IR 05000315/1988019
| ML17325A917 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/25/1988 |
| From: | Greger L, Michael Kunowski NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17325A916 | List: |
| References | |
| 50-315-88-19, 50-316-88-22, NUDOCS 8809010131 | |
| Download: ML17325A917 (15) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/88019(DRSS);
50-316/88022(DRSS)
Docket Nos. 50-315; 50-316 Licensee:
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Licenses No. DPR-58; DPR-74 Facility Name:
D.C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.C.
Cook Site, Bridgman, Michigan Inspection Conducted:
July 25 through August 16, 1988 Inspector:
M. A. Kunowski Accompanying Inspector:
W.
W.
Ogg Approved By:
L.
Ro r
Greger, Chief Facilities Radiation Protection Section ate Ins ection Summar Ins ection on Jul 25 throu h Au ust 16, 1988 (Re orts No. 50-315/88019(DRSS);
di p
i f
1 ii 'i protection program during an outage for repair/replacement of the Unit 2 steam generators including:
organization and management controls (IP 83722); audits and appraisals (IP 83729);
program changes (IP 83729); planning and preparation (IP 83729); training and qualifications (IP 83729); external exposure control ( IP 83729); internal exposure control (IP 83729); control of radioactive materials and contamination, surveys, and monitoring (IP 83729);
and maintaining occupational exposure ALARA (IP 83729).
The inspection also included a revi'ew of allegations concerning respiratory protection requirements for a job and an individual's exposure records.
Results:
No violations were identified.
The allegations could not be substantiated.
Within the scope of the inspection, radiological controls for the steam generator repair/replacement outage appeared good.
880'piOi013i 880828)
PDR ADDC< 050003i5
PNU
DETAILS Persons Contacted W.
G. Smith, Jr., Plant Manager
- L. S.
Gibson, Assistant Plant Manager, Technical
- J. White, Steam Generator Repair Project (SGRP), Site Project Manager
- S. Brewer, Section Manager Radiological Support
- S. Klementowicz, Project Health Physicist, SGRP M. Lesinski, Project Radiation Protection Coordinator, SGRP K. Barr, Project. ALARA Coordinator, SGRP R. Sexton, Project ALARA Coordinator, SGRP J.
Epperson, Radiation Protection'upervisor, SGRP
- J.
Kambach, Radiation Protection Supervisor, SGRP B. Hickey, Prism System Supervisor, SGRP J. Tozser, Dosimetry and Records Supervisor, SGRP D. Eldridge, Training Supervisor, SGRP D. Allen, Radiation Protection Supervisor
~D.
Loope, Plant Radiation Protection Supervisor
- B. Svensson, Licensing Activity Coordinator M.
Gumns, Technical Physical Sciences, Administrative Compliance Coordinator
- B. A. Jepkema, gA Auditor.
J. Heller, NRC Resident Inspector
"B. Jorgensen, NRC Senior Resident Inspector
"Denotes those present at the onsite exit meeting on July 29, 1988.
The inspectors also contacted other members of the licensee's staff.
General The inspection was conducted to review aspects of the licensee's radiation protection program during an outage to repair/replace four steam generators in Unit 2, including organization and management controls; audits and appraisals; program changes; planning and preparation; training and qualifications; external exposure control; internal exposure control; control of radioactive materials and contamination, surveys and monitoring; and maintaining occupational exposure ALARA.
Also reviewed were allegations regarding respiratory protection requirements for a job conducted in 1982 and the availability of an individual's exposure records.
Aspects of the licensee's radiation protection program for the steam generator repair project (SGRP)
have been reviewed previously by regional specialists (see Inspection Reports No. 50-315/88011(DRSS);
50-316/88013(DRSS)
and No. 50-315/88012(DRP);
50-316/88014(DRP)),
and continue to be reviewed by the NRC resident inspectors as part of their routine inspection activities.
The SGRP has progressed to where the
reactor coolant piping has been cut and two of the four steam drums (upper assemblies of the steam generators)
have been removed and relocated to the turbine building south trackway.
