IR 05000315/1986001
| ML17324A965 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/25/1986 |
| From: | Gill C, Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17324A963 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-315-86-01, 50-315-86-1, 50-316-86-01, 50-316-86-1, IEIN-85-061, IEIN-85-61, IEIN-86-022, IEIN-86-22, NUDOCS 8607070142 | |
| Download: ML17324A965 (37) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/86001(DRSS);
50-316/86001(DRSS)
Docket Nos.
50-315; 50-316 Licenses No.
American Electric Power Service Corporation Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
D.
C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.
C.
Cook Site, Bridgman, MI Inspection Conducted:
April 7 through May 29, 1986 e,~~
Inspectors:
C.
F. Gill a
e R.
A. Paul ate, Approved By:
.
R. Greger, Chief Facil'ities Radiation Protection Section ate Ins ection 'Summar Ins ection durin the eriod A ril 7 throu h
Ma
1986 (Re or ts No.
50-315 86001 DRSS 50-316 8600 DRS II d p>>f h
dhoti p
i
g during a refueling and maintenance outage including:
status of the Radiation Protection Improvement Program; changes in organization, personnel, facilities, equipment, programs, and procedures; audits and appraisals; planning and preparation; training and qualifications of new personnel; internal and external exposure control; control of radioactive materials and contamination, surveys, and monitoring; and the ALARA program.
Also, certain TMI Action Plan Items, open items, radiation protection staff stability, use of the HNS waste sorter, IE Information Notices No. 85-61 and 86-22, and certain radioactive material shipment concerns identified at the Barnwell waste burial facility by State of South Carolina inspectors were reviewed.
H Results:
Three violations were identified (failure to comply with radioactive waste burial,site regulations - Section 18, failure to prevent shifting of radioactive waste shipment lading - Section 18, and failure to post contaminated areas - Section 10).
Bb07070i42 Bb0b25 PDR ADOCK 050003i5
,
Persons Contacted DETAILS
- A. Blind, Assistant Plant Manager-Maintenance
~S.
Brewer, Radiological Support Section Manager-AEP W. Burns, Site Coordinator, HNS
"R. Clendenning, Plant Radiation Protection Supervisor D. Climer, Performance Engineer K. Cunningham, Radwaste Handling Supervisor C. Flis, Senior Performance Engineer
~J. Fryer, Environmental Coordinator M. Glissman, Performance Engineer
~L. Holmes, Administrative Compliance Coordinator A. Johnson, Engineer-HNS
- J. Joseph, ALARA Coordinator S. Kahlil, Senior Performance Engineer T. Kriesel, Technical Superintendent Physical Sciences G. Laren, Chemical Engineer-AEP
"J. Leichner, Radiological Support Nuclear Engineer-AEP W.
MacRae, Radiological Support Nuclear Engineer-AEP T. Postlewait, Performance'ngineering Supervisor
~J. Rischling, equality Control
~J.
Rutkowski, Staff Assistant G. Smith, Senior Radiological Engineer-HNS
"W. Smith, Jr., Plant Manager H. Springer, ALARA Engineering Technologist J.
St.
Armand, Performance Engineer
~B. Svensson, Assistant Plant Manager-Operations
~J. Heller, NRC Resident Inspector B. Jorgensen, NRC Senior Resident Inspector
- W. Shafer, Chief, Emergency Preparedness and Radiological Protection Branch C. Wolfsen, NRC Resident Inspector The inspectors also contacted other licensee and contractor employees including radiation protection technicians and members of the technical staff.
2.
"Denotes those present at the exit meeting on May 9, 1986.
General This inspection, which began at 2:00 p.m.
on April 7, 1986, was conducted to review the Radiation Protection Improvement Program and the radiation protection program during a refueling and maintenance outage, including changes in organization and management controls, qualifications and training, audits and appraisals, planning and preparation, internal and
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external exposure controls, ALARA program, and control of radioactive material and contamination.
Also, certain TMI Action Plan Items, open items, radiation protection staff stability, use of the HNS waste sorter, selected IE Information Notices, and certain radioactive material shipment concerns were reviewed.
The inspectors conducted radiation and contamina-tion surveys of selected plant areas using NRC and licensee survey instruments (Xetex 305-B and Eberline RM-14); except as noted in Section 10, readings were in general agreement with posted licensee data.
Access controls and procedural adherence were good.
Housekeeping and storage of radioactive materials showed improvement.
Licensee Actions on Previous Ins ection Findin s (Open)
Open Item (315/80023-06; 316/80019-06):
Unsuitable monitor location.
This item remains open pending the December 1986 scheduled replacement of liquid effluent monitor R-18.
(Open)
Open Item (315/84017-03; 316/84019-03):
HVAC filter housing drain system bypass and fire protection system water leakage problems.
The corrective actions for this identified weakness (Inspection Reports No. 50-315/85024; 50-316/85024, Section 13) outlined in the licensee's response dated November 8, 1985, were reviewed.
Although no problems were noted with the proposed design changes, the licensee did not address the necessary procedural modifications to ensure that the modified valving arrangements will be under adequ'ate positive administrative control.
Pending completion of design changes and procedural modifications, this item remains open.
(Open)
Open Item (315/84017-04; 316/84019-04):
High range iodine and particulate sampling system design concerns regarding provisions for continuous and representative, sampling, adequacy of shielding for sample transport, and prevention of contamination of high range noble gas monitor with iodine.
This item remains open pending licensee completion and NRC review of NUREG-0737 Item 11. F. 1, Attachment-2, compliance documentation.
(Open)
Open Item (315/84017-05; 316/84019-,05):
Review SPING setpoints and calibrations.
This item remains open pending licensee completion and NRC review of NUREG-0737 Item ll.F. 1, Attachment 1, compliance documentation.
