IR 05000315/1981007
| ML17326A911 | |
| Person / Time | |
|---|---|
| Site: | 02700010, Cook |
| Issue date: | 03/24/1981 |
| From: | Book H, Pang J, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17326A910 | List: |
| References | |
| 50-315-81-07, 50-315-81-7, 50-316-81-11, NUDOCS 8107210243 | |
| Download: ML17326A911 (20) | |
Text
U. S.
NUCLEAR REGULATORY CO'MISS IOtt
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OFFICE OF INSPECTIOli AND ENFORCE."K'.iT REC ION III Report No. 50-315/81-07'0-316/81-11 Docket Ho ~ 50 315; 0-316 Lic e ns e Ho. DPR-58'PR-74 Safeguards Group Licensee:
American Electric Power Service 2 Broadwa New York, NY 10004 Fac fIfty fame D. C.
Cool; 'Nuclear Power Plant Inspection at: Beatty, Nevada Inspection conducted:
February 23, 1981 Inspectors:
J.
F. Pano, Radiation Specialist Date Signed R.
D. Thomas, Chief t/aterials Radiation Protection Section D te Signed Date Si ned Approved By:
Date Signed H. E. Book, Chief Radiological Safety Branch Su~ ry:
Inspection on Februar
1981 Re ort No.
5o-315/81-07 50-316/81-11)
This inspection was conducted at V. S. Ecology, Inc., Beatty, Nevada to observe low level waste shipments.
Shipping documents, vehicle placarding, packaging, labels and radiation levels were inspected.
As part of the inspection conducted on February 23, 1981, the inspection of the shipping papers and trailer no.
440043 are detailed in this report.
A representative from the State of Nevada was present during this inspection.
Results:
Two apparent items of noncompliance with DOT/NRC regulations were observed.
See paragraphs 7 and 8. It appears that the State of Nevada, HRC Region III, and the Department of Transportation are the appropriate organizations to <ake enforcement actions.
81072i 0243 8i0707 PDR ADOCK 050003i5 PDR Ry Fo~
2 19 (2)
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DE7AILS Persons Contacted Steve Carpenter, Site Manager, U. S. Ecology, Inc.
Jimgruickshank, Radiation Safety Officer, Beatty Site, U.
S.
Ecology, Inc.
Walter Hipsner, Corporate Radiation Safety'Officer, U. S. Ecolooy, Inc.
,Kenneth Wailer, Asst.
Corporate Radiation Safety Officer, U. S. Ecology, Inc.
Thomas Kriesel, Fnvironmental Coordinator, D.
C.
Cook Plant Bert Gray, Nevada State Health Division Back round As part of a low level waste inspection conducted during February 23-27, 1981, trailer no. 440043 was inspected on February 23, 1981.
The instrument used for the radiation survey was the Keithly Model 36100 Serial No. 9864, due for recalibration on July 8, 1981.
Contamination survey of the unloaded trailer and checks for removable radioactive contamination were performed with an Eberline E-520 and HP-260 pancake probe due for recalibration on Yay 11, 1981.
Wipes for removable radioactive contamination were also analyzed on the NRC Region V Nuclear Measurement Corp.
Yodel PC-55 gas flow proportional counter.
Ins ection Licensee-Shipper:
Indiana and Michigan Electric Co.
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D. C.
Cook Plant Bridgman, Michigan Shipment Inspected:
February 23, 1981 Freight Bill No.
13026 Docket Nos.
05000315 05000316 1.
This shipment consisted of five (5) steel tanks of radioactive material, LSA, N.O.S., containing a total activity of 20.8 millicuries of cobalt-58 and cesium-137 as the metal oxide.
2.
A radiation survey of the trailer indicated a maximum dose rate of 11 mr/hr adjacent to one of the tanks.
3.
A bung located approximately three inches from the bottom of tank no.
4 was observed to have been leaking a liquid because of the presence of a white powdery residue around the bung and on the trailer surface
.
underneath the bung.
A small amount of residue was also noted to be present on the adjacent tank and on the trailer bed slightly to the rear of tank no. 4.
This appeared to have resulted from the leakage being carried and deposited by the air flow created during transportation.
An area of approxirrately six inches by two feet on the trailer bed was covered with a thin layer of dried residu e ~ 4.
5.
6.
7.
8.
Wipes of, the contaminated areas indicated that the levels of removable radioactive contamination were well within the DOT contamination limits.
On February 24, 1981, tank no.
4 was removed to the shop and the bung was opened by U. S. Ecology Inc. using appropriate radiological safety procedures.
