ML20080E036
| ML20080E036 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/03/1983 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| CNSS837228, NUDOCS 8308300702 | |
| Download: ML20080E036 (4) | |
Text
7
/
- "?dokS[d!b%'**""
Nebraska Public Power District CNS0837228 August 3, 1983 e cmt% _
h[h, 1 Mr. G. L. Madsen
!g, ffM f'
Reactor Project Branch I u y[
U. S. Nuclear Regulatory Commission f
Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011
Subject:
NPPD Response to IE Inspection Report No. 50-298/83-11
Dear Mr. Madsen:
This letter is written in response to your letter dated July 8, 1983, trans-mitting Inspection Report No. 50-298/83-11. You also requested that we respond to the open items discussed in paragraph 2 and expressed concern regarding lack of action on these open items. NPPD does not agree that a lack of action is evident. Four of the six open items were identified during inspection 50-298/82-32. Inspectfon Report No. 50-298/82-32 was received on March 11, 1983, and inspection 50-298/83-11 was conducted beginning May 9, 1983. This allowed approximately 60 days for these items to be addressed.
Most of the items require much attention and short-term solutions are not available.
It is hoped that this is evident in our responses to these open items provided below.
Open Item (298/8220-02): Exposure Control - This item was discussed in NRC Inspection Report 50-298/82-20 and involved the lack of a documented thermoluminescent (TLD) versus direct-reading dosimeter (DRD) discrepancy evaluation. The licensee had initiated a program to review the TLD vs. DRD results, but had not completed a written procedure which detailed the review criteria, documentation, and approval of the discrepancy evaluation. This item remains open. See paragraph 5 for details.
Response
After receiving Inspection Report No. 50-298/82-20, a computer program was written and implemented to compare monthly vendor TLD results with pocket chamber dosimeter exposure readings. This program identified those compari-sons which did not correlate within acceptable levels. During inspection number 50-298/82-32 the inspector felt the review of the comparison results needed better documentation and review. Procedure 9.1.1.3 " Personnel Dosimeter Program" was revised to require a review of the comparison results by the llealth Physicist. During inspection number 50-298/83-11 the inspector 8308300702 830803 PDR ADOCK 05000298 i
i G
,_L,-
II D i
.g G. L. Madsen August 3, 1983 Page 2 did not feel this was adequate. After the inspection was completed, and prior to receiving the associated inspection report, Procedure 9.1.1.3 was revised to include guidance on how the comparison results are to be reviewed by the Health Physicist, and that the Chemistry and Health Physics Supervisor will also review the results of the comparison and exposure determination.
It is hoped that this will resolve this open item.
Open Item (298/8220-02): ALARA Program - This item was discussed in NRC Inspection Report 50-298/82-20 and involved the lack of a formal ALARA program which satisfied the recommendations of Regulatory Guide 8.8.
The licensee had not completed procedures for the ALARA program. This item remains open.
See paragraph 11 for details.
Response
An ALARA program procedure has been drafted and is undergoing final review within the Chemistry and Health Physics Department.
It is anticipated that the procedure will be available for station and upper management's review shortly af ter the 1983 outage is completed. A position authorization request has been submitted to management for the ALARA Coordinator position. It is anticipated that the resulting ALARA program will be implemented during the fourth quarter of 1983.
Open Item (298/8232-01): Radiation Worker Training - This item was discussed in NRC Inspection Report 50-298/82-32 and involved the lack of a radiation worker training program that included all the elenents of Regulatory Guides 8.27 and 8.29 recommendations. This item remains open.
See paragraph 7 for details.
Response
NPPD is implementing a very extensive upgrade in the CNS training program.
In order to rapidly implement this program, a vendor has been hired to develop and initiate it.
As permanent training staff members are hired, they will assume the training responsibilities from the vendor. Radiation protection training (with the elements in regulatory guides 8.27 and 8.29 added) will be included in the general employee training section of the training program.
Also, a position authorization request has been submitted for the General Employee Instructor position to administer this section of the training effort.
It is anticipated that the new general employee training program will be implemented by December 31, 1983.
Open Item (298/8232-02): Beta Radiation Calibration of Portable Survey Instrumentation - This item was identified in NRC Inspection Report 50-298/82-32 and involved the-lack of full range beta calibration as recom-mended by ANSI N323-1978. This item remains open.
See paragraph 10 for details.
Response
While NPPD does not disagree with the NRC interpretation of ANSI N323-1978, NPPD has not been able to locate any commercial instrument calibration service capable of doing beta calibrations as described, nor are commercial sources
4 G. L. Madsen August 3, 1983 Page 3 available such that on-site calibrations could be performed. For further guidance, the Radiation Physics branch of the National Bureau of Standards was contacted. They stated that to their knowledge, no commercially available service or sources are available to perform this calibration. They further stated that they are presently investigating a method of doing this type of calibration, but at the present time are not aware that it can be accomplished in a satisfactory manner.
A letter has been written to the-Radiation Physics branch of the National Bureau of Standards requesting that NPPD be provided with any available information pertaining to beta calibration of portable survey instruments and a time estimate as to when their investigation on this subject will be completed. This item will have to remain open pending further research and development by the National Bureau of Standards, or until services and/or sources are commercially available.
Open Item (298/8232-03): Whole Body Counter Operational Check - This item was identified in NRC Inspection Report 50-298/82-32 and involved the lack of an operational check of the whole body counter as recommended by ANSI N343-1978.
This item remains open.
See paragraph 6 for details.
Open Item (298/8232-04): Whole Body Counter Calibration - This item was identified in NRC Inspection Report 50-298/82-32 and involved the lack of a comprehensive calibration and testing program as recommended by ANSI N343-1978. This item remains open.
See paragraph 6 for details.
Response
Since these two open items are very closely related, they will be addressed under one response.
The whole body counting program has had several modifications over the last few months. The whole body counter itself was moved to a better location within the new EOF building. The unit was completely serviced by a Helegson representative. A new direct access telephone line was installed for automatic dial by the counter's computer to the main computer at the Helegson offices. Brownville does not have complete access direct dial capabilities.
Also, a new computer program is about to be installed in the counter that will give more information about the count before the results are transmitted to Helegson.
NPPD was performing a quarterly calibration check with a phanton and sources.
As discussed in section 4.f. of Inspection Report 50-298/82-32, the inspector felt that the number and range of the sources used in this calibration check should be expanded. Health Physics personnel have been working closely with Helegson on upgrading this calibration check.
It was originally felt the whole body counter's built-in source would suf fice as a daily or prior to use operational check, but as discussed in paragraph 6 of this Inspection Report (50-298/83-11) this is not satisfactory. The phantom and source calibration check coordination is nearly completed. With this clarification on the operational source check, a procedure revision _and program conversion can proceed.
It is anticipated that the whole body counting program, including procedure and computer program revision, can be accomplished. We anticipate completing this item by November 1,1983.
G. L. Mad: n e
August 3, 1983 Page 4 If you have any questions regarding this response please contact me or Paul Thomason at the site.
Sincerely, M
Jay M. Pilant Technical Staff Manager Nuclear Power Group JMP:JVS:RJM: Is/sn
_