IR 05000298/1996028

Insp Rept 50-298/96-28 on 961209-13.No Violations Noted. Major Areas Inspected:Portions of Radiation Protection Program,Reviews of Audits & Appraisals,Radiation Protection Organization & Staffing & Qualifications

ML20133C773
Person / Time
Site:	Cooper
Issue date:	01/02/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133C755	List: IR 05000298/1996028 ML20133C752
References
50-298-96-28, NUDOCS 9701080090
Download: ML20133C773 (12)

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i ENCLOSURE ,

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

i Docket No.: 50-298- l l

l License No.: DPR-46 i l l Report No.: 50-298/96-28 '

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} Licensee: Nebraska Public Power District '

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i Facility: Cooper Nuclear Station

Location: P.O. Box 98 l

Brownville, Nebraska Dates: December 9-13,1996

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inspector: L. T. Ricketson, P.E., Senior Radiation Specialist j

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Approved By: Blaine Murray, Chief, Plant Support Branch i

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Division of Reactor Safety Attachment: Supplemental Information l

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PDR ADOCK 05000298 i G PDR

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EXECUTIVE SUMMARY Cooper Nuclear Station NRC Inspection Report 50-298/96-28 This routine, announced inspection reviewed portions of the radiation protection progra Included were reviews of audits and appraisals, radiation protection organization and staffing, training and qualifications, exposure controls, and the program to maintain occupational exposures as low as is reasonably achievable (ALARA).

Plant Sucoort

Improvements were inade in the ALARA program. The ALARA staffing was increased, the ALAP.A committee was given a higher profile by changing the level of management participation, significant initiatives were implemented or budgeted for implementation (Section R1.1).

The 1996 person-rem total was the lowest in plant history. The 3-year average of person-rem totals were well below the national average for total exposure (Section R1.1).

The ALARA goal setting was not refined. The licensee's metnod of scheduling and sequencing of outage activities could be improved to prevent repetition of work activities and reduce worker dose (Section R1.1).

• Exposure controls were implemented appropriately. The reduction of the number of high radiation area keys was an excellent initiative to improvement high radiation area controls (Section R1.2).

• Overall, the technical expertise of the radiation protection staff was increased. The continuing training program improved within the assessment period. Good training was provided to radiation protection technicians. The continuing technical training program for radiation protection supervisors and professionals showed good management support (Section RS).

• The radiation protection organization remained appropriately staffed (Section R6).

• Excellent self assessments were performed; however, corrective actions for some of ,

the concerns identified during self assessments were not completed,9 to 12 months after identification. This was due, in part, because of the use of the site-wide prioritizing directive (Section R7).

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l Report Details

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Ill. Enoineerina E2 Engineering Support of Facilities and Equipment l A recent discovery of a licensee operating their facility in a manner contrary to the l Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures, and/or parameters to the UFSAR description. While performing the inspection discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspectors verified that the UFSAR wording was consistent with the observed plant practices, procedures, and/or parameter IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Maintainina Occupational Exoosures ALARA insoection Scoce (83728)

The radiation protection manager, ALARA supervisor, and an ALARA technician were interviewed. The following items were reviewed:

• ALARA committee meeting minutes since the previous inspection,

• ALARA suggestion log, ,

• ALARA goals, l

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• Person-rem totals,

• Hot spot tracking and reduction program results, and

• Applicable procedure Observations and Findinas The ALARA committee was revised to include department managers instead of l supervisors. The Vice President-Nuclear assumed the responsibility of ALARA committee chairma An ALARA representative was integrated into the work control orgariization. The l individual met routinely with work control personnel to review upcoming work. The i process improved planning of non-outage radiological work activities. Scheduling I and sequencing radiological work activities during refueling outage was performed in an average manner. No particular initiative were implemented by the lice:aee to

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ensure that work activities such as scaffolding erection and removal or insulation removal and reinstallation were not performed repetitively. The ALARA supervisor acknowledged that there had been examples of duplication of certain work activities and the associated increase in personnel exposure. The radiation protection manager stated that this was an area that would be evaluated to identify potential means of dose reduction.