Approximately 100 milliliters of a fluid mixture drained out.
A corrugated metal rod was thrust back and forth into the opening
. to see if there was more liquid in the tank.
There was none evident.
Instead, a
damp white powder which was caked up because of the moisture content was extracted when the metal rod was withdrawn from the bung.
The tank was subsequently sealed and buried.
Mr. T. Kriesel, Environmental Coordinator for the D.
C.
Cook. plant arrived onsite on February 24, 1981 and was present when the bung was opened.
He stated that tank no.
4 contained 15 to 20 cubic feet of boric acid crystals as well as solid waste material and that the weld around the bung was defective.
He stated that they had attempted to repair the defective weld prior to shipping by coating it with a thick layer of epoxy resin.
However, the epoxy patch did not appear to have cured properly since it was somewhat soft to the touch, and as a result the radioactive liquid leaked through the epoxy patch.
CFR 173.392(c)(1)
requires that materials must be packaged in strong, tight packages so that there will be no leakage of radioactive material under conditions normally incident to transportation.
Contrary to 49 CFR 173.392(c)(1)
there was a leakage of radioactive material from tank no.
4 during shipment from the D. C.
Cook plant to the Beatty, Nevada burial site.
The State of Nevada specific license issued to U. S. Ecology, Inc. does not authorize the presence of free standing liquids in packages received for burial.
As noted in paragraph 5 above, approximately 100 milliliters of liquid drained out of tank no.
4 when the bung was opened.
NRC Regulation
- 10 CFR 30.3 states that no person shall transfer byproduct material except as authorized by a specific or general license.
Apparently, the shipment of tank no.
4 by the NRC licensee to U. S. Ecology, Inc.
was not in compliance with the conditions of the Nevada State specific license.
9.
The traiier bed was decontaminated P steam cieaning and surveyed.
A small area of approximately
cm measured 320 dpm/15 cm
.
A wipe of this area indicated that the radioactive contamination was fixed.
10.
Appendix A contains photographs of tank no. 4.
Photograph no.
1 illustrates
-'he dried residue which resulted from the leakage of liquid through the defective weld around the bung of tank no. 4.
Photograph no.
illustrates the cqllection of the liquid drainage when the bung of tank no.
4 was opened.
Photograph no.
3 illustrates the use of the corrugated rod which was thrust back and forth into the open bung hole of tank no.
4 to determine if there is any more liquid in the tank.
The damp white material shown was stated by Mr. Kriesel of the D.
C.
Cook plant, to be boric acid crystals.
- 10 CFR 30.41 prohibits transfer of byproduct material to unauthorized persons /!jig.rara.:~
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~0 UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION III
799 ROOSEVELT ROAD GLEN ELLYN,ILLINOIS60137 M4P,;. g.;ge)
Docket No. 50-315 Docket No. 50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN:
Mr. John ED Dolan Vice Chairman
,Engineering 2 Broadway New York, NY 10004 Gentlemem:
This refers to the routine inspection conducted by Mr. M. L. Gildner of this office on January 19, 27-30 and February 5, 1981, of activities at D.
C.
Cook, Units 1 and 2, authorized by NRC Operating Licenses No.
DPR-58 and No. DPR-74 and to the discussion of our findings with D. Schaller and others of your staff at the conclusion of the inspection.
I'he enclosed copy of our inspection report identifies areas examined during the inspection.
Within these areas, the inspection consisted of a selecgive examination of procedures and representative records, observations, and interviews with personnel.
No items of noncompliance with NRC requirements were identified during the course of this inspection.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follows. If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty-five days of the date of this letter, to withhold such information from public disclosure.
The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the'pplication is contained in an enclosure to the applicatio American Electric Power Service
- 2-Corporation
'MAR i 9 i981 We will gladly discuss any questions you have concerning this inspection.
Sincerely, C." E. Norelius, Acting Director Division of Engineering and Technical Inspection
Enclosure:
IE Inspection Reports No. 50-315/81-06 and No. 50-316/81-06
REGION III==
Report No. 50-315/81-06; 50-316/81-06 Docket No. 50-315; 50-316 Licensee:
American Electric Power Service Corporation Indiana 8 Michigan Power Company 2 Broadway New York, NY 10004 License No. DPR-58; DPR-74 Facility Name:
D.
C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.
C.
Cook Site, Bridgman, MI Inspection Conducted:
January 19, 27-30, and February 5, 1981 Inspectors:
. L. Gildner Approved By:
. R. Baker, Chief Management Programs Section Ins ection Summar Ins ection on Januar
27-30 and Februa
1981 (Re ort No.
