IR 05000298/1986033

Insp Rept 50-298/86-33 on 861117-20.No Violations or Deviations Noted.Major Areas Inspected:Licensee Radiation Protection Program During Refueling Outage

ML20212E336
Person / Time
Site:	Cooper
Issue date:	12/11/1986
From:	Murray B, Wise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212E303	List: IR 05000298/1986033 ML20212E298
References
RTR-REGGD-08.015, RTR-REGGD-8.015 50-298-86-33, NUDOCS 8701050300
Download: ML20212E336 (7)

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APPENDIX U.S. NUCLEAR REGULATORY C0tWISSION

REGION IV

NRC Inspection Report: 50-298/86-33 License: 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: Brownville, Nebraska Inspection Conducted: November 17-20, 1986 Inspector: - - ' ' ' .

/2/u/5 R. Wise, Radiation Specialist, Facilities Date Radiological Protection Section Approved: / 3 O(Lf W / /Z///A$i B. Murray, Chief, Fac/lities Radiological Date'

Protection Section Inspection Summary Inspection Conducted November 17-20, 1986 (Report 50-298/86-33)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program during a refueling outag Results; Within the areas inspected, no violations or deviations were identifie PDR O ADOCK 05000298 PDR i

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DETAILS Persons Contacted NPPD

• R.. Horn, Division Manager, Nuclear Operations

• J. V. Sayer, Radiological Manager

• R. L. Beilke, Chemistry and Health Physics (HP) Supervisor

• C. R. Goings, Regulatory Compliance Specialist

• G. E. Smith, Acting QA Manager T. J. Chard, Health Physicist B. Hall, Lead HP Technician E. M. Rotkvic, Lead HP Technician J. P. Morris, ALARA Coordinator R. Brungardt, Operations Manager J. R. Flaherty, Plant Engineering Supervisor Other Personnel-

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• W. R. Bennett, USNRC

• M. E. Skow, USNRC

• Denotes those present during the exit briefing on November 20, 198 The NRC inspector also interviewed several other licensee employees, including health physics, maintenance, operations, and administrative personne . Inspector Observations

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The following are observations the NRC inspector discussed with the licensee during the exit briefing on Nr/ ember 20, 1986. These observations are neither violations nor unresolved items. These items were recommended for licensee considerr. tion for program improvements, but they have no special regulatory requiremen Radiological Posting " Hot Spot" posting is not addressed in HP procedures. See paragraph 8 for detail Survey Instrument Response Tests - Portable radiation survey instruments are not response tested at the expected ranges of operation. See paragraph 12 for detail Neutron Survey Instruments - The portable neutron radiation survey instrumentation calibration program does not satisfy the recommendations in ANSI N323-1978. See paragraph 12 for detail ,

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3 Fuel Transfer Operations - A well defined radiological control

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program has not been established for fuel transfer operations; See paragraph 5 for details, Personnel-Dosimetry - The capabilities of the present beta monitoring device and the use of multiple badging for select personnel is not described in HP procedures. See paragraph 5 for detail Training - Contractors previously employed by CNS are not routinely required to take written examinations prior to commencing current employment. See paragraph 4 for detail Testing of HEPA Filters - Temporary HEPA filter systems are not tested. See paragraph 10 for detail . Advance Planning and Preparation The NRC inspector observed work activities in the refueling area, drywell, control rod drive (CRD) rebuild room, multipurpose facility, turbine building, and selected radwaste area The licensee had implemented the use of additional personnel contamination monitors, portable constant air monitors, and portable temporary HEPA filter system < The NRC inspector expressed concern that the ALARA coordinator was not involved with job preplanning in the early design change phase to permit ALARA concerns to be addressed prior to the issuance of work request The licensee had augmented the permanent HP staff with eight contractor HP

technician No violations or deviations were identifie . Staffing, Qualifications, and Training Staffing, personnel qualifications, and training programs provided to workers were inspected for compliance with the requirements of Technical

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Specification (TS) 6.1.4; commitments in Chapter 13 of the Updated Safety Analysis Report (USAR); and the recommendations of ANSI N18.1-197 The NRC inspector reviewed the training and screening program for contractor HP support personnel. The NRC inspector noted that contractor personnel with previous experience at CNS are not given written screening examinations, regardless of the period of time which has elapsed since the previous employment period. The NRC inspector discussed the need.to provide periodic retraining for contractor personnel concerning changes to plant operating procedures, radiation protection practices, and plant specific informatio No violations or deviations were identifie . - .

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4 External Exposure Control The NRC inspector 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 The NRC inspector determined that all personnel entering the radiation controlled area (RCA) were issued thermoluminescent docimeters (TLD)

which were processed monthly, and direct-reading dosimeters (DRD) as required by the special work permit (SWP). The licensee uses the DRD results for tracking personnel exposures on a daily basis until the monthly TLD processing is completed.

