IR 05000298/1998018

Insp Rept 50-298/98-18 on 980518-21 & 0608-11.No Violations Noted.Major Areas Inspected:Reviewed Radiation Protection Activities Including Exposure Controls,Controls of Radioactive Matls & Contamination

ML20236H092
Person / Time
Site:	Cooper
Issue date:	06/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236H075	List: IR 05000298/1998018 ML20236H072
References
50-298-98-18, NUDOCS 9807070082
Download: ML20236H092 (12)

Text

- _ . __- _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ - - _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ - _ _ _ _

.

.

ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-298 License No.: DPR 46 Report No.: 50-298/98-18 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: P.O. Box 98 Brownville, Nebraska Dates: May 18-21 and June 8-11,1998 Inspector (s): Larry Ricketson, P E., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety .

Attachment: Supplemental Information

l L

9907070082 990630 PDR P

O ADOCK 05000298 i

[: PDR

- _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ J

-____ - _ _ _ - - _ - - _ _ - __ _ - __ - _ _ _ - _ - _ _ - _ _ . .__- - -

-

.

.

-2-

%

EXECUTIVE SUMMARY

,

_ Cooper Nuclear Station

NRC Inspection Report 50-298/98-18 This routine, announced inspection reviewed radiation protection activities, included in the inspection were. reviews of exposure controls, controls of radioactive materials and .

contamination, surveying and monitoring, the program to maintain occupational exposures as low as is reasonably achievable (ALARA), procedures and documentation, training and qualifications, and quality assurance in radiation protection activitie q Plant Support

.- - Overall,. the radiation protection organization performed well. Improvements were noted in some aspects of the progra :. Good exposure controls were implemented. Radiation protection personnel took

. appropriate corrective actions in response to 'a respiratory protection equipment problem

.  : (Section R1.1).-

.  : Controls placed on radioactive materials and contamination were effective; however, a high number of personnel contamination alarms (17,000 in 1997) were recorded. The

licensee was evaluating altemate radiation detection instrumentation to address the situation so that radiation workers did not become desensitized to the alarms (Section R1.2)?

. The Al. ARA program produced excellent results. The 1995-1997 person-rem average

- was the fourth best boiling water reactor average, nationally (Section R1.3).

.- . New procedures provided enhanced guidance. Corrective actions for documentation problems were generally effective (Section R3).

. The licensee increased the level of expertise in both the radiation protection professional

,

staff and the radiation protection technician staff. The amount of continuing training

provided to radiation protection technicians in 1997 was low, but the amount provided or scheduled improved in 1998. Good training opportunities were provided to radiation

- protechon professionals (Section RS).

i:

. - The radiation protebtion organization identified problems wit'h the completeness,.

,"', - correctness, and retrievability of its documentation and records. Corrective actions were implemented to address the problems (Section R3). .

.. The 1998 quality assurance audit and the 1997 radiation protection self-assessment-were goo dexampes l o crf t ii ca rev l ews i t ah t demonstrated good management oversigh These reviews made good use of industry peers to identify problems and potential areas of improvement (Section R7).

< .

'1

-)

,

.-

_ - __ ____ __ _- - ____ _ _ _ _ _ - ..

.

..

-3-Report Details IV. Plant Suonort R1 Radiological Protection and Chemistry Controls R1.1. Exoosure Controls Insoection Scooe (83750)

The inspector interviewed radiation protection personnel and reviewed the following:

-

Control of high radiation areas

-

High radiation area key control

-

Radiological area posting

- Radiation work permits

-

Access controls

-

' Dosimetry use

- Dosimetry records

.

Whole-body counting and skin dose measurements

- Respiratory protection Observations and Findinas T he inspector observed radiation workers entering the radiological controlled area and determined that access controls were easy for workers to understand and use and the access controls functioned correctl During tours of the radiological controlled area, the inspector reviewed radiological area postings and controls of locked high radiation areas. No problems were identified. A review of problem identification reports confirmed that the licensee had not identified problems with locked high radiation area controls. The inspector conducted an inventory of the keys used to controllocked high radiation areas and verified that the licensee could account for all keys.