(Closed)
Unresolved Item (315/85011-01; 316/85011-01):
Removal of the RPM from the radiation protection management chain and addition of two additional managers (one of which is responsible for maintenance activities) between the RPM and the Plant Manager.
Effective August 9, 1985, the RPM terminated his employment and a new RPM was appointed.
The new RPM meets the qualification requirements of, Regulatory Guide 1.8.
The RPM has been returned to the manageme'nt chain'osition 'as indicated in the technical specifications, but the two additional managers between 'the RPM and the Plant Manager remain.
However, because the licensee has consistently demonstrated that the Plant Manager is readily accessible to the RPM, this matter is'considered close (Closed) Violation (315/85011-02; 316/85011-02):
Failure to perform evaluations of radiation hazards as required by,l0 CFR 20.201(b) (three examples).
The corrective actions outlined in the licensee s response dated August 8, 1985, were reviewed.
No problems were noted.
(Closed) Violation (315/85011-04; 316/85011-03):
Failure to maintain the steam relief/PORY release pathway monitors operational.
The corrective actions outlined in the licensee's response dated August 8, 1985, were reviewed.
The procedure to track equipment required to be operable under NRC Confirming Order has been issued for use and is apparently effective in that two letters were recently transmitted to the Regional Administrator in accordance with the licensee letter AEP:NRC:678N, dated August 8, 1985:
(1) letter AEP:NRC:0678(,
dated December 9, 1985, which discussed two steam generator PORV radiation monitors that were out of service due to detector problems, and (2) letter AEP:NRC:0678R, dated January 9, 1986, which discussed two containment high-range area radiation monitors that were out of service due to analog-to-digital converter board problems.
The inspectors reviewed the procedure and the condition reports and discussed the monitor failures with the licensee personnel who identified and corrected the technical difficulties; no problems were noted.
I (Open) Unresolved Item (315/85011-05; 316/85011-:04):
Obtain NRR concurrence on the locations of the steam relief/PORV monitors.
This matter was discussed during a meeting between the licensee and NRR on December 19, 1985.
- This item remains open, pending resolution by NRR.
f (Open)
Open Item (315/85011-06; 316/85011-05):
Two weaknesses related to an NRC Confirming Order and NUREG-0737 compliance.
In letter AEP:NRC:0678N, dated August 8, 1985, the l'icensee addressed these weaknesses and stated that Open Items No. 315/84017-04; 316/84019-04 and 315/84017-05; 316/84019-05 are being entered into the compliance analysis report program which has been implemented for NUREG-0737 Items II.F.1, Attachments 1, 2, and 3, and II.B.3.
The licensee's progress regarding this matter is discussed in Section 16.
(Closed) Violation (315/85024-01; 316/85024-01):
Failure to adhere to or establish adequate procedures.
The corrective actions outlined in the licensee's response dated November 8, 1985, were reviewed.
No problems were noted.
(Cl osed)
Open Item (315/85024-03; 315/85024-03):
Auxi 1 iary bui1 ding cluttered with numerous small radioactive/contaminated storage areas filled with bags, tools, and equipment.
On January 28, 1986, the licensee issued radioactive material control guidelines which have been effective in reducing the floor space occupied by temporary radioactive/contaminated storage areas.
See Section 10.
(Closed) Violation (315/85024-04; 316/85024-04):
Failure to perform needed evaluations of radiation hazards.
The corrective actions outlined in the licensee's response dated November 8, 1985, were reviewed.
No problems were note d M
C ll t
(Closed) Violation (315/85024-05; 316/85024-05):
Failure to follow a radiation protection procedure.
The corrective actions outlined in the licensee's response dated November 8, 1985, were reviewed.
No problems were noted.
(Open)
Open Item (315/85024-06; 316/85024-06):
Operation of the HNS DAW sorter.
See Section 17.
(Cl osed)
Unresolved Item (315/85024-08; 316/85024-08):
Damaged charcoal trays and adsorber water damage in ventilation systems.
The inspectors reviewed documentation and interviewed licensee personnel regarding the licensee's corrective actions following the surveillance test discovery in March 1985 of water damage to several trays of charcoal adsorber in Unit 2 Auxiliary Building ESF Ventilation Systems filter housing No.
(2-HV-AES-1) and subsequent damage found in other technical specification HVAC filter housings beginning on September 3, 1985.
It appears that the licensee, in general, has given the matter proper priority, begun corrective actions, adequately addressed the inspectors'oncerns expressed in Section 12 of Inspection Reports No. 50-315/85024; 50-316/85024, and complied with the commitments made in Subsection 14.g of the same inspection report.
~Chan aa The inspectors reviewed changes in organization, personnel, facilities, equipment, programs, and procedures that could affect the outage radiation protection program.
A Radiation Protection Supervisor has been appointed as Outage Coordinator for the radiation protection group.
He ensures that sufficient health physics coverage is available for planned work.
In addition, plant senior radiation protection technicians who have received temporary upgrades to supervisory positions have been assigned to each shift as the plant representative at Containment Access Control (CAC).
This individual ensures contracted technician adherence to plant radiation protection procedures.
These changes appear to benefit the licensee's outage radiation protection program by providing-the needed radiation protection coverage on all.shifts and oversight of contractor activities.
No violations or deviations were identified.
Radiation Protection Staff The radiation protection staff consists of five supervisors and five engineers, seven senior radiation protection technicians (RPT's),
17 RPT's, and four junior RPT's.
Of the five supervisors, two have over eight years as permanent members of the radiation protection staff and three others
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(including the RPM) have less than 1.5 years experience as permanent members of the staff.
The current senior RPT's all have between four to six years plant experience; the 21 RPT's and junior RPT's have an average experience level of about 2.5 years at the plant.
