ML20151S668

Insp Rept 50-298/88-03 on 880229-0302.Deviation Noted.Major Areas Inspected:Selected Areas of Radiation Protection Program

ML20151S668
Person / Time
Site:	Cooper
Issue date:	04/07/1988
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151R786	List: ML20151R783 ML20151R789 ML20151S668
References
50-298-88-03, 50-298-88-3, IEB-79-19, NUDOCS 8804280414
Download: ML20151S668 (9)

See also: IR 05000298/1988003

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/88-03 Operating License: DPR-46

Docket: 50-298

Licensee: Nebraska Public Power District (NPPD)

P. O. Box 499

Columbus, NE 68601

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS, Brownville, Nebraska

Inspection Conducted: February 29 through March 2, 1988

Inspector: ( ~

R.'E. Baer, Radiation Specialist Facilities

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Facilities Radiological Protection Section

Approved: fl D. ,YMflfQV/A

B. Fiur~ ray, Chief, TacilitiepAadiological

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Protection Section v

Inspect',on Summary

Inspectian Conducted February 29 through March 2, 1988 (Report 50-298/88-03)

Areas Inspected: Routine, unannounced inspection of selected areas of the

radiation protection program.

Results: Within the area inspected, one deviation was identified (failure to

provide training en transportation requirements, paragraph 5).

8804280414 880420

PDR ADOCK 05000298

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DETAILS

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1. Personnel Contacted

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NPPD

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• G. R. Horn, Division Manager, Nuclear Operations

• R.' L. Beilke, Radiological Support Supervisor

• L. E. Bray, Regulatory Compliance Specialist

• T. L. Chard, Health Physics Supervisor ,

• J. W. Dutton, Nuclear Training Manager

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• B. Hall, Health Physicist

P.. A. Jansky, Outage and Modification Manager

C. A. Putnam Jr. , Quality Assurance Specialist

E. M. Rotkvic, Training Instructor

• J. V. Sayer, Radiological Manager

• G. E. Smith, Quality Assurance Manager

P. R. Windham, Technical Training Supervisor

M. A. Wolken, Outage Coordinator

NRC Personnel

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• W. R. Bennett, Senior Resident Inspector

• E. A. Plettner, Resident Inspector

• Denotes those present during the exit briefing on March 2, 1988.

The NRC inspector also interviewed several other licensee employees,

including health physics, chemistry, training, and administrative

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2. Licensee Action on Previous Inspection Findings

(Closed) Open Item (298/8232-02): Beta Radiation Calibration of Portable

Survey Meters - This item was identified in NRC Inspection

Report 50-298/82-32 and involved the lack of a beta radiation calibration i

on each range / scale used for beta radiation measurements. The licensee

revised Procedures 9.3.l.4.2 and 9.3.1.4.4 for ionization chamber I

calibration to include beta radiation calibrations and had implemented

these procedures.

(Closed) Open Item (298/8514-02): Portable Radiation Survey Meter Pre-Use  ;

Operational Check - This item was identified in NRC Inspection r

Report 50-298/85-14 and involved the lack of a pre-use operational check  :'

on each range for portable radiation survey meters. The licensee had

implemented a program where portable radiation survey meters routinely

used for surveys were daily response checked on each range, and portable.

! radiation survey meters placed in strategic locations within the plant are

response checked on each range on a weekly interval.

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

Technician Coverage - This. item was identified in NRC Inspection

Report 50-298/86-05 and involved the use' of. chemistry technicians on the

backshift to provide health physics' coverage. The licensee assigns only

chemistry technicians to-the backshift who are also health physics

qualified and training is provided to these individuals to keep them_-

current in health physics work practices.

(Closed) Open Item (298/8716-01): General Employee Training (GET) - This

item was identified in NRC Inspection Report 50-298/87-16 and involved the

lack of the GET Lesson Plan to include the instruction concerning the

availability of worker exposure records. The licensee had revised the

Lesson Plan GEN 001-01-01, "Radiation Protection," in Section XX.B.1, to

include the availability of information pertaining to the individual

radiation exposure history.

(Closed) Open Item (298/8716-02): Contractor Qualifications - This item

was identified in NRC Inspection Report 50-298/87-16 and involved the lack

of a formal testing and evaluation program for prospective contractor

health physics technicians. The licensee had revised Procedure 9.1.1.1,

Section VIII B.3, to provide _ a formal testing and evaluation program which

includes oral and written examinations and a formalized

training / qualifications program.

(Closed) Open Item (298/8716-03): Backshift Health Physics Technician

Training - This item was identified in NRC Inspection Report 50-298/87-16

and involved the lack of an established procedure that specified the

specific training and experience required to qualify for backshift health

physics /chemi:;try duty. The licensee had revised Procedure 9.1.1

Section VIII B.2, which now specifies the specific training and experience

necessary to be qualified for backshift health physics / chemistry duty.