'

A vendor processed dosimetry for the licensee. This was not a change to the program; however, the licensee changed vendors since the previous NRC review of this area. The new vendor was accredited by the National Voluntary Laboratory Accreditation Program in all categories. The new vendor was audited as part of the licensee's vendor audit program.

The licensee changed the interval at which the thermoluminescent dosimeters were submitted to the vendor for processing. Instead of quarterly, the licensee submitted

'

dosimeters for processing every six months. The inspector reviewed the licensee's justification and change process and concluded there were no regulatory discrepancies involved with the change. The licensee's justification included information from the i

r

, '

I I_

'

_ _ _

- - _ _ _ _ . _ _ _ _ _ - _ _ _ - _ _ _ - _

.

a 1-4-vendor stating that additional thermoluminescent dosimeter fading was addressed in the dose algorith During the first week of the inspection, the licensee's whole-body counter was inoperable because it was damaged by a lightening strike. As a contingency for an emergency, the

licensee arranged for the use of the whole-body counting facilities at Fort Calhoun '

Station. The whole-body counter was operable during the second week of the inspection. The inspector reviewed calibration records and noted that the whole-body )

counter was calibrated annually.- No problems related to the whole-body counter calibration process or the licensee compensatory actions were identifie The inspector selected examples of personnel contamination event records and i confirmed that skin dose calculations were performed when procedural criteria were met

!

or exceeded. Skin dose calculations were conducted in accordance with the protocol established in licensee's procedures, and the results were recorded property in the appropriate radiation worker dosimetry record >

Radiation protection representatives found defects in the breathing tubes used on their belt-mounted regulator type self-contained breathing apparatus. One step of the manufacturer's " Breathing Tube inspection Instruction," instructed the user to " stretch the breathing tube 10-12 inches beyond its normal length.. " When the licensee j exceeded this recommendation by a small amount, the breathing tube separated at the corrugations. The licensee determined that this could represent a problem if the wearer snagged the breathing hose. The licensee had approximately 25 breathing tubes of an older-style in storage. Licensee representatives stated that the older-style breathing tube ,

did not seem to be susceptible to the same sort of problem. Licensee representatives j used the spares immediately as replacements on units staged for potential use by control room operators or fire responders; contacted the manufacturer about the problem; borrowed examples of the older style breathing hose from another licensee to repair the remaining units; and put information concerning the problem on a nuclear utility internet web sit Conclusions Good exposure controls were implemented. Radiation protection personnel took appropriate corrective actions in response to a respiratory protection equipment proble j

' R1.2 ' Control of Radioactive Material and Contamination: Surveyina and Monitorina

. , insoection Scone (83750)

The inspector interviewed radiation protection personnel and reviewed the following:

(

• Source accountability L

• Source leak testing

! *

Personnel contamination events

• Portable survey instrument calibration i I-i

,

'

L

.

.

-5-b. : Observations and Findinas The' inspector reviewed radioactive source inventory records and confirmed that u . inventories were performed at the interval required by the licensee's procedure. The L

inspector selected _ examples of radioactive sources from the.most recent inventcry record and, with the aid of a radiation protection technician; verified that the sources were stored in the locations indicated on the inventory record.. The inspector also -

confirmed that selected radioactive sources were tested for leakage, as required.

i:

~

The inspector observed radiation protection technicians as they conducted radiation surveys prior to the unconditional release of items from the radiological controlled area and identified no problems. To verify that radioactive material had not been released from the radiological controlled area, the inspector accompanied a radiation protection f- technician who conducted radiation surveys with a gamma scintillation instrument in a warehouse, the cold tool room, the instruments and controls shop, and the electrical maintenance shops. l No uncontrolled radioactive material was identified.

.

.

!' ' The inspector reviewed radiation survey records and recorded the identification numbers

, of the instruments used to perform the surveys. The inspector then verified that the p r

^

- radiation survey instruments were within the allowed calibration interval. The inspector and a radiation protection representative checked selected emergency response kits and confirmed that radiation detection instruments were within the allowed calibration interval.