Or anization and Mana ement Controls (IP 83722)
The inspectors reviewed the licensee's organization and management controls for the radiation protection program, including changes in the organizational structure and staffing, oversight of contractor outage activities, effectiveness of procedures, and experience concerning self-identification and correction of program implementation weaknesses.
The organization and staffing level of the radiation protection (RP) staff of the SGRP has remained relatively stable, with only minor attrition of technicians, the reassignment of the dosimetry records manager to the ALARA group, and the promotion of the corporate Section Manager for Radiological Support to manager of Nuclear Safety and Licensing.
None 'of the changes are expected to reduce the effectiveness of the SGRP radiation protection program.
Currently, there are approximately 110 radiation protection technicians, 30 support technicians, 14 radwaste technicians, and 4 decontamination facility operators.
Management is provided by approximately 20 contractor, corporate, and station health physicists.
According to a licensee representative, the SGRP manager located at the corporate office requires regular containment entries by SGRP onsite managers to ensure that the managers stay aware of activities in the containment.
The corporate manager reviews compliance with this requirement during frequent visits to the site by reviewing printouts of records of 'entries from the SGRP's PRISM dose tracking system.
The SGRP has been in RP control of the Unit 2 containment since June 20, 1988.
Since then, interface of the SGRP RP with the project main contractor, M.
K. Ferguson, and with the station has been good.
Major interface activities between SGRP RP and the station involve ongoing tours and maintenance by station personnel in the Unit 2 containment, coordination of containment purge cycling with station operations, and preparation for and movement of the contaminated steam generator lower assemblies from containment to the storage building located outside the protected area.
No violations or-deviations were identified.
Audits and A
raisals The inspectors selectively reviewed the results of audits/appraisals of the SGRP RP program.
These audits/appraisals have been conducted by the SGRP RP staff, by the corporate and SGRP gA staffs, by the American Nuclear Insurers, and by industry groups.
The focus of the audits/appraisals have ranged from a review of'ompliance with specific procedural requirements and commitments to the NRC and others to broader scope programmatic reviews.
The results of the audits and appraisals
reviewed by the inspectors indicated no major problems with the SGRP RP program.
The frequency and focus of the audits/appraisals and the licensee's responses to resulting observations and findings appeared adequate.
Pro ram Chan es IP 83729)
The inspectors reviewed changes in organization, personnel, facilities, equipment, and procedures since the last inspection of the SGRP RP program (Inspection Reports No. 50-315/88012(DRP);
50-316/88014(DRP)).
Changes in organization and personnel are discussed in Section
~
The inspectors selectively reviewed changes to the RP procedures developed for the SGRP.
These procedures are applicable only to SGRP; however, the procedures and subsequent revisions are reviewed by the plant radiation protection supervisor as well as by SGRP personnel.
The review indicated that the revisions were made in response to problems identified during initial implementation of the procedures and to audit findings.
The inspectors noted a change in the designated work and personnel traffic areas near the main access control desk.
Licensee representatives stated that the change has resulted in better space utilization and personnel traffic control.
'o violations or problems were identified.
Plannin and Pre aration (IP 83729)
Planning and preparation for the SGRP was reviewed in Inspection Reports No. 50-315/88012(DRP);
50-316/88014(DRP).
Aspects were again reviewed to verify that the licensee is continuing to plan and prepare for routine and special jobs.
Work packages for upcoming jobs are reviewed by a committee of SGRP managers, including the two ALARA coordinators.
In addition, jobs estimated to cost 1.5 person-rem are given formal ALARA reviews.
Special training given to workers included the use of a mockup channel head and reactor coolant piping on which to practice entries; installation and removal of purge bags, SILTEMP pillows, and splatter shields; and to practice plasma-arc cutting.
The licensee has attributed the low dose total of the cutting of reactor coolant legs (approximately 23 person-rem actual compared to 105 estimated)
to the low dose rates in the channel heads.and pipes and to the efficiency of the tabletop planning and mockup training.
See Section ll for additional discussion of the cutting of the reactor coolant piping.
