IR 05000315/1989003
| ML17325B167 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/24/1989 |
| From: | Bocanegra R, Januska A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17325B166 | List: |
| References | |
| 50-315-89-03, 50-315-89-3, 50-316-89-03, 50-316-89-3, NUDOCS 8903080078 | |
| Download: ML17325B167 (13) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No.
50-315/89003(DRSS);
50-316/89003(DRSS)
Docket Nos.
50-315; 50-316 Licensee:
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Licenses No.
D.C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.C.
Cook Site, Bridgman, Michigan Inspection Conducted:
January 12 through February 10, 1989 Inspectors:
A.
G. Januska J
R.
Bocanegra ate ate Accompanied By:
M.
C.
Schumacher (January 19-20, 1989)
F P?Mgl~ r~
Approved By:
M.
C.
Schumacher, Chief Radiological Controls and Chemistry Section ate ate Ins ection Summar Ins ection on Januar 12 throu h Februar
1989 (Re orts No.
50-315/89003(DRSS)
50-316 89003 DRSS df p
f f
ff including:
plant chemistry organization, management controls, training, and qualifications (IP 83722, 83723, 84750), quality assurance, confirmatory measurements for in-plant radiochemical analysis, and post accident sampling analysis (IP 84725, 84750);
environmental monitoring results (IP 80721, 84750);
and action taken on open items and a Licensee Event Report (LER) (IP 92701).
Results:
Laboratory quality control and confirmatory measurements results were generally good.
A minor problem regarding Sb-122 quantification was discovered and corrected.
The quality of the licensee's internal audits was found to be above average.
Four open items and one LER were closed out during this inspection.
No violations or deviations were identifie DETAILS Persons Contacted T. Andert, Physical Science Specialist D. Avery, Training Specialist J.
Car lson, Chemical Supervisor S. Coffing, Senior Chemical Technician
"L. Gibson, Assistant Plant Manager
", D. Fitzgerald, Environmental Supervisor
- L. Holmes, gA Auditor-AEPSC
"K. Haglund, Plant Chemical Supervisor
- +M. Gumns, Administrative Compliance Coordinator
"'H. Jones, Radiological Support Services-AEPSC
"+R. Looker, Chemical Supervisor L. Rogers, Environmental Specialist S.
McLea, Chemical Supervisor
"T. Postlewait, Technical Engineering Superintendent D.
Loope, Radiation Protection Supervisor
- J. Rutkowski, Assistant Plant Manager
- B. Svenson, Licensing Activity Coordinator
"J. Wojci k, Superintendent-TSP
- J. Passehl, NRC Resident Inspector
- Present at the exit meeting.
+Telephone conversations on January 26-27 and February 1, 1989.
'Telephone conversation on February 10, 1989.
Licensee Action on Previousl Identified Findin s (IP 92701)
(Closed)
Licensee Event Re ort 50-315/88009 50-316/89009):
On September 27, 1988, dur ing the uarter y adiochemistry echnical Review it was determined that the Lower Limit of Detection for gross radioactivity had not been met for compensatory samples for Radioactive Liquid Effluent Monitors and the Turbine Building Sump Composite Sampler Flow Monitor.
This was caused when the Technical Specification (T/S) value "E-7" was interpreted to mean the range E-7 instead of 1.0E-7.
A review performed by the licensee found that although the LLD was not met, the plant was still within the limits of 10 CFR 20 Appendix B, Table II, Column 2.
The licensee has changed procedures to perform a 4000 second analysis on a
4 liter Marinelli sample within 30 minutes after collection in order to meet the LLD.
(Closed)
0 en Item (315/86038-03 316/86038-03):
Generate new nuclide ibraries dedicated to requirements be ore the next required EBAR measurement.
The licensee has prepared nuclide libraries for liquid, gas, and crud to be used when determining EBA (Cl osed)
0 en Item 315/87030-03 316/87030-03):
Correct
THP 6020 LAB.048 Tab e
1 values.
Use new values and recalculate EBAR for last two T/S requirements to demonstrate compliance.
The licensee revised Table 1 which was in error primarily for beta particles and also corrected a calculational statement in Section 6.3.
A review of the application of the new values indicated higher values and compliance with the T/S limit, however, it was noted that beta energies of several positron emitting nuclides were omitted.
The licensee revised
THP 6020 LAB.048 to allow incorporation of Sr-89, Sr-90, and Y-90 by determining ratio factors between these nuclides and Cs-137.
The inspector reviewed the results of the first semiannual analysis where these ratios were determined.
(Closed)
0 en Item (315/87030-01 316/87030-01):
Completely recal ibr ate etector and reca librate etector or gas by November 30, 1987.
Detector 3 was recalibrated for all nongaseous geometries between November 15-18, 1987.
A gas standard in the licensee's possession, when opened was found to be suspect.
The licensee acquired a
new standard and the gas calibrations were completed on December 28, 1987.
(Closed)
0 en Item (315/87030-02.
316/87030-02):
Analyze a liquid sample'for gross beta, H-
,
r-
,
r-
,
an e-and report the results to Region III.
Results of the sample comparisons are given in Table 1; the comparison criteria are given in Attachment 1.