50-315/81-06'0-316/81-06)
Areas Ins ected:
Routine unannounced inspection of equipment calibration activities.
The'inspection involved a-total of 50 inspector-hours onsite by one NRC inspector.
None of the inspector-hours were spent on.site during off-shifts.
Results:
In the area inspected, no apparent items of noncompliance or deviations were identifie DETAILS 1.
Persons Contacted
-"D. Shaller, Plant Manager
+E. Townley, Assistant Plant Manager
-"D. Duncan, CSI Supervisor C. Miles, Calibration Supervisor J. Harsh, Senior Clerk T. Beilman, QCIC R. Biqchoff, Performance Engineer Additional plant technical and administrative personnel were contacted during the course of the inspection by the inspector.
2.
Activit Controllin Procedures The procedures listed below were reviewed by the inspector for conformance to Technical Specification requirements, applicable industry standards, and general workability.
THI 4030 - Surveillance Testing THI 5030 - Preventive Maintenance THP 6030 IMP.001 - Test Equipment Calibration Program THP 6030 IMP.044 - Preventive Maintenance Program THP 2030 IMP.002 - CSI Instrument Calibration System No items of noncompliance or deviations were identified in this arear'.
Test E ui ment Calibration The inspector selected eleven (11) pieces of test or calibration equipment which were in the control program from the test equipment crib and the calibration shop.
The random selection was representative of both mechanical and electrical test equipment in the program.
Each of the selected test devices was examined for proper storage, proper identification of calibration status, and traceability of its calibration to nationally recognized standards.
No items of noncompliance or deviations in this area were identified, but the following areas of concern were noted and discussed with plant personnel.
a
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An equipment usage log is maintained to monitor equipment location and which equipment was used on a specific test or calibration.
It was noted that the technicians checking out the equipment usually list only the location of usage and not the specific test.
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Although the specific test could be derived by looking at activities on a specific day in that location, listing the specific test would greatly speed the validation process if that instrument were found to be out of calibration.
b.
Precision analog meters are calibrated by Indiana and Michigan Power's Fort Wayne facilities.
While reviewing calibration documents, it was found that several of these instruments lacked adequate traceability.
It could not be determined if any of these meters were used for safety related testing.
D.
C.
Cook Nuclear Plant Testing Equipment Calibration and Inspection -Procedure PO 040-437 is inadequate in that it does not require the reference standard to be identified.
The procedure calls for a report on calibration to be issued for each instrument tested.
The report states in part that all data pertinent to this test is retained on file and is available for audit.
A copy of such data was included for several of these instruments and the standard reference traceability was not noted.
The Fort Wayne facility is a part of Indiana and Michigan Power and therefore does not fall under the vendor audit program.
It has not been demonstrated that certification support documents are adequate in this area.
It was discussed with the licensee that documentation requirements should be detailed to Fort Wayne as there is the possibility that an instrument without a traceable calibration could be used for safety related testing.
The licensee noted the inspectors comments and took action to bring the problem to the attention of Fort Wayne.
There are no further concerns in this area at this time.
4.
Test/Calibration Procedure Content Nine (9) randomly selected functional tests, time response tests, or calibration procedures for the reactor protection system and the engineering safety system, along with their other unit counterparts, were reviewed for procedure technical content.
These procedures were examined for proper reviews, cautionary notations, applicable acceptance criteria, as-found and as-left values, proper documentation of test equipment used, instructions for returning the system to normal operation on test completion, and appropriate signoffs.
No items of noncompliance or deviations were identified in this are.
Procedure Im lementation Twenty-seven (27) randomly selected tests and calibrations of safety systems were reviewed for proper implementation and documentation.
These completed tests and calibrations were examined for compliance with technical specification stated frequency and accuracy, completeness of the finished test with all required data and signatures, proper reviews for both technical and administrative issues and verification that the scheduling system acknowledged test/calibration completion.
No items of noncompliance or deviations were identified in this area.
6.
Non-Technical S ecification Calibration Nine (9) instruments from safety function systems whose calibration was not specifically called out by Technical Specifications were randomly selected for documentation review.
The instruments were examined for inclusion in a calibration program utilizing proper procedures which would result in the instrument meeting the required accuracy for its intended function.
No items of noncompliance or deviations were identified in this area.
The exit meeting was held with those plant personnel indicated by an asterisk in paragraph 1 on Friday, February 6, 1981.
The findings of this report were discussed with those present.
The inspector indicated to those present his appreciation of the cooperation of plant personnel during the conduct of this inspection.
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