ML20128N775

Insp Rept 50-298/85-14 on 850401-05.Violation Noted:Failure to Calibr Radiation Monitoring Instruments Per Tech Spec 6.3.4,during Feb-Nov 1984

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: ML20128N745 ML20128N756 ML20128N775
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.-

U -Docket: 50-298 :

? Licensee: l Nebraska Public' Power District (NPPD)

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. P. O. Box 499

~ Columbus, Nebraska: 68601L

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~ Facility Name: Cooper. Nuclear Station-(CNS)--

Inspection'At: LCNS, Brownville,LNebraska

- ' Inspection Conducted: April 1-5, 1985

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-Inspector: , M [

R.E.Baer, Radiation}{4cialist, Facilities Date-

Radiological Protection Section

-' Approved: 2 O '

BlaineMurray, Chief,facilites. Radiological. Date

Protection Sect r

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J{P.(Ja on, Chief, Reactor. Project Section A

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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DETAILS

1. Persons Contacted

NPPD

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

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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

10 mg/cm8 and 285 mg/cm 2 filters. A third LIF chip (TLD 100) is used in

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,

b .1 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-

, job functions, and had the vendor recheck the TLD records. The

' 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

i, 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

-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

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.

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.