ML20128N775
| ML20128N775 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/22/1985 |
| From: | Baer R, Jaudon J, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20128N749 | List: |
| References | |
| 50-298-85-14, NUDOCS 8506030383 | |
| Download: ML20128N775 (8) | |
See also: IR 05000298/1985014
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APPENDIX B
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.U.
S.: NUCLEAR' REGULATORY COMMISSION
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REGION IV
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NRC' Inspection Report: l50-298/85-14-
License: DPR-46.-
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-Docket: 50-298 :
? Licensee: l Nebraska Public' Power District (NPPD)
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P. O. Box 499
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~ Columbus, Nebraska: 68601L
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Facility Name: Cooper. Nuclear Station-(CNS)--
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Inspection'At: LCNS, Brownville,LNebraska
- ' Inspection Conducted: April 1-5, 1985
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-Inspector:
M
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R.E.Baer, Radiation}{4cialist, Facilities
Date-
Radiological Protection Section
-' Approved:
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BlaineMurray, Chief,facilites. Radiological.
Date
Protection Sect
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J{P.(Ja on, Chief, Reactor. Project Section A
Datst
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Inspection' Summary
Inspection Conducted April 1-5. 1985 (Report 50-298/85-14)
Areas Inspected: Routine, unannounced inspection of the licensee's radiation
protection program' including:- internal exposure control; external exposure
control; facilities and equipment;-control of radioactive materials and'
- contamination; and. surveys and monitoring. An allegation regarding personal
. dosimetry records was also reviewed. The inspection involved
42 inspector-hours onsite by one NRC inspectcr.
Results:; Within the five areas inspected, one violation was identified
(failure to. follow procedure, paragraph 7.a).
The allegation was partially
substantiated (paragraph 6). Two open items are discussed in paragraph 3.
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8506030393 850529
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DETAILS
1.
Persons Contacted
P. V. Thomason, Nuclear Operations Division Manager
- D. A. Whitman, Technical Staff Manager
- R. L. Beilke, Chemistry and Health Physics Supervisor
L. E. Bray, Administrative Secretary
- C, R. Going, Reculatory Compliance Specialist
- H..A. Jantzen, Instrument and Control Supervisor
J.- Kuttler, Health Physicist
R. J. Mcdonald, Assistant to Chemistry and Health Physics Supervisor
- J. M. Meacham, Technical Manager
P. Morris, ALARA Coordinator
C. R. Root, Dosimetry Clerk
- J. Sayer, Senior Technical Radiological Advisor
M. Unruh, Maintenance Planner
Others
- 0. L. DuBois, NRC Senior Resident Inspector
- Denotes those present during the exit interview on April 4, 1985.
The NRC inspector also interviewed several other licensee and contractor
employees including health physics, maintenance, warehouse, and
construction personnel.
2.
Licensee Action on Previous Inspection Findings
(Closed) Violation (298/8325-05):
Surveys - This item was identified in
NRC Inspection Report 50-298/83-25 and involved the failure to initiate
preliminary monitoring to accurately evaluate the radiation hazards for
several Special Work Permits (SWPs). The licensee had revised
Procedure 9.1.1.4, "Special Work Permit" Revision 11, January 26, 1984,
Section VI.B.5. to make allowance for areas where radiation levels are
rapidly increasing due to reactor power being resumed. This item is
considered closed.
(Closed) Unresolved Item (298/8325-08):
Radiation Protection Activities
Audit - This item involved the lack of documentation for review of a
corporate audit stated to have been conducted in June 1983. The NPPD
Safety Review and Audit Board (SRAB) approved health physics activities
audit 83-23 which had been conducted during the period September 26
through October 7,1983, during SRAB meeting number 80, held on
January 31, 1984. This item is considered closed.
