ML20211G132
| ML20211G132 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/25/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20211G119 | List: |
| References | |
| CNSS865719, NUDOCS 8606190308 | |
| Download: ML20211G132 (4) | |
Text
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COOPER NUCLEAR STATION Nebraska Public Power District
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a CNSS865719 April 25, 1986 bbb$h
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NW '5En6 Mr. J. E. Gagliardo, Chief j
s Reactor Projects Branch de U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Subject:
Nebraska Public Power District Response to IE Inspection Report No.
50-298/86-05
Dear Mr. Gagliardo:
This letter is written in response to your letter dated April 1, 1986, transmitting Inspection Report No. 50-298/86-05. Therein you indicated concerns with regard to certain aspects of our Radiation Protection Program.
Following are the statements of concern and our responses to these concerns:
Statement of Concern Organization and Management Controls 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) commitments, and recommendations of RG 8.8.
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 personnel. 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 left 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 leaving a total of five licensee HP technicians and three contract HP technicians that meet ANSI-18.1-1971 criteria available for radiation protection activities.
8606190308 860613 PDR ADOCK 05000298 l
7
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-:J. E. Gagliardo
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-April 25,.1986 Page 2 The NRC inspector expressed concern to licensee representatives during the exit interview on. February 28, 1986, regarding the shortage of qualified HP technicians and the large turnover in the last year.
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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 technicians or chemistry technicians to provide for HP technician coverage on the backshift. The licensee stated in a letter from J. M..Pilant (NPPD) to.D. G. Eisenhut (NRC), dated April 14, 1981, that, "one HP/ chemistry technician would be assigned on shift effective July 1, 1982. Our health physics and chemistry technicians are cross-trained to perform both functions". The NRC in NUREG-0654, Table B-1 requires that one HP technician and one Rad / Chem technician be on shift. The NRC inspector informed the licensee that not having an ANSI N18.1-1971 qualified HP technician on shift would be considered an unresolved item (298/8605-01) pending review of correspondence between the licensee and Office of Nuclear Reactor Regulation. The NRC inspector discussed with licensee representatives that a chemistry technician would need to be qualified in both disciplines 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 in addition 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 Technician would be the alternate for the Radiological Assessment Coordinator and Assistant Chem and HP Coordinator positions. However.
the licensee has not developed a position description for the designated Senior HP Technician.
NPPD Response Two months prior to this NRC inspection, the Chemistry and Health Physics Supervisor had performed an investigation into the root cause for the noticeable turnover of health physics technicians. This investigation revealed that technicians had left the department to seek higher salary, a less stressful working environment, and educational advancement.
In regard to salary, a wage study is presently being conducted for all Cooper Nuclear Station employees in comparison to other nuclear plants in this locale. The results of this study will be reviewed by Nebraska Public Power District to determine'what salary actions may be required. We anticipate completing the wage study and implementing any necessary salary actions during 1986.
.Js E. Gaglicrdo April 25, 1986 Page 3 It should be noted that since the inspection, one of the open Lead HP Technician positions has been filled, with the other Lead position in the process of being filled.
In addition, the individual who was in an " acting" capacity as Health Physicist has accepted the position permanently. Two offers have been made to experienced individuals (Navy nuclear experience) and one has been accepted so far for the open HP Technician positions noted in the referenced inspection report. We are also aggressively pursuing hiring other experienced individuals. Once all open positions are filled, the negative effects of stressful working environment noted by our root cause analysis should be less pronounced.
On a related matter, the assigning of two experienced HP technicians to the Training Department was done with a full understanding of the impact which would result on normal HP duties.
It was felt that the long term benefits to be derived from havirg a program developed by knowledgeable, in-house personnel outweighed the resulting short-term increase in work load. In view of the training program which has been developed, we remain convinced that the decision was correct.
Regarding backshift coverage concerns, a program to update and upgrade selected chemistry technicians in health physics training pertinent to backshift coverage, as well as providing documentation of periodic health physics work assignments, will begin prior to May 31, 1986. The program will be instituted and maintained by the CNS Health Physicist.
Lastly, the Senior HP Technician described in the CNS Emergency Plan Table 5.2-1 was to denote a more experienced HP Technician as opposed to a newly ANSI qualified HP Technician to fulfill these duties. The Emergency Planning Coordinator will submit a change through the annual revision to the Emergency Plan to remove the word " Senior" from the designation " Senior HP Technician".
Statement of Concern Maintaining Occupational Exposures ALARA The NRC inspector reviewed the licensee's ALARA program to determine compliance with USAR commitments and recommendations 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 performed in 1985:
(1) "ALARA Review of Recirculation Pipe Replacement at CNS"; (2) "RCT-8601"; (3)
"ICSCC Pipe Replacement Project Final Report"; (4) " Post-Job Review Record"; and (5) "CNS Dose Tracking System Job Summary File", dated August 19, 1985.
The licensee appeared to have an effective ALARA program during the recirculation pipe replacement project. The original estimate of 1416 man-rem and 67,000 man-hours was later revised to 1751 man-rem and 124,000 man-hours with the increase of job scope and underestimation of
- ' ' ',,'., '. *h E. Cc glicrdo April 25, 1986 Page 4 time to perform some job functions. The final results were 1636 man-rem as measured with thermoluminescence dosimetry (TLD), 1919 man-rem with direct reading pocket dosimeters (DRPD), and 187,000 man-hours. The difference between the results of the two radiation exposures for TLD and DRPD are within the expected error. This error is due primarily from over estimating the DRPD's actual reading when leaving the job site and the large number of entries made into the work areas. The radiation exposure history for CNS during the past 5 years and average for all boiling water reactors is depicted in Table 1.
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 changes or work packages in sufficient time to perform a detail review, and that neither ALARA 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 continued for routine plant operation.
NPPD Response The Division Manager of Nuclear Operations listed the formation of an ALARA program similar to the program used during the recirculation pipe replacement project as a 1986 Nuclete Power Group goal. As a result of this goal, the Chemistry and Health Physics Supervisor has assigned the ALARA Coordinator to submit a detailed report outlining the necessary requirements needed to upgrade the existing ALARA program to the standards of the comprehensive ALARA program used during the recirculation pipe replacement. This report will be submitted to the Chemistry and Health Physics Supervisor by May 31, 1986, and forwarded to the Division Manager of Nuclear Operations by June 30, 1986.
If you have any questions regarding this response, please contact me or G. R. Horn at the site.
Sincerely, M'
J.
"'lant Technical Staff Manager Nuclear Power Group JMP:GRH:JMM:RLB:ya