ML20141C800
| 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: |
| 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
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APPENDIX
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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:
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3/2/ @
R. E. Baer, Radiation Specialist, Facilities
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Radiological Protection Section
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Approved:
./cvB.Murray, Chief,FacilitiesRadio
ical
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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
- 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
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involved the lack of development and implementation of an approved general
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employee training (GET) program including lesson plans, goal and objectives,
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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
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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
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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
three contract HP technicians that meet ANSI-18.1-1971 criteria available
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for radiation protection activities.
The NRC inspector expressed concern to licensee representatives during the
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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
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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
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chemistry technicians to provide for HP technician coversge on the
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backshift. The licensee stated in a letter from J. H. Pilant (NPPD) to
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D. G. Eisenhut (NRC), dated April 14, 1981 that, "one HP/ chemistry
technician would be assigned on shif t effective July 1,1962. Our health
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physics and chemistry technicians are cross-trained to perform both
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functions." The NRC in NUREG-0654, Table B-1 requires that one HP
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technician and one Rad / Chem technician be on shift. The NRC inspector
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informed the licen.ee that not having an ANSI N18.1 - 1971 qualified HP
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
individuals would also need to be kept current with HP technician training
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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.
6.
Training and Qualifications
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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.
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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
power plant experience and permits them to challenge the course, and
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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
present in the class and these individuals are required to complete
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form CNS HP-21, " Acknowledgement of Instruction Concerning Prenatal
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
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
TPD 510," and was in the process of subnitting the accreditation self-
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evaluation report to the Institute of Nuclear Power Operations for
acceptance. - The NRC inspector reviewe1 the course outline to ensur ?
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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.
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The NRC inspector noted that trainirg for HP technicians on procedure
changes and commitments made to the HRC was being performed by members
of the HP staff.
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No violations or deviations were identified.
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7.
Maintaining Occupational Exposures ALARA
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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-
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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
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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
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measured with trermoluminescence dosimetry (TLD),1919 man-rem with direct
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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
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estimiting the DRPD's actual reading when Itaving the Job site and the
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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
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
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
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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
(8)
D= Deviation
T= Temporary Instructicn',
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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Description
Report
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