[ ' The inspector reviewed personnel contamination log entries and noted that the licensee recorded more than 17,000 contamination entries in 1997. When asked about this larga

~

j

'

~ number of entries, licensee representatives stated that all personnel contamination alarms were recorded, and a large percentage of the events were caused by radon ga The inspector expressed a concern that workers and radiation protection personnel would become insensitive to personnel contamination alarms because of the high

,

number of occurrences.- Licensee representatives acknowledged the comment and stated that they were evaluating the use of radiation detection instrumentation that could be used to confirm that alarms were caused by radon progen ' Conclusions Controls placed on radioactive materials and contamination were effective; however, a L ! high number of personnel contamination alarms (17,000 in 1997) were recorded. The licensee was evaluating alternate radiation detection instrumentation to address the situation so that radiation workers did not become desensitized to the alarms L

Li ^

I

'

l

!

^

!

_ - _ _ __ _ _ _

.

.

-6-R1.3 ALARA Insoection Scoce (83750)

-

Person-rem totals

'

- Annual ALARA reports

-

ALARA committee activities -

-

ALARA initiatives 1

-

Source term reduction programs

- Hot spot tracking and removal results

-

ALARA post job reviews Lessons learned

-

-

l l Observations and Findinos The licensee's person-rem totals for 1995-1997 are listed belo :

TOTAL RADIATION EXPOSURE (in Person-rems)

1995 1996 1997

]

Site Total 228 47 174 3-Year Average 233 118 150

National BWR 327 256 Not available Average The licensee's three-year average for 1994-1996 was the lowest of any boiling water reactor in the country. With the inclusion of the 1997 refueling outage, the licensee's 1995-1997 three-year average was the fourth lowest average for boiling water reactor The ALARA committee met management expectations for meeting frequency and addressed issues, as outlined by procedural requirements. Support, as indicated by meeting attendance, was generally good by all department The ALARA suggestion program was very successfulin garnering input from radiation workers. The suggestion program received more than 80 suggestions in 1997, an outage year, and 29 in 1998, thus far. The inspector reviewed examples of the suggestions and confirmed that they were properly reviewed and evaluated for viabilit The licensee had been successful in reducing the number of drip catches in the plant. At j the time of the inspection, only five drip catches were in us The stell;te removal program was implemented only when components were scheduled for replacement. A replacement component with non-stellite material was used if t-----_ _ _ _ _ _ _ _ _ _

-7-evaluation results indicated that a component with such material was acceptable for its l particular function.

l The inspector reviewed a list of 1997 refueling outage work activities and confirmed that post-job reviews were conducted to identify lessons learned and the reasons for dose overruns, where applicable. Lessons leamed were clearly identified for future referenc Conclusions The ALARA program produced excellent results. The 1995-1997 person-rem average was the fourth best boiling water reactor average, nationall R3 Radiological Protection and Chemistry Procedures and Documentation Insoection Scoce (83750)

A major project to rewrite the radiation protection procedures was in progress. The inspector reviewed the procedures listed in the attachment to this repor Observations and Findinas All replacement procedures had not been issued at the time of the inspection, and the inspector identified examples in which procedures referenced other procedures that had been discontinued. For example, Procedure 9.2.4, " Surveying Materials for Release Off-Site," Revision 10, referenced the release limits in Procedure 9.1.3. Procedure 9. was discontinued; Procedure 9.2.4 was yet to be revised or replaced and was still in effect. When asked how the licensee handled such a situation, radiation protection representatives supplied the inspector with a procedure cross reference that linked the old and new procedures. In the example, Procedure 9.1.3 was replaced by Procedure 9.RADOPS.2, " Radiation Safety Standards and Limits." Procedure 9.2.4 would soon be replaced by 9.RADOPS.4, " Radiation and Contamination Surveys." The inspector concluded the licensee use of a cross reference list was a suitable short-term measure to eliminate confusion related to procedural references. After reviewing selected examples of old and new procedures the inspector concluded that the new procedures were an improvement over the old guidanc The radiation protection organization identified what it termed a generic problem involving documentation. Radiation protection representatives found errors in respirator evaluations, radiation protection log books incorrectly stored, incomplete records, and failures to perform timely reviews. The problem was described in Condition Averse to Quality - 98-0092. The inspector reviewed the licensee's ongoing corrective and determined that they were generally effectiv Conclusions l

