IR 05000298/1986024

Insp Rept 50-298/86-24 on 860804-08.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Including Internal & External Exposure Control & Control of Radioactive Matls & Contamination

ML20214M748
Person / Time
Site:	Cooper
Issue date:	09/02/1986
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214M739	List: IR 05000298/1986024 ML20214M736
References
50-298-86-24, NUDOCS 8609110261
Download: ML20214M748 (7)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION- - -

REGION IV .

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NRC Inspection Report: 50-298/86-24 Lic'ense: DPR-46 Docket: 50-298 Licensee: Nebraska Public Power District (NPPD)

P. O. Box 499 . -

Columbus, Nebraska 68601 Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS, Brownville, Nebraska Inspection Conducted: August 4-8, 1986 Inspector: / f M JK E. B&er, Radiation Specialist, Facilities Dite '

Radiological Protection Section Approyed: lA() h ])Al/5$$ $fb6 04te '

B. Murray, Ch9ef, Fac/'lities Radiological Protection Section Inspection Summary Inspection Conducted August 4-8, 1986 (Report 50-298/86-24)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program including: internal exposure control; external exposure control; control of radioactive materials and contamination, surveys and monitoring; and facilities and equipmen Results: Within the areas inspected, no violations or deviations were identifie '103 PDR ADOCK 05000298 G PDR

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-2-DETAILS c Persons Contacted (NPPD)

• R. Horn, Division Manager, Nuclear Operations

• L. Beilke, Chemistry and Health Physics Supervisor T. J. Chard, Health Physicist L. J. Cooper, Environmental Manager

• C. R. Goings, Regulatory Compliance Specialist B. Hall, Lead Health Physics (HP) Technician J. H. Kuttler, H.P. Specialist

• J. M. Meacham, Technical Manager E. M. Rotkvic, Lead H.P. Technician

• J. V. Sayer, Acting Technical Staff Manager M. Unruh, Maintenance Planning / Scheduler P. R. Windham, Emergency Planning Coordinator

• V. L. Wolstenholm, Acting Division Manager, Quality Assurance (QA)

Other Personnel

• E. A. Plettner, Resident Inspector, USNRC

• Denotes those present during the exit interview on August 8, 198 The NRC inspector also interviewed several other licensee and contractor employees including health physics, chemistry, maintenance, and administrative personne . Inspector Observations The following are observations the NRC inspector discussed with the licensee during the exit interview on August 8, 1986. 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 considered: Respiratory Fit Test - The licensee does not specify the frequency for respirator fit testin See paragraph 3 for additional detail Regulatory Guide 8.13 - The licensee does not provide Regulatory Guide 8.13 training to all worker See paragraph 4 for additional detail Portal and Laundry Monitor Calibrations - The licensee lacks supporting data for instrument calibration Sea paragraph 5 for additional detail . - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ __ - __ _ ___ ___ _ _ _ _ . . _ . _ ___

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'* -3-i ' Inventory of Emergency Equipment - The licensee's records do not

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reflect the actual date of inventories. See paragraph 6 for detail .' ' Internal Exposure Control and Assessment The NRC inspector reviewed the licensee's internal exposure control and assessment program to determine compliance with 10 CFR Part 20.103 and the recommendations of NRC Regulatory Guides (kG) 8.7, 8.8, 8.9, 8.15, and 8.26, ANSI Standards N13.1-1969 and N343-1978, and NUREG-004 The NRC inspector reviewed the licensee's internal exposure control program including administrative controls exercised by the issuance of special work permits (SWP) to control access to airborne radioactivity areas and the control levels and posting above which access to areas are restricted. The licensee routinely evaluates the use of auxiliary ventilation systems prior to requiring personnel to wear respiratory equipmen The licensee's respiratory protection program is detailed in Procedures 9.1.5, " Respiratory Program," Revision 19, October 30, 1985 and 9.1.5.1, which covers the operation of the respiratory fit test boot The NRC inspector discussed with licensee representatives the implementation of Procedure 9.1.5,Section IV.6, which requires respiratory protection equipment requalification training on a 2 year frequency and an annual physical examination. However, Procedure 9.1.5.1 does not specify the frequency at which personnel are required to demonstrate the ability to successfully wear a respirator. The licensee stated at the exit interview on August 8, 1986, that the NRC inspector's concerns would be reviewe The NRC inspector discussed bioassay techniques other than whole body counting with licensee representatives. The licensee stated that there had been no instances when the chemistry and health physics supervisor had deemed it necessary to collect and analyze urine and/or fecal sample Should it be necessary to collect samples, they would be sent to the University of Nebraska or a national laborator; for analysi No violations or deviations were identifie . External Occupational Exposure Control and Personal Dosimetry The NRC inspector reviewed the licensee's external occupational exposure control and personal dosimetry program for compliance with the requirements of 10 CFR Parts 19.13,20.101(a),20.101(b),20.102, 20.202(a), 20.104(a), and 20.401(a) and the recommendations of RGs 8.2, 8.3, 8.4, 8.7, 8.14, and 8.28, and ANSI Standards N13.11-1983 and N13.15-198 The NRC inspector reviewed selected licensee exposure history records for 37 current CNS and contractor employees to verify that NRC exposure limits were not exceede ,