From January 1984 through May 1986, the Radiation Protection Department lost three senior RPT's and four RPT's.
I In addition to the plant radiation protection staff, the licensee utilizes approx'imately 16 full-time contract radiation protection personnel.
During refueling outages, additional contract radiation protection personnel are utilized to approximately double the radiation protection staff size under nonoutage conditions.
The experience level of the plant radiation protection staff is low when compared with Region III plants possessing strong radiation protection programs, and the turnover rate of the radiation protection staff appears somewhat high in a similar comparison.
Actual experience of the plant radiation protection technicians is further diminished by the licensee's practice of assigning most job coverage to contract personnel.
Because of the dependence on contract radiation protection personnel during nonoutage conditions and the relatively low experience level of the 21 plant RPT's and junior RPT's, the inspectors specifically reviewed areas affecting radiation protection personnel stability and qualifications through discussions with personnel and review of records.
Based on the inspectors'iscussions with radiation protection staff members, it.appears that worker morale may have adversely affected staff stability in the past and may continue to do 'so in the future, and therefore may be having an adverse impact on experience levels and performance of the radiation protection staff.
The lack of plant staff experience appears to have been evidenced recently when in the absence of the RPM, the inspector attempted to clarify a report from the plant to the NRC Headquarters Operations Office that a containment particulate radioactivity concentration of SE-1 pCi/ml had initiated a containment purge isolation signal.
Clarification was sought because the reported particulate concentration was unrealistically high.
Although twice informed by the inspector that the reported concentration was unrealistically high and requested to review the reported concentration for accuracy and comparison with expected containment particulate concen-trations, the acting RPM and radiation protection staff did not, over a 24-hour period, explain why the reported containment particulate concentra-tion was so high, indicate that the reported concentration was invalid, or provide data on normal containment particulate concentrations for comparison.
Only after the RPM's supervisor was 'contacted by the inspector the second morning and asked to review the matter did the licensee report late that afternoon, a day and one half after the initial inquiry of the plant, that 8E-1 pCi was the total activity on the particu-late filter and not the concentration which existed in containment.
The particulate concentration, was finally reported to have been about 2E-8 pCi/ml, which was about two orders of magnitude greater than the normal particulate activit These inspection findings concerning radiation protection staff experiences, stability, and morale, although not conclusive, indicate a need for further review by the licensee.
This matter was discussed in the exit interview and will be reviewed further during a future inspection.
(Open Items No. 315/860001-01; 316/860001-01)
Plannin and Pre aration The inspectors reviewed the outage planning and preparation performed by the licensee, including:
additional staffing, special training, increased equipment supplies, and job related health physics considerations.
Health physics personnel participated in preplanning meetings and were aware of major radiation jobs in-advance of the outage.
According to the licensee, job priorities were established, sufficient information was given to radiation protection to supply job coverage for noncritical path activities, there was suffi'cient available manpower to cover the jobs, and interdepartmental cooperation was adequate.
Evidence that job planning and preparation is influenced by radiation protection includes containment decontamination and shielding prior to allowing outage work to begin and radiation protection and ALARA partici-pation in all planning and outage meetings.
No violations or deviations were identified.
'rainin and ualifications of Contractor Personnel The inspectors reviewed the experience qualifications of the contractor radiation protection personnel and the training provided to them.
Also, radiation protection training provided to other contractor personnel was reviewed.
The licensee contracted approximately 70 radiation, protection technicians and supervisors for the refueling outage and 16 technicians to provide
'ob coverage during. normal operations.'Several plant health physics technicians were temporarily made supervisors for the refueling outage and were assigned as liaison for contractor personnel who are assigned to radiation protection coverage.
The supervisors monitor contract radiation protection personnel performance.
Before individual contract senior radiation protection technicians are hired, the licensee require they meet ANSI 18. 1-1971 qualifications.
Based on a selective review of resumes and observations of several contractor radiation protection technicians performing their duties, it appears they are properly qualified.
Contractors are required to attend the General Employee Training (GET)
course.
This program has been certified by the Institute of Nuclear Power Operations'raining instructors must be qualified in 16 plant proficiency exercises in accordance with the instructors training manua The course consists of a series of formal classroom instruction, video tapes, practical factors, and demonstrations covering radiation protection and site specific modules.
Practical factors training consists of donning and removal of protective clothing, use of step-off pads, proper frisking techniques and use of the Data Entry Terminal Units (DETU's).
To success-fully complete the course, each student must pass two written exams.
Respiratory protection training is required for all radiation workers who work in areas where respirators are used.
The course appears to meet the training requirements of 10 CFR 19. 12, "Instructions to Workers."
Records of selected contractor personnel were reviewed to verify that they completed the required training.
No problems were noted.
Pre-outage special training provided to station and contract workers includes mock-up training for certain steam generator work, ALARA briefings for each work group, and RWP program training.
No problems were noted in this area.
'i No violations or deviations wer'e 'identified.
Internal Ex osure Control and Assessment The inspectors reviewed the licensee's internal exposure control and assessment program, including:
changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for main-tenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.
The program to control internal exposures during outage activities includes engineering controls, airborne sampling and contamination surveillance, and use of approved respiratory devices and protective clothing.
Whole body counting is used to supplement the monitoring program to ensure its effectiveness.
The engineering controls include use of portable ventila-tion units with filters to exhaust and clean air from certain areas in the containment when possible radioactive airborne producing work is performed.
A selected review of air sample and smears survey results were made.
No problems were noted.
All persons involved in outage activities receive a base line (incoming)
whole body count (WBC) and a termination MBC.
Other WBCs may be required at the discretion of the health physics staff and as required by station procedures.
The inspectors selectively reviewed the whole body count results for the period October 1985 to March 1986.
