ML20244C949

Insp Rept 50-298/89-16 on 890501-05.Violations Noted.No Deviations Noted.Major Areas Inspected:Selected Areas of Radiation Protection Program as Set Forth in Core Insp Program,As Related to Outage Activities

ML20244C949
Person / Time
Site:	Cooper
Issue date:	06/02/1989
From:	Baer R, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20244C941	List: ML20244C938 ML20244C942 ML20244C949
References
50-298-89-16, NUDOCS 8906150219
Download: ML20244C949 (8)

See also: IR 05000298/1989016

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/89-16 Operating License: DPR-46

Docket: 50-298

Licensee: Nebraska Public Power District (NPPD)

P.O. Box 499

Columbus, NE 68602-0499

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS, Brownsville, Nebraska

Inspection Conducted: May 1-5, 1989

Inspector: h

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L.' T. R! cketsorp,~ PkE. , Radiation Speciali st Date

Facilit- eyRapologfM1' Protection Section

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Approved: 6- SE9

Rf E. Baer, Chief, Facili..es Radiological Date

l Protection Section

Inspection Summary

Inspection Conducted May 1-5, 1989 (Report 50-298/89-16)

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

radiation protection program as set forth in the core inspection program

(83750), as they related to outage activities.

Results: Planning and preparation for outage activities supported ALARA

principles. Staffing of Health Physics (HP) appeared adequate to handle the

demands brought about by outage work. The HP technicians were judged to be

technically qualified. The radioactive material transportation program was

adequate. Two examples of one apparent violation were identified in the area

of radioactive material and contamination controls (see paragraph 8). No

deviations were identified.

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8906150219

DR 890605

ADDCK 0500029s

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DETAILS

l 1. Persons Contacted

NPPD

• G. H. Horn, Nuclear Operations Division Manager

• J. V. Sayer, Radiological Manager

• T. J. Chard, HP Supervisor

R. L. Beilke, Radiological Support Supervisor

• D. R. Robinson, Quality' Assurance Suptrvisor

G. R. Smith, Licensing Supervisor

• L. E. Bray, Regulatory Compliance Specialist

B. L. Hall, Health Physicist

T. E. Carson, ALARA Coordinator

J. H. Kuttler, HP Specialist

D. P. Oshlo, Lead HP Technician

J. P. Morris, Chemistry Technician

NRC, Reaion IV

• G. A. Pick, Resident Inspector

• W. M. McNeill, Reactor Inspector

In addition to the above, the NRC inspector contacted other licensee and

contractor personnel during the intra etion.

• Denotes those present at the exit meeting on May 5, 1989.

2. Inspector Observations

The following observations were discussed with the licensee during the

exit meeting. Inspector observations are not violations, deviations, or

open items, but were identified for the licensee's consideration for

possible program improvement. Observations have no specific regulatory

requirements.

ALARA packages documenting prejob planning and other efforts taken by

the licensee to reduce radiation exposure did not contain attendance

lists for prejob briefings given by HP or ALARA personnel.

Increased surveillance of contract workers in less frequented

controlled areas by the HP staff would have improved contamination

controls.

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3. Followup on Previous Inspection Findings

(Closed) Open Item (298/8910-01) - Hot Particle Controls Around Laundry.

Monitor. This item was discussed in NRC Inspection Report 50-298/89-10

and involved the lack of controls around the laundry monitor and the

handling of potentially contaminated protective clothing. After the

previous inspection, the licensee's radiological protection staff

evaluated the operation and instituted contamination controls. The NRC

inspector verified that a rope barrier surrounded the laundry monitor and -

the area was labeled as contaminated. Individuals working inside the

barrier wore gloves, booties, and lab coats. Laundry to be monitored was

treated as contaminated until monitored and found to be clean.

s Individuals were required to clear personnel contamination monitors upon

completion of work in the area.

4. Planning, Preparation, and ALARA

In order to review the licensee's planning and preparation, the NRC

inspector attended daily meetings of department supervisors in which the

progress of outage activities was discussed, along with upcoming

projects. The NRC inspector noted that the discussions were open and

participants seemed cooperative. The NRC inspector also attended meetings >

of the ALARA committee and of the HPs at shift change. All involved a

good exchange of information; such as job progress, problem areas,

possible alternate work methods, radiation levels, and special

precautions.

