IR 05000315/1989016
| ML17325B232 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/01/1989 |
| From: | Gill C, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17325B231 | List: |
| References | |
| TASK-2.F.1, TASK-TM 50-315-89-16, 50-316-89-17, IEIN-88-008, IEIN-88-022, IEIN-88-101, IEIN-88-22, IEIN-88-8, NUDOCS 8906160031 | |
| Download: ML17325B232 (12) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/89016(DRSS);
50-316/89017(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, Bridgman, Michigan Inspection Conducted:
April 24 through May 22, 1989 Inspector:
u3 C.. Gill
~/i'!gp Date Approved By:
u3.G,. <<~Q
.
G. Snell, Chief Emergency Preparedness and Effluents Section ate
Ins ection Summar Ins ection on A ril 24 throu h Ma
1989 Re orts No. 50-315/89016 DRSS No. 50-316 89017 DRSS Areas Ins ected:
Rout>ne, unannounced inspection of the radwaste/transportation program, inc uding:
organization and management controls (IP 83750, 84750),
training and qualifications (IP 83750, 84750),
gaseous radwaste (IP 84750, 84724), liquid radwaste (IP 84750, 84723), solid radwaste (IP 83750, 84750),
audits and appraisals (IP 83750, 84750), effluent reports (IP 84750), effluent control instrumentation (IP 84750, 93702), primary coolant radiochemistry (IP 84750), air cleaning systems (IP 84750),
and selected Information Notices (92701).
Results:
The organizational structure, management controls, staffing levels, and upper management support for the radwaste/transportation program appeared generally adequate.
One violation was identified (failure to report required information in the semiannual radioactive effluent release reports - Section 11);
however, because the provisions of Section V.A of Appendix C to 10 CFR Part
have been satisfied, a Notice of Violation will not be issued.
Weaknesses were perceived in the gaseous batch effluent release program (Section 6) and the radioactive effluent monitoring reliability program (Section 12).
Also unresolved items were identified regarding the apparently questionable acceptance criteria for HVAC system carbon adsorber surveillance tests (Section 14) and to track NRR resolution of variance requests regarding certain TMI Action Plan Items (Section 3).
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DETAILS Persons Contacted
¹"M. Ackerman, Engineer, AEPSC
¹ D. Black, Engineer, AEPSC
"D.Fitzgerald, Environmental Supervisor C. Flis, Senior Performance Engineer PD. Foster, Radioactive Material Specialist
¹ J. Fryer, Radioactive Material Control General Supervisor
~L. Gibson, Assistant Plant Manager, Technical Support M. Gumns, Administrative Compliance Coordinator
"R. Hennen, Nuclear Engineering Supervisor
¹"L. Holmes, Administrative Compliance Coordinator M. Horvath, AEPSC Site gA Supervisor J.
Jackson, Radiation Protection Training Specialist B. Jepkema, AEPSC Site gA Auditor
¹ S.
Klementowicz, Radiological Support Section Manager, AEPSC
¹"B. Lauzau, Nuclear Safety and Licensing, AEPSC M. Lester, Performance Engineer
"J.
Looker, Chemical Supervisor
"D. Loope, Plant Radiation Protection Supervisor
¹ W. MacRae, Radiological Support Scientist, AEPSC S.
McLea, Chemical Supervisor
- D. McWethy, Technical Engineering Performance Engineer D. Noble, Health Physicist
"R. Rickman, Technical Engineering ISI Supervisor
"W. Smith, Jr., Plant Manager
"B. Svensson, Licensing Activity Coordinator
¹ B, Zordell, Senior Chemical Technician B. Jorgensen, NRC Senior Resident Inspector D. Passehl, NRC Resident Inspector The inspector also contacted several other licensee and contractor employees including technicians and members of the technical and engineering staffs.
"Denotes those present at the onsite exit meeting on April 28, 1989.
¹Denotes those contacted by telephone during the period May 1-22, 1989.
General This inspection was conducted to review the radwaste/transportation program.
The inspection included tours of the onsite facilities, observation of work in progress, review of records, and discussions with licensee personne Licensee Action on Ins ection Findin s
Closed 0 en Item 315/85011-06 316/85011-05):
Two weaknesses related to an NRC Confsrmsng Order and NUREG-0737 compliance.
Since the licensee has apparently completed all NRC identified actions regarding this matter, this item is closed.
However, a
new unresolved item is being issued to track NRR resolution of the licensee's variance requests regarding TMI Action Plan (NUREG 0737) Item II'. 1 (Attachments 1, 2, and 3).
(Unreso1 ved Item 315/89016-01; 316/89017-01)
0 en Unresolved Item (315/87002-23.
316/87002-23):
Resolve CREVS operab)
1 ity concerns.
