IR 05000298/1990023
| ML20044A904 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/25/1990 |
| From: | Murray B, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20044A903 | List: |
| References | |
| 50-298-90-23, NUDOCS 9007160324 | |
| Download: ML20044A904 (9) | |
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APPENDIX o
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U.S. NUCLEAR REGULATORY COMMISSION:
REGION IV
NRC Inspection-Report:
50-298/90-23 Operating License:
DPR-46 Docket:
50-298 a1 Licensee:
Nebraska'Public Power District (NPPD)
P.O. Box 499
i Columbus, Nebraska 68602-0499
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. Facility Name:
Cooper Nuclet.- Station (CNS)
= Inspection At: CNS, Brownsville, Nebraska Inspection Conducted: June 4-8, 1990 Inspector:
h dfM 6-2E-#o i
LM. F icke)) son,t.E_., Senior Radiation
'Date J
Speci414 st FaciTTties Radiological Protection Section
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Accompanied
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By:
Blaine Murray, Section Chief, Facilities Radiological
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.c Protection Section (June-4-6, 1990)
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Approved:
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BlaineMpfray,SectionChiff, Facilities Date Radiological Protection (/Section
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fInspection Summary Inspection Conducted June 4-8, 1990 (Report 50-298/90-23)
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Areas Inspected:
Routine, unannounced inspection of portions of the radiation protection program including organization and management controls, training and
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qualifications, external exposure control, internal exposure control, and controls of radioactive material and contamination.
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Results: Within the areas inspectad, no violations o-deviations were identified.
An adequate staff was maintained in the health physics (HP)
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department with very little turnover.
l'echnic'ans met qualification requirements, but there appeared little emphasis, on the part of the licensee, t
to promote professional development. The radiological controlled area (RCA)
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-2-F was still not completely implemented. The number of personnel contaminations
. and the amount of contaminated area within the RCA has been reduced. Quality..
- assurance (QA) personnel responsible for HP auditing appeared'to.have little "
- technical; expertise-to-rely on-in-evaluating-the radiation protection program...
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DETAILS =
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Persons' Contacted NPPD
"G.~R. Horn, Nuclear Power Group Manager
- J. M. Meacham, Division Manager, Nuclear Operations
.R.LL. Beilke, Radiological Support Supervisor
- L. E. Bray, Regulatory Compliance Specialist-
- S; L. Bray, Operations QA Supervisor
- T. E. Carson, ALARA Coordinator
- T. J. Chard, HP Supervisor J. W. Dutton, Nuclear Training Manager D. L. Gibson, Audit'and Procurement QA Supervisor
- M.. A. Gillan, Nuclear Training Supervisor-B.
L.-Hall, Health Physicist
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- J. V. Sayer, Radiological Manager
- G. R. Smith, Licensing Supervisor
- V. L. Wolstenholm, Division Manager, QA NRC
- W. R. Bennett, Senior Resident Inspector
- Denotes those present at the exit meeting on June 8, 1990,
2.
Open Items Identified During This Inspection An open item is a matter that requires further review and evaluation by the inspector, such as an item pending specific action by the licensee or La previously iden'ified violation, deviation, unresolved item, or programmatic weakness. Open items are used to document, track, and ensure adequate. followup on matters of concern to the inspector. The following; open item was identified.
Open Item-Title Paragraph 298/9023-01 Technical Training for Managers
and Supervisor; 3.
Observations The following are observations the inspector discussed with the licensee representatives. The observations are not violations, deviations, unresolved items, or open items. Observations are identified for licensee consideration as program improvement items, but have no specific regulatory requirement.
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QA personnel Qualifications QA personnel had.little or no training ~in matters related to HP.
See paragraph 4~..
Exchange of Information Key personnel in various departments had not-had the opportunity to visit counterparts at other sites to share information related to-their job functions.
See paragraphs 4 and 5.
Respiratory protection Issuance Instructio'ns given to personnel issuing respiratory protection equipment did not include instructions to ensure that' individuals receive respirators of the-same size as that indicated by fit testing.
See paragraph 7.
Decontamination Crew The licensee did not have full-time decontamination personnel.
See paragraph 8.
4.
Organization, Staffing, and Management Controls The inspector reviewed the organization, staffing, and management controls to-determine compliance with-Technical Specifications (TSs) 6.1.2 and 6.1.3; and agreement with Chapter XIII and Appendix D of the Updated Safety Analysis Report (USAR).
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During nonoutage times, contract.HP personnel were not employed and licensee personnel, except for those.in Operations, worked only one shift.
A HP technician'was on site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, however, in compliance with TS 6.1.3.E.
Residence quarters were furnished for the HP personnel _on backshift who worked on a voluntary, rotating basis.