One disagreement, gross beta, resulted where the licensee result is conservative by a factor of 1.82 over the NRC Reference Laboratory result.
No reason for the disagreement is apparent.
This will be examined further with the results of a monitor tank sample collected during this inspection.
Hang ement Controls Or anization and Trainin (IP 83722 83723)
The Chemical Section has undergone some changes since the previous inspection in this area~.
The Plant Chemical Supervisor (PCS)
was promoted to Technical Physical Sciences Superintendent and has been replaced by a former Technical Physical Science Chemistry Supervisor.
A new Chemical Supervisor is ANSI N18. 1-1971 qualified in accordance with the T/S.
One additional position, a Physical Science Specialist, now reports to the new PCS and a Chemical Supervisor on loan to the Operations Department has been transferred to the Operations Department.
Promotions and transfers have resulted in the loss of two Senior Technician positions.
The exempt staff plant employment now averages 9. 1 years and the technicians average 5.4 years.
No violations or deviations were identified.
~Region III Inspection Reports No. 50-315/88010; 50-316/8801.
Confirmator Measurements IP 84725.
84750)
~
~
The inspectors examined the licensee's 1988 intercomparison results from a crosscheck program with an outside vendor.
The samples analyzed included a liquid for gamma analysis, an iodine cartridge, a gas and liquid for gross alpha, beta, and tritium.
The results for the three quarters available were very good with the licensee expanding the scope of the program in the third quarter by analyzing the appropriate samples on all detectors and performing multiple counts on gross alpha, gross beta, and tritium.
The inspectors noted a small conservative bias for gross beta in the first quarter and a conservative bias of 1.25 in the second and third quarters.
The bias also appeared in the results of a sample previously split with the NRC (Section 2).
The licensee acknowledged the inspector's comments and will examine the quality of the standard being used for this analysis.
The inspectors reviewed the radioactivity measurements laboratory quality assurance program including the physical facilities, laboratory operations, and procedures.
Housekeeping was generally good; laboratory working space appeared adequate but limited.
A sampling of pertinent laboratory procedures found in Technical Head Procedure THP 6020 LAB.044 and THP 6020 LAB. 175 was reviewed for technical content by the inspectors.
The inspectors also reviewed germanium detector calibration records for 1988.
The inspectors verified that calibrations for all release geometries being used for radiological effluent analyses were cur rent.
A Chemical Technician was observed and evaluated on sample acquisition, preparation, analysis, and general laboratory practices.
The technician appeared to be very knowledgeable, followed proper laboratory procedures, and took appropriate precautions when handling radioactive materials.
Expired standard reagents were found in the laboratory by the inspectors.
The reagents were then promptly disposed of by a technician.
Although the expiration date was only one day old, the inspectors noted that expired reagents had been found in the laboratory during two previous gA audits performed by the licensee.
The inspectors notified licensee management of the expired reagents and questioned the adequacy of earlier corrective action.
The licensee responded that this matter will receive renewed emphasis.
Sam le S lit Six samples (air particulate, charcoal adsorber, spiked charcoal adsorber, reactor coolant, crud, and gas)
were analyzed for gamma emitting isotopes by the licensee and in the Region III Mobile Laboratory onsite.
Comparisons were made with the licensee's three Radiochemistry detectors, and one off-site detector.
The licensee achieved 46 agreements in 51 comparisons as listed in Table 2; the comparison criteria are given in Attachment The last air particulate filter and charcoal adsorber analyzed by the licensee prior to the start of the inspection were analyzed by the inspectors.
The results (not shown in Table 2) confirmed the licensee results of no detectable activity on either filter.
A spiked charcoal adsorber was treated as an unknown and analyzed on two licensee detectors and the results compared to the NRC analysis yielding agreements for all nuclides present.
A filtered reactor coolant sample was analyzed on Oetector 4 resulting in disagreement for Sb-122 when the licensee's counting system failed to quantify that nuclide.
After deleting the Oetector 4 "confirmation peak" criterion in the nuclide library, the system was able to accurately quantify Sb-122.
The same library problem was observed and corrected during the analysis o'f the unfiltered reactor coolant and the crud filter sample.
Zr-97 and Xe-133 results were in disagreement for the liquid waste analysis and the gas analysis respectively.
Counting parameters, libraries, and geometries were verified and interfering nuclides stripped, but no apparent reason for the disagreement could be established.
A portion of a monitor tank sample will be analyzed for gross beta, H-3, Sr-89, Sr-90, and Fe-55 by the licensee and the results reported to Region III for comparison with an analysis by the NRC Reference Laboratory on a split of the sample.
(Open Item 50-315/89003-01; 50-316/89003"01)
Reviews and Audits The inspectors reviewed corporate QA Audit No.
QA-88-16 performed on March 28 through May 10, 1988.
The audit was very detailed and extensive and identified 10 findings.
One of the findings resulted in LER 50-315/88009; 50-316/88009 being issued.
Corrective action on all the findings appeared timely and technically acceptable.