No violations or deviations were identifie Trainin and ualifications of New Personnel IP 83729 SGRP workers needing unescorted access to radiologically controlled areas must attend a nuclear general employee training (NGET) course offered by SGRP instructors.
Workers who had taken the station's NGET or requal NGET within a year were required to take the SGRP version of a 'requal NGET.
SGRP representatives stated that the SGRP version of the requal NGET was required to inform workers of differences between the operations of the SGRP and normal station activities; the requal training was approximately four hours in length with students required to demonstrate proper donning and removal of protective clothing (PC), zeroing a pocket dosimeter, and use of a frisker.
Successful completion of a 40 question examination was also required.
The NRC inspectors received the requal NGET.
The instructor was knowledgeable and enthusiastic.
For workers with limited or no experience in nuclear power plants, a day-long NGET course is required.
Completion of this course requires passing a written exam and demonstration of the proper donning and removal of PCs and use of a frisker.
Workers with nuclear power plant experience who have not had the station's NGET or requal NGET within a year can take a written challenge exam.
A passing score on the exam allows the worker to forego the full-day NGET course and take the requal NGET.
Observations by the inspectors and discussions with SGRP personnel indicate the training given to workers meets regulatory requirements.
~
No violations or deviations were identified.
External Ex osure Control IP 83729 The inspectors reviewed the licensee's SGRP's external exposure control and personal dosimetry programs including:
routine and multiple dosimetry use; and required records, reports, and notifications.
The SGRP received NVLAP accreditation for its Panasonic dosimetry system on April 28, 1988.
Personnel dose records and RWP dose information are managed with a software program (PRISM) provided by the contractor who also provided most of the SGRP RP managers.
Exposure records are maintained at, and dosimeters are distributed from, facilities in the station's training building adjacent to the station's dosimetry facilities.
The inspectors observed the use of dosimeters in radiologically controlled areas.
No.problems were noted.
Dose records, including daily printouts of workers'elf-reading dosimeter doses; NRC Form-4 records; administrative dose-limit extension records; and termination reports were selectively reviewed.
The inspectors noted several instances where evaluations were performed and documented to resolve unexpected discrepancies between SRD monthly dose totals and TLD dose determinations.
(The PRISM system automatically compares the two totals and flags the printout for individuals whose totals or the value of the comparison exceed certain values.)
The licensee has determined, after testing
SRDs, re-reading TLDs, and questioning individuals who had these discrepancies, that the dosimeters were functioning properly, but that individuals were incorrectly reporting the SRD readings to the access control personnel when entering and leaving the controlled area.
The licensee stated that requiring workers to re-zero the SRD for each entry probably contributed to the incor rect reporting, in that after a quick unsuccessful attempt to zero the SRD, an individual may have reported a
reading of zero when the SRD actually read a higher value.
Licensee representatives also stated that some workers may have simply reported higher readings than actually indicated on the SRD in a belief that the SRDs did not accurately indicate dose.
The licensee has subsequently rescinded the policy requiring re-zeroing for each entry.
In addition to testing dosimeters and revising the re-zeroing policy, the licensee has emphasized NGET instructions on the use and limitations of dosimeters, and spot checks the accuracy of SRD readings reported by workers entering and exiting the radiologically controlled areas.
The licensee's evaluation and corrective actions for this matter appeared appropriate.
No violations or deviations were identified.
9.
Internal Ex osure Control and Assessment IP 83729 The inspectors reviewed the licensee's internal exposure control and assessment programs, including:
determination whether engineering controls, respiratory equipment, and assessment of intakes meet regulatory requirements; and planning and preparation for steam generator repair tasks including ALARA considerations.
The inspectors observed engineering controls in use to reduce internal exposure, for example:
~
Double HEPA filtered exhausts connected to legs of the steam generators reduced airborne activity in the channel head to less than 1/4 MPC.
~
The construction of temporary containments in the turbine building for modification of the four upper assemblies, and in the lower containment for the cutting of the reactor coolant piping.
~
, The capping of the lower assembly openings, and the waxing of the lower assembly external surfaces to contain surface contamination.
