IR 05000315/1979009
| ML17317B319 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/11/1979 |
| From: | Fisher W, Foster J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17317B318 | List: |
| References | |
| 50-315-79-09, 50-315-79-9, NUDOCS 7907180354 | |
| Download: ML17317B319 (16) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-315/79-09 Docket No. 50-315 License No. DPR-58 Licensee:
American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, NY 10004 Facility Name:
Donald C.
Cook Nuclear Plant, Unit
Investigation At:
Donald C.
Cook Site, Bridgman, Michigan Investigation Conducted:
January 9-10, 1979 Inspector:
M. C. Schumacher
.; >. n~~
Reviewed By:
C. E. Norelius, Assistant to the Director Fuel Facility Projects and Radiation Support Section Investi ation Summar Investi ation on Januar 9-10 1979 (Re ort No. 50-315/79-09)
Areas Ins ected:
Special, unannounced investigation of radioactive liquid release procedures and records; review of pertinent records, inspection of equipment, and interviews with personnel.
The inves-tigation involved 32 inspector-hours onsite by two NRC personne Results:
No items of noncompliance with NRC regulations were iden-tified.
No evidence to corroborate or deny the allegations could be developed.
However, worst-case analysis indicated that no limits would be exceeded if the allegation was confirmed'
INTRODUCTION The Donald C.
Cook Unit 1 Nuclear Power Plant, licensed to the Indiana and Michigan Electric Company, is located near Bridgman, Michigan.
The plant utilizes a pressurized water reactor (PWR)
designed by the Westinghouse Corporation, and began commercial operation in August, 1975.
During reactor operations, quantities of radioactive liquids and gases are accumulated and processed by the plant's radioactive waste systems.
Releases of radioactive liquids and gases are made at intervals.
REASON FOR INVESTIGATION On December 12, l978, Mr. Bruce Peek, of radio station WHFB, Benton Harbor, Michigan, contacted Mr. Ken Baker, resident NRC inspector for the Cook facility.
Mr. Peek indicated that he had information from a former plant operator who was concerned about technical specification violations and records falsification at the Cook plant.
On December 14, 1978, Mr. Peek provided the Resident Inspec-tor with the name and telephone number for individual "A", the former plant operator.
Individual "A" was contacted, and his con-cerns were discussed.
An NRC investigation was initiated into these concerns.
SUMMARY OF FACTS Individual "A" was contacted by the NRC Region III (RIII) Inves-tigation Specialist on December 14, 1978.
individual "A" indicated that he had been an auxiliary equipment operator at the Cook
plant, and his concerns related to releases of radioactive liquids from the plant.
He stated that he had been involved in two liquid releases from the plant during l977, where the length of time over which the release took place was altered by five to ten minutes so that release data would not show that a maximum release rate had been exceeded.
He indicated that these two releases had taken place from monitor tanks during periods 'when one plant recirculation pump was running.
Individual "A" indicated that he did not feel that plant management was aware of these time falsifications, as only the auxiliary equipment operators involved would be knowledgeable of the occurrences.
He stated that he could not recall any information as to the date of these releases or recall other individuals who participated in the release Region III personnel visited the Cook Unit 1 Site, inspected equip-ment utilized in controlling radioactive liquid releases, interviewed auxiliary operators, reviewed release procedures, individual release data, plant condition reports related to radioactive releases, computer trend records pertaining to release data, and held discus-sions with plant personnel.
Radioactive liquid release data for all liquid releases, both monitor and condensate storage tanks, conducted during 1977 while only one plant recirculation pump was running were reviewed.
It could not be determined which release had been referred to by individual "A".
Computer trend records for all monitor tank releases were reviewed, and appeared to substantiate release time periods reflected in other records.
This data was not conclusive, as radiation levels during releases were not high enough to be discernible from background levels, and the computer trend is normally stopped several minutes after a release.
Reviews of the radioactive waste log indicated identical times to those recorded on various release data sheets.
Interviews with auxiliary operators did not indicate that liquid release times were falsified,or that other auxiliary operators knew of such occurrences, It was found that several auxiliary operators believed that a violation of the maximum release rate (Station Procedures)
would automatically result in a violation of the Station Technical Specifications.
A review of station procedures, and calculations performed on selected releases indicated that Station Procedures are conservative, and releases could be performed at much higher release rates before approaching regulatory limits.
"Worst case" calculations were performed on several monitor tank releases, assuming slightly higher concentrations than recorded and assuming that release time was actually ten minutes less than that recorded.
In no case were technical specification limits approached.
Discussions with plant personnel indicated that actions were in progress to provide improved instrumentation for monitoring liquid releases and that consideration would be given to installation of a flow recording device.