Thi s matter rema> ns unresol ved pending NRR review of a scheduled June 30, 1989 submittal by the licensee.
0 en Unresolved Item 315/89012-01 316/89012-01):
Regulatory concer ns regarding the fa>lure to >dentsfy the RS discharge as an effluent pathway to an unrestricted area.
This matter remains unresolved pending further licensee action which is scheduled for completion by June 16, 1989.
(Closed Violation (315/89016-03 316/89017-03:
Violation of T/S 6.9.1.9 failure to report requ)red
>nformat)on sn the'emiannual radioactive effluent release reports).
Because the provisions of Section V.A of Appendix C to 10 CFR Part 2 have been satisfied, no Notice of Violation was issued; this item is closed (See Section 11).
Or anization and Mana ement Controls (IP 83750 84750)
The inspector reviewed the licensee's organization and management controls for the radwaste/transportation program, including:
organizational structure; staffing; effectiveness of procedures and other management techniques used to implement the program; and experience concerning self-identification and correction of program implementation weaknesses.
The overall management of the radwaste/transportation program is the responsibility of the Technical Physical Sciences Superintendent, who reports to the Plant Manager via the Assistant Plant Manager, Technical Support.
The implementation of the program is the responsibility of the General Supervisor, Radioactive Material Control (RMC), who is supported by two Radwaste Handling Supervisors, a Radioactive Material Specialist, an Engineering Technologist and contract radwaste handlers, as needed.
The radwaste systems are operated by the operations department.
The responsibility for the effluent radiation monitoring systems is shared between the functional areas of operations, radiation protection, instrumentation and control, and system engineering.
The organization and management controls for the radwaste/transportation program appear adequate.
No violations or deviations were identifie Trainin and ual ifications IP 83750 84750)
The inspector reviewed the training and qualification aspects of the licensee's radwaste/transportation program, including:
changes in responsibilities, policies, programs and methods; qualifications of newly-hired or promoted personnel; and provisions for appropriate radwaste/transportation training of personnel.
The inspector reviewed the training and qualification requirements and selected qualification documentation for appropriate licensee personnel; no significant problems were noted.
Although only one of the RMC support staff has significant relevant experience, the inspector verified that the radwaste/transportation technical staff planned to regularly attend seminars and workshops concerning packaging and transportation of radioactive waste material.
It appears highly desirable for the licensee to accelerate the professional development of the new RHC staff members.
No violations or deviations were identified.
Gaseous Radioactive Radwaste (IP 84750 84724)
The inspector reviewed the licensee's gaseous radwaste management program, including:
changes in equipment and procedures; gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records.,
reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesses.
Sampling and release methods and procedures, records, and reports appear generally adequate with some exceptions which are delineated in Section 11.
The inspector reviewed summary records of gaseous radioactive effluent releases for 1985-1988.
The 1988 noble gas activity release, gamma, and beta air dose (percent of T/S limit) totals were approximately 258 curies, 0.298K, and 0.332K, respectively; corresponding 1987 totals were 875 curies, 1.74K, and 2.36K, respectively.
The 1988 I-131, tritium, and particulate activity release and critical organ dose (percent of T/S limit) totals were approximately 7.67 E-3 curies, 6.04 curies, 1.22 E-3 curies, and 1. 19K, respectively; corresponding 1987 totals were 5.34 E-2 curies, 11.5 curies, l. 11 E-2 curies, and 8.37K, respectively.
A comparison with 1985-1986 gaseous radioactive effluent release data indicates that the amount of noble gas released significantly increased in 1987 and decreased in 1988 (compared to 329 and 4940 curies in 1986 and 1985, respectively),
the amount of I-131 release also followed the same trend in 1987 and 1988 (compared to 1.64 E-2 and 1.03 E-1 curies in 1986 and 1985, respectively),
as did the calculated organ dose in 1987 and 1988 (compared to 1.80K and 12.5X in 1986 and 1985, respectively).
The release data seem to follow the operational evolution of the two units and apparently is a function of the frequency of gaseous batch releases (waste gas decay tank discharges
and containment purges);
there were 37, 7, 18, and 1 gaseous batch
. releases in 1985, 1986, 1987, and 1988, respectively.
Discussions with licensee representatives indicate that the containment atmosphere air cleaning systems are not being effectively used to reduce radioiodine levels in containment before purges.
It appears highly desirable for the licensee to improve the effectiveness of these air cleaning systems and to find additional means to upgrade the gaseous release control program to further reduce radioactive gaseous effluents.
The inspector's review of the licensee's release permit program for gaseous batch releases identified several apparent weaknesses.
Although Procedure No.
12 THP 6010 ENV.003, Preparation of Semiannual Radioactive Effluent Release Report, identifies gaseous batch releases as those from waste gas storage tanks, containment purges, and containment vents, the licensee has only formalized a batch release permit program for the waste gas storage tanks and containment purges.