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(Closed) Unresolved Item (298/8421-11): Qualifications of Health Physics
Technicians on Backshift - This item involved the lack of ANSI N18.1-1971
qualified personnel in responsible positions on the backshift and in
positions which approved SWPs. This item had been previously discussed in
NRC-Inspection Report 50-298/82-32. The licensee has health physics
technicians assigned to on-call duty onsite to cover backshifts should the
need arise. The licensee also has supervisory personnel assigned to
on-call duty offsite. The supervisory personnel are available to approve
SWPs or provide other guidance for technicians during the backshift. All
SWPs written and approved by technicians are also reviewed and initialed
by ANSI N18.1-1971 qualified persons. This item is considered closed.
(Closed) Unresolved Item (298/8421-13): Monitoring of Potentially
Contaminated Trash - This item involved the use of an E-140 radiation
detection device to monitor potentially contaminated trash being removed
from the radiologically controlled area. The E-140 had been calibrated
with a pancake type beta gamma GM tube contained in an HP-210 probe.
The
lowest scale read from 0 to 0.5 mR/hr in increments of 0.02 mR/hr.
The
background in this area where the trash was monitored varied from 0.02 to
0.04 mR/hr. This item is considered closed.
(Closed) Unresolved Item (298/8421-15) - Calibration of Portable Radiation
Monitoring Equipment - This item involved the calibration performed on
extender probe-extender Model 1000W survey meters not being performed in
accordance with approved station procedure.
The NRC inspector determined
that the instruments were not calibrated at three points on each scale as
required by procedures. This is considered a violation of Technical
Specifications. This item is considered closed as an unresolved item and
designated as a Violation (298/8514-01).
See paragraph 7.a.
(Closed) Open Item (298/8232-05): High Range Containment Monitor - This
item involved the lack of an approved electronic calibration procedure for
the containment high range radiation monitors. The licensee had developed
and implemented Surveillance Procedure 6.4.9.2, " Containment High Range
Area Monitor Calibration and Functional Test," Revision 0, March 22,1985.
This procedure provides for electronic calibration on the 10 R/hr through
107 R/hr ranges at one point on each decade. This item is considered
closed.
(Closed)OpenItem(298/8504-05): ALARA Checklist for QA Audits - This
item involved the lack of the quality assurance (QA) audit checklist used
to support audits performed in accordance with Procedure QAP-900 to
include ALARA program areas.
The licensee had revised QAP-900 checklist,
Revision 2, February 8, 1985, and included Section C which addresses the
ALARA program. These checklist questions are based on compliance with
Station Procedure 9.1.1.2, "ALARA Program." This item is considered
closed.
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3.
Open Items Identified During This Inspection
'Open items are matters that require further review and evaluation by the
inspector or licensee. Open' items are used to document, track, and
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ensure adequate followup on matters of concern to the inspector.
0 pen' Item
Description
Paragraph
298/8514-02
Portable survey meter pre-use
7.a.
operational check
298/8514-03
Frisker Operational Check
7.b.
4.
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 ANSI Standards N13.1-1969 and N343-1978 and NUREG-0041.
The NRC inspector reviewed procedures, representative records for the
airborne radioactivity sampling program, whole body counting, respiratory
protection program, and interviewed personnel to determine the
effectiveness of the program. The NRC inspector evaluated the respiratory
equipment used for both normal and emergency conditions, the equipment
accessibility, inventory of emergency equipment' lockers, and maintenance
of spare. breathing air bottles.
No violations or deviations were identified.
5.
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 Regulatory
Guides (RGs) 8.2,'8.3, 8.4, 8.7, 8.14 and 8.28 and ANSI
Standards N13.11-1983 and N13.15-1981.
The NRC inspector reviewed selected licensee training and exposure history
records for 32 current and past CNS employees and contractor personnel.
The licensee utilizes a vendor supplied thermoluminescence dosimeter (TLD)
which contains two lithium fluoride (LIF) chips (TLD 100) for beta and
gamma radiation exposure determinations. These LIF chips are behind
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2 filters. A third LIF chip (TLD 100) is used in
10 mg/cm and 285 mg/cm
approximately 45 badges worn by select plant staff personnel for neutron
exposure determination. The neutron TLD is designed to measure incident
neutrons. The vendor has been awarded a Certificate of Accreditation
under the National Voluntary Laboratory Accreditation Program for
providing specific personnel radiation dosimetry processing services for
exposure categories I through VIII.