The inspectors also reviewed several licensee identified problems documented as problem reports.
i)
Problem Re ort No.88-132 and No. 88-185:
The licensee issued Problem Reports when a Radio ogica nvironmental Monitoring Program (REMP) charcoal cartridge sample from station ONS6 was found to be missing for the period of 2/29/88 to 3/7/88 (88-132)
and from station ONS4 for the period 4/4/88 to 4/ll/88 (88-185).
The inspectors reviewed the licensee's preventive actions and discussed them with Environmental personnel.
The licensee's actions and preventive actions were proper and timely.
ii)
Problem Re ort No. 87-949:
The licensee noted, during a
ec naca peci icatson T/S) review, that the then current milk sampling program did not literally comply with Item 4a of T/S Table 3. 12-1.
The problem occurred when no milk samples were collected in Stevensvi lie or South Bend or sectors in which these cities are located because there were no willing
farmers who wished to participate in the milk sampling program.
The licensee submitted an application for a T/S amendment on February 1, 1988 and received Amendment Nos.
119 and 105 'in a letter dated December 6,
1988.
The amendment clarifies the milk sampling program requirements and now provides for vegetation sampling as a replacement for milk sampling if the required number of indicator and background milk samples cannot be obtained.
iv)
) Problem Re ort No. 88-434:
During the Second Quarter ad>oc emistry echn>ca Review the licensee determined that its LLD calculation was not consistent with the T/S LLD calculation in its use of only the centroid channel of the energy peak to determine background manually, and in misinterpreting the factor Y to mean gamma-ray branching intensity instead of chemical yield.
The licensee found that after recalculating the LLD's, all T/S'LD limits were met except for Lake/Circ.
The licensee now sends these samples to a contract laboratory for analysis in order to meet the LLD limits.
The LLD calculation in Procedure THP 6020 LAB.175 was revised to make it consistent with the T/S.
Problem Re ort No. 88-721:
During a Quarterly Radiochemistry eview t e licensee etermined that effluent releases of short lived nuclides which are determined from composite samples may have been under-reported in Effluent Release Reports from 1976 through the first half of 1988 owing to improper decay correction by the contractor performing the analyses.
The licensee has recalculated activity for release for the isotope of principal interest (Sr-89)
and found that the corrected values are well below the T/S limit.
The inspector reviewed the licensee calculations and determined they were conservatively done.
d.
Post Accident Sam lin Anal sis The inspectors discussed the post accident sampling system (PASS),
its operation, and maintenance with the licensee.
The system is not used to collect routine samples.
In-line oxygen and pH meters are calibrated, the gas chromatograph calibration is verified, and the unit is functionally tested quarterly by the licensee.
NUS performs semiannual calibrations of pH, dissolved oxygen, fluoroborate, and hydrogen, and checks the repeatabi lity of the gas chromatograph and verifies the liquid dilution factor.
A review of the 1988 semiannual PASS calibration and preventative maintenance reports indicate that the contractor implements a comprehensive program and that except for one test, the system results are within acceptance criteria.
In addition, the system is used by all Chemical Technicians every 12-18 months to satisfy the training/retraining requirement of completing five Qualification (Qual) Cards.
The Qual Cards require hands-on operation and calibration of this system.
Although a
formal gC program for routinely assuring the operability is not in place, the quarterly and semiannual tests, augmented by the gual Card requirements should provide for a reliable system.
No violations or deviations were identified.
5.
Environmental Monitorin (IP 80721)
The inspectors reviewed the licensee's 1987 Radiological Environmental Monitoring Program and noted the absence of fourth quarter thermoluminescent dosimeter (TLD) results and some unexplained positive results.
The licensee reviewed the positive TLD results and concluded that the readings were due to an'in-transit exposure, since the control badge also showed a comparable exposure.
Except for four groundwater sites, which have a history of positive results for tritium, no other results appear to be attributable to plant operation.
6.
~0en Items Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or both.
Open items disclosed during the inspection are discussed in Section 4.b.
7.
Exit Meetin IP 30703)
The inspectors met with licensee representatives denoted in Section
at the conclusion of the inspection on January 20, 1989.
The scope and findings of the inspection were discussed with emphasis on counting problems and Problem Reports.
The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
Licensee representatives did not identify any such documents or procedures as proprietary.
Attachments:
1.
Criteria for Comparing Analytical Measurements 2.
Table 1, Confirmatory Measurements Program Results, 4th quarter 1987 3.
Table 2, Confirmatory Measurements Program Results, 1st quarter 1989
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ATTACHMENT 2, CRITERIA FOR COMPARING ANALYTICALMEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.
In these criteria, the )udgment limits are variable in relation to the comparison of the NRC's value to its associated one sigma uncertainty.
As that ratio, referred to in this program as "Resolution", increases, the acceptability of a licensee's measurement should be aore selective.
Conversely, poorer agreement should be considered acceptable as the resolution decreases.
The values in the ratio criteria may be rounded to fewer significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptance.
'RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE
~Ar cement
<4 4 -
8-
16 -
51 - 200 200-0.4
- 2.5 0.5
- 2.0 0.6
- 1.66 0.75 - 1.33 0.80 - 1.25 0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides.
These may be factored into the acceptance criteria and identified on the data sheet.