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The licensee initiated a worker awareness program and provided incentive for participation in the ALARA suggestion program. The number of ALARA suggestions increased to 88 in 1995, refueling outage year. Thus far in 1996, a non-outage year,28 suggestions have been submitted. There was a significant increase in worker participation from the previous assessment period. NRC Inspection 50-298/96-15 identified potentialimprovement areas for the ALARA suggestion program. A quality assurance evaluation conducted in November 1996 )

concluded that response to ALARA suggestions was slow. The licensee initiated actions to address some of this these items; however, the actions were not complet From discussions with the ALARA supervisor, the inspector determined that setting ALARA outage work activity exposure goals was not a refined process. Sometimes 4 the goals were merely "best guesses." A great deal of dependence was placed on the primary work group's estimate of the man-hour necessary to complete the job, I even though the site has a long history of performing repetitive work activitie l Licensee representatives stated that, typically, there are few plant modifications to 1 address in which unknowns would be introduced. The best past performance was i rarely used as a starting point for the establishment of outage exposure goal Licensee representatives acknowledged the inspectors comments and stated that this was one of the areas in which they were attempting to improv The inspector noted that the licensee initiated a hot spot tracking and reduction program in 1996. Five of 27 hot spots had been removed and the program was ongoing. Through another initiative, the licensee significantly reduced the area posted as a radiation or high radiation araa. This was accomplished by placing boundaries closer to the actual points requiring controls, rather than by simply controlling the entrances to the areas. Licensee representatives felt that this aided in preventing worker complacency or insensitivity to radiological hazards. The inspector reviewed area controls and identified no problem According to licensee representatives, funding wat approved in November 1996 for an additional 24 television cameras and approximately 100 telemetric dosimeter This initiative will allow observation and area monitoring to be performed remotely, thereby reducing personnel exposur )

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.t-5-From interviews with licensee personnel, the inspector determined that one element of the source term reduction program, stellite reduction and removal, made no progress since December 1994. Licensee representatives stated, at the exit i meeting, that this portion of the program would be reviewed to determine if more )

can be done to reduce the cobalt-60 source ter The licensee's person-rem totals are shown below:

1994 1995 1996 Licensee 83 228 45 i

Three-average 182 234 119 National BWR 327 256 Average

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This nar's total of 45 person-rems is the best in the site's history. Licensee l

personnel credited good water chemistry, which has kept the source term low, as being a large factor in the site's success with maintaining low personnel exposure. ]

The latest 3-year average was well below the national average for boiling water l reactors. (See NRC Inspection Report 50-298/94-33 for previous person-rem )

totals.) The inspector also noted that the plant was shut down from May 1994 to February 1995. A licensee representative stated that a minimum of maintenance activities was performed during this time, thus, aiding in maintaining low total exposur Conclusions improvements were made in the ALARA program. The ALARA staffing was l

increased, the ALARA committee was given a higher profile by changing the level of management participation, significant initiatives related to the ALARA program were implemented or budgeted for implementatio The 1996 person-rem total was the lowest in plant history. The 1994-1996 person-rem average was well below the national average for total exposur ALARA goal setting methodology was not refined. The licensee's method of scheduling and sequencing of outage activities could be improved to prevent l

repetition of work activities and reduce worker dose.

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R1.2 Exoosure Controls 4 Insoection Scone (83750)

I Radiation protection supervisors and technicians were interviewed. The radiological controlled area was toured and exposure controls were reviewed.