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- The licensee exchanges TLDs on a monthly bests during normal operations. A
supplemental dosimetry ' service, operated by a vendor supplied technician, was -
established at CNS to provide additional TLD capacity during the recirculation
pipe replacement program outage.
Pocket chamber dosimeters direct reading
(DRD)~ assigned to individuals are read and exposures recorded each time the-
' individual. exits the. radiologically controlled area and daily when leaving at-
- the security guard house. These data are entered into the exposure control
computer system and used to track the individuals exposure until the'TLDs are
processed,'at which time the TLD data becomes the official exposure record.
The licensee routinely compares the TLD and DRD exposure ~results and when the
ratio' exceeds l.2 or is less than D.5 an evaluation is performed in accordance
with Section VI.B.1.c or VI.E.1.c of Station Procedure 9.1.1.3.
No violations or deviations were identified.
6.
NRC Findings and Conclusions Related to Allegation
a.
Allegation
Health physics department personnel altered individual radiation
exposure history records by reducing the radiation exposure results
or assigned the wrong exposure to individuals,
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NRC Findings ^
The NRC inspector observed the onsite TLD processing and quality
control (QC) applied to ensure accurate reading and recording of TLD
results. The' vendor had QC checks at the start of operations and
after every tenth badge was processed to ensure the TLD reader was
operating correctly and within tolerances. Procedures require that
.the technician remove i.he identification label from the.TLD and place
it on a sheet to verify that TLDs were read in the correct sequence.
The NRC inspector reviewed the TLD versus DRD discrepancy reports for
the period January 1984 through' February 1985. The NRC inspector
noted that in February 1985 discrepancy ratios as low as 0.239 had
-been reported. The licensee had leak tested and checked the accuracy-
of the DRDs assigned to the individuals, verified input data into the
dose tracking computer was correct, interviewed the individuals
involved, compared daily DRD results with other workers in similar-
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job functions, and had the vendor recheck the TLD records. The
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' licensee could not disprove either the TLD or DRD exposure results
and would routinely assign the TLD results regardless if the results
were high or low. The licensee interviewed one of five individuals,
(the other four had terminated employment), who's TLD results were
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low. After reviewing the information regarding the personnel
dosimetry results, the licensee elected to assign the more conservative
DRD exposure as the permanent record.
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c.
JNRC Conclusions-
The NRC inspector. determined thati (1) The allegation was
substantiated in part in that the licensee had initially assigned-
radiation exposure:results:from the TLD in accordance with station
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-procedures whf'h:were lower than the DRD results; (2) While differences
-between TLD's'and DRD's routinely occur and the differencas in this
. incident were greater than~the expected variance the licensee.had
followed.their written procedure and initially assigned the TLD
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exposure results; (3) The licensee did not intentionally attempt to
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- any NRC requirements by initially assigning-the TLD
results;1(4) No NRC requirement relating.to the permissible exposures
in a calender quarter would have been exceeded had the licensee
~ initially assigned this DRD results; and (5) The licensee assigned
the more conservative DRD results after re-evaluation of the
incident.
7.
Control of Radioactive Materials and Contamination. Surveys. and
- Monitoring
lThe NRC inspector reviewed the implementation of the licenset's program
- for control of radioactive materials and contamination, surveys, and
monitoring.for compliance with 10 CFR 19.11 and 20.203, and station
procedures,
a.
Portable Instrumentation
The NRC inspector reviewed the licensee's procedures, calibration,
and operation of radiation protection instrumentation use for both
routine and emergency operations against the requirements of the CNS
Technical Specifications and recommendations of RGs 8.4 and 8.25 and
ANSI Standard N323-1978.
The NRC inspector reviewed the calibration records.for the extender
probe extender Model 1000W portable GM survey meter Serial Number
15684, 15702, 15705, 15706, 15709, 15918 and 15920 which had been
performed during the period of February 1984 through March 1985.