Key staff members are required to' carry pagers so that they may be reached in-the event of an emergency. The inspector reviewed tL emergency phone list. maintained by the licensee.
The inspector reviewed QA Audit 89-23, the most recent audit of the HP department, performed January 5 through February 20, 1990. The audit resulted in three " findings" and one observation. The results were presented to the plant-manager and HP manager and the HP department's response to the items was timely.
The inspector observed that in some cases the-audit was not thorough.
For example, the auditors reviewed records of respirator issue and verified that individuals given respirators had received the necessary respiratory protection training as required, but did not verify that fit testing was completed satisfactorily
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t or that' the individuals had received annual physicals.. The' inspector noted.that two of the findings involved plant personnel's failure to follow procedure rather than programmatic weaknesse's within-the HP department.
The inspector interviewed'the auditor responsible for reviewing the HP
. area and determined that the individual had limited HP expertise. The licensee representative stated that he had once received a 4-week course in HP, but since that time he had received no training from the site training center in'HP matters, had never had a rotational assignment with'
the HP department, or had never visited a QA program at another site for counterpart discussions.
The inspector reviewed 10 surveillances performed thus far this year and noted that 7 were performed by individuals with.less HP experience than
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the HP auditor (who performed-the remaining three).
The inspector reviewed _ the " Surveillance Checklist Index," which lists the repetitive core surveillances and not(J the absence of surveillances in such areas as respiratory. protection, wh>1e body counting, and contractor qualifications.
The licen.ae representative stated that the core surveillances, in many cases, were developed in response to third party audits but QA could perform sirveillances of any areas as it determined appropriate.- However, the inspector determined that auditors lacked sufficient time to review HP procedures and initiate new surveillances.
No violations or deviations were identified.
5.
Training and Qualifications
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The inspector reviewed the training program for radiation protection (RP)
workers and RP : technicians and reviewed qualifications for RP'tecnnicians _
s to determine compliance with TS 6.1.4 and 10 CFR 19.12.
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Representatives from the HP and training departments met monthly to
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-discuss the training needs of the HP department.
HP personnel met 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> weekly for industry events training which included discussions of items-such as-information notices and bulletins, as well as information from other sources.
The HP department had no designated training coordinator. However, the
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licensee's representative stated that-it is expected that one of the duties of the new HP advisor will be to keep abreast of training courses and seminars available it, the industry.
Until recently, there was only one training instructor providing technical training for HP personnel.
With the transfer of one of the HP technicians to the training department, the HP training staff has been increased to two; however, the second individual will rot be instructing full time until November, i
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-6-The inspector interviewed the technical instructor and determined that he had adequate time to prepare for classes; however, the instructor appeared
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to have limited resources in regard to a reference library, not having such documents'as regulatory guides or the proposed 10 CFR Part 20.
The
instructor. stated that he had never v' sited other sites to review other
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training programs.
The licensee was performing an analysis of current qualification training i
to determine which segments should be required on a recurrent basis.
-Currently, there is no recurrent' training except for that given'in the onsite availability training.
It did not appear that the. licensee placed emphasis on developing the HP.
technicians beyond minimum requirements.
This was evidenced by the fact that only one individual, the HP technician instructor, had been certified by:the National Registry of Radiation Protection Technologists.
The< inspector. determined that there was no technical training program for supervisors and managers as recommended by industry standard, A14SI:18.1-1971.
This was also identified by the licensee during the 1988 QA audit of-.the training department. The department responded that such a.
program would be developed and subsequently the licensee decided,that such'
.a training program would be adapted corporate wide.
It had not been implemented at the time of the inspection and may not be, according to licensee representatives, 'until the end of 1990 or early 1991. This was
--identified as an open-item (298/9023-01).
.No violations or deviations were identified, e
6.
External Exposure Control The inspector reviewed the licensee's external exposure control program to determine compliance-with TS 6.3.4 and the requirements of 10 CFR parts =20.101,_20.102, 20.105, 20.202, and 20.401.
The licensee used. vendor to provide personnel monitoring devices. The
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inspector determinn' that the licensee exposed a control group of thermoluminescen dosimeters (TLDs) and returned them for processing. The
' licensee verified-that the results were within their acceptance criteria of 125 percent. The-licensee's representative stated that there had been a sufficient supply of TLDs for the recent outage and that reporting time for. exposure.results was sufficiently short.
The inspector reviewed posting and controls on locked high radiation areas in the RCA and identified no problems.
No violations or deviations were identified.
