ML20236W124
| ML20236W124 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/31/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| 50-298-98-16, NUDOCS 9808050094 | |
| Download: ML20236W124 (4) | |
See also: IR 05000298/1998016
Text
_ - _ - _ _ _ _ _ _ - - _ _ - _ - _ - _ _ _ _ - _ _ _ _ _ _ _
__. - - - - - - _ - _ - _ _ _ _ _ _ _ _ - - -
._
_
-
- _ _
_ _ _ _
ourg
+
9,
UNITED STATES
8, .
$
NUCLEAR REGULATORY COMMISSION
5
rj
REGION IV
611 RYAN PLAZA DRIVE. SUITE 400
Q,
%, * * *ol,d,c
ARLINGTON. T EXAS 76011-8064
July 31,1998
G. R. Horn, Senior Vice President
of Energy Supply
Nebraska Public Power District
141415th Street
Columbus, Nebraska 68601
SUBJECT:
NRC INSPECTION REPORT 50-298/98-16
Dear Mr. Horn:
Thank you for your letter of July 21,1998, in response to the exercise weakness
identified in NRC :nspection Report 50-298/98-16, dated June 22,1998. We have reviewed
your reply and find it responsive to the concerns raised in our inspection report. We will review
the implementation of your corrective actions during a future inspection.
Sincerely,
Blaine Murray, Chief
Plant Support Branch
Division of Reactor Safety
Docket No.:
50-298
License No.: DPR-46
cc:
John R. McPhail, General Counsel
Nebraska Public Power District
P.O. Box 499
Columbus, Nebraska 68602-0499
'
J. H. Swailes, Vice President of
Nuclear Energy
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
9808050094 980731
ADOCK 05000298
G
,
_ - _ - _ _ .
_ _ _ - -_ - __-___ - . _
_ ___- _- .
.
.
Nebraska Public Power District
-2-
l
l
B. L. Houston, Nuclear Licensing
and Safety Manager
Nebraska Public Power District
P.O. Box 98
Brownville, Nebraska 68321
Dr. William D. Leech
MidAmerican Energy -
907 Walnut Street
P.O. Box 657
,
l
Des Moines, Iowa 50303-0657
,
ii. . Ron Stoddard
Lic. win Electric System -
l
1040 O Street
l
P.O. Box 80869
l
Lincoln, Nebraska 68501-0869
l
!
Randolph Wood, Director
j-
Nebraska Department of Environmental
i
Quality
P.O. Box 98922
Lincoln, Nebraska 68509-8922
[
Chairman
'
Nemaha County Board of Commissioners
Nemaha County Courthouse
'1824 N Street
!
Auburn, Nebraska 68305
i
Cheryl Rogers, LLRW Program Manager -
Environmental Protection Section
Nebraska Department of Health
301 Centennial Mall, South
!-
P.O. Box 95007
!
Lincoln, Nebraska 68509-5007
I
,
R. A. Kucera, Department Director
L
of Intergovemmental Cooperation
,
l
Department of Natural Resources
F.O. Box 176 -
L
Jefferson City, Missouri 65102
Kansas Radiation Control Program Director
l
l
l'
.
.
Nebraska Public Power District
-3-
DISTRIBUTION w/coov of licensee's letter dated July 21.1998:
DCD (IE35)
j
Regional Administrator
i
CNS Resident inspector
I
DRS Director
I
DRS Deputy Director
DRP Director
DRS-PSB
Branch Chief (DRP/C)
Branch Chief (DRP/TSS)
Project Engineer (DRP/C)
MIS System
RIV File
DRS Action item File (Goines)(98-G-0102)
!
I
i
,
,
i
DOCUMENT NAME: R:\\_CNS\\CN816AK.GMG
To receive copy of document, Indicate in box:"C" = Copy without enclosures "E" = Copy with enc!osures "N" = No copy
RIV:PSB
E
C:DRS\\PSB
!
GMGood:nh (#
BMurray
k)
1 ft /98
4 / 9/98
4
OFFICIAL RECORD COPY
_ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- _ _ _ _ _ _ _ - _ _ _ _ _ - - _ - _ _ _ - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _ _
_
_ - .
. _ _ _ - _ _ _ _ - _ _ _ _ _ _ _
_ _ _ _ _ _ - _ _ .
