IR 05000298/1985026

Insp Rept 50-298/85-26 on 850930-1004.Violations Noted: Gaseous Radiation Monitors Not Calibr Quarterly & Two Employees Entered Transversing in-core Probe Encl W/O Permits

ML20151N629
Person / Time
Site:	Cooper
Issue date:	12/10/1985
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151N623	List: IR 05000298/1985026 ML20151N619 ML20151N626
References
50-298-85-26, NUDOCS 8601030038
Download: ML20151N629 (12)

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APPENDIX B

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U.S.' NUCLEAR REGULATORY COMMISSION

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REGION IV

NRC Inspection Report:~ 50-298/85-26

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Docket: '50-298- License: DPR'-46 h' Licensee: Nebraska Public Power District.(NPPD)

~ O. Box 499 Columbus, Nebraska 68601

- Facility Name: Cooper Nuclear Station (CNS)

- Inspection At: Cooper Site, Brownville, Nebraska 6 In'spection Conducted: September 30 through October 4, 1985

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.r Inspector: J(A > 41 o/f5 R.<E. Baer, Radiation Specialist, Facilities Date '

Radiological Protection Section f

f Accompanying

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Personnel: J. J. Hayes, Meteorology and Effluent Treatment Branch, Office of Nuclear Reactor Regulation (NRR)

M. D. Carnes, Contractor, Argonne National Laboratory (ANL)

J. W. Driscoll, Contractor, ANL Approved: Al ! M//4188'/ /2//8hb BlaineMurray, Chief,facilitiesRadiological Date Protection Section

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S Inspection Summary

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Inspection Conducted September 30 through October 4, 1985 (Report 50-298/85-26)

Areas Inspected: Routine, unannounced inspection of the licensee's radioactive waste systems including, organization and management controls, training and qualifications, liquid waste system, gaseous waste system, and followup on

' licensee event reports (LERs). The inspection involved 37 inspector-hours

onsite by one NRC inspecto Results

Within the areas inspected, three violations were identified -

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(instrument calibrations, Paragraph 7, failure to follow maintenance

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' procedures, Paragraph 8, and failure to follow health physics procedures,

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DETAILS Persons Contacted NPPD

• P. V. Thomason, Division Manager, Nuclear Operations C. Bean, Preventative Maintenance Specialist

• L. Beilke, Chemistry and Health Physics Supervisor R. Black, Acting Operations Supervisor G. A. Davis, Unit Operator Temporary Station Operator Instructor C. R. Going, Regulatory Compliance Specialist

• H. A. Jantzen, Instrumentation and Control (I&C) Supervisor G. W. Ketner, Lead Chemistry Technician J. M. Meacham, Technical Manager

J. A. Mesher, Radwaste Operator

• D. L. Reeves, Training Operator

• J. V. Sayer, Acting Technical Staff Manager D. L. Snyder, Chemistry Technician P. V. Sukup, I&C Technician M. Unruh, Maintenance Planner J. Warren, Chemist T. A. Wilson

• V. L. Wolstenholm, Quality Assurance Manager Others R. A. Rossi, Training Instructor General Electric Company

• D. L. DuBois, NRC Senior Resident Inspector

• Denotes those present during the exit interview on October 4, 198 The NRC inspector also interviewed several other licensee employees including health physics, chemistry, I&C, and operations personne . Licensee Action on Previous Inspection Findings (Closed) Open Item (298/8319-02): Training Program For Radwaste Operations Personnel - This item involved the absence of a formal training program for operations personnel responsible for operating radwaste system The licensee had developed implementing procedures and a formal lesson plan for training of operations personnel on radwaste system This item is considered close (Closed) Open/ Item (298/8504-02): High Range Noble Gas Effluent Monitor Concentration Units This item involved the recording of calibration data in counts per-minute while the monitors indicate results in units of

