ML20141C800

Insp Rept 50-298/86-05 on 860228-29.No Violation or Deviation Noted.Major Areas Inspected:Organization & Mgt Controls,Training & Qualifications,Maintaining Occupational Exposures ALARA & Audits

ML20141C800
Person / Time
Site:	Cooper
Issue date:	03/31/1986
From:	Baer R, Jaudon J, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141C770	List: ML20141C766 ML20141C800
References
RTR-NUREG-0761, RTR-NUREG-761, RTR-NUREG-CR-3254 50-298-86-05, 50-298-86-5, NUDOCS 8604070311
Download: ML20141C800 (10)

See also: IR 05000298/1986005

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV ,

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NRC Inspection Report: 50-298/86-05 License: DPR-46

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Docket: 50-298

Licensee: Nebraska Public Power District (NPPD)

P. O. Box 499

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Columbus, Nebraska 68601

1FacilityName: Cooper Nuclear?.tation (CNS)'

Inspection At: Brownville, Nebraska

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. Inspection Conducted: February 24-28,146

Inspector: ( O

R. E. Baer, Radiation Specialist, Facilities

3/2/ @

Date

Radiological Protection Section

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Approved: 2

./cvB.Murray, Chief,FacilitiesRadio ical Date

f Protection Section /

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'ht udon, [hief, Reacg Proj'ects Branch

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Inspection Summary

Inspection Conducted February 24-28, 1986 (Report 50-298/86-05)

' Areas Inspected: Routine, unanncunced inspection of the licensee's radiation

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protection program including: organization and management controls, training

and qualifications, mainta'ining occupational exposures ALARA, and audits. The

inspection involved 37 inspector-hours onsite by one NRC inspector.

Results: Within the areas inspecte'd, no violations or deviations were

identified. One unresolved item is discussed in paragraph 5.

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DETAILS

1. Persons Contacted

NPPD

• G. R. Horn, Nuclear Operations Division Manager

R. -L. Beilke, Chemistry and Health Physics Supervisor

L. E. Bray, Administrative Secretary

T. J. Chard, Health Physicist ( Acting)

R. F. Drier, Training Materials Specialist

M. D. Hamm, Security Supervisor

J. M. Hinz, General Employee Trainer

• J. M. Meacham, Technical Manager

E. M. Rotkvic, Training Materials Specialist

• J. V. Sayer, Technical Staff Manager

J. C. Shrader, Staticn Operator

D. L. Snyder, Chemistry / Health Physics Instructor

• P. V. Thomason, Senior Nuclear Advisor

R. L. Uhri, Training Materials Specialist

V. L. Wolstenholm, Quality Assurance Manager

Others

R. L. Beasing, Security Training Coordinator, PerHar

• D. L. DuBois, NRC, Senior Resident Inspector

• J. P. Jaudon, NRC,- Chief, Reactor Projects Section A

• W. M. McNeill, NRC, Project Engineer

• E. A. Plettner, NRC, Resident Inspector

• Denotes those present during the exit interview on February 28, 1986.

The NRC inspector also interviewed several other licensee employees

including health physics, chemistry, maintenance and admir.istrative

personnel.

2. Licensee Action on Previous Inspection Findings

(Closed) Open Item (298/8232-01): Radworker Training - This item involved

the lack of incorporation into the radworker training program those

elements identified in Regulatory Guides (RG) 8.27 and 8.29. The licensee

had developed lesson plans for the general employee Category II training

which included those elements of RG s 8.27 and 8.29 previously identified

as missing. This item is considered closed.

(Closed) Open Item (298/8412-04): General Employee Training - This item

l involved the lack of development and implementation of an approved general

l employee training (GET) program including lesson plans, goal and objectives,

l training and retraining schedules, evaluation of training efforts, and

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records of training performed. The licensee had developed and implemented

the GET Category II training program including lesson plans, goal and

objectives, initial training and biennial retraining schedules, and records

of training conducted. This item is considered closed.