New procedures provided enhanced guidance. Corrective actions for documentation problems were generally effectiv _ _ _ _ _ _ _ _ _ _ _ _ _ _ 1

.

.

-8-l

! R5 Staff Training and Qualification Insoection Scooe (83750)

The inspector interviewed the technical training supervisor and a radiation protection technician instructor and reviewed the following:

.

Radiation protection technician continuing training topics

.

Training for radiation protection supervisors and professionals

. Personnel qualifications Observations and Findinos All radiation protection supervisory personnel, between the level of radiation protection manager and crew lead technician, held bachelor of science degrees. One individual, in the radiation protection organization, was certified by the American Board of Health Physicists. Twenty-two of 39 people in the radiation protection operations, support, dosimetry, and technical groups were registered by the National Registry of Radiation Protection Technologist The inspector determined through interviews that supervisors and professionals had been provided with good training caportunities. These were most often professional meetings, peer visits, or peer review Conclusions The licensee increased the level of expertise in both the radiation protection professional staff and the radiation protection technician staff, Good training opportunities were provided to radiation protection professionals R6 Radiological Protection and Chemistry Organization and Administration The radiation protection organization and the chemistry organization were under the supervision of the radiological manager. There were 58 authorized staffing positions. All positions were not filled at the time of inspection. This was approximately equal to the number of staffing positions held during the previous assessment period (January 12, 1997, to July 11,1998) with the exception of the addition of personnel in the Nuclear Environmental / Industrial Safety group. The addition of environmental specialists and safety specialists to the organization was made since the previous review of the radiation protection program. Radiation protection representatives estimated that staffing tumover within the radiation protection organization was approximately 20 percent during the assessment period. However, almost all the individuals leaving the radiation protection organization assumed other staffing positions offered by the licensee. When this was !

considered, tumover was less than 10 percent. The radiation protection manager stated !

that individuals leaving the radiation protection organization were replaced with experienced individuals, resulting in little net loss of radiation protection experienc _ _ _ _ _ _ _ _ _ _ _

.

.

. R7 Quality Assurance in Radiological Protection and Chemistry Activities insoection Scoce (83750)

-

Audits

-

Surveillar.ces

Corrective action documents

-

Internal assessments b. Observations and Findings The 1998 quality assurance audit team included a technical specialist from another nuclear power facility as well as a radiation protection training specialist. The inspector concluded the audit was a critical review of radiation protection activities identifying program weaknesses, concerns, and potential improvement areas. The audit team concluded that the radiation protection program was effective, overall. The radiation protection organization addressed the audit findings promptl A noteworthy self-assessment was conducted December 8-11,1997. The assessment team consisted of four technical specialists from other nuclear power sites, and the

} assessment was coordinated by a licensee senior staff health physicist. The scope of the assessment included many radiation protection functions and processes. The findings were documented in the Problem identification Report system and the enhancements were tracked in the Continuous Improvement Program. The inspector reviewed selected actions taken by the radiation protection organization in response to the assessment findings and concluded the actions were appropriate to address the finding Conclusions The 1998 quality assurance audit and the 1997 radiation protection self-assessment were good examples of critical reviews that demonstrated good management oversigh These reviews made good use of industry peers to identify problems and potential areas of improvement R8 Miscellaneous RP&C issues 8.1 (Closed) Violation 50-298/9615-01: Failure to follow radiological orocedures Specifically, the failures involved failuret, of workers to always wear electronic, alarming '

dosimeters into the radiological controlled area and failures to remove respirator canisters from use at the end of their three-year shelf life, as required by procedure .