There were no results exceeding the 40 MPC-hour control measure.
A check of respirators that were ready for use showed they were properly stored, inspected and maintained.
No problems were noted concerning the use, distribution, and accountability of respirator t I,
The inspectors also reviewed the Whole Body Counting Procedure No.
12 THP 6010.RAD.409,
"Assessment of Whole Body Count Results,"
(Revision B) and its method of relating whole body counting data to regulatory requirements.
It was noted the procedure does not correctly relate whole body counting data to MPC-hours for iodine-131 and 133 and cesium-134 and 137.
For instance, the procedure indicates that 57 nanocuries (nCi) of iodine-131, 188 nCi of iodine-133, 250 nCi of cesium-134 and 375 nCi of cesium-137 is equivalent to 40 MPC-hours.
These values are incorrect but conservative because they assume the fraction of the air (fa) which goes to the critical organ is the fa used for the lungs'n addition, some discrepancies in the quantities constituting maximum permissible whole body burdens were also noted.
After the inspector informed the licensee of the above noted discrepancies, the procedure was revised to reflect the corrected values.
No violations or deviations were identified.
External Ex osure Control The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including:
changes in the dosimetry program to meet outage needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.
The external. exposure measurement and control program for the current outage consists of whole body monitoring using thermoluminescent dosimeters (TLDs), self-reading dosimeters (SRDs), direct surveys, radiation work permits, and administrative dose limits.
The TLD results are normally maintained as the official record of personal exposure data.
The SRD results are used for daily updating'of personal exposures and can be entered into the official exposure records only when other TLD results are not available, or if the TLD results are determined to be invalid.
The total dose through April 30, 1986, was 441 person-rems.
No regulatory limits for personal exposures were exceeded during this period.
No violations or deviations were identified.
Control of Radioactive Materials and Contamination The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including:
adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control radioactive and contaminated materials.
The licensee's whole body personal contamination monitoring (frisking)
program requires workers to perform.a minimum hand and foot frisk for contamination if they entered the radiologically controlled area but did
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not enter any contaminated areas, and a whole body frisk (usually directed by signs to use a nearby 'shielded frisker booth) for those workers exiting a contamination area.
In addition to required frisking, all workers exiting the controlled area must pass through a portal monitor.
The inspectors observed that although the workers made an attempt to perform the required frisking, many need to improve on their frisking technique.
The most common errors noted were frisking too rapidly or holding the probe too far from the surface being frisked.
The radiation protection technicians periodically observe the use of the friskers at access control exits and correct workers who are improperly frisking.
An inspector also observed,two workers leaving a contaminated area without following posted directions to conduct whole body frisking at a nearby booth.
The workers indicated that they planned to whole body frisk at access control; however, when reminded of the posted instructions by the inspector, they quickly adhered to procedures.
The inspectors discussed with the Radiation Protection Manager the need for closer adherence to posted requirements for the use of frisker booths to prevent the potential spread of contamination between the step-off pads and the access control frisking stations.
The inspectors noted that access control radiation protection technicians were responsive to frisker and portal monitor alarms.
Although, as discussed above, there are still some problems with the implementation of the whole body frisking program, significant improvement in procedural adherence was noted when compared to observations made during earlier inspections.
The licensee appears to have sufficient contamination survey and monitoring equipment to accommodate outage requirements.
Radiation monitors are available at the auxiliary building access control facility and are source checked daily.
Inspector concerns regarding the availability of these instruments to individuals who may not be properly trained in their use is discussed in Section 12.
The licensee issued guidelines for radioactive material control in the auxiliary building on January 28, 1986.
These guidelines were issued for the purposes of preventing the unauthorized addition/alterations of radiocative materials into/in storage areas and the reduction of temporary areas utilized for equipment storage by at least 50K.
The inspectors observed that each storage area is now clearly defined and controlled by radioactive equipment release and radioactive material laydown area request forms and procedures.
The licensee's response to the SALP 5 report states that as of September 30, 1985, there were 17,278 square feet of contami-nated hallway which included 4,709 square feet of contaminated equipment storage areas; by February 14, 1986, 'these figures had been reduced to 7,451 square feet and 2,467 square feet, respectively.
Some of the reduction of equipment storage area has been accomplished by stacking equipment higher in storage areas and by placing some equipment in boxes marked internal contamination.
The actual volume of contaminated material and equipment stored in general access areas of the auxiliary building seems to be much the same as during early inspections; however, the consolidation of storages areas created more, useable floor space for general access.
Although the licensee has made significant improvements regarding this matter, there appears to be little t'echnical justification
for most of the temporary storage of material, tools, and, equipment in the auxiliary building general, access areas.
It also appears that the licensee's internal proposal to allot space in the new steam generator storage facility for a significant portion of the objects presently in auxiliary building temporary storage is desirable.
The inspectors performed a radiation and contamination survey of tools, equipment, and areas in the auxiliary building.
In general, independent surveys of radiation areas were in good agreement with licensee posted results; however, some surveys posted outside radiation areas were not updated to reflect the latest survey results, maintained with the RWPs in the access control facility.
This matter was discussed with the Radiation Protection Manager (RPM).
Procedure 12 THP 6010.RAD.404, Establishing Posted Areas, requires any area in which the removable contamination on any accessible surface or equipment exceeds 500 dpm/100 cm~ beta-gamma to be posted as a contamination area.
Contrary to the above, on May 6, 1986, the inspectors found equipment with removable contamination greater than 500 dpm/100 cm~ beta-gamma located outside designated contamination areas on the 633-foot elevation level of the auxiliary building, in that:
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Pipe fittings stored in an open cabinet adjacent to Freon tool decontamination area had removable contamination of 4000 dpm/100 cm~
beta-gamma.