_
e
o'
Nebraska Public Power District
-3-
DISTRIBUTION w/coov of licensee's letter dated July 21.1998:
40C0 M "
Regional Administrator
CNS Resident inspector
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB
Branch Chief (DRP/C)
Branch Chief (DRP/TSS)
Project Engineer (DRP/C)
MIS System
' RIV File
DRS Action item File (Goines)(98-G-0102)
.
.
i
1
i
-
DOCUMENT NAME: R:\\_CNS\\CN816AK.GMG
'
To receive copy of document. Indicate in box:"c" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV:PSB
E
C:DRS\\PSB
GMGood:nh (#
BMurray
i)
'l /3 /98
q 49/98
i
OFFICIAL RECORD COPY
C's0UEG
-
.
.
..
..
P.O. BOX B
ILLE B ASKA 68321
Nebraska Public Power District
==ggg"
-.- _
NLS980106
July 21,1998
-
'
R27
l
U.S. Nuclear Regulatory Commission
!
Attention: Document Control Desk
!
'
Washington, D.C. 20555-0001
Gentlemen:
)
i
Subject:
Rep:y to an Exercise Weakness
l
NRC Inspection Report No. 50-298/98-16
Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
1. Letter to G. R. Horn (NPPD) from Blaine Murray (USNRC) dated June
22,1998, "NRC Inspection Report 50-298/98-16"
By letter dated June 22,1998 (Reference 1), the NRC reported the results of an emergency
i
preparedness inspection at Cooper Nuclear Station. One Exercise Weakness was identified in the
{
referenced report. This letter, including Attachment 1, constitutes the Nebraska Public Power
District's (District) reply to the identified Exercise Weakness. The District acknowledges the
Exercise Weakness and has initiated appropriate corrective actions as described in Attachment 1.
Should you have any questions concerning this matter, please contact me.
Sincerely,
0
h
L&
John i Swailes
Vice President of Nuclear Energy
,
/lrd
Attachment
'
cc: Regional Administrator w/ attachment
USNRC - Region IV
Senior Project Manager w/ attachment
USNRC - NRR Project Directorate IV-1
Senior Resident inspector w/ attachment
NPG Distribution w/ attachment
Nk
, e JEl-99-WM 7 a/-
,
. .
_
- -
xw
,
i
-
.
.
.-
- .'
!
Attachment I
to NLS980106
Page 1 of 5
l
REPLY TO IR 50-298/98-16, EXERCISE WEAKNESS
l
COOPER NUCLEAR STATION
!
i
NRC DOCKET NO. 50-298, LICENSE DPR-46
I
During NRC inspection acdvities conducted from June 8,1998 through June 11,1998, one
i
!
Exercise Weakness was identified. The particular weakness and the District's reply are set forth
l
below;
i
Exercise weane==
,
!
!
Radiological contamination controls were notproperly implemented in the TSC and OSC (the
twofacilities are collocated). Inspectors observed thefollowing sequence:
At 11 a.m., about 15 minutes after initial contamination controls were established
}
(personnel contamination monitor activation / riskerplacement nearby on thefloor), the
f
trouble light on the personnel contamination monitor illuminated, indicating the monitor
was out ofservice.
At about 12:10p.m., a team of three, including a radiationprotection technician, entered
the TSC/OSC without using the personnel monitoring equipment to checkfor
contamination.
At 12:15p.m., the TSC radiationprotection coordinator noted the condition of the
personnel contamination monitor but took no actions to either correct the monitor
..
problem or to inform the TSC/OSC staff of the need to use thefrisker.
Between approximately 12:15 and I p.m., at leastfive more workers bypassed the
personnel contamination monitoring equipment, andagain, at least one of thefive
workers was a radiation protection technician.
I
At 1:08p.m., the OSC supervisorfinally announced to the OSCpersonnel that the
personnel contamination monitor was out-of-service and that allpersonnel entering the
TSC/OSC were required to perform a manualfriskprior to entering the centers.
A contamination survey wasfinally conductedat 1:10p.m., after an OSC worker
informed radiation protection personnel that some people did not use the contamination
)
equipmentprior to entering the TSC/OSC. Inspectors questionedthe appropriateness of
the habitability surveyprocedure since only airborne andarea radiation readings were
initially specified, even after contamination controls were established outside the
TSC/OSCdoor.
_-__-_____ _ _____-__ - _- - __ _______ - _
[.
-
..
.