The licensee representatives stated that there has been little or no airborne radioactivity and no intake/uptake has exceeded 1X HPBB.
Air sample results and whole body count records reviewed by the inspectors (also see Section 10) supported this statement.
No violations or deviations were identifie.
Control of Radioactive Materials and Contamination IP 83729)
The ins ectors reviewed the licensee's ro ram for control o
p p
g f radioactive materials and contamination, including:
instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey data; effectiveness of methods of control of radioactive and contaminated materials; management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.
To date 85,000 RWP-hours have been expended at the SGRP.
a.
E ui ment Its Use and Calibration The inspectors examined radiation detection and radiological control equipment and instrumentation, their types, complement, and calibration along with 24 controlling procedures.
The licensee stated that the procedures were written following the appropriate ANSI standards.
The licensee has installed a commercial portable survey meter calibrator and stated that dose rates are sufficiently high to calibrate all ranges.
The inspectors noted that an internal audit identified a source-check documentation problem; this problem had been corrected.
Contamination of issued survey meters is strictly controlled.
Survey meters to be used in contaminated areas are issued and used inside transparent green plastic bags.
Only radiation protection technicians (RPTs) are issued survey meters and the technician using the survey meter is responsible for its decontamination if it becomes contaminated.
The inspectors noted that the standards used for calibrating electronic instruments (e. g., voltmeters), air flowmeters, area and process monitors, and radiation count rate and dose rate meters were traceable to the National Bureau of Standards.
b.
Steam Generator Insulation Removal The inspectors reviewed the radiological controls and surveillances for insulation removed during May and June 1988; RWP 2018,
"Remove/
Bag All Insulation from Steam Generators" governed the work.
The inspectors interviewed one of tlie four radiation protection foremen who covered the job.
At the beginning of the work, and for any subsequent insulation removal involving possibly high levels of contamination, the RWP required double PCs.
Full-face respirators were worn at all times during the steam generator insulation removal work.
However, insulation and external steam generator contamination was relatively high on only No.
2 steam generator:
contamination levels were up to 1 rad/100 cm~ smearable.
On Nos.
1, 3, and 4 no
contamination survey yielded a count rate higher than 10 mrad/100 cm2 smearable.
Any highly contaminated insulation padding was discarded as radwaste.
An RP supervisor stated that prior to steam generator re-insulation, stored bags of damaged mirror insulation will be repaired unless the damage is extensive or the insulation is highly contaminated; those not highly contaminated will be wiped down sufficiently and repaired in a controlled containment (e.g., tent with HEPA exhaust).
RWP work tasks included the building of platforms and contiguous areas for support of wiping down mirror insulation prior to bagging it for storage.
The licensee stressed at pre-job briefings that all information from bags of insulation must be transferred to any outer bags.
The inspectors reviewed representative samples of steam generator de-insulation RWP access logs which showed worker task doses; examples of air sample computer printouts, which documented airborne concentrations and subsequent whole body counts of insulation workers, which showed no detectable inhalations.
Airborne activity and doses were not significant during de-insulation tasks.
The inspectors consider ALARA and surveillance practices to be good; no problems with steam generator insulation removal were found.
er Assemblies Surveillances The internals of the upper assemblies contain mostly fixed contamination of a few mrad/hr;.smearable contamination was a
few thousand dpm/100 cm~.
The licensee stated that no significant alpha contamination has been found.
During the inspection, two upper assemblies had been placed on the ground floor level of the turbine building.
Later, the third and fourth upper assemblies were brought over via a load-leveling trailer.
Framed tents equipped with HEPA exhausts were constructed around each assembly.
Personnel Contamination/Hot Particles The inspectors reviewed procedure RPAP-650,'"Personnel Contamination Monitoring and Decontamination,"
and RPAP-651,
"Contaminated Skin Dose Assessment,"
as well as a representative sampling of the
personnel contamination events to date.
The project health physicist stated that most personnel contaminations had been of deconners and shielders, and this statement was confirmed by the inspectors'ecord reviews.
About 15K of the personnel contaminations were from discrete particles.
