure 1.5 only establishes qualification criteria for the Radiation Protection Manager and does not address the ANSI N18.1 qualification criteria for health physics technicians.
The Station Superintendent stated that the necessary steps would be taken to correct this discrepancy.
This item will be considered open (50-298/81-08/01) until action is completed.
(Closed) Significant Weakness - Health Physics Appraisal (Inspection Report 50-298/80-07):
No written procedures to implement internal dosimetry techniques for evaluating internal exposure in
terms of guidance in ANSI N343-1978 and requirements of 10 CFR 20.103.
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The inspector. verified that Procedures 9.1.5, " Respiratory ' Program" and 9.1.8, " Bioassay-Whole Body. Counting" had been revised to incorrorate guidance on internal exposure evaluation, and appropriate
. training of the health physics staff conducted.
(Closed) Significant Weakness - Health Physics *.79raisal (Inspection-Report No.- 50-298/80-07):
Personnel exiting the reactor building were not required to survey for contamination with a sensitive radiation detection instrument.
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The inspector verified that the licensee had implemented a program' of requiring the use of a -sensitive frisker instrument when exiting -
'the reactor building if a contaminated area had been entered or if con-tamination is suspected.
The licensee is also evaluating the feasibility of using new sensitive walk through monitors for personnel surveys.
(Closed) Infraction - Health Physics Appraisal (Inspection Report No. 50-298/80-07): Two health physics technicians appointed to responsible positons prior to attaining requisite working experience.
The licensee has updated qualification and training records of the technicians and implemented a policy that technicians can not perform independent tasks unless qualifications are met and documented.
(Closed) Infraction - Health Physics Apprsf;6i (Inspection Report No. 50-298/80-07):
Control of entry in+. ' gh radiation area in drywell not in accordance with re? *r.gwits.
The licensee has provided dose rat Ae
~ing devices in high radiation areas inside the drywell :hich ccatinuously indicate the dose rate and alarm if the dose rate increases significantly.
Entry into the drywell is authorized by the shift supervisor's signature on the Special Work Permit.
(Closed) Infraction - Health Physics Appraisal (Inspectior deport No. 50-298/80-07):
Failure to provide proper respiratory prc'*ction device to painter working in the torus.
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The inspector verified that Procedure 3.1.5, " Respiratory Program,"
had been revised (Revision 9, 1/14/81) to specify proper selection of respiratory protection devices and that instructions in implementing this procedure had been provided to the health pnysics staff.
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3.
Advanced Planning and Preparation for Refueling The' inspector discussed the licensee's advanced-planning and preparations for the outage with-the Chemistry and Health Physics Supervisor (CHPS)
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and examined the licensee's inventory of supplies and equipment.
Tha inventory of supplies and equipment appeared to be adequate to support
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the outage.
The inspector noted that.the licensee has recently obtained additional _ portable survey instruments, air soi.plers,'new sample
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counters and frisker probes.
The-CHPS described the radiation protection considerations related to:
(1) input of information identifying work requiring rad'ation control; (2) estimation of health physics manpower needs; (3) inventory of supplies and instrumentation; (4) special training, and (5) use of information
- rom previous outages in regard to dose reduction techniques which can ce applied to work involving significant personnel exposure potentials.
The CHPS stated that he was provided sufficient advance notice of activities scheduled for the outage to enable proper planning and pre-parations by the health physics staff.
The inspector also examined the communications during the outage, both within the health physics staff and with other departments.
No problems were noted.
No violations or deviation were identified.
4.
Radiation Pretection Training The inspector discussed initial and refresher radiation protection training with licensee representatives and reviewed selected training
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records for new employees, regular plant staff, contract employees and heilth physics technicians.
The inspector also attended and observed a general employee radiation protection training session presented for new contract personnel reporting onsite.
The review of records and observation of training indicated compliance with 10 CFR 19.12 requirements and CNS radiation protection training procedures.
No violations or deviations were identified.
5.
Internal and External Excosure Control The inspector reviewed the outage external exoosure stat'is sheets
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showing daily accumulated whole Ocdy exposures; and rniewed the
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licensee's exposure records for permanent employees, transient workers and terminated per=annel.
This review indicated tnat personnel
exposures were being properly documented and that no worker had l
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received whole body exposure in excess of the limits specified in 10 CFR 20.101(b).
Records in the licensee's files also indicated that exposure reports had been sent to terminated personnel in accordance with the requirements of 10 CFR 19.13 and 20.409(b).
The inspector found that the licensee has initiated a computerized dose data management system and is currently operating it in parallel with the manual procedure until the system is confirmed to be operat ng correctly.
The licensee uses a cocinercial dosimetry service to supply and process their TLD badges.. The.fnspector noted that the licensee was not perfonning quality control checks on the vendor's performance by supplying TLDs irradiated to known doses.
Further investigation showed that this had been 'done routinely prior to 1980, and -had simply lapsed since that time. This was discussed with the CHPS and the licensee will reinstate this practice on a routine, periodic basis.
This item is considered open (50-298/81-08/02) and will be reviewed during a future inspection.