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-Internal Exposure Control
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The in'spector reviewed the licensee's program for control of internal.
radiation exposure to determine compliance with-TS 6.3.4, 10-CFR b
Parts =20.103, 20.201, and 20.401; and agreement with the recommendations
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of Regulatory Guide (RG) 8.16, NUREG-0041, Industry Standards ANSI Z88.2-1980-and ANSI /GCA G-7.1-1989.
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l, The area _used for cleaning, maintenance, and storage of respiratory protection equipment has been= moved and e~nlarged.- Licensee L-representatives stated that respiratory protection training will be'
~. required ' annually as will fit testing. _ ihe inspector noted that-currently
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the respirator issue records do not indicate the size of the respirator; issued. 'The licensee utilizes one make of respirator-in three sizes.
The size of the respirator for which the individual is qualified is currently indicated on:the individual's respirator. card.
The' inspector-further-noted that there W.s'no instruction to the issuing personnel to t.
H" verify that individuals ro.:eive respirators of a size matching that for L
which they were successfT ly fit tested, j
The licensee reported only one example in 1990 of an individual's whole
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body count results being above the reporting guidelines (10 nanocuries) of the Institute of Nuclear Power Operations. An individual's axit count-indicated an uptake of 15 nanocuries of cobalt-60.
The licensee representatives pointen out that the individual left the sight before-L L
further whole body counting could be performed to determine if there had-L been an'actualiuptake rather than external contamination.
Therefore the occurrence was considered an example of internal. contamination.
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No violations or desiations were identified.
8.
Control of Radioactive Material and Contamination, Surveys, and Monitoring E
The inspector reviewed the licensee's program for surveying / monitoring and controlling radioactive materials to determine compliance with TS 6.3.4,
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10 CFR Parts' 19.12,-20.201, 20.203, 20.205, 20.207, 20.301,.and 20.401;
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and agreement with the commitments in Chapter VII o# the USAR.
The licensee had 39 percent fewer personnel contaminations in the 9-week, L
1990 outage than in the 10-week, 1989 outage.
There were a total of 391 personnel contaminations in 1989 and 230 thus far, in 1990.
'The licensee initiated the use of color-coded trash bags to minimize the
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L amount of trash which had to be monitored.
In this way bags from the
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reactor building or other areas within the RCA and likely to have
- contaminated waste were easily identifiable and were checked by hand frisking in a trailer specifically designated for that purpose.
Bags
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originating outside the RCA,- and so distinguished by their color, were not L
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b subjected to hand frisking. To reduce the amount of trash generated in l
the RCA, items were removed from their packaging before being moved from
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the warehouse to the RCA.
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- During the first part of the year and through the outage, the licensee?
employed a 12-man crew of decontamination contractors and made substantial improvements-in reducing the amount of contaminated area within the RCA.;
At thet time of the inspection, the contractors were no longer employed and any decontamination was performod by a group of individuals in the
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maintenance department. The individuals had other duties to perform as well-and thus were not solely. dedicated to decontamination activities.
The licensee has not yet implemented a means of checking items leaving the'RCA,- such as tools, for contamination. All. personnel were instructed to-use personnel contamination monitors before leaving through any of three exits from the RCA. Within the RCA wert ' ingestion areas." These
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were areas in which eating and drinking were permitted, since the site
.does not_have a' centralized dining facility.- Personnel entering the ingestion areas were required to first use automatic hand and foot
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monitors to-check.for contamination.
Items such as lunch boxes were not
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observed to be monitored.
The inspector observed personnel both entering ingestion areas and leaving the RCA-and did not identify anyone-f ailing to use either the hand and foot monitors or the personnel contamination monitors.
No violations or deviations were identified.
9.
Transportation
The inspector reviewed the licensee's program for transportation of radioactive materials and radioactive waste to determine compliance with the requirements of 10 CFR Part 71 and 49 CFR Parts 170 through 189.
The licensee had made 15 shipments of radioactive waste in 1990. They
- consisted of dry activated waste and dewatered resins.
Fourteen shipments were sent to Washington; one was sent to Nevada. Two people were assigned to the transportation program.
They received training in transportation requirements and current events in 1988 and will receive additional training in 1990.
The inspector verified that the licensee had burial site permits, current NRC'and Department of Transportation regulations, certificates of compliance, and a quality assurance program for transportation. The inspector reviewed records of shipments and determined that they contained
- checklists for preparing shipments, radiological surveys of the shipments, and manifests of. materials.
No violations or deviations were identified.
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- 10.- Exit Meeting.
The inspector met with the resident inspector and the 1icensee's representatives denoted in paragraph-1 at the conclusion of the inspection on June 8, 1990, and summarized the scope and findings of the inspection
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as presented in this report.
The-licensee did not identify as_ proprietary A
any of the ~ materials 'provided to, or reviewed by, the inspector during the inspection.
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