.i
(
Attachment 1
'
to NLS980106
Page 2 of .5
Between about 1:15 and 1:45p.m., three morepeople entered the TSC/OSC without
using the contamination monitoring equipment. One security officer noted thepersonnel
contamination monitor was cut-of-service andpagedradiationprotection, via
GAITRONICS, to get direction on how to enter the TSC/OSC. This action was
appropriate. Although the individualcontacted was nonparticipating in the exercise, the
response given was incorrect (the officer was told to bypass the contamination
monitoring equipment).
Thefailure to implement proper radiological contamination controls in the TSC and OSC was
~ identifiedas an exercise weakness due to the potentialdisruption to the response effort that
'
would have occurred if the TSC and OSCpersonnel andfacilities became contaminated (50-
2983 8016-01).
l
Root Cama of Exercise Wankness
!
The root cause of this weakness is the failure to appropriately communicate the requirements for
personnel contamination monitoring immediately prior to entering the Technical Support
Center / Operations Support Center (TSC/OSC) once contamination controls are established. A
significant contributor to this root cause was the use of unfamiliar postings, not normally used in
l
the plant, to indicate that the TSC/OSC entrance was a radiological boundary.
Evaluation of Soecific Attributes ofExercise Weakness
Although during the drill there were individuals who appropriately utilized contamination
monitoring equipment (frisker) and properly obeyed postings prior to entry to the TSC/OSC,
there were individuals whose performance in personnel monitoring was less than adequate. There
are several behavioral patterns attributed to the sequence of events as described above which led
to a weakness in contamination controls. This includes inappropriate assumptions, drill control,
and radworker practices.
At 1210, a team of personnel, including a Radiation Protection (PP) technician entered the
TSC/OSC without using personnel monitoring equipment. The personnel contamination monitor
(PCM) located at the entrance was out of service (as indicated by a trouble light), however a
frisker was located nearby on the floor. The team which entered did not see the frisker and
simulated using the PCM. The RP technician informed the TSC Chemistry / Radiation Protection
Coordinator (Chem /RP Coordinator) that a frisker was not available at the access to the
L
TSC/OSC and that the PCM had a trouble light. While responding to this concern, the Chem /RP
Coordinator discovered that a frisker was present at the entrance, but failed to follow up on the
potential spread of contamination in the facility. This was due to an inappropriate assumption that
l
since the team was told to simulate they could be considered free of contamination.
l
- _ _
_ - _ _ _ _ _ _ .
-_
__
- _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
Attachment I
to NLS980106
Page 3 of 5
Additional individuals were observed by the NRC to enter the TSC/OSC facility without
performing appropriate contamination monitoring. The postings which were established by RP
personnel to direct contamination monitoring were different than what is normally used in the
plant. This resulted in confusion for one individual; since the postings deviated from what is
normally encountered in training and in the plant, the individual exhibited less than adequate
radworker practices and lack of questioning attitude, and therefore inappropriately bypassed the
postings. Other individuals entered without frisking because they were instructed by the
controller to simulate frisking, which is inappropriate drill control in that simulation of
radiological monitoring does not promote the desired worker behaviors. A separate group of
individuals entered without frisking because they had monitored at the plant Radiological
Controlled Area (RCA) access point and inappropriately assumed that this met the intent of the
postings at the TSC/OSC entrance.
At 1308 the OSC supervisor announced the expectation that personnel perform manual frisks
prior to entry to the TSC or OSC due to the PCM being out of service. A contamination survey
was conducted at 1310, after an OSC worker informed RP personnel that some people were not
utilizing the contamination monitoring equipment prior to entry. The ins'pectors questioned'the
appropriateness of the habitability survey procedure since only airborne and area radiation
readings were initially specified, even after contamination controls were established outside the
i
TSC/OSC door. Based on this observation, a review of the habitability procedure (which is an
I
Emergency Preparedness Position Instruction Manual, or PIM) was conducted which revealed
that guidance for performing a survey ofloose surface contamination should be added.