(Closed) Open Item (298/8716-04): Skin Contamination / Hot Particles - This

item was identified in NRC Inspection Report 50-298/87-16 and involved the

lack of incorporation of the Varskin Computer Program to determine skin

dose from hot particles and use of an ionization chamber survey meter when

activity levels exceed the range of use for a pancake probe frisker. The

licensee had revised Procedure 9.1.6 to incorporate the Varskin Computer

Program and address the concern relating to instrumentation usage.

(Closed), Unresolved Item (298/8723-01) Training Records For Radiation i

protection and Maintenance Personnel - This item was identified in NRC  !

Inspection Report 50-298/87-23 and involved the availability of the

necessary training records for radiation protection and maintenance

personnel involved in transportation activities. The licensee located the

training records and these records indicated that the necessary training

had been performed.

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3. Inspector Observations

The following is an observation the NRC inspector discussed with the

licensee during-the exit interview on March 2, 1988. This observation is-

not a violation, dev,iation, unresolved item, or open item. The

observation was identified for licensee consideration for program

improvement, but the observation had.no specific regulatory req 6irement.

The licensee stated that the observation would be evaluated for program

improvement.

GET - Hot Particles - The licensee discusses hot particles and cautions

individuals to carefully monitor themselves when exiting from the

radiologically controlled area during GET; however, the Course Lesson

Plan GET001-01-01, "Radiation Protection," does not include any reference

to monitoring for hot particles.

4. Occupational Exposure During Extended Outages (83729)

a. Audits and Appraisals

' The NRC inspc tor reviewed the licensee's audit and appraisal program

for health physics activities. This review included QA

Procedure QAP-900, "Chemistry, Health Physics, and Environmental

Monitoring." The licensee had completed Audit QAP-900, "Health

Physics Audit 87-19," during the. period January 20 through

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February 29, 1988. The audit report indicated that no. items of >

nonconformance or significance were identified during the audit.

No violations or deviations were identified.

b. Changes

The NRC inspector reviewed changes the licensee had made in

organization, personnel, facilities, equipment, program and

procedures. The NRC inspector reviewed the procedures listed in

Attachment 1. The NRC inspector also noted that the only program

change made was to the ALARA program. The licensee had developed an

ALARA progra in response to commitments made to Region IV in a

letter from G. A. Trevors to J. E. Gagliardo dated January 19, 1987, ,

"Nebraska Public Power District Response to IE Inspection Report

No. 50-298/86-33." J

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The licensee had increased the assigned ALARA staff to include, in

addition to the ALARA coordinator, a dedicated technician and records

clerk. Procedures for the ALARA program were developed and

implemented in Volume 0, CNS procedures. The ALARA program is not

the responsibility of the health physics organization alone, but is a

station-wide program that involves everyone.

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The NRC inspector determined that the ALARA program as implemented

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met ~the commitment made to Region IV.

No violations or deviations were identified,

c. Planning and Preparations

The NRC inspector reviewed the licensee's advanced planning and

preparations including increased supplies, special training and

mockup training, adequacy of controlling contractor work practices,

health physics involvement in work planning, and the radioactive

waste reduction program concerning the 1988 refueling outage.

The NRC inspector noted that the licensee had~ increased the quantity-

of expendable protective clothing supplies and made preparations to ,

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segregate the protective clothing.used in the reactor building from

other areas. The licensee had experienced hot particles during the

last refueling / maintenance outage and has plans for increased

surveillance to detect and isolate these hot particles during the

current outage. '

No violations or deviations were identified.

d. Training and Qualification of New Personnel

The NRC inspector reviewed the increased staffing for the health

physics group, contractor training and qualifications, and the

radiation worker training program. ,

The licensee had increased the health physics technician staff with

12 senior grade technicians and 4 junior grade technicians.

Contractor technicians were tested and qualified as specified in

Procedure 9.1.1.1,Section VII B.3.

The NRC inspector reviewed the GET program provided to new personnel.

The NRC inspector noted that the licensee discussed the need for

careful monitoring of personnel when exiting the radiologically

controlled area because of the potential for hot particles, but this

information was not contained in the course Lesson Plan GEN 001-01-01.

The NRC inspector discussed this observation with members of the

training department and was informed that the course lesson plan

would be revised. A training work request (TWR) was initiated on

M:rch 1, 1988, to include the hot particle discussion in the training

course. This TWR provided for immediate inclusion,of hot particle

problem monitoring and detection into the current course lesson plan

as presented.

No violations or deviations were identified.