RIII personnel were advised that relocation of a pressure reading device was planned which would greatly simplify release flow regulation.
4-
CONCLUSIONS l.
It was not possible to identify the releases mentioned by individual "A".
2.
No evidence could be developed to show release time falsification.
3.
"Worst-case" analysis of releases show no regulatory limits were approached, nor would they have been approached if the allegation made by individual "A" had been verifie DETAILS Personnel Contacted Indiana and Michi an Power Com any R.
S. Keith, Operations D. V. Shaller, Plant Manager L. K. Smith, Shift Operating Engineer J. F. Stietzel, QA Supervisor Individuals Individual "A"
~Sco e
This investigation focused on radioactive releases performed at the D.
C.
Cook Unit 1 plant during 1977.
Emphasis was placed on releases performed while one circulation pump was in operation, with particular attention to monitor tank releases.
Introduction On December 12, 1978, Mr. Bruce Peek, of radio station WHFB, Benton Harbor, contacted the Resident Inspector for the Cook facility.
During the conversation, Mr. Peek indicated that he had been contacted by an ex-operator from the plant who had concerns regarding falsified records at the facility and tech-
.
nical specification violations.
The resident inspector provided Mr. Peek with information regarding known plant releases.
On December 14, 1978, Mr. Peek provided the Resident Inspector upwith a phone number and the name of the indivi.'dual who had concerns related to radioactive liquid releases.
This information was provided to the Region III office.
Contact with Individual "A" Individual "A" was contacted on December 14, 1978, and again on January 6, 1979.
He indicated that he had worked at the D.
C.
Cook Unit 1 as an auxiliary equipment operator during the period of March 1977 to August 1978.
He indicated that during his employment at the Cook plant he had participated in various liquid releases to the lake.
Individual "A" stated that on two occasions during 1977 when the plant was functioning
with one circulating water pump running radioactive liquid releases were performed more rapidly than allowed by the plant specifications.
He indicated that this had been recognized by the auxiliary equipment operators participating in the two releases, and release data sheets had been'hanged to reflect longer release periods thereby lowering the release rate to within plant specifications.
He indicated that this time falsification was approximately five to ten minutes, but was not able to identify either the date of the two releases,'nor the other personnel who had participated in them.
During the second contact, individual "A" stated that the release had taken place from a monitor tank, and that it had to be in the latter part of the year, as the weather had been cold.
He indicated that he had worked on the "D" shift and the release should have taken place during the time that shift was in operation.
Individual "A" was unable to provide any other identifying information concerning the release, the tank released, date of release, or participants in the release.
He indicated that it was possible his initials might be on the valve line-up sheets for these particular releases but he was not certain of this information.
Review of Procedures Prior to performing a site investigation, Region III personnel reviewed D.
C.
Co'ok procedures for liquid waste releases.
These procedures require a sampling of the tank to be released, calculation of concentration of radioactive material, and additional calculations to determine the maximum discharge flow rate which can be accomplished within the plant specifications.
It was found that maximum flow rates for liquid waste discharges depend on the type of tank discharged at the D.
CD Cook plant, with a maximum flow rate of twenty seven gallons per minute for condensate waste tank, and a 150 gallon per minute limit for a monitor waste tank release.
These two flow rates are specified as maximum flow rates in the plant release procedure, although flow rate could be of a higher or lesser rate depending upon the concentrations in the liquids to be released and dilution flow at the time.
Both of the two procedures were intended to provide conservative release rates for radioactive liquids, so that no regulatory limits would be approached during these release Review of Release Data The D.
C.
Cook Unit I Resident Inspector provided the Investiga-tion Specialist with liquid release data sheets for those releases during calendar year 1977 where one circulating pump had been in operation.
It was found that 31 such releases had taken place and were concentrated in six months of calendar year 1977.
Information on the data sheets was used to calculate the gallons released, maximum release rate, actual gallons per minute released and notations were made on what type of release was accomplished.
From this information it was noted that releases generally took place within the plant specifications of either 27 or 150 gallons per minute maximum depending upon on the type of waste tank released.
However, it was noted that in several cases release rates had been slightly higher than these rates (2-5 gpm).
Visit to D.
C.
Cook Unit 1 During January 9-10, 1979, Region III personnel visited the D.
C.
Cook Unit 1 site.
During this visit records related to radioactive liquid releases were reviewed, equipment was inspected, and interviews were held with auxiliary operators who had participated in liquid releases.
Ins ection of E ui ment Region III personnel toured the area where valves and monitoring equipment utilized for radioactive releases are located.
During this tour the procedures followed in performing a radio-active release were explained by auxiliary operating personnel, and various flow rates for the systems involved were described.
