IR 05000298/1993010
| ML20035A096 | |
| Person / Time | |
|---|---|
| Site: | Cooper |
| Issue date: | 03/19/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20035A095 | List: |
| References | |
| 50-298-93-10, NUDOCS 9303240059 | |
| Download: ML20035A096 (10) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-298/93-10 Operating Licenses:
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Licensee: Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499
Facility Name:
Cooper Nuclear Station Inspection At:
Brownville, Nebraska Inspection Conducted:
February 22-26, 1993 Inspector:
L. T. Ricketson, P.E., Senior Radiation Specialist Facilities Inspection Programs Section Approved:
O d W'hM(lO h
B. Murray, Chief, faci g s Inspection Date'
Programs Section
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Inspection Summary Areas Inspected: Routine, announced. inspection of the radiation protection program, including audits and appraisals, program changes, planning and
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preparation for the 1993 refueling outage, external exposure controls, internal exposure controls, controls of radioactive materials and contamination, and the program to maintain occupational exposures as low as reasonably achievable (ALARA).
Results:
The most recent quality assurance audit was comprehensive and the audit
team included members with technical expertise. The audit report had not been finalized, so the timeliness of the radiation protection department's responses to the findings could not be evaluated (Section 2.1)
Good quality assurance surveillances provided meaningful information
regarding the daily performance of the radiation protection department (Section 2.1).
The radiological reporting system ensured that corrective actions were
implemented for licensee-identified problems (Section 2.1)-
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9303240059 930319 PDR ADDCK 05000298 G
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The radiological reporting system did not lend itself to the tracking or
trending of minor issues which might be precursors of eventual problems
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(Section 2.1).
There were no major changes to the radiation protection program or
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organization. The radiation protection work force was very stable, with -
no turnover (Section 2.2).
l The licensee made appropriate preparations for the upcoming refueling
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outage (Section 2.3).
The radiation work permit program had been improved.
Locked high
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radiation areas were appropriately controlled (Section 2.4).
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An excellent internal exposure control program was maintained
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(Section 2.5).
A very low number of personnel contaminations t ccurred in 1992
(Section 2.6).
Superior performance was noted with respect to persoc-rem totals during-
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1992 (Section 2.7).
Attachment:
Attachment - Persons Contacted and Exit Meeting
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DETAILS 1 PLANT STATUS During this inspection, plant power output was being reduced (from 89 to 87 percent) in preparatior, for the 1993 refueling outage.
2 OCCUPATIONAL EXPOSURE (83750)
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The licensee's program was inspected to determine compliance with Technical
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Speci fications 6.1.2, 6.1.3, and 6.1.4 and the requirements of 10 CFR Part 20, and agreement with the commitments of Chapter XIII of the Final Safety Analysis Report 2.1 Audits and Appraisals The inspector reviewed the audit of the radiation protection department
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performed November 2, 1992, through January 8, 1993. The inspector noted that a radiation protection foreman from another boiling water reactor facility and
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a radiation protection technician on rotational assignment to the quality
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assurance department were on the audit team. The audit was comprehensive and identified deficiencies in two areas.
It 3':0 included observations and made
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suggestions for possible program improvement. The audit report had not been
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issued at the time of the inspection, so the inspector did not evaluate the radiation protection department's responses. A quality assurance management representative stated that, typically, the radiation protection department a
responses were timely and addressed the issues well.
The inspector also reviewed quality assurance surveillances and noted that they were performed in sufficient number and covered a wide range of activities in the radiation protection area. The surveillances reviewed were
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performed by the radiation protection technician on rotational assignment'to
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the quality assurance department and represented a good overview of the daily radiation protection performance.
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The licensee performed a self assessment of the respiratory protection program which included interviews with workers to obtain their input and suggestions.
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The assessment resulted in the identification and implementation of
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refinements to the program.
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-The inspector reviewed the licensee radiological reporting system. There'were three Radiological Safety Incident Reports written in 1992. Guidance as to the types of events to be reported were set forth by procedure. The events documented in the reports were investigated by the organization assigned primary responsibility. Corrective actions were developed and implemented based on the findings of the investigation. There were no provisions for i
trending the causes for the events, but given the number of occurrences, this l
.did not constitute a weakness. All three of the reports were initiated by the l
radiation protection department.
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i 2.2 Changes i
i There were no major changes in the radiation protection department
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organization or personnel. The radiation protection department participated
in a rotational program that involved the exchange' of a radiation protection
technician for a specialist in the quality assurance department and an
instructor from the training department. Representatives from the radiation
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protection and quality assurance departments were interviewed and stated that l
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they felt the program was beneficial to both departments.
i The radiation protection department had a very stable work force with no
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personnel turnover during 1992.
i The licensee continued to refine its rsdiological controlled area. The area j
had one entrance / exit area for routine operations. The licensee had recently
opened a second access control point in preparation for outage activities.
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The licensee was reviewing the radiation protection procedures to determine i'
what changes would be necessary prior to the implementation of the new 10 CFR Part 20 regulations on January 1, 1994.