The inspector verified the corrective actions described in the licensee's response letter, dated September 23,1996, were implemented. No similar problems were identifie l

_ - _ _ _ _ __

_ _ _ _ - - _ _ _ _ _ _ - _ - - _ - _ _ _ _ _ _ _ - _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ - _ _

.

-10-V. Management Meetings

~

X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting'on June 11,1998. The licensee' acknowledged the findings presente No proprietary information was identified.'

l

,

i I

i f

f

..

_ . _ _ _ - _ _-__m _-

- .. __-_-___ - - _ - - _ - _ - _ _ _ _ - - _ _ - - _ _ _ _ _ _ _ - _ _ - _ _ ___ _____-_

'

l i

E. :

ATTACHMENT

, . . j PARTIAL LIST OF PERSONS CONTACTED j ucemann-R. Beilke, Senior Staff Health Physicist '

S. Blitchington, ALARA Supervisor, Radiological Department T. Chard, Assistant Radiation Protection Manager, Radiological Department

- J. Dixon, Radiological Operations Crew Leader -

J. Geyer, Senior Staff Health Physicists

{

M. Hale, Radiation Protection Manager, Radiological Department i B. Houston, Manager, Nuclear Licensing and Safety Department '

!

D. Kimball, Radiological Operations Supervisor j D. Jones, Decontamination Crewleader, Radiological Department  !

L. Lockard, Chemistry Supervisor, Radiological Department l M. Peckham, Plant Manager l J. Swailes, Vice President . i K. Tanner, Radiological Cperations Crew Leader  !

C. Weers, Radiological Support Supervisor, Radiological Department-  !

J. White, instrumentation Specialist  !

NBC M. Miller, Senior Resident inspector B. Murray, Chief, Plant Support Branch, Region IV j C. Skinner, Resident inspector j i

l lNSPECTION PROCEDURES USED I i

83750 Occupational Raciation Exposure l

ITEMS OPENED. CLOSED. AND DISCUSSED  !

!

Opened  ;

None

Closed l

'50-298/9615-01 , VIO Failure to follow procedure l Discussed None

l

\

l'

I

,

-_- - - - - - . - - - - _ - _ - - - - - - _ - - -

.

l:;n ib

l~ LIST OF DOCUMENTS REVIEWED

-

. Procedures

l Control and Retention of Records, Revision 28 i. 7

,

0.ALARA.1-'

CNS ALARA Program, Revision 0

'

0.ALARA.2 : ALARA Organization and Management, Revision 0 L 0.ALAR ALARA Work Review, Revision 0

- 0.ALARA.4 '. ALARA Reports, Revision 0 t ..,. 0.ALAR ALARA Job Files, Revision 0 L 0.ALAR ALARA Document Control, Revision 0

,

- 9.ALARA.3 ' in-vitro and in-vivo Bioassays, Revision 0 L 9.ALARA.4 ' Radiation Work Permit, Revision 0 9.RADO Radiation Protection at CNS, Revision 0

'

- 9.RADOP.2 Radiation Safety Standards and Limits, Revision 0 9.RADOP 3 - Area Posting and Access Control, Revision 0 x

9.RADOP,5 Airborne Radioactivity Sampling, Revision 0 '

9.RADOP.10 ' Radioactive Sources Control and Accountability, Revision 0 9. RES Respiratory Protection Program, Revision 0 9.1.1 3 Personnel Dcisimetry Program, Revision 42 9.1.6 - Personnel Contamination, Revision 2 /9. . Calibration of the Canberra Whole-body Counter, Revision 0 1 ' 9.2.4 : Surveying Material for Release Off-site Revision 10 9.3.1.5.2' Eberline Model ASP-1 with Model NRD Neutron Detector, Revision 5

. ,

Audds and Assessments

/ . Audit No. 98-07, Radiological Controls (April 7-21,1998)

1997 Cooper Nuclear Station Radiation Protection Self Assessment

, ,

I 'y'_

l <

s i

._

.