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uCi/cc. The licensee had revised Chemistry Procedures 8.6.2, "ERP and Vent Monitor Calibrations," Revision 11, August 22, 1985, and data form 8.5.11.8.5 used to' record the quarterly calibration of high range noble gas ~ effluent monitora to record the data in units of uCi/cc. This item is considered close '(Closed).0 pen / Item (298/8504-03): High Range Noble Gas Effluent Monitor Plateout and Deposition Studies - This item involved the lack of an evaluation to determine the amount of sample.that is lost due to plateout and deposition in the sample lines. ~The. licensee performed an evaluation of sample lines for sample plateout and deposition based on the guidance in-ANSI N13.1-1969. This item is considered close ., Inspector Observations The following are' observations the NRC inspector called to the licensee's attention. These observations are neither violations nor unresolved items. These items were -recommended for. licensee consideration for program improvement, but they have no specific regulatory requiremen The licensee stated during the exit interview that these items would be reviewed:

• Table VII-12-1 in the Updated Safety Analysis Report (USAR) lists the reactor _ building ventilation monitor range of operation as

. 0.1-1 mr/hr. However,:Section 12.5.3 of the USAR states the range of operation as 0.1-103 mr/h * The USAR does not address or identify the liquid radwaste discharge monitor. (See paragraph 7)

• The Technical Specifications for Cooper Nuclear Station Operating-License DPR-46, Appendix A, in Table 3.2.0 list the liquid radwaste discharge monitor as RMV-RM-2, and Table 4.2.0 list the same monitor as RMP-RM-35 (See paragraph 7)

• Chemistry Procedure 8.8.11, " Liquid Radioactive Waste Discharge Authorization,"Section III.A references USAR Volume VI,Section IX, Subsection 4.9. There is no such section or subsection in the referenced material. (See paragraph 4)

4 .' Radwaste Organization and Management Control The NRC inspector examined the licensee's onsite organization regarding radioactive waste' management to determine compliance with the USAR, Chapter 13.3.1 and 13.3.5 commitments, CNS Technical Specifications (TS),

Section 6.1, and the recommendations of Regulatory Guide (RG) 4.1 ,- - s- ,

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The NRC inspector determined there was no-single individual overseeing the

!.- . entire radwaste progra Various station groups were responsible for select portions of th'e program: operations for equipment operation,

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chemistry for radionuclide analysis of effluents'and source calibration of instrumentation, I&C for functional and logic testing of instrumentation, and maintenance for compaction of dry active wast The NRC= inspector reviewed selected station procedures listed in Attachment 1 during the inspection. The NRC inspector noted that Procedure 8.8.11,Section III.A referenced the USAR, Volume VI, 4 Section IX, Subsection 4.9. There is no Section IX, Subsection 4.9'in

' Volume VI of the USAR. This inconsistency was brought to the licensee's attentio The NRC inspector reviewed licensee audits 84-05, conducted during the period March 26 through April 26, 1984, and 85-10 conducted April 15

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through May 10, 1985. The NRC inspector noted that all findings and observations had been responded to in a timely manner. Followup reviews had been performed and findings closed ou *

No violations or deviations were identifie . Radwaste Training and Qualifications The NRC inspector reviewed the licensee's radwaste training program and individual qualifications to determine compliance with USAR Chapter 13.3-

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commitments and TS Section 6.1.4 and 10 CFR Part 19.12 requirement The NRC inspector reviewed the licensee's training program for radwaste system operators and qualifications of personnel involved in radwaste activities. The licensee had developed Training Procedure 12.4,

"Non-Licensed Operator Training" and Training Outline, "Radwaste System,"

Revision 0,.0ctober 1984. This training program was being presented to station non-licensed operators. The licensee was also working towards Institute of Nuclear Power Operations accreditation of the entire training program by December 198 No violations or deviations were identifie . Gaseous Radioactive Waste System The NRC inspector reviewed the licensee's gaseous waste management system to determine compliance with TS Sections 3.2.0, 3.7.8, 3.12.A, and Environmental Technical Specifications (ETS) 2.4.3 and 3.4.3 requirements ,

and the commitments in USAR Sections VII-12, VII-13, VII-17, IX-4, IX-5, IX-10 and XIV-1 .