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A cart located adjacent to the hot tool crib decontamination area had removable contamination of 5000 dpm/100 cm~ beta-gamma.
A slag hammer stored on a rack affixed to the outside of an equipment cabinet, located adjacent to the hot tool crib, had removable contamination of 220,000 dpm/100 cm~.beta-gamma.
Failure to place the above contaminated objects in posted contamination areas as required by Procedure 12 THP 6010.RAD.404 is a violation of Technical Specification 6. 11 which requires adherence to radiation pr otecti on procedures.
(315/86001-02; 316/86001-02)
In their review of the Radiological Deviation Reports (RDRs), the inspectors noted that a significant number dealt with contaminated objects found outside posted areas in the same general vicinity of the 633-foot elevation of the auxiliary building where the inspectors found contaminated tools and equipment during this inspection and an earlier inspection (Inspection Report No. 50-315/85024; 50-316/85024, Violation 315/85024-04; 316/85024-04).
The inspectors discussed with the RPM the apparent poor control of contaminated material at the 633-foot elevation of the auxiliary building in the vicinity of the Freon tool decontamination area, the hot tool crib, and the hot tool crib decontamination area.
The RPM was aware of the above radioactive material control problems and presented the inspectors with his draft plan to consolidate the various individual areas of this portion of the auxiliary building so that the flow of contaminated
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material into the area, its decontamination, storage, and reissue are under strict radiation protection control.
It appears that the plan, as presented to the inspectors, has merit and it, or a similar positive control reconfiguration of area, is desirable and should be pursued.
This matter will be reviewed further during a future inspection.
(315/86001-03; 316/86001-03)
One violation with three examples was identified.
Maintainin Occu ational Ex osures ALARA The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including:
changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outage; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them.
Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of implementation weaknesses.
The inspectors reviewed the ALARA organization, the qualification and experience of its members, and the effectiveness of the organization in continuing to institute dose saving 'programs during outages.
The professional ALARA staff consists of an ALARA coordinator, an engineering technologist, and a full-time clerk; all of whom seem to have the proper qualifications, experience, expertise, and dedication to establish and maintain an effective ALARA program.
, The location of, the ALARA,group in the station organization, consideration of ALARA pr'incipl'es by other station groups and departments and their working relationship with the ALARA group, management involvement, and the types and number of workers assigned to meet ALARA goals also seem conducive to the establishment of an effective ALARA program.
However, the licensee does not maintain records which would allow a review of the perons-rem expended during this outage compared to similar tasks during previous outages to ascertain whether the licensee has learned well from past experience and has realized dose savings by establishing and diligently maintaining an effective ALARA program.
The Al ARA program is governed by the Plant ALARA Review Committee (PARC)
which consists of the Plant Manager, top level managers from each station functional area, and members of the ALARA Subcommittee.
The PARC meets at least quarterly to establish program goals, review status in relation to those goals, and review activities which may result in exposures greater than 10 person-rem.
The ALARA Subcommittee consists of the plant ALARA Coordinator and ALARA representatives from each station functional area.
Meetings are held at least three times per quarter to review work items which are estimated to result in greater than 1.5 person-rem, conduct post work. review of tasks, and review all suggestions relating to radiological exposure.
The licensee is developing what appears to be an effective and comprehensive job history file and temporary shielding request and analysis program.
The ALARA suggestion forms seems to be well utilized both by the workers -and the formal ALARA organization.
Pre-job planning, ALARA shift coverage, and post job review are adequate.
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The licensee does not establish annual numerical ALARA goals for the plant or for individual work groups.
ALARA goals are set for each job as they are planned.
The ALARA program includes provisions for dose reduction by minimizing contaminated areas but the extent of contaminated areas is tracked by the radiation protection group instead of the ALARA group.
The amount of the controlled area that is contaminated has remained relatively constant over the last few years, despite the improvements represented by the reduction of contaminated hallway and equipment storage areas discussed in Section 10.
Currently, about 53,000 square feet of area is controlled as contaminated in the auxiliary building.
Although formal ALARA numerical dose goals are not established by the licensee and records have not been kept in such a manner as to ascertain dose-savings due to effective ALARA involvement in plant operations, the D. C.,Cook Nuclear Plant has consistently reported annual person-rem doses below the national average of pressurized water reactors.
The total dose for 1985 was 410 person-rem per reactor, below the national average of approximately 550-600 person-rem per reactor.
Although D.
C.
Cook continues to compare well with the national average each year, the total annual dose, continues an upward trend which may indicate the need for a more sophisticated tracking and trending methodology to ensure that the licensee is properly applying state of the act dose-savings technology in the management of the ALARA program.
The presently utilized computer system with the existing software seems ill suited for effective use by the ALARA group in achieving their primary task of initiating a detailed and comprehensive dose-saving program.
The computer system (REM) is presently able to accomplish lower tier functions such as producing job dose reports by RMP, collective daily doses for individuals, and dose reports as required by 10 CFR 20.407 and in the annual operation report; however, these functions appear ill suited for use in a comprehensive ALARA program.
At present the ALARA group is laboriously, by manual means, extracting data from the REM system and breaking the data down into work subgroups and individual tasks so that the stored data may be of some use in the ALARA program.
This manual effort is quite time consuming and needlessly interjects an inefficient element into the ALARA program.
The inspectors discussed other available software options and ALARA management techniques with the ALARA group.
It appears that the effective implementation of the ALARA program requires significant upgrading in computer capabilities, numerical goal setting by subgroup and subtask, and adequate detailed historical records to research dose-saving techniques.
It also appears that appropriate requests made by members of the ALARA group to upgrade the ALARA,program should be vigorously supported by management.
This matter'as discussed at the exit and will be reviewed further during future inspections.