The inspector also reviewed MPC-hour tabulations for workers in airborne radioactivity areas, and routine and special whole body counting results.
_ It was noted that the MPC-hour log indicated no internal exposures in excess of the 40 MPC-hour control measure or quarterly.. intake limits specified in 10'CFR 20.103, and whole body cou'nting data indicated no internal body burdens in excess of the licensee's action. level of 10
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percent of the maximum body burden recommended by the ICRP.
The inspector questioned the adequacy of-the whole body counting action level to identify potential intakes of all nuclides at the 40 MPC-hour
- ontrol measure level. The CHPS stated that-the whole body counting _
action level will be reevaluated for nuclides routinely encountered at CNS to detcranne if a lower level should be used.
This item is
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consideredopen(50-298/81-08/03) until this reevaluation is completed.
c No violations or deviations were identified.
6.
Resoiratory Protection Program
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The inspector reviewed the licensee's program for use of respiratory protection during the outage.
It was noted that the program had been updated since the Health Physics Appraisal by special training and revised procedures.
Review of airborne radioactivity survey results indicated that work requiring respiratory protection had-not been extensive. The inspector examined the licensee's records of respiratory protection training together with medical qualification and re-qualification for respiratory users and found no discrepancies.
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inspector's review. indicated that the respiratory protection program was being conduted in accordance witn the requirements of 10 CFR 20.103 and Regulatory Guide 8.15.
No violations or' deviations were identified.
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Surveys
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The inspector reviewed selected records of radiation and' airborne radioactivity surveys to determine compliance with 10 CFR 20.201 and 20.401.
The scope and frequency of the surveys reviewed appeared to be adequate to support the Special Work Permit (SWP) control program.
During the records review, the inspector noted that air sample filters were routinely counted for beta gamma and alpha radioactivity shortly after collection.
The Hecith Physics Appraisal (Report No. 50-298/80-07)
previously identified proolems in the determination of alpha radioactivity-in air with the CNS routine procedure.
This was discussed with the CHPS, and it was found that CNS had instituted a special procedure for collection and counting of airborne radioactivity to provide a more accurate concentration determination.
The CHPS stated that the routine air samples were not supposed to be counted for alpha radio-
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activity and immediate action would be taken to stop this practice.
No violations or deviations were identified.
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8.
Access and Contamination Control The inspector reviewed SWPs for outage work and visited various radiologically controlled areas to observe access controls, compliance with SWP conditions, posting and labeling, personnel contamination monitoring and general housekeeping.
During a general tour of the reactor building on May 6, the inspector observed a TLD and self-reading dosimeter hanging on a clothing rack.
The licensee was notified, and it was subsequently determined that a contractor employee had forgotten to replace the dosimetry after removing it to don protective clothing prior to entry to the torus.
The licensee conducted an investigation of this occurrence and a dose of 20 millirem was estimated based on
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the general radiation level of about 10 millirem per hour, the stay time and the self-reading dosimeter of another individual who accompanied this person in the torus.
The proper use of personnel dosimetry was reemphasized to the employee, and a whole body dose of twice the estimated value was added to his exposure record.
No violations or deviations were identified.
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9.
Procedures-The inspector reviewed the following health physics procedures which had been changed or revised since the Health Physics Appraisal:
9.1.1.4.
Special Work Permit, Revision 4 9.1.2.1 Radiation, Contamination and.4irborne Radioactivity Limits, Revision 8 9.1.2.2 Area Posting and Access Control, Revision 4 9.1.5 Respiratory Program, Revision 9 9.1.8 Bioassay - Whole Body Counting, Revision 7 9.3.1.1.3 Mini Rad, Model 3006, Revision 2 9.3.1.2.2 Extended Probe Teletector - Eberline Model 61128, Revision 3 9.3.3.2 TLD Program, Revision 3 9.5.3 Radioactive Material Shipment, Revision 4 9.5.4.2 Solid Radioactive Waste Calculations, Revision 3 The inspector commented that HP Procedure 9.1.2.1 implemented new, lower contamination levels for protective clothing while HP Procedure 9.1.4 still has the old, higher values.
Also, HP Procedure No. 9.3.1.2. 2 described beta monitoring with the Teletector but did not caution that the high range detector location in the probe effectively shields out incident beta radiation.
The CHPS stated that appropriate changes to the procedures would be made.
No violations or deviations were identified.
10. Audi ts The inspector reviewed reports of audits related to the radiation
. protection program which had been conducted by the licensee since the Heal th Physics Appraisal.
The following audits were reviewed:
Audit 81-8, QAP-200 Training, 2/18/81-3/4/81 Audit 80-20, QAP-903 Health Physics 10/7/80-10/22/80
Audit 81-9, QAP-1200 Radwaste, 3/11/81-3/19/81 l
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The audit reports were reviewed for scope and timely. followup actions fo-items identified during the audits.
No problems in this regard were noted.
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No violations or deviations were identified.
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11.
Exit Interview The inspector met with the Station Superintendent at the CNS site at the conclusion of the inspection on May 8, 1981.~
The inspector summarized the purpose and scope of the inspection, and discussed
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'the inspection findings.
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