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f 2.3 Plannina and Preparation The licensee planned to shutdown the reactor for the 1993 refueling outage on l
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t March 5, 1993. The inspector interviewed ALARA personnel concerning the -
preparation for the outage and reviewed maintenance work requests.
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personnel stated that they had sufficient time to review the work items and
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develop work packages. All packages for planned, major work items were reviewed as of the end of January 1993. The inspector reviewed selected work packages and noted that they included ALARA checklists, briefing outlines,
survey information, and projected required man-hours. The ALARA checklist j
prompted the reviewer to consider lessons learned _ from previous, similar work.
The inspector discussed with the ' licensee's representatives the possibility of-
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including such items as a review of industry events and NRC information U
notices, as they related to the work item under review. Licensee j
representatives stated that this_ would be considered as a means of obtaining
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additional information on hazards or lessons learned.
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Approximately.75 contract radiation protection technicians were already on
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j site undergoing training in preparation for the 1993 outage._ The licensee had
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six decontamination technicians for routine plant operation and planned to add-
six more for the. refueling. outage.
~i The licensee planned to use a different technique to manage the contract i
radiation protection technicians during' the outage. Previously, when-
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radiation protection coverage was required for a work item, a technician was a
selected from the pool of technicians available and assigned to the work.- For j
.the upcoming outage, the contract radiation protection technicians have been
divided into groups and assigned to different areas. _ A permanent-staff radiation protection technician will be in charge of each group of contract.
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-5-t technicians and that group will assume ownership of the work occurring in i
their area.
A torus mock-up was used to train workers for the iron grit blasting which will be used to prepare the torus for resurfacing. Mock-up training was also
provided for personnel preparing to work on residual heat removal motor
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operated valves. Maintenance workers were shown a film from a previous refueling outage which reviewed the steps involved in the disassembly / assembly of the reactor head. Selected radiation protection-technicians will attend maintenance training focusing on the control rod drive mechani.sm rebuilding.
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The inspector questioned licensee representatives concerning supplies, equipment, and temporary shielding needed for the outage.
The representatives responded that they felt they had appropriate supplies, etc. Provisions have been made for extensive use of filtered, forced ventilation units in various work areas to reduce the amount of airborne radioactivity.
The licensee had four cameras in the heater bay area and will use as many as five more cameras in various areas to observe activities during the outage.
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2.4 External Exoosure Control f
The licensee continued to use vendor-supplied personnel monitoring devices.
Licensee representatives stated that they had experienced no trouble in receiving rapid turnaround for special dosimetry processed during outage work.
The licensee used overnight mail service to deliver the dosimetry to the processor and received the results by facsimile.
l The licensee procured vests for multibadging use and arranged to have
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extremity monitoring available for use when appropriate.
i The inspector reviewed the radiation work permit program and noted the
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licensee had made changes to the format of the Special Work Permits in an effort to increase the clarity of their instructions. One of the changes included the use of red highlights to emphasis important instructions.
Attachment 2 of the Special Work Permit was kept at the work site and updated by_ radiation protection personnel after radiation surveys, ensuring current information was available to workers. The ir.spector reviewed examples of Special Work Permits and determined that they offered appropriate guidance.
During tours of the radiological controlled area, the inspector reviewed area
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posting and control of locked, high radiation areas and identified no problems.
2.5 Internal Exposure Control The inspector reviewed the internal radiation exposure control program and
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. determined that the licensee was tracking maximum permissible concentration-r hours as a result of airborne radioactivity.
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The inspector reviewed the respirator maintenance and storage area and determined that the licensee maintained a suitable program and work area for the cleaning, sterilizing, and storing of respirators.
The licensee used ambient air fit testing equipment to test respirator users
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and to determine the proper size respirator. The inspector reviewed the licensee's written fitting procedure and observed radiation protection technicians as they tested respirator users.
The inspector observed radiation protection personnel as they performed whole-body counting. Proper background counts were performed before use of equipment. Procedures in this area provided good guidance. Licensee i
representatives stated that new whole-body counting equipment will be procured
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in the near future as part of a program upgrade.
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The licensee identified one instance during 1992 in which an individual ingested radioactive material. The material was identified as cobalt-60 and dose calculations indicated that the dose to the individual was 0.5 mrems and, thus, no regulatory limits were exceeded.
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2.6 Controls of Radioactive Materials and Contamination. Survevs. and
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Monitorino The inspector reviewed the licensee's radiation survey schedule and examined selected weekly and monthly survey records to confirm that the survey schedule was maintained and that the records contained all necessary information.
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the records, the inspector noted the instruments used for area surveys and verified that they were in calibration at the time of use. Additionally, the inspector verified that the instruments were calibrated using a source traceable to a national standard and that the individual performing the
calibration was qualified in accordance to applicable procedures. An appropriate beta calibration source was used to calculate the beta correction i
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factor for each instrument. Radiation protection instruments were response tested prior to use and a record was kept of the test.