(315/86001-04; 316/86001-04)
No violations or deviations were identified.
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12.
Surveillance - Plant Tours
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The following problems were identified by the inspectors during numerous tours of the plant:
Two workers and a radiation protection technician were observed performing a job involving grinding inside sections of,two main steam relief valves.
An inspector questioned the workers about their activities and was told that the valves were being ground to reduce fixed contamination levels (2,000 to 48,000 dpm/100 cm~) before unconditional release to an offsite facility.
The inspector then reviewed the licensee s unconditional release policy.
According to Plant Manager Procedure 6010 RAD.001, the release limit for levels of fixed contamination is 0. 1 mR/hr at one inch (converted to 250 cpm above background using a frisker).
This limit implies that material with detectable levels of.radioactivity may be released offsite.
The licensee was informed that there are no allowances in 10 CFR 20 which permit detectable radioactive material to be unconditionally released to an unrestricted area, and that the procedure should be revised to reflect the requirements of 10 CFR 20.
During the exit meeting, the licensee agreed to the revision.
This matter will be reviewed further during a future inspection.
(315/86001-05; 316/86001-05)
The inspectors also noted that although there are administrative controls to prevent potentially contaminated material from being released to unrestricted areas, there is a potential release path for contaminated material and equipment from the secondary side of the plant via the maintenance department, and possibly by other departments.
The licensee was requested to review the matter and make appropriate corrections to strengthen the controls, if necessary.
During the exit meeting, the licensee agreed to perform an evaluation of this matter.
This matter will be reviewed further during a future inspecti on.
(315/86001-06; 316/86001-06)
The inspectors frequently observed workers wearing thermoluminescent (TLD) and self reading (SRD) dosimeters at various locations of the body including the chest, trouser pockets, side of the hip, and in one instance, the back of a hard hat.
The most common location of the TLD's and SRD's were on chains worn around the workers neck inside or outside of the worker's PCs.
Morn in this fashion, the TLD's are generally located in the front area of the upper whole body, however, they are not oriented with the window of the TLD facing away from the body.
There are no apparent written procedures or instructions on TLD-SRD placement.
In General Employee Training, the workers are instructed to wear the TLD's on the inside of the PC's and the SRD'.s on the outside of the PC s, with no specific instructions concerning the area of the whole body on which the TLD-SRD's are to be worn.
In the Radiation Protection requalification tape, the workers are instructed to wear the TLD's paper side out and at the center of the body.
No instructions are given concerning the location of the SRD's.
The inspectors requested the licensee to review the current placement of TLD's to determine if they are worn appropriately, and based on
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their findings, to develop written procedures specifying the proper placement and orientation of the TLD's.
During the exit meeting, the licensee agreed to evaluate this matter.
This matter will be reviewed further during a future inspection.
(315/86001-07; 316/86001-07)
The licensee requires personnel entering high radiation areas (HRA's)
to use portable survey meters; however, it appears there are no specific qualifications required by the licensee for the employees who use these meters.
The only instructions given to personnel before use of the meters is in General Employee Training.
The inspectors reviewed that section of the training program which covers the use of the meters.
The inspectors found that although the use of the meter is shown on a taped presentation, and a meter is passed among the training class, there is no practical training on the use of the instrument to observe actual response to radiation over the range of instrument detection.
Based on the review, the inspectors informed the licensee that the current program does not appear to support qualification of all meter users without additional training.
The licensee was requested to review this matter to determine what steps will be taken to strengthen this program.
This matter will be reviewed further during a future inspection.
(315/86001-08; 316/86001-08)
Carts and yellow plastic bags used to transfer contaminated laundry are not designated with markings to indicate radioactive material.
Also, it appeared to the inspectors that many employees observed working in the plant do not have a clear understanding of licensee's policy that yellow plastic bags should be used for containment/
transfer of contaminated or potentially contaminated equipment, and green bags for noncontaminated equipment.
During the exit meeting, these matters were discussed with the licensee who stated that these deficiencies would be corrected.
This matter will be reviewed further during a future inspection.
(315/86001-09; 316/86001-09)
Laboratory and other workers frequently use the normal access to the radiologically controlled area as an egress to the uncontrolled area.-
The portal monitor used for personal survey at this point has poor detection sensitivity.
The inspector informed the licensee that if persons continue to use this are'a for egress, then the frisking/
monitoring equipment'should have comparable detection sensitivity as those detectors stationed at other egress stations.
During the exit meeting, the licensee agreed to correct this deficiency.
This matter will be reviewed further during a'uture inspection.
(315/86001-10;.
316/86001-10)
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During the tours, it was noted the licensee provided sufficient frisker/
frisker booths, laundry hampers, posting and control of areas, step-off-pad instructions, surveys, smears and air samples.
Throughout this inspection, it appeared there was sufficient radiological control over outage activities.
No violati ons or devi ati ons were identi fied.
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Radiolo ical Deviation Re orts RDR's Radiological Deviation Reports (RDR's) for the period of January through April 1986, were reviewed.
The licensee trends occurrences to determine repetitive violations.
The inspectors'eview of the RDR's indicated a
general downward trend in repeat occurrences for the two most common repetitive occurrences, failure to return portable instruments and contaminated material found outside of posted area.
It appears that the RDR program is given adequate management attention, investigation, and support.
The inspectors noted that the effectiveness of the RDR system at other licensee facilities is based on worker understanding of the system, their willingness to initiate them, and conscientious management attention to each RDR.
Based on discussions with plant and contractor technicians concerning this matter, it appears they understand and promote the use of RDR's.
No violations or deviations were identified.
IE Information Notices The inspectors reviewed licensee action in response to the following selected Information Notices.
The actions are considered adequate.