(Closed) Violation (298/8514-01): Radiation Control Procedures - This item

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involved the lack of calibration for extender probe survey meters in

accordance with approved station procedures. The licensee revised health

physics procedure 9.3.1.2.2, " Extender Probe Models 1000W and 2000W" to

permit calibration of the 1000 R/hr scale at two points. This item is

considered closed.

3. Unresolved Items

An unresolved item is a matter about which more information is required in

order to ascertain whether it is an acceptable item, an open item, a

deviation, or a violation.

Unresolved Item (298/8605-01): Backshift Health Physics Technician

Coverage - This item involves the use of chemistry technicians on the

backshift to provide health physics coverage. See paragraph 5 for

additional details.

4. Inspector Observations l

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The following are observations the NRC inspector discussed with the

licensee during the exit interview on February 28, 1986. These observations

are neither violations nor unresolved items. These items were recommended

for licensee consideration for program improvement, but they have no

specific regulato y requirement. The licensee stated that these items

would be reviewed.

a. Health Physics Technician Turnover - The licensee has experienced a

40 percent loss of health physics technicians during the last year.

See paragraph 5 for additional details.

b. Emergency Plan Staffing - Table 5.2-1 of the Emergency Plan refers to

a position of a Senior Health Physics Technician, but a position

description has not been developed for this position. See paragraph 5

for additional details.

c. R.G. 8.13 Training - The licensee does not provide training to

supervisors and co-worker and only provides initial training to female

employees relating to prenatal exposures, but this topic is not

included during retraining. See paragraph 6 for additional details.

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d. ALARA Program Weaknesses - The effectiveness of the ALARA program has

declined in the areas of ALARA committees, planning and scheduling,

setting of goals, exposure tracking, procedures and checklists, and

reviews of plant changes. See paragraph 7 for additional details.

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5. Organization and Management Controls

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The NRC' inspector examined the licensee's onsite organization regarding

radiation protection management to determine compliance with the Updated

Safety Analysis Report (USAR) and CNS Technical Specifications (TS)

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commitments, and recommendations of RG 8.8.

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The NRC inspector reviewed the current health physics (HP) organization.

See attached Figure 1. The licensee has experienced a large turnover,

40 percent, in the HP technician area during the past year and has had

, difficulty in obtaining qualified experienced replacement persornel. The

licensee had four positions vacant at the time of this inspection, two for

lead HP technicians and two HP technicians. The NRC inspector noted that

the licensee had assigned two HP technicians to the training department to

develop the HP staff training course. This lef t eight HP technicians

assigned to perform routine HP duties. Three of the HP technicians had no

prior formal training or extensive work experience in the field of

radiation protection leasing a total of five licensee HP technicians and

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three contract HP technicians that meet ANSI-18.1-1971 criteria available

for radiation protection activities.

The NRC inspector expressed concern to licensee representatives during the

i exit interview on February 28, 1986, regarding the shortage of qualified HP

technicians and the large turnover in the last year. A total of five

technicians had left the department in the last year which included one

, lead HP technician, three had transferred to other departments. The NRC

inspector requested that management review the HP program and determine the

root cause for this large turnover.

The NRC inspector reviewed the backshift coverage provided by HP personnel

to meet the requirements of the CNS Emergency Plan, Table 5.2-2. The

licensee has assigned ANSI N18.1 - 1971 qualified HP technicie.ns or

! chemistry technicians to provide for HP technician coversge on the

j backshift. The licensee stated in a letter from J. H. Pilant (NPPD) to

l D. G. Eisenhut (NRC), dated April 14, 1981 that, "one HP/ chemistry

r technician would be assigned on shif t effective July 1,1962. Our health

physics and chemistry technicians are cross-trained to perform both >

f functions." The NRC in NUREG-0654, Table B-1 requires that one HP

l technician and one Rad / Chem technician be on shift. The NRC inspector

informed the licen.ee that not having an ANSI N18.1 - 1971 qualified HP

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technician on shift would be considered an unresolved item (298/8605-01)

pending a review of correspondence between the licensee and Office of

Nuclea- Reactor Regulation. The NRC inspector discussed with licensee

representatives that a chemistry technician would need to be qualified in

both cisciplines and the licensee would need to provide documentation to

demonstrate periods of work assignments and job functions performed. These

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individuals would also need to be kept current with HP technician training

in a-idition to chemistry training requirements.