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The licensee had established criteria to exceed the 10 CFR Part 20 )

exposure limits and site emergency exposure limits in '

Procedures EPIP 5.7.12 " Emergency Radiation Exposure Control" Revision 6, June 12, 1986, and EPIP 5.7.20 " Protective Action Recommendations" l Revision 5, August 19, 1985. The licensee's procedures were in agreement l with the recommendations of NUREG-0654 and the Environmental Protection 1 Agency Protective Action Guides. The NRC inspector noted the licensee had I not exceeded 10 CFR Part 20 limit The NRC inspector discussed with licensee representatives the l recommendations of RG 8.13 regarding the instruction to female workers about prenatal exposure risks to developing embryo and fetus. The ;

licensee routinely provides this information to female employees as part '

of the general employee training and documents this with a form signed by l the employe This form is only signed once, when the original training l is received. RG 8.13 recommends that, in addition to the employee (female),

her supervisor and her co-workers be provided instruction on prenatal exposure and be asked to acknowledge in writing that the instruction has been received. The NRC inspector stated that normally the instruction and l acknowledgement would be reaffirmed each time individuals received the I general employee training. The licensee stated at the exit interview on l August 8, 1986, that the NRC inspector's observation would be reviewe The NRC inspector verified that reports and notifications required to comply with 10 CFR Parts 19.13, 20.403, 20.405, 20.408, and 50.72(b) had been prepared in a timely manne No violations or deviations were identifie . 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 10 CFR Parts 19.11 and 20.203, and station procedures.

! Instrumentation i

The NRC inspector reviewed the licensee's procedures, calibration,

! and operation of radiation protection instrumentation used for both

, routine and emergency operations for agreement with the requirements i of the CNS Technical Specifications and recommendations of RGs and 8.25 and ANSI Standard N323-1978, i

l The NRC inspector reviewed the calibration records for the

survey meters, laboratory counters, portal monitors, and the laundry monitor. The NRC inspector noted that the licensee had changed from

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a cesium-137 to a cobalt-60 calibration source for laboratory counters.

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The licensee prepared the new cobalt-60 sources in accordance with i

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5-Procedure 8.9.3 " Radioactive Source Preparation," Revision 1, July 10, 1986. The NRC inspector noted that Procedure 8.9.3 does not require a verification of source activity of the prepared source with equipment calibrated to other National Bureau of Standards traceable standard The NRC inspector discussed with licensee representatives the documentation for calibration of the portal and laundry monitors in that the results did not always include the necessary supporting information such as source number, isotope, source calibration, and distance from source to detector calculations needed to verify that the calibration was correct. The licensee stated at the exit interview on August 8,1986, that Procedures 9.3.7, " Laundry Monitor" Revision 5, April 29, 1985, 9.3.4.1, " Portal Monitors (National Nuclear Corporation)" Revision 2, December 26, 1985, and 9.3.4.2, "Eberline Portal Monito s" Revision 5, July 16, 1984, would be reviewed and revised as necessary to include the supporting calibration data by October 31, 198 Radioactive Materials and Contamination Control The NRC inspector reviewed the licensee's radioactive material and contamination control progra The licensee has maintained an ongoing effort to reduce the size and

, number of contaminated areas in the plant. The licensee was in the

process of providing for a more positive control of personnel exiting from radiological controlled areas with the purchase of

" state-of-the-art" personnel contamination monitors,

• ' Surveys The NRC inspector reviewed selected radiation, contamination, and airborne surveys for the period January 1 through July 30, 1986, i

I conducted by the licensee for compliance with 10 CFR 20.201(a) to support work being performed on special work permit The NRC inspector performed independent surveys of areas inside and outside l the radiological controlled areas to confirm the licensee's survey data.