No. 85-81:
Problems Resulting, in Erroneously High Reading With Panasonic 800 Series Thermoluminescent'osimeters.
The licensee uses the Eberline TLD Model 100 which consists of a lithium(6)-fluoride chip in an aluminum filter.
The Eberline TLD does not contain the lead filter which is susceptible to contamination with,trace 'amounts of naturally occurring radioisotopes.
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Il No. 86-22:
Underresponse of Radiation Survey Instrument To High Radiation Fields:
The licensee has taken all Eberline Model ESP-1 with a HP-290 gamma probe (may underrespond to high radiation fields) from service.
These instruments will not be used until this matter is resolved.
Facilities and E ui ment The inspectors toured radiation protection facilities, observed radiation protection equipment in use, and discussed plans for improving access control facilities and equipment with the health physics staff.
Newly procured or ordered equipment which should enhance the radiation protection program include:
(1) three state-of-the-art portal monitors to replace less sensitive portal monitors; (2) a standby whole body counter to replace a less sensitive and much longer counting time chair whole body counter; (3) approximately one dozen hand and foot monitors; (4) a radwaste compactor which can compact two 52-gallon drums into one 55-gallon drum; (5) a more modern and efficient replacement DAW bailer; (6) a radwaste demineralizer to replace a less efficient evaporator; and (7) a newly designed mop head dryer which should significantly reduce a rather large contaminated inventory (several thousand mop heads).
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Status of Certain TMI Action Plan Items The inspectors reviewed the status of the post-accident sampling system (II.B. 3), high range noble gas effluent monitors (II.F. l. 1), accident range'odine and particulate effluent sampling systems (II.F.1.2),
and containment high range radiation monitors (II.F.1.3). It had been noted during an earlier inspection that although these systems are installed
'nd functional, documentation demonstrating compliance with NUREG-0737 clarification items was not readily available for review (Inspection Reports No. 50-315/85011; 50-316/85011).
As a result of'his concern, the licensee, in a letter dated August 8, 1985, committed to prepare a Compliance Analysis Report for NUREG-0737 Items II.B.3 and II.F.1, Attachments 1, 2, and 3.
The inspectors met with licensee represen-tatives during the present inspection to discuss progress made towards the completion of this internal report.
The scope of the report and its present status are discussed below.
The NUREG-0737 Compliance Analysis Report is subdivided into two categories:
Phase I and Phase II.
Phase I was developed to identify the commitments made to the NRC, the compliance documentation, and any deviations from the four NUREG-0737 items.
Phase II will discuss the various actions needed to bring the D.
C.
Cook Plant into full compliance with the four NUREG-0737.items.
It will consist of a detailed schedule with assigned responsible individuals for open items identified in Phase I, including any variance requests to NRR and actions needed to document compliances.
The licensee completed Phase I on September 30, 1985; Phase II is expected to be completed by July 1986.
Ninety-six items were identified and reviewed by the licensee during the Phase I analysis.
Licensee representatives stated that 50 of the items have documented compliance.
Forty-six of the items require further documentation in the form of supporting calculations, procedure modifications, technical specifications, etc.,
and will remain as open items for the Phase II portion of the report.
The inspectors selectively reviewed portions of the report; the commitment and compliance analysis appears sufficiently detailed to define documenta-tion necessary to demonstrate compliance.
Because nearly half of the items are to be resolved in Phase II, the detailed review of compliance documentation action will be done during a future inspection after Phase II is completed.
H dro Nuclear Services Waste Volume Reduction S stem Inspection Reports No. 50-315/85011; 50-316/85011 noted that the use of the Hydro Nuclear "dry active waste (DAW) segregation and volume reduction system was acceptable to the'NRC providing it is operated in accordance with the manufacturer's instructions and that all detected radioactive waste is disposed of properly.
In a subsequent inspection (Inspection Reports No. 50-315/85024; 50-316/85024), it appeared that contrary to
manufacturer's instructions, the operators had been routinely reprocessing this material without treating it as detected radioactive waste.
Example
of Violation 315/85024-01; 316/85024-01 was issued for failure to establish an adequate procedure for limiting material released to the environment.
Based on the licensee response dated November 8, 1985, this second example was retracted and the region stated in a letter dated December 9, 1985, that we would review the matter further during a future inspection.
On May 9, 1986, an inspector met with the Environmental Coordinator, a
a Radwaste Handling Supervisor, the Hydro Nuclear Services (HNS) Site Coordinator, and two HNS engineers to review the present operation procedure and post operating methodology for the HNS DAW sorter.
The meeting attendees agreed that the present procedure would allow boxed process material, which had alarmed the bag monitor, to be mixed back into a nearly full conveyor hopper; this material could then be reprocessed by the system and dumped into a nearly full box of shredded material at the end of the process stream.
Because this mode of operation would represent the potential for significant activity dilution, the licensee agreed during the exit meeting to make the appropriate corrections to the operation procedure.
During the meeting on Hay 9, 1986, the licensee representatives stated to the inspector that the HNS DAW sorter had been and would continue to be operated such that the processed and boxed material, which has set off the bag monitor, would be reprocessed unmixed with any other material and the final shredded reprocessed material,.would be placed into an initially empty box and that the revised procedure would state this in a specific manner.
The inspector expressed concern that if the conveyor monitors do not detect and reject some radioactive material during,reprocessing, the reboxed material should still be considered as radioactive waste, even,if it did not realarm the log monitor.
The Environment Coordinator agreed to temporarily store all processed material which alarms the bag monitor until this matter is resolved.
The meeting attendees agreed that one possible resolution of this issue would be to follow normal station release procedures for any reprocessed material for which the conveyor system detects and rejects some radioactive material and the reboxed material does not alarm the log monitor; the Environmental Coordinator stated that this criteria would be in the revised operation procedure, if appropriate.