This survey meter has seven ranges for radiation detection and
utilizes two GM tube detectors located at the end of a telescopic
probe. The NRC inspector determined that Procedure 9.3.1.2.2,
" Extender Probe - Extender Model.1000W," Revision 0, March 17, 1982,
Section VI.B.10, 11 and 14, requires the instrument to be calibrated
at 20 percent, 50 percent and 80 percent of full-scale for each
scale. The license had performed a calibration check between 40 and
55 percent of full. scale for each scale and selectively performed a
linearity check on two or three points on one or more ranges. The
high range, 0-1000 R/hr, was only checked at 10 percent and
40 percent of full scale. The failure to perform full range
calibration is considered a violation of Technical Specification Section 6.3.4. which states that procedures will be maintained con-
sistent with the requirements of 10 CFR Part 20(298/8514-01). The
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NRC inspector expressed concern that portable radiation survey meters
are only pre-use operational checked up to approximately 10 mR/hr and
are not always operationally checked on the range of intended use.
The licensee stated they would review the inspector's concern
re;.rding the pre-use operational check and make any needed
procedure changes by December 1985. This is considered an open
item (298/8514-02) pending the licensee's review of the inspector's
concerns.
b.
Rad *oactive Materials and Contamination Control
The NRC inspector reviewed the licensee's radioactive material and
contamination control program to determine compliance with station
procedures.
The licensee had recorded approximately 75 personal contamination
incidents during the period January 1 through March 29, 1985. The
licensee records did not differentiate between skin and clothing
contamination for personal contamination incidents. Contractor
personnel accounted for a majority of these incidents of contamination
and were decontaminated by soap and water washing. The NRC inspector
discussed with licensee representatives the response testing of friskers
used to monitor personnel for radioactive contamination. The NRC
inspector expressed concern that the licensee does not response test
these instruments daily when in use. The licensee stated they would
review the inspector's concerns regarding the response testing of
friskers and make any needed procedure changes by December 1985. This
is considered an open item (298/8514-03).
The licensee has maintained an ongoing effort to reduce the size and
number of contaminated areas in the plant. There are presently
approximately 40 separate areas, half of these in the reactor
building, where contamination exists and most of these have been
reduced to less than 2200 disintegrations per minute per 100 square
centimeters.
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No violations or deviations were identified,
c.
Surveys
The NRC inspector reviewed selective radiation, contamination, and
airborne surveys for the period November 1984 through March '95
conducted by the licensee for compliance with Station
Procedure 9.2.1, " Radiation and Contamination Survey Frequency,"
Revision ll, January 27, 1984, and other surveys to support work
being performed on SWPs.
No violations or deviations were identified.
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8.
Facilities and Equipment
The NRC inspector reviewed the licensee's facilities and equipment
provided to implement the radiation protection. program. There were no
changes to existing facilities or additional facilities added to support
the radiation protection program since the last-inspection. The licensee
had procured a digital alarming dosimeter and teledose telemetry system
for use during the current outage.
The NRC inspector reviewed
Procedures 9.3.4.5, "Xetex 415B Digital Alarming Dosimeter," Revision 0,
October 2, 1984 and 9.3.4.6, "Teledose Model 503A Telemetry System,"
Revision 0, November 7, 1984. These procedures describe the operation and
calibration criteria.
The NRC inspector discussed with licensee representatives the status of
Open Item (287/8202-04), " Calibration of Off-Gas and Stack Effluent
Monitors," which involves the lack of full scale calibration, of the
monitors. During the exit interview on April 4, 1985, the licensee stated
that he revised procedures to address full scale calibration of the
off gas monitor. The licensee committed to perform full scale calibration
on the off gas monitor prior to reactor startup.
No violations or deviations were identified.
9.
Exit Interview
The NRC inspector met with licensee representatives and the NRC resident
inspector denoted in paragraph 1 on April 4, 1985. The NRC inspector
summarized the scope and findings of the inspection. The NRC inspector
discussed concerns identified as open items in paragraph 3 of this report
with a licensee's representative by telephone on May 9, 1985. A
licensee's representative acknowledged the inspectors concern and stated
that these items would be reviewed by December 1985.