The NRC inspector noted that the CNS Emergency Plan, Table 5.2-1, in the

site area and general emergency section designated that a Senior HP

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Technician would be the alternate for the Radiological Assess'aent

Coordinator and Assistant Chem and HP Coordinator positions. However, the

1icensee has not developed a position description for the designated Senior

HP Technician.

No violaticns or deviations were bentified.

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Training and Qualifications

The NRC inspector reviewed the licensee ~s rad 1ation protection trainisig

program to determine compliance with USAR commitments, 10 CFR Part 19.12

requirements, and recommendations of NUREG-0761, RG's 4.15, 8.8, 8.10, 8.13,

8.27, and 8.29.

a. General Employee Training-(GET)

The NRC inspector reviewed the course outline for the Category I GET

which was identified as the training program for new personnel

assigned-to the station. This course contained segments on: response

to plant emergencies, biological effects of radiation, exposure

control, identification of controlled areas, radiological incidents,

dosimetry, and workers rights and responsibilities. The licensee

. stated that this course outline was not being used and that new

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employees were being given training as contained in Category II GET.

The NRC inspector reviewed the Category II GET course outline to

ensure that those elements addressed in the Category I training were

being presented.

b. Radiation Worker Training

The NRC inspector reviewed the course outline and lesson plans for

Category II GET. This training is conducted initially for all indivi-

duals whose work assignments requires unescorted access to the plants

controlled areas and is composed of a combination of video tape and

lecture presentations. The training is documented by an examination

which the individual must obtain a score of 70 percent or better to

pass. The licensee makes allowance for individuals with prior nuclear

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power plant experience and permits them to challenge the course, and

take the examination withoat attending class, but requires a passing

grade of 80 percent. The NRC inspector determined that the licensee

did not provide for and document training as recommended by RG 8.13

to supervisors and co-workers of female employees relating to prenatal

radiation exposures. The licensee indicated that indoctrination

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training in the particular dangers of prenatal radiation exposures for

all women was included in the GET on a one-time basis if women were

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present in the class and these individuals are required to complete

form CNS HP-21, " Acknowledgement of Instruction Concerning Prenatal

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Radiation Exposure," as required in HP Procedure 9.1.1.3. The NRC

inspector interviewed several women employees and they all indicated

an awareness to the prenatal radiation exposure dangers, but some were

not cognizant of the exact radiation exposure recommendations discussed

in RG 8.13. This training short coming had been previously discussed

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in NRC Inspection Report 298/84-12.

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c. Health Physics Staff Training

The NRC inspector reviewed the training program provided for HP

supervisors and technicians. The luensee was not conducting a formal

training course for HP personnel at the time of this inspection. The

licensee had completed a course outline, " Training Program Description

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TPD 510," and was in the process of subnitting the accreditation self-

evaluation report to the Institute of Nuclear Power Operations for

acceptance. - The NRC inspector reviewe1 the course outline to ensur ? .

that those elements contained in NUFEG-0761 were addressed.

The NRC inspector discussed with the chemistry and HP training

instructors the formalization of the on-the-jeb training program to

ensure that each individual is presented simildr and complete

information. The licensee indicated that this catter was being

considered and would be undertaken after the fornal course lesson

. plans were completed.

The NRC inspector noted that trainirg for HP technicians on procedure

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changes and commitments made to the HRC was being performed by members

of the HP staff.

I No violations or deviations were identified.

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7. Maintaining Occupational Exposures ALARA

i' The NRC inspector reviewed the licensee's ALARA program to dete'emine

compliance with USAR commitments and recomendations of RG's 8.8) 8.10,

8.19, NUREG/CR-3254 and 0761.