During discussions with auxiliary operating personnel concerning the operation of equipment, Region III personnel were provided with plant flow diagrams which indicate that the maximum gallon per minute rating of the waste evaporator condensate tank pumps is twenty gallons per minute, and the maximum rating for the monitor tank pumps is 150 gallons per minute. It was noted that release rates in excess of these amounts are possible, due to the positive head pressure on these pumps.
It was noted that the maximum rating for the meter formerly utilized to monitor condensate waste tanks was 27 gallons per minute.
This maximum figure on the monitoring instrument apparently had been used to set the maximum release rate for the facility (site procedure).
Flowrates are presently monitored by a differential pressure orifice (flowrate is calculated from a chart).
- 8-
Review of Records Region III personnel reviewed radioactive release data sheets for waste condensate and monitor tank releases which had taken place during 1977 while one circulation pump was running, and compared this information with data contained in the radioactive waste log.
In addition, information contained on digital computer trends performed while monitor tanks were being released was reviewed in an attempt to determine if discharge times indicated on release data sheets were correct.
Information contained on the release data sheets both for condensate tank and monitor releases was found to be corroborated by notes in the radioactive liquid waste log, and information contained in the computer digital trend analysis performed while monitor tanks were being released appeared to substantiate release time information contained on the release data sheets.
However, this information was not totally conclusive in that the computer digital trend showed basically background level radiation, and is normally terminated several minutes after a
release has been terminated.
All of the data sheets and logs reviewed were examined to see if changes had been made in the recorded times.
Only one such change was noted and it appeared to be substantiated by information contained in the radioactive waste log and computer digital trend analysis.
No information could be developed from the record review to indicate that any of the site records had been falsified regarding liquid waste release times.
Interviews of Auxilia E ui ment erators On January 10, 1979, Region III personnel interviewed several auxiliary equipment operators at the D.
C.
Cook Unit 1 plant who had participated in liquid releases.
None of the individuals interviewed indicated that they had participated in nor heard of any falsification regarding liquid waste release data.
The auxiliary operators interviewed indicated that they had not performed a waste condensate tank release for some time, present practice being to use the monitor tanks, which had a larger volume, and could release wastes at a higher flow rate, reducing auxiliary operator monitoring time.
Operators interviewed indicated that the monitoring equipment alarms at 10$ of remaining tank volume and that shortly there-after the pump will trip due to lack of fluid to pump.
This time would then be noted on the radioactive waste log sheet.
Auxiliary operators indicated that they were not aware of any
- 9-
pressure on them or motivation for falsifying release times, but indicated a belief that violation of the plant maximum release rate specifications would result in a violation of the facility Technical Specifications.
Auxiliary operators also noted that in some cases they had to adjust valves during releases in order to prevent facility maximum flow rates from being exceeded.
They again indicated they felt that exceeding of the facility procedure flow rate would result in a technical specification violation and that as such they might be criticized by plant management when such release rates were exceeded.
Review of Condition Re orts During the investigation Region III personnel reviewed Condi-tion Reports, (nonconformance reports) related to liquid waste releases.
It was found that two Condition Reports had been generated regarding release of radioactive liquids from conden-sate tanks at rates higher than the plant procedures allowed.
One release had taken place on April 9, 1977 (46 gallons per minute),
and the other release had taken place on January 14, 1977 (30.5 gallons per minute).
No NRC limits had been exceeded during these releases.
It was noted that if the time span for the January release was increased by five minutes, the release rate would have been 27 gallons per minute.
No such time change had been made, however.
See Exhibit I.
Mana ement Discussion and Exit Interview On January 10, 1979, Region III personnel discussed the find-ings of the investigation with plant management personnel, and performed an exit interview.
Region III personnel indicated they had found no evidence to substantiate the allegations concerning falsified liquid release times, but indicated concern that the licensee relied wholly upon release time information supplied by auxiliary equipment operators.
Concern was also expressed that the monitoring devices used to indicate flow rates for liquid releases appeared somewhat cumbersome, requiring calculations to be performed to determine actual flow rate in some cases.
Licensee personnel indicated that improvement of monitoring for liquid release flow rates had been under consideration for some time, and that equipment to improve the precision of flow rate measurement had been on order and was expected to be installed-10-
in the near future.
Licensee personnel indicated that they would take under consideration installing recording devices which would indicate the liquid release rate and time frames of liquid releases to provide documentation of flow rates.
13.
Contact with Individual "A" On January 14, 1979, Individual "A" was contacted by the Region III Investigation Specialist.
The results of the investigation were discussed in detail.
Individual "A" again indicated that he believed that the liquid release which he had participated in (with the alleged adjusted time frame)
was a monitor tank but he was not entirely certain, and indicated that it could have been a waste condensate tank release.