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The NRC inspector reviewed the licensee's records for calibration of gaseous radioactivity monitors. This review indicated that gaseous radioactivity monitors were not being calibrated at the required frequency stated in station surveillance procedures or ETS. The ETS, Section 3.4.3.a.8, requires that "All waste gas monitors shall be cali-brated at least quarterly by means of a known radioactive source." The NRC inspector noted the following instrument calibration violations:

(1) The radwaste building ventilation monitor was not calibrated between the period January 7 and July 10, 1985. (2) The elevated release point (ERP) ventilation monitor was not calibrated between the periods February 22 and July 26, 1984, and January 8 to' July 9, 1985. (3) The turbine building ventilation monitor was not calibrated between the period May 4 to October 16, 1984, and the mid and high range detectors were not calibrated between the period January 7 to July 9, 1985. (4) The reactor building ventilation monitor (primary containment) was not calibrated in 1984 prior to July 27, 1984, and between the period October 17, 1984, and April 9, 1985. (5) The ERP-GE radioactivity monitors "A" and "B"'were not calibrated between the period October 3, 1984, and March 18, 198 (6) Steam jet air ejector off gas monitor was not calibrated between the period August 28, 1984, and July 23, 1985. (7) The control room ventilation monitors RMV-1A, 1B, and 1C were not calibrated between the period November 29, 1984, and March 25, 1985. The NRC inspector stated that failure to perform calibrations on a quarterly schedule was considered a violation of ETS 3.4.3.a.8 (298/8526-01).

The NRC inspector expressed concern that there appeared to be a programmatic deficiency in the method of performing calibrations. When the radioactivity monitor had not passed the monthly functional test they did not perform the quarterly calibration; however, they signed off the quarterly calibration tracking record and did not perform a calibration until the next quarterly calibration was due. 'The NRC inspector stated the calibration of these radioactivity monitors should be performed on a defined schedule. If the monitor could not be calibrated, the reason should be noted on the calibration record and a calibration performed when the monitor is returned to servic The licensee acknowledged the NRC inspector's concerns and indicated they would take them under advisemen The NRC inspector also expressed concern regarding the lack of a standardized identification system for the process and effluent radioactivity monitors that would be consistent with all calibration, surveillance procedures, USAR, and T The NRC inspector experienced problems obtaining records of instrument calibrations which were caused by a lack of standardization between various station groups to utilize a common identification system such as the instrument identification numbe The NRC inspector had requested calibration records for the steam jet air ejector off gas monitors "A" and "B" and received records for the ERP GE

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gaseous radiation monitors "A" and "B". This had the potential to create a problem. The licensee stated they would review the NRC inspector's concer The NRC inspector reviewed the records for the Standby Gas Treatment System Trains 1A and 1B, Technical Support Center and Emergency Offsite Facility Air' Cleaning-Systems which' utilize high efficiency air particulate-(HEPA) and carbon filters, and the Augmented Radwaste Building System which utilized HEPA filters. The NRC' inspector reviewed the HEPA

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in place filter test, carbon methyl iodide analysis, certification of l individual performing the tests, equipment calibration, visual inspection records, and verified the contractor performing the testing appeared on the licensee's approved Qualified Vendor Lis The NRC inspector reviewed the semi-annual effluent release reports for the periods July through December 1984 and January 1 through June 30, 1985. The licensee's records indicated that gaseous radioactive waste releases were in accordance with ETS requirements.

! No violations or deviations were identified.

i Liquid Radioactive Waste System ,

! The NRC inspector reviewed the licensee's liquid radioactive waste system l .to determine compliance with TS Sections 3.2.0, 3.6, 4.2.D, 4.7 and ETS

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Sections 2.4.1 and 3.4.1 requirements and commitments in the USAR '

Sections VII-12, IX-2, and IX- .

The NRC inspector reviewed selected liquid effluent discharge records for

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discharges conducted during the period January 1 through September 21, 1985. All discharges appeared to be in accordance with the TS and station operating procedures. The NRC inspector also reviewed the semi-annual effluent release reports for the periods of July through ,

, . -December 1984 and January 1 through June 30, 1985. These reports also indicated that 1.iquid effluent releases were within the TS release limit The NRC inspector reviewed selected laboratory analyses for reactor water and condensate storace tank (Demineralizer Water Storage) samples taken to-i satisfy TS Sections 3.6.8 and 4.6.B.1 requirements. All analyses were i

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within the TS requirtments.