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e. * Maintaining-Occupational Exposure ALARA

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The NRC inspectorLreviewed the licensee's'ALARA program to determine.

agreement with the recommendations;of~ Regulatory Guides 8.8 and 8.10.

The NRC inspector also reviewed the program-for: worker awareness, -'

goalsandobjectives,results,committeezinvolvement, job

. preplanning, and post job,. reviews.

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The NRC inspector exnresse'd concern that the licensee had not

resolved the probleia of work packages for design changes and

modifications not being submitted to.the ALARA group for a timely

review. The ALARA coordinator,-a week prior to the outage, had not

received all work packages. The licensee acknowiedged the NRC

inspector's concern and stated that improvement in this area was

needed.  ;

The licensee had established a goal for 150 person-rem for the 1988

outage based on the work scheduled and an18-week outage. The ALARA

group was actively involked in pre-job planning.

No violations or deviations were identified.

5. Followup of Previously Identified Unresolved Items (92701)

The NRC inspector reviewed training department records of health physics,

operations and maintenance personnel involved in the transfer, packaging,

and transport of radioactive materials. Training department

representatives stated that it appeared some records were misplaced in the

transfer of training responsibilities from various departments in the

plant to the training department. As a result, the training records

indicated that some maintenance personnel involved in the transfer and

. packaging of radioactive material had not received periodic retraining in

the Department of Transportation (00T) and NRC regulatory requirements,

the waste burial license requirements, and plant specific procedures.

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Inspection and Enforcement Bulletin (IEB) No. 79-19 requires in~ action

item 5 that the licensee provide training and periodic retraining in the

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D0T and NRC regulatory . requirements, the waste burial license

requirements, and instructions and operating procedures for all personnel

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involved in the transfer, packaging and transport of radioactive material.

The licensee is also required to maintain records of training dates,

attendees,andsubjectmaterial.

The licensee responded to IEB No. 79-19 on August 31, 1979, and stated, in

part, that the indicated training for appropriate personnel would be

completed by November 16, 1979. Retraining for appropriate personnel '

involved in the transfer, packaging, and transport of-radioactive material

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would be scheduled periodically and training records would be available for .

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The failure to provide the necessary training and maintain a record of j

training is an apparent deviation from commitments made in response to '

IEB No. 79-19. (298/8803-01) l

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6. Exit Interview

The NRC inspector met with the NRC resident inspectors and licensee

representatives denoted in paragraph 1 at this conclusion of the

inspection on March 2, 1988. The NRC inspector summarized the inspection

scope and findings. j

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ATTACHMENT 1

Procedures Reviewed

9.1.1.1 Radiation Protection at CNS, Revision 6, October 22, 1987

9.1.1. 3 Personnel Dosimeter Program, Revision 23, November 25, 1987

9.1.1. 4 Special Work Permit, Revision 16, April 15, 1987

9.1. 2.1 Radiation Contamination, and Airborne Radioactivity Limits

Revision 19, February 1, 1988

9.1. 2. 2 Area Posting and Access Control, Revision 8, March.5, 1987

9.1. 3 Radiation Safety Standards, Revision 10, October 9, 1986

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9.1.4 Protective Clothing.(Anti-C) Revision 8, September 24, 1987

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9.1.5 Respiratory Program, Revision 21, October 29, 1987

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9.1. 6 Personnel Contamination,, Revision 12, February-2, 1988

9.2.2 Radiation Surveys, Revision 12, June 4,'1'987 l

9.2.3 Contamination Surveys, Revision 6, October 9, 1986 ,

9.2.4 Surveying Material for Release Offsite, Revision 1, July 1, 1987

9.3.4.7 Eberline Hand and Foot Monitor Model HFM-6, Revision 0,

August 20, 1987  ;

9.3.4.8 Eberline Personnel Contamination Monitor Model PCM-1B,

Revision 0, August 20, 1987

9.3.4.3 Friskers, Revision 7, February 8, 1988-

9.3.4.1 National Nuclear Corporation (NNC) Portal Monitors, Revision 4, <

November 5, 1987 '

O.14 Notices to Workers, Revision 2, December 18, 1986

0.31 Radiological Safety Incident Report, Revision 0, December 4, 1986

0.32 CNS ALARA Program Description Document, Revision 0, June 25, 1987

0.32.1 ALARA Organization and Management, Revision 1, September 3, 1987

0.32.2 ALARA Work Review, Revision 0, June 25, 1987

0.32.3 ALARA Reports and Audits, Revision 0, June 25, 1987

0.32.4 ALARA Data Collection, Revision 0, June 25, 1987

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0.32.5 ALARA Training Program, Revision 0, June 25, 1987

0.32.6 ALARA Document Control, Revision 0, June 25, 1987

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