The NRC inspector verified that the ALARA coordinator received a listing

of work to be performed and that an ALARA review was performed when deemed '

appropriate. The NRC inspector reviewed selected ALARA packages and found

them to be comprehensive, except lists of attendance for prejob briefings ,

were not included in the packages. l

The NRC inspector determined that individuals involved in the ALARA

reviews had adequate knowledge of plant systems and maintenance

procedures. The NRC inspector noted, however, that the former ALARA'

coordinator, still working half time reviewing ALARA packages', had

attended a formal course in ALARA training, while the new ALARA

oordinator had not. The individual's supervisor stated to the NRC

inspector that the training was planned, but had not yet been scheduled.

The licensee's representatives stated that, in way of preparation, a

mockup was used for training purposes in preparation for work on the

control rod drives. In addition, a film of the drywell was used to help

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orient individuals with that area before they performed work _there,_and a i

vendor representative conducted training in the procedure for the removal

of the source range monitor.

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The licensee established a' goal:of 185.5 man-rem.for.the outage, which i

began April 8, 1989, and.a' goal of 275 man-rem for.the. year. The total;  !

exposure through week 17 was' approximately 101 man-rems for the outage

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(based on pocket dosimeter data thusfar) and 133 man-rem'for'the year,

No violations'or deviations were. identified. b

5. Staffing and Qualification l

The NRC inspector reviewed the staffing plan for the outage and!noted that;

the licensee had recruited 20 senior contract technicians and 8 junior- ,

contract technicians for additional HP supportLduringithe outage. ?Before-

hiring the technicians, a background check was madeto determine as.much

as possible about 'the' work history and qualifications ofe the individuals.

All' senior technicians were qualified in accordance with recommendations

of Industry Standard ANSI N18.1-1971. Technicians were given the~ site-

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specific HP procedures for review and were required to' demonstrate-a ..

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practical knowledge of them. The NRC inspector reviewed selected _ records.

documenting this process. During the course of.the inspection,'the NRC_ a

inspector interviewed approximately eight. technicians at random and found-

them to be sufficiently qualified. The work force of house technicians

remained fairly stable over the last 16 months with a turnover. rate'of. -

about 10 percent.

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The NRC inspector also reviewed station radiation protection procedures

identified in the attachment to this report.

No violations or deviations were identified.

6. Radiation Exposure Controls )1

The licensee's external and internal controis were examined for agreement

with 10 CFR Parts 20.101, 20.102, 20.103, 20.104, 20.105,~' 20.202,

20.203, 20.205, 20,206, and~ recommendations of'RG 8.15.

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As determined during the previous inspection, the license'e 'uses

thermoluminescent dosimeters from a vendor. Representatives of the'

licensee stated that, should it;be necessary, the' vendor could process:the

badges and provide exposure data in 3-4 days. The licensees'

representatives stated that there would be jobs requiring individuals to. i;

wear multiple. badges and that'there were an adequate number of dosimetry i

devices. The NRC inspector confirmed that there had been' no instanceLof.

an individual receiving more than the allowable ~1imits of exposure.

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The NRC inspector confirmed that air sampling was performed in work areas l

and that' calibrated continuous air monitors were in use. The licensee's

representatives stated that, based on whole body counting, there has been

no ingestion of radioactive material. '

No violations or deviationr, were identified. .i

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Posting, Labeling, and Worker Controls

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The licensee's program of! posting, labeling, and' worker controls were

examined for agreement with 10 CFR Parts 19.12, 20.203, 20.205, and

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The NRC inspector observed that posting andlabeling were appropriate and

adequate. HP coverage at main stepoff pad was judged, by the NRC

inspector, to be adequate but, as noted in paragraph 7, lessl often :

used stepoff pads needed.to be checked more often.

7. Control of Radioactive Material and Contamination,' Surveys, and Monitoring

Thelicensee'sprogramofcontrolofIradioactive'materialand ..

contamination, surveys, and monitoring was' examined for. agreement with:

Technical Specification (TS) 6.3.4.and 10 CFR Parts 20.201, 20.301, and

20.401. i

TS 6.3.4 requires that procedures shall be mainta'ined and made available.

to all station personnel . . . and shall.be. consistent with the-

requirements of 10 CFR 20. 10 CFR 20.201(b) requires that-the licenseeL

make such radiation surveys as may be necessary to evaluate the extent of

radiation hazards that may be present. HP Procedure 9.2.3,

Section VIII.B.I, requires that equipment and tools used in a controlled

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I area be surveyed by instrument or smear prior to removal from the area.