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The NRC 'nspector discussed with licensee representatives that chemistry l data foras for sample analysis and radioactive source. calibrations of l

liquid ar.d gaseous effluent monitors did not always contain the ,

l measurement units such as counts per minute per milliliter or microcuries

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per cubic centimeter. The licensee stated they would review this matter.

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The NRC inspector discussed with a licensee representative that the USAR f .did not address or identify a liquid radwaste discharge monitor or-the ability to automatically terminate a release with an isolation valve i

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because of high radioactivit Also, that the TS in Table 3.2.0 listed the Liquid Radwarte Discharge Monitor as RMV-RM-2 and Table 4.2.D listed the same monitor as RMP-RM-351. The NRC inspector discussed the advantages of using a unique identification number for the process and effluent radioactivity monitors and using the same number to identify the associated calibration, functional, and logic test dat The licensee stated they would review this matte No violations or deviations were identified.'

8. Inspector Followup on LERs and Nonconformance Reports (NCR)

The NRC inspector reviewed the circumstances and calculations performed by the licensee regarding the incident of August 28, 1985, where two individuals received internal contamination from radioactive materials while performing a Traversing Incore Probe (TIP) alignment. This incident was documented in NCR 004740, August 28, 198 The two I&C technicians were performing special test procedure 85-12. As part of the TIP alignment, on-the-spot change number 4 was required to be performed which required the TIP to be moved in accordance with Procedure 7.5.2.6, "TIP Drive Torque Measurements and Core Top Programming," Revision 6, June 7, 1985. Procedure 7.5.2.6,Section VI, Precautions C states, "Be aware of radiological hazard by contacting health physics prior to performing work in the TIP enclosure and comply with posted special work permit if required," and Section VI.D warns that the Gleason Reel is spring loaded and the detector could be withdrawn by the spring tension and the detector could be highly radioactiv The NRC inspector determined that the two technicians did not obtain a special work permit (SWP), entered the TIP enclosure which had the access posted " Notify Health Physics Prior to Opening," and proceeded to perform their work. The TIP B was withdrawn by spring tension into the TIP enclosure and the detector was broken off from the cable. As a result, the TIP enclosure became an airborne radioactivity and high radiation area. The two technicians immediately exited the area and notified the control roo Health physics personnel performed radiation surveys, air sampling of the TIP room and TIP enclosure, and performed whole body counting and decontamination on the two individuals. Self-reading dosimeters, 0-200 mrem range, were read and found to be slightly off scale; therefore, thermoluminescent dosimeters (TLD) were sent to the offsite vendor for processing. Table 1 depicts the radiation exposure received by the two individuals.

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", TABLE 1 Individual Exposure Data Individual A Individual B E

Work between August 1-27 (Self reading 27 mrem 42 mrem

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August 28 (Self reading Dosimeter) 200 mrem 200 mrem TLD August 1-28 229 mrem 244 mrem Assigned from internal exposure 19 mrem 21 mrem ,

Maximum permissible concentration hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 8 hours TS Section 6.3.3 requires that maintenance and test procedures be provided to satisfy routine inspection, preventative maintenance programs, and operating license requirements. Procedure 7.5.2.6 was written to satisfy

'these TS requirements. The NRC inspector stated that failure to follow Procedure 7.5.2.6 and notify the health physics group prior to performing work in the TIP enclosure was considered a violation of TS Section 6. (298/8526-02). TS Section 6.3.4 requires that radiation control procedures be maintained consistent with the requirements of 10 CFR Part 20, and Procedure 9.1.1.4 requires that work being performed in areas that may involve the presence of high radiation or hazardous airborne radioactivity concentrations be done under a SWP. The NRC inspector stated that failure to follow Procedure 9.1.1.4 and obtain an SWP prior to performing the TIP work was considered a violation of TS Section 6. '(298/856-03)

The NRC inspector reviewed LER 85.004, August 13, 1985, regarding an overexposure of an individual under eighteen years of age in 1982. The individual'had been exposed to 0.185 rem during the period May 21 through June 30, 1982, and 0.150 rem during the period July 1 through

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~ September 3, 1982, while he was seventeen years old in violation of 10 CFR Part 20.104 which would have limited his exposure to 0.125 rem per calendar quarter. The individual had certified on May 21, 1982 and again on' April 25, 1983, to be a year older than his actual age.