1 No violations or deviations were identifie . Facilities and Equipment The NRC inspector reviewed the licensee's facilities and equipment provided to implement the radiation protection program for agreement with the commitments contained in the Updated Safety Analysis Report. There had been no changes to existing facil1 ties or the addition of new facilities since the last inspection.

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-6-The NRC inspector reviewed quarterly inspection checklist for emergency monitoring and supporting supplies to determine compliance with Section 7 of the CNS Emergency Plan and Emergency Plan Implementing Procedure 5.7.21

" Emergency Equipment Inventory" Revision 7, June 5, 1986. The licensee uses a preventive maintenance (F.1) card to document the quarterly inventory. The NRC inspector discussed with licensee representatives that the PM cards do not accurately depict the date the inventory was conducted and status of equipment contained in the emergency lockers. For example, PM 04308 issued to the health physicist states " inventory emergency lockers / equipment IAW Attachment B; C; 0; E; F; G; of EPIP 5.7.2 Replace seals; sign this card when completed." This one card covers the inventories at the Technical Support Center (TSC), Onsite Support Center (OSC), Alternate Emergency Offsite Facility (AE0F). Emergency Offsite Facility (EOF), hospital, and ambulance. Other PMs which cover multiple areas are 04307, for the EOF and AE0F by the administrative support supervisor, and 04309 for the TSC, EOF, and AEOF by the emergency planning coordinator. The single signature and date indicates that all inventory requirements were conducted on one day. The licensee stated at the exit interview on August 8, 1986, that the PM cards would be reviewed

to improve documentation of inventorie The NRC inspector also discussed that Attachments A, B, and C to EPIP 5.7.21 requires a specific instrument to be in an emergency locker and that the licensee had a different instrument presen The NRC inspector noted that the replacement instrument was comparable by instrument type and range to the stated instrument. The licensee stated that the procedure was in the process of revision to specify a generic and not a specific instrumen The NRC inspector discussed replacement of equipment due for calibratio The licensee's Procedure 5.7.21,Section VIII.A.6., states "During inspection any equipment found inoperative or out of calibration shall be replaced in a timely manner." The NRC inspector noted that operational readiness of equipment in the emergency lockers should be maintained at all times and that replacement in a " timely manner" could involve a considerable length of time. The licensee stated at the exit interview on August 8, 1986, that they would review this matter to ensure operational readiness of equipmen The NRC inspector reviewed those procedures listed in Attachment 1 during this inspectio No violations or deviations were identifie . Exit Interview The NRC inspector met with licensee representatives and the NRC resident inspector denoted in paragraph 1 on August 8, 1986. The NRC inspector summarized the scope and findings of the inspection. The NRC inspector discussed the observations identified in paragraph 2 of this repor The licensee stated that these items would be reviewe "

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s-7-ATTACHMENT 1 9.1. Radiation Protection at CNS, Revision 5, August 15, 1985 9.1. ALARA Program, Revision 2, July 18, 1985 9.1. Personnel Dosimeter Program, Revision 20, May 19, 1986 9.1. Special Work Permit, Revision 15, March 21, 1986 9.1. Radiation, Contamination, and Airborne Radioactivity Limits, Revision 15, May 21, 1985 9.1. Area Posting and Access Control, Revision 7, April 25, 1985 9.1. TLD Area Radiation Monitoring, Revision 8, January 30, 1986 9.1. 3 Radiation Safety Standards, Revision 9 May 7, 1985 9. Protective Clothing (Anti-C), Revision 7, July 25, 1985 9. Respiratory Program, Revision 19, October 30, 1985 9. Personnel Decontamination, Revision 9, May 21, 1985 9.1. 8 Bio-Assays and Whole Body Counting, Revision 12, March 13, 1986 9. Radiation and Contamination Survey Frequency, Revision 12, March 13, 1986 9. Contamination Surveys, Revision 5, December 26, 1985 9. 3. 2. 3 Automatic Sample Changer (Gas Flow) Smear Counter, Revision 4, May 21, 1985 9.3. Gas Flow Proportional Counter Baird Atomic Automatic Sample Changer, Revision 4, July 2, 1986 9.3. Tennelec - LB5100 11 Operation and Calibration, Revision 1, June 26, 1986 l

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