The inspector observed the HNS Volume Reduction System installation, and discussed the equipment operation with HNS and licensee personnel who were present.
The inspector noted that the equipment was still located in the radwaste compactor room.
According to persons interviewed, this location has caused some operational problems due to varying background radiation levels in the room.
During a previous inspection (Inspection Reports No. 50-315/85024; 50-316/85024), it was noted that there were three radwaste liners measuring in excess of 100 mrems/hr at contact located just outside this room.
Although these liners have since been moved, the high back-ground location continues to plague the operability of the HNS DAW sorter in that the system was shutdown for more than a week due to nearby temporary
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storage of contaminated mop heads, and the adjacent r adwaste truck loading bay remains a constant concern.
The inspector stated, and the HNS and licensee representatives concurred, that the equipment would be better located in a very low background area because of the low sensitivities operators are attempting to achieve.
This matter remains open pending relocation of the HNS DAW sorter, procedural revision, and resolution of operational methodology.
Radwaste Shi ment Incidents Licensee Procedure No.
PMP 3150 PCP.001, Radioactive Waste Process Control Manual, requires that all plant generated radioactive wastes be transferred, packaged and shipped such that radioactive waste shipment and burial regulations are satisfied.
Contrary to the above, on September 17, 1985, at the Barnwell waste burial facility, a State of South Carolina inspector found that the licensee was in violation of South Carolina Department of Health and Environmental Control Regulation No. 61-83, Section 1.2, for Radioactive Waste Shipment No. 0985-292-A from D.
C.
Cook to Barnwell, in that:
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The disposal container was found to have one end of the lifting cable not properly attached, contrary to the requirements of Condition No.
64 of South Carolina Radioactive Material License No. 097.
The shipping cask was found to contain loose contaminated material, contrary to requirements of Condition No.
60 of South Carolina Radioactive Material License No. 097.
The State of South Carolina, in a letter dated September 20, 1985, notified the licensee of the violations.
The licensee, in a letter dated October 8,
1985, informed the State of South Carolina that corrective measures had been taken in that:
(1) all liner lifting cable clevis and pin devices would be secured with safety wire as a positive means to prevent detachment, and (2) the receipt and inspection provisions of Procedure No.
12 THP 6040 PER.467, Radwaste Shipping Casks Handling, are to be reviewed in light of the loose material found in the cask.
Failure to adhere to Procedure No.
PMP 3150 PCP.001 is a violation of Technical Specification 6.8. 1 which requires adherence to the procedures covering Process Control Program implementation.
The corrective actions appear adequate to prevent recurrence.
(315/86001-11; 316/86001-11)
CFR 173.425(b)(6) requires that exclusive-use shipments of low specific activity (LSA) material must be braced so as to prevent shifting of lading.
Contrary to above, on April 25, 1986, at the Barnwell waste burial facility, a State of South Carolina inspector found that, due to inadequate blocking and bracing, all three packages on the flatbed trailer had undergone a shift of lading during the transportation of LSA exclusive-use shipment No. 0486-294-A from D.
C.
Cook to Barnwell.
The State of South Carolina, in a letter dated May 1, 1986, notified the licensee of the above violations.
The licensee and the shipment contractor sent representatives to Barnwell to investigate the incident.
As of May 15, 1986, the licensee had not formally responded to the State of South Carolina.
Failure to adhere to 49 CFR 173.425(b)(6) is a violation of 10 CFR 71. 5 which prohibits transport of any licensed material outside the confines of a plant or other place of use or delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR Parts 170-189.
(315/86001-12; 316/86001-12)
Two violations and no deviations were identified.
Radiation Protection Im rovement Pro ram At the conclusion of an inspection (Inspection Reports No. 50-315/85024; 50-316/85024)
on September 6, 1985, a meeting was held at the D.
C.
Cook plant between licensee representatives and members of the NRC/Region III staff to discuss specific weaknesses in the D.
C.
Cook radiation protection program which required corrective action.
At a subsequent meeting in the Region III office in Glen Ellyn, Illinois, on October 3, 1985, the licensee proposed a Radiation Protection Improvement Program (RPIP) to correct the identified weaknesses.
Region III confirmed the acceptability of the proposed RPIP to the licensee in a letter dated November 1, 1985.
A status update and additional information concerning RPIP was transmitted by the licensee to Region III in a letter dated March 4, 1986, in response to the SALP 5 report.
During this inspection, the inspectors reviewed the status and apparent effectiveness of RPIP.
Although, in general, the licensee was able to demonstrate that the program has been implemented in a timely manner and that some radiation protection improvements have resulted, it appears to the inspectors that some of the RPIP accomplishments are minor and that many areas still need significant improvement, for example:
(1) inspector concerns exist regarding staff stability and expertise which is a key component necessary for an effective RPIP (Section 5); (2) although radiation protection training appears improved (Section 7), there are still instances of poor performance (Section 10) and practices (Section 12); (3) progress has been made towards reducing the temporary storage of contaminated tools, equipment, and material in the auxiliary building, but a permanent solution is apparently needed (Section 10);
(4) examples of weaknesses in the control of contaminated material continue to exist (Section 10); (5) the ALARA program should be upgraded (Section 11); (6) formal numerical goals have not been established for exposure, contaminated areas, personnel contamination, etc.
(Section 11);
and (7) although the RDR program seems to be used properly (Section 13),
more effort should be made to ascertain and correct generic root causes.
Other'mprovement items which need attention are listed in Section 12.
The status and effectiveness of RPIP will continue to be reviewed during future inspections.
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The inspect ors met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on May 9, 1986, arid by telephone through May 29, 1986.
The inspectors summarized the scope and findings of the inspection, including the three violations.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.
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