Licensee representatives stated that when hot particles are found on personnel, RP surveys the area in which the individuals worked using cleaning cloths in order to search for other particles.
To
date, however, additional particles have not been found.
The inspectors noted that "frisker watches" were established after several workers were observed by licensee personnel to not frisk properly.
I For personnel contaminations involving contamination above the shoulders, a whole-body count is required by procedure.
The inspectors selectively reviewed records of personnel who had contamination above the shoulders.
The personnel were whole body counted as required, and all had a whole body burden documented as OX.
tl The inspectors also reviewed the dose calculation for an individual
.who had a 0.26 pCi cobalt-60 particle on his skin.
The resultant dose, calculated using the VARSKIN software program, was 3.2 rem.
No problems were noted by the inspectors.
No violations or deviations were identified.
11.
Maintainin Occu ational Ex osures ALARA (IP 83729 The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including:
changes in ALARA policy and procedures, worker awareness and involvement in the ALARA program, the establishment and realization of goals and objectives; and management techniques used to implement the program.
The inspectors'bservations in radiologically controlled areas, discussions with SGRP RP personnel and other workers, and a selective review of ALARA program procedures, equipment, and records indicated the SGRP has a strong ALARA program.
As of July 26, 1988, the collective dose for the SGRP was 201 person-rem, significantly below the estimated total of 286 person-rem.
Considering the low dose rates and contamination levels encountered, and assuming that the relatively smooth preparation for and completion of tasks will continue, the final collective dose for the SGRP should be well below the goal of 1,733 person-rem.
Two of the work packages/RWPs reviewed by the inspectors are'discussed briefly below.
The licensee can extract dose information from the PRISM system using any of several parameters, such as RWP number, an individual,',s name, date, and work location.
During a routine review of dose totals for certain RWPs, the licensee noticed that the dose total for the RWP for the lower containment tool crib was higher than expected.
Temporary shielding was subsequently installed in a section of the crib and instructions were given to the crib attendants to spend as much time as possible in the shielded section.
As a result of these efforts, the dose rate in the shielded area was reduced from about 5 mR/hr to 1 mR/hr; and the average daily dose total for the RWP was reduced by at least 30 mrem.to approximately 25 mre In the "Steam Generator Repair Report," submitted by the licensee and dated November 4, 1986, the licensee estimated that the cutting of the eight reactor coolant pipes (one hot leg and one cold leg per steam generator)
and associated preparatory work would result in 105.4 person-rem.
This estimate was based on information from other steam generator replacement jobs and surveys of the reactor coolant pipes at D. C.
Cook.
A revised estimate of 31 person-rem was made just prior to the start of the cutting using current survey data.
For the initial cut, the licensee found that the thickness of metal that had to be cut was twice what had been planned on and that slag produced during the cut rolled back to, the starter hole and extinguished the cutting flame.
For the remaining cuts, the licensee adjusted the person-hour estimate to account for the different pipe thickness that needed to be cut and to redrill starter holes on the three remaining legs of steam generators
and 4.
Starter holes had not yet been drilled on the legs of steam generators 2 and 3 so there was no need for redrilling; however, the positions of the holes was changed from what was originally planned.
Water was maintained in the secondary side of the lower assemblies during the cuts.
Licensee representatives stated that the actual dose total for the job was about 23 person-rems.
A review by the inspectors of pre-and post-job briefings and in-progress ALARA reviews, and discussions with workers indicated that no major problems, high dose rates, or contamination levels were encountered during the cuts.
No violations or deviations were identified.
~
~
12.
All e ation Fol 1 owu AMS No. RIII-88-A-0053 Discussed below are two allegations received by the NRC Region III Office, relating to the radiation protection program-at D.C.
Cook, which were evaluated during this inspection.
The evaluation consisted of record and procedure review and interviews with licensee personnel.
Alle ation:
The radiation protection staff did not require the alleger to use respiratory protection equipment for steam generator work done in 1982 although the alleger was required to wear respiratory protection equipment for similar work both before and after the work in 1982.