Individual "A" was advised that releases for both types of tanks had been reviewed during the investigation effort.
Individual "A" stated that he had read newspaper articles which dealt with his concerns and felt that he had been misquoted on several occasions by the news media.
Individual "A" stated he felt that even though Region III had not been able to substan-tiate his allegations, the effort had been worthwhile in direct-ing the licensee's attention to an area which individual "A" felt required additional attention.
Attachment:
Exhibit I
g, gh C'.
le lA6
~rxut.cuuxc r -OHP 4021.022.007 ATI'ACHMENT NO.
RELEASE OF RADIOACTIVE LIOUIDS RELEASE NO.
L 7 7 2. C 1.
DATE
/
O The lorth South Maste Eva rator Condensate Tank recirculating for hours.
The tank FORWARD TO CHEMICAL SECTION.
O7 S
contains Hrs.
- al<ons and has been AW OE/
<J3Z. (
i~eady for sampling~rior to relea e.
2.
The South Waste Evaporator Condensate Tank has been sampled and may be released at a maximum flow rate of pm with 230,000 npm minimum dilution flow......
This Release is in compliance with Environmental Technical Specifications 2.4.1 a, b and c andxpe~
ave, Table 2.4-1 and the release is approved.
(RRC-285 (R-18) alarm/trip setpointZBQpcpm. /3 g c p~
l A,&O~<
/%5 Qkcj N
The Release is not approved.
Reason:
RADIATIOH PR C
N If not approved by Radiation Protection,
/
APPROVED P
G
- his Release must be completed within 24 FORWARD TO SOE.
DATE approval og the DATE hours. fre+ntime of approval.
TIME Hour s Hours TIME Plant Manager is required prior to relea 3.
DATE TIME E ~Hours hours on to ~/~/
hours on Humber of Circulating Mater Punps in operation during this release was Dilution Flow Rate Z~0 8CrO pm
~gpm Total Dilution 3500 al Final Tank Volume gal<<
Initial Tank Volume 3 Z.
al*
gal I
L cc Discharge Path c
C.o 072. Vn <
~one/
Release Flow Rate Total Release Permission is hereby granted to telease the contents of the or t South Waste Evaporator Condensate Tank at or below the flow rate specified below.
An independent verification of the valve lineup for this release has been made.
DF, Dilution Flow from Section
CWF Operating Circulating Mater P~ps X 230,000 GPM
<<NOTE-Subtract 1/2 pump if one half of a-FR
~ Release Flow Rate from Section
condense~
is valve out.
J FRma~ Maximum Release Flow Rate
+~x FR< - ~ Zzoopox 2
-~2<<<<
S ORIGINAL TO MASTER FILE COPY TO RADIATION PROTECTION
<<From approved tank volume curve.
a-8'
OPERA< IONS DEPARTM Exhibit I page 1 of 2 Page I of 2 Rev. 4 <<7/4/lF"-
~PROCEDURE 1-OHP 4021.022.007 ATTACHMENT 1 RELEASE OF RADIOACTIVE LIOUIDS RELEASE HO. L 7 7 -
2('ppendix B, Technical Specification 2.4.2.b requires actual analysis prior to release.
ISOTOPE I131 Cs137 Cs134 Coso Cosa Crs1 l@s4 Znss COHCENTRATION
>ms
Ob K-lo
.S'.l
.O'I
&.
MCP 3xl0 ~
2xl0 s gx10 s
3xlo"s gxl0 s 2xl0 3 lx10 "
lx10 4 NCP ISOTOPE H3 Gross o Gross B
CNCN N
Ci/ml 2 )3g
'2 ~ I (.5 P.7 3xl0 Boron Concentration Submitted By ppm.
All significant gaama peaks have been identified and quantified.
This release is in compliance with Section 2.2 and 2.4.2.b 5 c of the Environmental Technical Specifications and 3 may ee released at a msfrom flmr rate of~fpm mite
< lo gpm minimum dilution flow.
APPROVED BY NOT APPROVED BY o
TDIEJ'3 JJ Hrs.
TIME Mrs Ci I
~lie /7 ~ls RELEASE NOT APPROVED.
REASON:
~lss f
<<.: ~ls s'aximum Release Flow
+ l
~
pm Minimum Dilution Flow 0.01 x" MPX x Release Flow
~3 0 8CDO pm.
Estimated reIease activity *
. 4
k t 0 Activity release last quarter * ae CoC RELEASE APPROVED
~p-RADI ON PROTECTIOll RADIAT sl PROT CT ON
+ Excluding tritium and dissolved gasses.
TIME Hrs (.
Exhibit I page 2 of 2 Page 2 of 2 August 26, 1976