The number of containment vents for 1985, 1986, 1987, and 1988 were 223, 239, 286, and 325, respectively.
The failure to report the containment vents as batch releases in the Semiannual Radioactive Effluent Release Reports is discussed in Section 11.
Not only does it appear that the licensee should develop a formal batch release program for containment vents, but should also investigate the cause of the apparently excessive frequency of such occurrences in order to determine means of reducing the frequency of containment vents and thus further reducing radioactive gaseous effluents.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(Open Item 315/89016-02; 316/89017-02)
No violations or deviations were identified; however, one open item was identified.
Li uid Radioactive Waste IP 84750 84723 The inspector reviewed the licensee's liquid radwaste management program, including:
changes in equipment and procedures; liquid radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesses.
Sampling and release methods and procedures, records, and reports appear generally adequate.
The inspector selectively reviewed liquid batch release permit records for 1987 and 1988; no significant problems were noted.
There were 236 and 152 liquid radioactive effluent batch releases for 1987 and 1988, respectively; corresponding 1985 and 1986 totals were 196 and 134, respectively.
The inspector reviewed summary records of liquid radioactive effluent releases for 1985-1988.
The 1988 whole body and maximum organ dose totals were 6.07K and 2.39K of the T/S dose limits, respectively; the
corresponding 1987 totals were 39.4X and 16.0X, respectively.
The total liquid tritium and fission/activation products (without tritium, gases, alpha) releases for 1988 were 1. 10 E+3 curies and 0.335 curies, respectively; the corresponding 1987 totals were 1.97 E+3 and 1.90 curies, respectively.
The liquid release data for 1985 and 1986 also indicate dose and activity release totals which are comparable to the corresponding totals for 1987 and 1988, respectively.
It is highly desirable that the licensee maintain the quality of plant systems and the radiological release program to preclude a recurrence of significant liquid and gaseous (see Section 6) radioactive effluent releases which occurred in 1985 and 1987.
No violations or deviations were identified.
Solid Radwaste IP 83750 84750 The inspector reviewed the licensee's solid radwaste management program, including:
changes to equipment and procedures; processing, control, and storage of solid wastes; adequacy of required records, reports, and notifications; implementation of procedures to properly classify and characterize waste, prepare manifests, and mark packages; and experience concerning identification and correction of programmatic weaknesses.
The inspector reviewed selected portions of the licensee's solid radwaste processing, storage, and shipping records for 1985-1988.
The licensee records indicate that approximately 29,230; 18,630; 10,340 and 8,680 cubic feet of solid radwaste were shipped in 1985, 1986, 1987, and 1988, respectively.
The licensee showed a downward trend in solid radwaste despite the potential for a significant increases in solid radwaste due to the Steam Generator Repair Project (SGRP).
The licensee's success in reducing the amount of radwaste generated is due, in part, to the licensee's decision to have a contractor remove the essentially unsorted dry active waste (OAM) to a remote site for processing; the licensee does, however, sort "clean" trash to identify and remove contaminated material and sort "contaminated" trash for removal of reusable or water retention items.
After processing, the contractor ships the solid radwaste to burial sites using the licensee's allocations.
The licensee still dewaters resins and prepares spent filters for shipment.
The inspector toured the solid radwaste facilities, including the storage facility and shipment staging area; no significant problems were noted.
No violations or deviations were identified.
Trans ortation Activities IP 83750 The inspector reviewed the licensee's transportation of radioactive materials program, including:
determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and OOT regulations and the licensee's quality assurance program;
determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses.
The inspector selectively reviewed portions of the radwaste shipment records for 1987 and 1988.
The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirements.
The licensee had 58 shipments in 1988 and 39 shipments in 1987 consisting of approximately 8,680 and 10,340 cubic feet, respectively.
The licensee's records also. showed there were 39 shipments in 1986 and 62 shipments in 1985 consisting of approximately 18,680 and 29,230 cubic feet, respectively.
No violations or deviations were identified.
Audits and A
raisals IP 83750 84750)
The inspector reviewed reports of audits and appraisals conducted for or by the licensee including audits required by Technical Specifications.
Also reviewed were management techniques used to implement and audit the program, and experience concerning identification and correction of programmatic weaknesses.
The inspector selectively reviewed portions of the gA audit and surveillance reports for 1988.
The licensee's gA audit/surveillance program appears adequate to assess technical performance, compliance with requirements, and personnel training/qualification relating to the radwaste/transportation program.
The gA auditors assigned to review this functional area appear to have the necessary expertise and experience prerequisites.
Interviews with appropriate licensee personnel indicate that responses to audit/surveillance findings are generally through, timely, and technically sound.
No violations or deviations were identified by the inspector.