The NRC inspector reviewed selected personnel exposure history filer to determine that NRC Form 4s were completed prior to exceeding 1250 mrem / quarter. exposure limi The NRC inspector reviewed selected records and observed radiological controls for radiation exposure monitoring, extremity badging, beta dosimetry, and multi-badging for nonuniform radiation levels. The NRC inspector noted that multi-badging is not a routine practice at CNS. The liceasee's procedures specify that, for a specific job, a single dosimeter is positioned on the body at the location considered to receive the highest dos The NRC inspector discussed the problems involved with attempting to use one dosimeter to provide proper personnel monitoring in nonuniform radiation field The licensee stated that beta surveys and shielding evaluations had been performed on the CRD prior to commencing work; however, detailed documentation was not available that indicated what protective clothing was used to reduce personnel exposure to high beta radiation level ,

The NRC inspector noted from discussions with health physics and  ;

, operations personnel that a well defined program has not been established regarding radiological controls in the drywell during spent fuel movemen The NRC inspector noted that procedures had not been established that addressed the following items: Personnel accountability within drywell prior to fuel movemen Verification that radiation area monitors are operational with appropriate warning lights and alarm A Verification that posting and positive control are established in drywel.l . Coordination of fuel movement activities between the health physics ;s:

and operations department No violations or deviations were identifh , - . _ - . . - . -_ . -

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- 5 s,, Internal Exposure Control The NRC inspector 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) 8.1 The NRC inspector inspected the drywell, CRD rebuild room, and the refueling floor during the inspection to revi u internal exposure control practices. Procedures and associated records were also reviewed and ( ,- '

discussions were held with licensee personnel to determine if internal

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," exposures during the outage were being controlled. The NRC inspector

N. reviewed a representative sample of the active and terminated special work permits (SWPs) and records associated with their implementation. The NRC ir.spector reviewed area grab air samples used to track maximum permissible

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concentration-hours (MPC-hr) exposure ,

j, The NRC inspector discussed with the licensee the concern that the CRD

, rebuild room atmosphere was not continuously monitored for airborne concer.tration during work activities. The licensee had taken periodic grab samples, but a continuous air monitor was not sampling airborne concentration in order to alert workers of high airborne concentration The NRC ins'pector reviewed the licensee's use o'f respiratory protection

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equipment and verified that the workers had completed the licensee's

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. qualification progra s

[ % No violations or deviations were identifie . Radioactive an Contaminated Materials Control The NRC inspector observed the program being implemented during the outage to control contaminstion and radwaste in the radiation controlled area (RCA). The NRC inspector observed that workers were properly dressed out in protective clothing (PC) for the areas in which they were working and that procedures for the removal of PC and for using step-off pads were-being followed. All personnel exiting the reactor building were required to monitor thelnselves with personnel friskers and then pass through se,nsi~tive portal monitor ,

t s 1 No violations or deviations were identifie ., Postind, Labelling, and Worker Control

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The NRC inspector verified that RCAs were properly posted and in compliance with 10 CFR 20.20 The NRC inspector performed independent radiation surveys and found them to be in agreement with licensee surveys and-area posting , . . .

l The NRC inspector noted that the licensee had not addressed " Hot Spot" posting in CNS Procedure 9.1.2.2, although the licensee routinely uses hot sp'ot posting in the plan i g 4

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The NRC inspector reviewed SWPs to ensure that CNS and contractor personnel were following approved instructions in the RCA Specified SWP approved procedures appeared to have been followe No violations or deviations were identifie . ALARA Program The NRC inspector reviewed the licensee's ALARA program to determine agreement with the recommendations of RG 8.8 and 8.1 The licensee had implemented an aggressive ALARA program during the 1985 pipe replacement outage; however, this ALARA program was not continued to include the normal operations and outage condition The NRC inspector expressed concern that the CNS ALARA program does not follow the recommendations of RG 8.8 and 8.10 and that these concerns were previously addressed in NRC Inspection Reports 50-298/80-07, 82-20, 83-11, 85-04, and 86-05. The NRC inspector noted that the present CNS ALARA program did not include the following features:

An ALARA committee ALARA checklists ALARA goals

ALARA coordinator involvement in design change discussions

Adequate staffing No violations or deviations were identifie . Surveys-The NRC inspector reviewed the licensee's program for implementing and performing radiation, contamination, and airborne radioactivity surveys to determine compliance with the requirements of 10 CFR Parts 20.103, 20.201, and 20.40 The licensee's survey program appeared to be~ adequate for contamination and radiation surveys for prework evaluations and SWP generation. The NRC inspector noted that the licensee had implemented the use of portable HEPA filter systems. The NRC inspector noted that temporary HEPA filter systems had not been leak teste l At various times during the inspection period, the NRC inspector conducted '

independent. surveys of the drywell, CRD rebuild room, multi purpose

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y-s facility, refueling floor, various radwaste work areas, and the turbine building to verify that radiological-conditions were as recorded on radiation. survey forms and SWPs.

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{ 'No violations or deviations were identifie . Notifications and Reports r

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The NRC inspector 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 inspector's review, in addition to radiological worker training, respiratory fit training, radiation exposure history, and radiation

. exposure' data,. included the radiological incident reports and personnel r . contamination' reports.

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No violations or deviations were identified.

. 1 Instrumentation

~The NRC inspector reviewed selected instrumentation calibration records to

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determine compliance with TS 6.3, station procedurcs, and the

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recommendations of RGs 8.4 and 8.25 and' ANSI Standard N323-1978.

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The NRC inspector, reviewed response check procedure for portable radiation survey instruments. The operational response test is conducted with a

small microcurie. source that only provides a 1-2 mR/hr reading. The NRC inspector noted that the present response test program does not provide

reference check points at similar radiation levels present in the plant as recommenced in ANSI N323-197 ; The NRC inspector noted that neutron survey instrumentation is calibrated l' by an offsite vendor. However, the calibration source used was not representative of the neutron energies identified at BWRs, and the highest calibration point was 27 mrem /hr from a Pu-Be calibration source, whereas

. survey results indicated that workers were exposed to neutron levels in the

300-400 mrem /hr range. The NRC inspector stated that although this calibration technique has been used in the past, improvements have been made in this area. The inspector discussed some of these improvements with the license No violations'or deviations were identifie , . , 13.' Exit Briefing-The NRC inspector met with licensee representatives denoted in paragraph 1 on November 20, 1986, summarized the scope and findings of the inspection, and discussed the-observations identified in paragraph 2 of this' repor s l-

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