Three additionalindividuals were observed to enter the facility between 1315 and 1345 without
i
using the contamination monitoring equipment. A security oflicer notified RP that the PCM was
'
out of service, however the security officer entered the facility without frisking based on
instructions given by the RP technician to bypass the monitoring equipment. The RP technician
who gave these instructions was not a participant in the drill, and consequently inar,propriately
assumed that the security oflicer would contact the OSC RP technicians. Upon being questioned
by the NRC, the oflicer was frisked and an RP technician was stationed at the crance to the
TSC/OSC.
l
The combination of these factors resulted in less than adequate controls over the potential spread
of contamination into the TSC/OSC, due to the failure of personnel to perform adequate
personnel contamination monitoring. This was determined to be a result of a failure to
communicate the requirement that personnel shall perform contamination monitoring at the
l
,
[
entrance to an Emergency Response Organization (ERO) facility, such as the TSC/OSC, once
l
l
contamination controls are established, regardless of postings used or if personnel monitored at
the RCA access point.
i
(
)
- _ __-__ -_
-__ _-_
_ _-
-
.
.
, .
.
,4
. Attachment I
to NLS980106
{
Page 4 of 5
i
,
A significant contributing factor was the use of unfamiliar equipment for the posting, in the form
of a step-off-pad (which was different from that normally encountered in the plant RCA or in
'
training). Postings are used as a method to communicate to plant personnel requirements for
entry into a particular location. In the plant RCA, step-off-pads clearly demarcate contaminated -
areas from " clean" areas in that they are divided in half, with one halfindicating " Contaminated"
and the other halfindicating " Clean." The step-off-pad which was utilized at the entrance to the
TSC/OSC was not of this form and simply provided instructions that personnel shall monitor prior
to entry, leading to the inappropriate assumption that the area prior to the TSC/OSC entrance was
" clean." In addition, yellow and magenta tape is typically used to clearly mark the radiological
boundaries; in the case of the TSC/OSC, a white chain was utilized,
i
Evaluation of Generic implications
The appropriate utilization of contamination monitors during routine operation, and
- contamination control at other Emergency Response Facilities was reviewed and no generic
concerns were identified.
A compatison of the requirements to enter the Emergency Operations Facility (EOF) versus the
TSC/OSC was performed and it was identified that monitoring controls at the EOF were
adequate. The security officers stationed at the TSC/OSC are posted inside the facility, however
the personnel monitoring equipment is outside the door and thus not within the line of sight of the
officers. The security officer stationed within the EOF is posted at the frisker for access control
issues and ensures personnel utilize the equipment prior to entry.
,
Corrective Manaures That Have 'Been Taken
f
'
1. The requirement for contamination monitoring during emergency response was reiterated with
RP personnel at a daily staff meeting.
l
2. A site-wide communication was sent to briefERO staff members on the requirements
regarding personnel contamination monitoring.
'
Improvement Actions That Have Been Taken
j
l
l'
Evaluated the adequacy of the PIM governing habitability survey requirements and provided
direction that habitability surveys should also include loose surface contamination, when
appropriate.
1
-
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - - - - _ _ _ _ - _ _ - - .
a
e:
.
,
- ..
Attachment 1
)
to NLS980106
Page 5 of 5
Improvement Actions That Will Be Taken
!
!
1. As a follow up to the site-wide communication, each ERO staff member shall review and
l
acknowledge understanding and awareness of the requirements for personnel contamination
monitoring.
2. Evaluate and appropriately enhance training for ERO staff regarding contamination control
1
requirements.
'
3. Revise the Chem /RP Coordinator PIM to provide guidance to inform the TSC/OSC when
(
contamination controls are implemented and the requirement to monitor prior to entering the
TSC/OSC.
)
)
.
4
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _
__
J
.
,
's
l
,
l
ATTACHMENT 3
LIST OF NRC COMMITMENTS
l
..
.
,
i
i
Correspondence No: NLS980106
'
The following table identifies those actions committed to by the District in this
document. Any other actions discussed in the submittal represent intended or
planned actions by the District. They are described to the NRC for the NRC's
j
i
information and are not regulatory commitments.
Please notify the )fL&S Manager at
Cooper Nuclear Station of any questions regarding this document or any associated
COMMITTED DATE
COMMITMENT
OR OUTAGE
As a follow up to the site-wide conununication, cach ERO staffmember shall review and
_
acknowledge understanding and awareness of the requirements for personnel
'
contamination monitonng.
Evaluate and appropriately enhance training for ERO stafIregarding contamination
0B/18/98
control requirements.
{
Revise the Chem /RP Coordinator PIM to provide guidance to inform the TSC/OSC when
contamination controls are implemented and the requirement to monitor prior to entering
08/18/98
the TSC/OSC.
I
l
l
PROCEDURE NUMBER 0.42
l_
REVISION NUMBER 6
l
PAGE 9 OF 13
l
1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _
_
)