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• .i 6-b. Observations and Findinas

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During tr rs of the radiological controlled area, the inspector noted that area postings sere correct and high radiation area controls were maintained properl l

The licensee reducd the number of high radiation area keys from approximately

100 keys to 4. Keys to locked high radiation areas were also stored in fire boxes in case operators had to enter the areas during emergencies.

i Conclusions

! Exposure controls were implemented appropriately. The reduction of the number of

{ high radiation area keys was an excellent initiative to improvement high radiation area control R5 Staff Training and Qualification

, Inspection Scoce (83750) i

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, The radiation protection manager was interviewed. The following items were l reviewed:

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* Organization chart for the radiological department (11-1-96), l Continuing training topics presented to radiation protection technicians, and

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• Continuing training for radiation protection supervisors and professional l 1 Observations and Findinas

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S All supervisory personnel, between the level'of radiation protection manager and I l- crew lead technician, held bachelor of science degrees. Seven of 19 radiation '

! protection and ALARA technicians were enrolled in an associates degree program.

This is an increase since the previous review of this area. One radiation protection j

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j staff member was a certified health physicist. The individual was added during the assessment perio Eighteen of 33 people (excluding the chemistry and decontamination groups) were ,

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registered by the National Registry of Radiation Protection Technologists. Another i 8 people were awaiting the results of the most recent examination. The number of individuals registered has increased from 9, since being reviewed last during NRC

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Inspection 50-298/94-05.

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Continuing radiation protection training addressed multiple topics. The inspector

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reviewed the topics presented in 1995 and 1996 and concluded that they were i appropriate to continuing training. The number of topics presented in 1995 were minimal; however, training was increased in 1996. A large percentage of radiation protection technicians had received training, since 1993,in plant system . \

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-7- I According to information provided by the licensee, all supervisors and professional within the radiation protection wganization attended continuing training in the individual's field of expertise and/or professional meetings, Conclusions The c antinuing training program improved within the assessment period. Good training was provided to radiation protection technicians. The continuing technical training program for radiation protection supervisors and professionals showed good management suppor Overall, the technical expertise of the radiation protection staff was increase R6 Radiological Protection and Chemistry Organization and Administration j i Insoection Scone (83750) l The radiation protection manager was interviewed and the current organization i chart for the radiological department was reviewe I Observations and Findinas The radiation protection organization was reorganized during the assessment perio Overall staffing remained constant. The professional staff included an assistant to the radiological manager and two health physicists. The radiological manager also had supervisory responsibility for the chemistry, industrial safety, and decontamination group Staffing of the ALARA group was increased. The ALARA group included a supervisor and four technicians. The previous staffing consisted of two individual c. Conclusions The radiation protection organization remained appropriately staffe R7 Quality Assurance in Radiological Protection and Chemistry Activities ,

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a. inspection Scope (83750)

The following items were reviewed:

• Quality assurance surveillances,

• Quality assurance evaluations,

• Radiation protection self assessments for 1995 and 1996,

• Continuous improvement item ctatus, and

• Applicable nuclear power group directive *. . ,

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-8-b. Observations and Findinas Quality assurance representatives performed surveillances and evaluations of several rad ation protection activities. Subject areas are listed in the attachment to this report. The surveillances were thorough and identified areas of potential program improvement. Quality assurance personnel cor'cluded during an evaluation of the ALARA program that the " conduct of the ALARA group was strong," but,

"the support given to [the] ALARA [ group] for immediate dose reduction processes has room for improvement." As a ba<s, the evaluator stated that ALARA has been given a low priority according to Nuclear Power Group Directive 4.12, " Work Prioritization," Revision Self assessments were conducted by the radiation protection organization in 1995 and 1996. The 1996 self assessment included five technical experts from other nuclear power sites. The assessments were broad in scope and the results demonstrated an ability to be self critical. Radiation protection personnelinitiated action items in response to the self-assessment findings and tracked them as part of their Continuous improvement Program tiacking syste The inspector reviewed actions taken in response to identified weaknest.as and concerns. Weaknesses are items that require timely attention and could have an adverse impact on the radiation protection program. Concerns are items that have a negative impact on the radiation protection program and if not addressed could escalate into a weaknes The inspector noted that weaknesses were appropriately addressed; however, after approximately 12 months,6 of 16 concerns identified in 1995 had not been addressed. After approximately 9 months,15 of 26 concerns identified during the 1996 self assessment had not been addresse Radiation protection personnel responded that they were using the guidance of Nuclear Power Group Directive 4.12, " Work Prioritization," Revision 1, to establish due dates. The directive was used site wid c. Conclusions Excellent self assessraunts were performed; however, correction actions for some of the concerns identified during self assessments were not completed,9 to 12 months after identification. This was due, in part, because of the use of the site-wide prioritizing directiv .