Discussion:
The licensee's program for establishing and implementing respiratory protection requirements is reviewed by NRC inspectors approximately annually.
Reviews conducted over-the preceding several years are documented in Inspection Reports Nos.
315/88011, 316/88013; 315/87002, 316/87002; 315/86013, 316/86013; 315/86001, 316/86001; and 315/85011, 316/85011.
Similarly, a review of NRC inspection reports for 1982'(315/82-13; 316/82-13; 315/83-08; and 316/83-09)
concerning the radiation protection program at D.C.
Cook, indicated no major problems with the internal exposure control methodology of the station, including respiratory protection.
These reviews have not identified any significant problems.
While these findings do not eliminate the possibility of isolated problems, they provide assurance that the respiratory protection program is generally implemented satisfactorily.
Significant isolated problems in the respiratory protection program implementation are identifiable through the licensee's whole body count program.
The inspectors reviewed the alleger's whole-body count records to determine if a significant intake of radioactive material may have occurred for the referenced work.
Records indicate that whole-body counts of the alleger were conducted in April 1982 and February 1983.
The results of the counts did not indicate the presence of radioactive material in the alleger; which provides reasonable assurance that a
significant breakdown of his respiratory protection did not occur.
~Findin s:
While no determination was made of the validity of the allegation that respiratory protection equipment was not consistently required for steam generator work, no significant discrepancies were identified with the licensee's respiratory protection program and the alleger had not experienced any significant respiratory protection breakdowns.
No regulatory problems or licensee program weaknesses were identified.
b.
Alle ation:
D.C.
Cook is hiding the alleger's exposure history from the alleger in that D.C.
Cook did not accurately record the alleger's social security number on exposure records.
Discussion:
In correspondence with the NRC Region III Office, the alleger noted his social security number and the "incorrect" social security number allegedly recorded on his exposure records.
The inspectors'eview of the licensee's exposure records for the alleger disclosed that his correct social security number was recorded.
No exposure records were found for the "incorrect" social security number noted by the alleger.
During the inspectors'eview of licensee records it was noted that the alleger had incorrectly listed his social security number on three Form NRC-4s, dated and signed by him on August 27, and December 9, 1982, and May 27, 1984.
The social security numbers on the August and December 1982 records had an incorrect number in the last digit position of the social security number, and on the May 1984 record no number was entered in the last digit position.
As noted above, these inaccuracies were not carried over onto the licensee's exposure records.
The licensee searched all exposure and NGET training records and found no record listing the social security number that the. alleger stated had been erroneously listed on his records.
~Findin s:
The allegation was not substantiated.
No violations or deviations were identifie ~
~
13.
Surveillance - Plant Tours The following were identified during tours of the plant:
The inspectors observed the temporary outdoor storage area of concrete pieces, properly tagged and labeled, which had been a
part of enclosures around the steam generators.
After removal of the surface layer, the concrete pieces containing only trace levels of radioactivity, if any, will be relocated to a controlled storage area outside the protected area fence.
The inspectors inspected the licensee's trailer-housed tool cleaning facility.
The licensee representative stated that to avoid EPA conflict no Freon will be used, only grit-blasting.
Also, nearby the inspectors noted the large trailer setup to clean project rigging equipment, e.g.,
cables.
c.
The licensee has constructed a new radwaste building; it is also used for loading/unloading SGRP laundry which is cleaned offsite.
The inspectors noted that the former radwaste drumming room is used for sorting trash.
d.
The inspectors examined the incoming cleaned-laundry survey setup which includes a herculite covered table and handheld pancake friskers.
The licensee has increased survey efforts of incoming clean laundry because a hot particle was recently found in a
"clean" rubber glove.
e.
The inspectors conducted radiation and contamination surveys of selected plant areas using NRC and licensee survey instruments; readings were in general agreement with posted licensee data.
No smears, including those taken inside containment, had any detectable contamination.
No violations or deviations were identified.
The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection to discuss the results of the inspection.
The license acknowledged the inspectors'rief statement of those results and a comment that SGRP had a strong radiation protection/ALARA program.
'12