The inspector reviewed contamination survey results and verified through
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records review that the samples were analyzed with properly calibrated i
counting equipment and that the technicians performing the analysis met the licensee's qualification requirements.
i The radiation protection department was responsible for the calibration of
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portable survey instruments, counting room instruments, air samplers,
continuous air monitors, pocket ion chambers (self-reading dosimeters),
i electronic alarming dosimeters, hand and foot monitors, personnel contamination monitors, and portal monitors. The inspector reviewed
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calibration procedures of the preceding equipment and determined that
appropriate calibration sources were used, proper minimum detectable
_ activities were achieved, and properly calibrated equipment was used (when calibrating such items as air samplers).
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included more sensitive electronics and an additional detector on each which monitored the head area. The upgrade resulted in portal monitors with a lower
minimum detectable activity and fewer dead spots. The monitors were response
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tested daily.
Housekeeping throughout most of the radiological controlled area was
excellent, except for the laundry handling area where protective clothing was-l being sorted in preparation for the refueling outage.
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During 1992, the licensee identified and recorded 17 skin contaminations.
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The inspector reviewed leak test records for select sealed calibration sources
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and determined that the sources were tested at the required intervals.
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2.7 Maintainino Occupational Exposures ALARA
On February 26, the inspector attended the licensee's first quarter ALARA
committee meeting. The inspector noted that the meeting was well attended.
j Review of the minutes of previous meetings confirmed that attendance by all
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work groups was good. The meeting was conducted well and communications-j between the group appeared to be good.
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As part of the agenda, the ALARA committee discussed outage work projected to accrue greater than 5 person-rem, temporary shielding, and the status of ALARA
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suggestions and design changes.
In accordance with their procedures, the ALARA group set a goal of 288 person-rem for the 1992 refueling outage. Subsequently, licensee management set forth what was termed as an " administrative goal" or " enhanced
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performance indicator." The more restrictive number was 256 person-rem.
The ALARA suggestion program appeared to be successful.
In 1991, there were l
13 suggestions, and in 1992 there were 15. All suggestions have been
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addressed. Some were waiting to be implemented. Licensee representatives-I stated that they had no established policy (or dollar value per person-rem savings) for guidance when considering design changes which are proposed
strictly for the purpose of dose savings.
t The licensee's 1992 person-rem total was 72.5.
There was no refueling outage
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in 1992.
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i 2.8 Conclusions l
l Radiation protection expertise on quality assurance audit teams was improved
by initiating a program of personnel rotations between the. radiation protection and quality assurance departments. Additionally, the licensee
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,obtained a radiation protection specialist from another boiling water reactor-
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facility to be on the audit team. These actions ensured an increased-level of
technical expertise for the 1992 quality assurance audit.
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Quality assurance surveillances of radiation protection activities provided meaningful evaluations of daily program performance.
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The radiological occurrence reporting system provided a means of documenting significant occurrences and ensuring that corrective actions were taken. The t
system did not lend itself to the tracking or trending of minor issues which
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might be precursors of eventual problems.
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There were no major changes to the radiation protection program or
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organization. The radiation protection work force was very stable, with no turnover.
l The licensee made appropriate preparations for the upcoming outage by l
supplementing of the permanent staff with a sufficient number of contract radiation protection technicians, reviewing maintenance work requests and
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incorporating dose saving measures suitably in advance, procuring proper supplies and equipment, and conducting mock-up training for radiation workers.
l The licensee enhanced its external exposure control program by making its Special Work Permits easier to understand. Area postings were appropriate and
locked high radiation areas were maintained under control.
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Elements of the internal exposure control program were state-of-the-art and the program had performed well during 1992.
Based on the number of personnel contaminations identified and recorded by the
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licensee, the program for control of radioactive materials and contamination,
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was excellent.
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An excellent radiation instrument calibration program was maintained.
The ALARA program received good support from management and workers.
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Performance by the licensee in regard to total radiation dose accrued in 1992 l
was superior.
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-g-ATTACHMENT 1 1 PERSONS CONTACTED 1.1 Licensee Personnel G. A. Armknecht, Calibration Specialist
- R. L. Beilke, Radiological Support Supervisor
- S. L. Bray, Operations Quality Assurance Supervisor
- T. J. Chard, Health Physics Supervisor
- M. A. Dean, Nuclear Licensing and Safety Supervisor
- J. Dutton, Training Manager
- M. Gillan, Technical Training Supervisor B. L. Hall, Health Physicist D. P. Oshlo, ALARA Ccordinator
- J. V. Sayer, Radiologi.al Manager
- S. Peterson, Acting Plant Manager G. E. Smith, Quality Assurance Manager 1.2 NRC Personnel R. Kopriva. Senior Resident Inspector
- Denotes personnel that attended the exit meeting.
In addition to the personnel listed, the inspector contacted other personnel during this inspection period.
2 EXIT MEETING An exit meeting was conducted on February 26, 1993.
During this meeting, the inspector reviewed the scope and findings of the report.
The licensee did not identify as proprietary any information provided to, or reviewed by the inspectcr.