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.The NRC inspector determined that the licensee identified this incident

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when the individual was terminating his third work assignment during a four year period at CNS. The licensee's thorough review of present and previous exposure histon identified the prior falsification of date of birth entries made on personal data form Corrective actions taken by the licensee appear to be appropriat ' Exit Interview

. The NRC inspector met with the CNS NRC senior resident inspector and licensee representatives denoted in paragraph 1 at the conclusion of the

, inspection on October 4, 1985. The NRC inspector summarized the scope and

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n findings of the inspection including the violations listed in Appendix A, and the observations expressed in paragraphs 3 and The licensee stated that the inspector's observations would be reviewed.

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ATTACHMENT 1 Procedures Reviewed

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Chemistry Procedure 8. " Chemistry Analysis and Instrument Calibration Schedule," Revision 13, t

July 11, 1985 8. " Table of Liquid and Gas Sample Points," Revision 3, August 20 1982 " Control Parameters and Limits", Revision 7, December 22, 1984 > " Routine Sampling Procedures", Revision 2, March 28, 1980 ,

8. " Air Ejector Off Gas Radiation Monitor (Calibration)," Revision 7, July 5, 1985 8. "ERP and Vent Monitor Calibrations," Revision 10, June 8, 1984

- 8. " Liquid Process Radiation Monitors SW and REC," Revision 8, September 6, 1984 8. "Radwaste Liquid Process Radiation Monitor,'_' Revision 10, March 7, 1984 8. " Control Room and Drywell Air Monitors," Revision 1, March 7, 1984 8.8.1.13 " Radiochemical Gross Activity Analysis," Revision 7, December 22, 1984 8.8.1.14 " Radiochemical Analysis Iodines," Revision 8, September 28, 1984 8. "Off Gas Grab Samples Isotopic Analysis," Revision 6, October 17, 1984 8. " Determination of Of f-Gas Flow Rate," Revision 2, July 13,1982 8. " Determination of Off-Gas Hold-Up Time," Revision 1, December 24, 1974

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8. " Liquid Waste Discharge Preparation and Analysis," Revision 8, October 2, 1984 8. " Particulate Filters, Iodine Cartridges, and Noble Gas ERP Vent Monitors Sample Collection," Revision 8, December 12, 1984 8.8.11 " Liquid Radioactive Waste Discharge Authorization," Revision 9,.

July 25, 1984

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i Surveillance Procedures 6.3. " Liquid Radwaste Effluent System Calibration and Functional and Logic Tests," Revision 13, February 20, 1984 6.3. "ERP Radiation Monitor (Kaman) Known Source Calibration / Functional i

Test," Revision 21, August 21, 1985 6.3. "ERP Radiation Monitor (GE) Calibration and Functional / Functional l

Test," Revision 15, July 6, 1984 6.3. "Off Gas Radiation Monitor Calibration and Functional / Functional Test," Revision 15, September 24, 1984 6.3. "SW and REC Radiation Monitor Calibration and Instrument Channel / Instrument Test," Revision 8, August 15, 1985 6.4. " Reactor Building Air Sampling System Functional and Known Source

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Calibration Test, Revision 23, August 19, 1985 l 6.4. " Turbine Building Ventilation Backup Sampling System RMV-RM-5 Calibration and Functional Test," Revision 0, August'24, 1985 l

6.4. " Control Room Ventilation Monitors Calibration and Functional / Functional and Logic Tests," Revision 22, February 1,1985 6.4. " Reactor Building Ventilation Backup Sampling System RMV-RM-3 Calibration and Functional Test," Revision 0, August 24, 1985

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