ML20008D940
| ML20008D940 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/08/1980 |
| From: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20008D942 | List: |
| References | |
| NUDOCS 8010230703 | |
| Download: ML20008D940 (4) | |
See also: IR 05000298/1980007
Text
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% NUCLEAR REGULATORY COMMISSION Jd . . ^ REGloN IV i
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b, 611 RY AN PLAZA oRIVE. SulTE 1000 {{ ARLINGTON, TEXAS 76012 4 '% # September 8, 1980 % .* Docket No. 50-298 Nebraska Public Power District ATDh Mr. J. M. P11 ant Licensing and Quality Assurance Manager Post Office 3ox 499 Columbus, Nebraska 68601 Gentlemen: Subj ect: Health Physics Appraisal The NRC has identified a need for licensees to strengthen the health physics programs at nuclear power plants and has undertaken a significant effort to assure that action is taken in this regard. As a first 'tep in this effort, the Office of Inspection and Enforcement is conducting r.pecial team appraisals of the health physics programs, including the health physics aspects of radio- active waste management and onsite emergency preparedness, at all operating power reactor sites. The objectives of these appraisals are to evaluate the overall adequacy and effectiveness of the total health physics program at each site and-to identify areas-of weakness that need to be strengthened. 'Je will use the findings from these appraisals as a basis not only for requesting individual licensee action to correct deficiencies and effect improvements but also for effecting improvements in NRC requirements and guidance. This effort was identified to you in a letter dated January 22, 1980, from Mr. Victor Stallo, Jr., Director, NRC Office of Inspection and Enforcement. During the period of May 5-16, 1980, the NRC conducted the special appraisal of the health physics program at the Cooper Nuclear Station. Areas a - 4 ed during this appraisal are described in the enclosed report (50-298/80-07). '41 thin these areas, the apprai<:a1 team reviewed selected procedures and respresentative records, observed work practices, and interviewed personnel. It is requested that you carefully. review the findings of this report for consideration in effecting -improvements to your health physics program. The findings of the appraisal at Cooper indicate that although your overall haalth physics program is adequate for present operations, several significant weaknesses exist. These include the following: -N (1) Personnel selection, qttalification and training criteria for the health ~"% physics staff have not. been established to neet NRC requirements and industry scandards. m* 8 010230 g3
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(2) The healta physics program is deficient in providing all of the necessary , i elements for evaluating personnel intakes of radioactivity and internal exposure dosimetry. (3) The personnel conemmination surv=41'=nce and control program is not consistant with good health physics practices. 1 l These. findings are discussed.in more detail in Appendix A, "Significant
Appraisal Findings." We recognize that an explicit regulatory requirement ! pertaining to each significant weakness identified in Appendix A may not l currently exist. However, to determine whether adequate pretection will be l protidad for the health and safety of workers and the public, you are requested to submit a written statement within twenty (20) days of your l receipt of this letter, describing your corrective action for each significant j weakness identified in Append 1x'A including: (1) steps which have been i taken; (2) steps which will be taken; and (3) a schedule for completion of l action. This request is made pursuant to Section 30.54(fi of Part 50, j Title 10, Code of Federal Regulations. { During this appraisal, it was also found that certain of your activities
do not appear to have been conducted in full compliance with NRC requirements as set forth in the Notice of Violation enclosed herewith as Appendix 3. The - ! items of noncompliance in Appandir 3 have been categorited into the levels of severity as described in our Criteria for F.nforcement Action dated December 31, 1974. Section 2.201 of Part 2, Title 10, Code of Federal Regulations, requires you to submit to this office, within twenty (20) days of your receipt-of this notice, a written statement or explanation in reply including: (1) corrective steps which have be.en cuan by you and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; end (3) the date when full conpliance will be achieved. You should be aware that the next step in the NRC effort to strengthen health physics programs at nuclear power plants will be the imposition of a requirement by the Office of Nuclear Reactor Regulation (NRR) that each licensee develop, submit to the NRC for approval, and implement a Radiation Protection Plan. F.ach licansee will be expected to include in the Radiation Protection Plan sufficient measures to provide lasting corrective action for significant- weaknesses identified during the special appraisal of the current health physics pror, ram. Guidance for the development of this plan will incorporate partinent findings from the special appraisals and will be -issued by NPJL in the fall of this year. " ' ' In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, ~" Title.10, Code of Federal Regulations, a copy of this letter and the enclosures wd11 be placed in the NRC's Public Document Room. If this - _,
1 . . . Nebraska Public Power District -3- saterial contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Commission as listed in Subparagraph (3)(4) of Section 2.790. The information sought to be withhe,1d shall be incorporated as far as possible into.a separate part of the affidavit. If we do not hear from you in this regard within the specified period, this letter and the enclosures will be placed in the Public Document Room. Should you have any questions concerning this inspection, we vill be pleased to discuss them with you. Sincerely, Karl V. Seyfrit Director Enclosures: 1. Appendix A, Significant Appraisal Findings 2. Appendix 3, Notice of Violation 3. Office of Inspection and Enforcement Inspection Report No. 50-298/80-07 cc w/ enclosures: L. C. Lessor, Station Superintendent P. O. Box 98 3rownv411e, Nebraska 68321 -r , , N* e <
. . -_ - - _ __ . . APPENDIX A SIGNIFICANT APPRAISAL FINDINGS Nebraska Public Power District Docket No. 50-298 Cooper Nuclear Station Based upon'the results of the NRC Health Physics Appraisal conducted May 5-16, 1980, it appears that several significant weaknesses exist in the health physics program as indicated below. (References are to sections of the appraisal report) A. Personnel selection, qualification and training criteria for health physics staff members have not been established in written Station procedures to assure that appointments to the health physics staff will meet the requirements of Technical Specification 6.1.4, which references ANSI N18.1-1971, and the guidance established in NRC Regulatory Guide 1.8. In addition, the initial training program for health physics staff is not structured to assure that the qualification criteria above are met prior to appointment to responsible positions. l ~(Section 2.0)
B. Internal exposure control program procedures containing necessary I biological models and calculational techniques have not been
established to assess the results of direct and indirect bioassay i measurements ir terms of intake limits specified in 10 CFR 20.103 and-internal dosimetry guidance available in ANSI N343-1978, " Internal dosimetry for mixed fission and. activation products." In addition, Station procedures do not fully implement the requirements of 10 CFR 20.203(d)(1)(li) and 10 CFR 20.103(b) in regard to defining an airborne radioactivity area, ensuring consideration of engineering _ controls for airborne radioactivity areas, defining the 40 MPC-HR control measure and evaluating exposures which exceed this control measure to assure against recurrence. (Section 3.2). l C. Personnel contamination monitoring procedures for workers exiting the ' reactor building are not in accordance with good practice, in that . workers are not. required to monitor for contamination with a sensitive instrument, such as a frisker or hand and foot monitor, prior to exiting from the reactor building airlock. Personnel contamination . monitoring at this point was observed to be limited to passing through . l a relatively insensitive portal monitor. (Section 3.3). ! . ,, , , - u= w d ,, ,, , , - , - .- <, w. }}