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R8 Miscellaneous Radiological Protection and Chemistry issues

j R (Closed) Violation 50-298/9615-02: Failure to oerform radioloaical surveys The inspector verified the corrective actions described in the licensee's response

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letter, dated September 23,1996, were implemented. No similar problems were j identified.

i 3 V. Manaaement Meetinas

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X1 Exit Meeting Summary The inspectors presente.-i .a inspection results to members of licensee management at an exit meeting on Decem5r 13,1996. The licenses acknowledged the findings presente The inspectors asked the licensee whether an, . aterials examined durin<- the inspection

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should be considered proprietary. No proprietary information was identifie i

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'. .t ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Licensee T. Chard, Assistant Radiation Protection Manager J. Dixon, Radiation Protection Crew Leader P. Graham, Vice President, Nuclear Energy M. Hale, Radiation protection Manager

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D. Kimball, Radiological Operations Supervisor B. Houston, Manager, Nuclear Licensing D. Oslo, ALARA Supervisor M. Peckham, Plant Manager B. Toline, Quality Assurance Audit Supervisor NRC B. Murray, Chief, Plant Support Branch INSPECTION PROCEDURES USED 83728 Maintaining Occupational Exposures ALARA 83750 Occupational Radiation Exposures ITEM CLOSED Closed 50-298/9615-02 VIO Failure to perform radiological surveys LIST OF DOCUMENTS REVIEWED Ccoper Nuclear Station Chart 17 (11/1/96), Sheet 4 of 14 (Radiological Department)

List of topics covered in Radiation Protection Technician Continuing Training (1995 and 1996)

List of training and professional meetings attended by radiation protection _ supervisors ariel professionals Cooper Nuclear Station Post-Outage (Rti-16) ALARA Report i ALARA committee meeting minutes for August 21 and October 4,1996 i

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i Hot Spot Reduction Plan

List of Problem Identification Reports (July 29,1996 to December 9,1996)

List of Active Radiological Controlled Area Work Permits I

List of Active Special Work Permits I i

1995 Radiation Protection Self Assessment i

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! l 1996 Radiation Protection Self Assessment l l

List of 1996 ALARA Job Packages  !

ALARA Job Packaaes 95-20, "lSI Program"

, 95-21, "MOV Program"

96-355, "RWCU-Pump B"- 96-362, " Steam Jet Air Ejector" Special Work Permits j

. 96-1005 96-1009

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Ouality Assurance Documents

Evaluation of the ALARA Program QE 9642 (QAD960326)(11/5-11/8/96)

Surveillance SC-402-05 - Control and Accountability of Radioactive Sources (9-19-96)

Surveillance SC-402-08- Control of Radiation and High Radiation Areas (9-13-96)

Surveillance SC-402-07- Whole body counting [ calibration] (9-5-96) l l

Surveillance SC-402-03 4 Surveying Materials for Release Off-site (10-15-96) l Surveillance SC-402-23- Radioactive Waste / Radioactive Materials Shipment (10-11-96)

QA/QC Activities Checklist - Transfer of HIC from the Low Level Storage to AOG Truck Bay (10-17-96)

Directives i

Nuclear Power Group Directive 4.12, " Work Prioritization," Revision 1 j

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l -3-Procedures 0.32 CNS ALARA Program, Revision 4 0.3 ALARA Organization and Management, Revision 10 0.3 ALARA Work Review, Revision 11 0.3 ALARA Reports, Revision 6 0.3 ALARA Job Files, Revision 4 l 0.3 ALARA Document Control, Revision 2 l 9.1. Radiation Work Permits, Revision 24

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