While observing in-service inspection activities, the NRC inspector'

observed an individual working in Residual Heat Removal (RHR) Heat '!

Exchanger Room A, a contaminated area, hand a' piece of electrical conduit  ?

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to another individual standing outside the area boundary without first

having the conduit checked for-contamination by HP. The individual

accepting the conduit stated that he had just handed it to the person

inside the contaminated area, who tried to put in place, found it to be j

too long, and returned it for trimming. . He' stated that he accepted the : q

item with his bare hand and immediately put it in a: plastic bag.and that-

he had forgotten that all items removed from the area should have been

surveyed first. HP personnel directed the individual to a hand and foot.

monitor. No contamination was found. The conduit was not checked at the~ +

time and therefore no information was available about its actual

contamination level.

The NRC inspector also observed, in RHR Heat Exchanger Room B, that hangers

made from steel I-beams were laying across the stepoff pad and partially'

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outside a controlled area. These hangers were removed from the walls in

the contaminated part of the room and were later found to have

approximately 300 disintegrations per minute of radioactive coritamination.

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The failure to perform smear surveys on both the conduit and the hanger to -

determine contamination levels are two examples of an apparent' violation l

of TS 6.3.4. J

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!. Records of surveys were examined during the previous -inspection and the;

survey program was found to be comprehensive. Selected examples of

surveys, involving work performed during the outage, were examined and-

they too were found to be adequate. An adequate supply of calibrated

. survey instruments was available.

~The NRC inspector observed that both hand and foot monitors and personnel

contamination monitors were available in sufficient' numbers and were used

appropriately by individuals leaving the contaminated areas. The NRC

inspector determined that the number (92)- of personnel contamination

incidents for the outage thusfar was approximately double the number for

the similar time period of the last outage. The licensee's

representatives stated they felt, based on the type and location of the

contamination found on individuals, the reason for the. increase was poor

undressing techniques used by employees of.the primary contractor and not-

the lack of hot particle controls. Licensee management addressed this

point on April 22, 1989, in a memo to the contractor, emphasizing the need  !

for following the proper undressing. procedure. The licensee's

representatives further stated that remedial training would be used if the

rate of personnel contamination did not significantly decrease.

No deviations were ident1fied.

8. Transportation

The licensee's transportation program was inspected to' determine )

compliance with 49 CFR 170-179 and 10 CFR 71. -

The licensee made 32 shipments in 1988 and 12 thusfar in 1989. Shipments

were made using steel liners., drums, and casks. Preparation and

documentation of shipments is the responsibility of the radiological

support portion of the radiological department.

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The NRC inspector examined a shipment consistinc of compacted (except

for one container) dry waste which was being prepared for shipment to- '

Richland, Washington. The NRC' inspector noted that the strong, tight-

containers (crates) appeared to be adequately braced and blocked to

prevent shifting during transportation. The NRC inspecto'r randomly

verified the licensee's surveys of the surfaces of the trailer containing

the radioactive waste. No radiation levels above 15 mR/h on contact were

detected. The shipment was labeled as low specific activity. The

licensee supplied calculations supporting the classification.

The NRC inspector reviewed documentation of various previous shipments of i

radioactive materials and concluded that it was adequate for those

examples. The NRC inspector verified that a certificate of compliance was

on file for the cask used and that the licensee was listed as a user.

No violations or deviations were identified.  :

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9. Exit Meeting

The NRC inspector met with the resident inspector and the licensee's

representatives, denoted in Section 1, and summarized the. scope and the-

findings of the inspection and the inspector's' observations as presented

in this report.

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ATTACHMENT-

PROCEDURES REVIEWED

Ittle Bevi si en Date

9.1.1.2: CNS Hot Particle _. Program L1. 6-02-88-

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9.1.1.4 Speci al Work Permit: . 17 ~2-23-89 1

9.1.4 Protective Clothing (Anti-C) L8; 9-24-87::

9.2.1 Radiation and Contamination' Survey Frequency 15= 2-20-89.

9.2.2 Radiation Survey

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9.2.3 Contamination Surveys L7' 12-08-88- ,

9.2.4 Surveying Materialifor. Release Offsite 1~ 7--01-87-

9.3.5 Constant Air Monitors (CAM) 6' 2-23-89

9.5.2 Radioactive Sources Control.and 6 6-30-88

Accountability

9.S.3.1 Radioactive Waste Shipment for Burial .6 8-11-88-

9.5.3.2 Radioactive Material Shipment 4l -8-11-88'

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