The NRC inspector reviewed the following documentation of the recirculation

pipe replacement project perforned in 1985: (1) "ALAPA Review of Recircu-

4 1ation Pipe Replacement at CNS"; (2) "RCT-8tiO1"; (3) "IGSCC Pipe Replacement

Project Final Report"; (4) " Post-Job Review Record"; and (5) "CNS Dose

Tracking System Job Surmary File," dated August 19, 1985.

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The licensee appeared to have an effective ALARA program during the

recirculation pipe replacement project. The original estimate of 1416

D man-rem and 67,000 man-hours was later revir.ed to 1751' man-rem and 124,000

man-hours with the ir. crease of job scope and underestimation of time to

perforn some job functions. The final results were 1636 man-rem as

. measured with trermoluminescence dosimetry (TLD),1919 man-rem with direct

j; reading pocket dosimaters (DRPD), and 187,0C0 man-hours. The difference

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between the results of the two radiation exrosures for TLD and DRPD are

within the expected error. This error is dLe primarily from over

o estimiting the DRPD's actual reading when Itaving the Job site and the

large number o# entries made into the work areas. The radiation exposure

[: history for CN3 during the past 5 years sud average for all boiling water

reactors is depicted in Table 1.

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The NRC inspector discussed with licensee representatives the status of-

the ALARA program since completion of the recirculation pipe replacement

program. The NRC inspector determined that the ALARA committee is no

longer functional and that the dose tracking system is not presently in use.

The licensee stated that the dose tracking system should be operational in

about 3 months. The NRC inspector noted that the ALARA coordinator does

not always receive task packages of plant c.hanges or. work packages in

sufficient time to perform a detail review, and that neither ALAPA

coordinator nor the Chemistry and HP Supervisor are not involved in

establishing ALARA goals.

The NRC inspector expressed concern that the comprehensive ALARA program

. implemented during the recirculation piping replacement project was not

being continced for routine plant operation.

No violations or deviations were identified.

8. Audits and Reviews

The NRC inspector reviewed the licensee's Quality Assurance (QA) audit

program for health physics and training activities. This review included:

QA procedures QAP-900, " Chemistry, Health Physics, and Environmental

Monitoring," Revision 9, August 30, 1985; QAP-2700, " Training," revision 0,

March 6,1985; Audits QAP-900, HP Audit 85-23 conducted December 16, 1985

through January 9, 1986; and QAP-2700, Training Audit 85-01, conducted

January 28 through February 12, 1985. The NRC inspector noted that audit

85-01 was limited to surveillance of the GET protective clothing dressing

and undressing procedures.

No violations or deviations were identified.

9. Exit Interview

The NRC inspector met with licensee representatives at the conclusion of

the inspection on February 28, 1986. The NRC inspector surmiarized the

scope and findirgs of the inspection as discussed in paragraphs 2, 3, and 4

of this report.

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Table 1

Man-Rem Expended During Last 5 Years

Year 1981 1982 1983 1984 1985

BWR Not

Average 957.0 940.0 1056.0 1003.0 Available

Cooper

Station 544.0 506.0 1293.0 799.0 1054.3

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FIGURE 1

Chemistry and

Health Physics

Supervisor

ALARA Assistant.to

Coordinator Chemistry and

1- (11 1 (1)

Senior Chemistry

and HP Specialist

2 (2)

Health

Physicist

1 (1)

Dosimetry

Clerk

1 (1)

Lead H.P.

Technicians

2 (0)

H.P. Technic ialis

__12 (10) *

(3) Contract HP Technicians

• Two of the ten H.F. Technicians assigned to training department.

( ) Indicates number of individuals assigned to the position including

temporary assignments.

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ATTACllMENT B

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OPEN ACTION ITEMS LIST _

u ta: Type Code: A= Allegation M= Miscellaneous

B= Bulletin 0=0 pen Item

locket flo: 50 - 2 9cS C= Circular R=Part 21 Iteport

D= Deviation T= Temporary Instructicn',

(8)

E=50.55(e) U= Unresolved Item

L=LER V=Vi ola t ion

tota - Max characters allowed for each entry shown in (1) '

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item Report Responsible Update /Closecut 5tatu.

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Paragraph Section Module Description Report Cotto

Item flo .

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