Effluent Re orts (IP 84750 The inspector selectively reviewed radiological effluent analysis results to determine accuracy of data reported in the Semiannual Radioactive Effluent Release Reports for 1985-1988.
Technical Specification 6.9. 1.9 requires, in part, that the Semiannual Radioactive Effluent Release Reports include a summary of radioactive gaseous effluents as specified in Appendix B to Regulatory Guide 1.21, Revision 1, June 1974.
Section A.5 of the aforementioned appendix specifies, in part, the identification of gaseous batch releases.
The inspector identified that the licensee had not identified the containment vents as batch releases (see Section 6) in the Semiannual Radioactive Effluent Release Reports for 1985, 1986, 1987, and 1988.
These are examples of a violation of Technical Specification 6.9. 1.9.;
however, pursuant to Section V.A of Appendix C to 10 CFR Part 2, a Notice of Violation will not be issued for this isolated Severity Level V violation because the licensee initiated
appropriate corrective action (Condition Report No. 12-05-89-856; Problem Report No.89-554 was issued on May 1, 1989) before the inspection ended.
(Violati on 315/89016-03; 316/89017-03)
One violation was identified; however, a Notice of Violation will not be issued.
Effluent Control Instrumentation IP 84750 93702)
The inspector reviewed the records for effluent control instrumentation surveillance/operability.
As discussed in Section 3 of Inspection Reports No.
50-315/87013(DRSS);
50-316/87013(DRSS),
LER No. 315/87-001 was issued on January 12, 1987, after a contractor observed that calibrations of the Westinghouse liquid effluent radiation monitors did not comply with Technical Specification requirements because their calibrations did not cover the full monitor range.
Upon discovery, all nine Westinghouse monitors were declared inoperable while the calibration procedure was revised to add a linearity check of the monitors, followed by a recalibration which was completed on January 23, 1987.
All but two monitors passed the linearity test; these problems were resolved by replacement of both detectors with new ones which met the criteria.
Because of continuing problems with maintaining the Westinghouse monitors within calibration specifications, the 18-month calibration frequency was changed to quarterly.
On October 4, 1988, the licensee issued Condition Report (C/R) No. 12=10-88-1373 (Problem Report (P/R)
No.88-713)
because performance of quarterly radiological calibrations of the Westinghouse liquid radiation monitoring system (RMS) resulted in the identification of an adverse trend concerning the ability of the monitors to maintain an acceptable level of performance between the periodic calibrations.
On October 5, 1988, the problem report was classified as a significant problem report.
The investigation of the significant problem report was extended to include additional Westinghouse RMS problems identified in CR 2-11-88-1584 and P/R's88-580, 88-589,88-620, and 88-652.
On February 1, 1989, the root cause for these Westinghouse RMS failures was attributed to system design, the non-performance of routine electric calibrations, misadjustment of the log pulse circuit, and poor correlation of the analog meter readings.
According to licensee personnel, it would be prudent to change the calibration frequencies to monthly.
During this inspection the inspector was informed that the troublesome Westinghouse RMS was originally scheduled for replacement by a Eber line RMS which had been in the warehouse onsite since 1981.
A tour of the warehouse revealed that 22 of the Eberline liquid effluent radiation monitors were in storage; a review of material receipt documentation confirmed that the Eberline RMS had arrived onsite in 1981.
Licensee representatives indicated the installation phase of the associated request for field change (RFC) was cancelled because it was decided that the Eberline monitors were not required by the licensee's TMI Action Plan commitments and the problems with the existing Westinghouse RMS was not
known until recently.
The licensee has yet to decide whether to attempt to increase the reliability of the existing Westinghouse RMS, replace the existing monitors with the Eberline RMS now in storage, or to purchase a
state-of-the-art RMS.
The poor handling of the liquid effluent RMS situation by the licensee over the last decade is indicative of poor licensee program oversight.
The failure of the licensee to quickly correct the technical problems with the existing RMS which were identified by the contractor in 1987 appear to indicate an poor response to a significant issue.
A memorandum dated January 27, 1987 from members of the Radiological Support Section (AEPSC) to the Technical Physical Sciences Superintendent strongly recommended that the present Westinghouse RMS be replaced as soon as possible; yet the licensee has made no significant progress in resolving the matter.
It is highly desirable for the licensee to expedite the resolution of this problem by giving it top priority and proper management attention.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(Open Item 315/89016-04, 316/89017-04)
No violations or deviations were identified; however, one open item was identified.
Pr imar Coolant Radiochemistr IP 84750 Technical Specification 3.4.8 requires that the specific activity of the primary coolant not exceed one microcurie of I-131 dose equi,valent per gram except under certain limiting conditions of operation.
The inspector selectively reviewed the licensee's primary coolant radiochemistry results for the past two years (since May 1987) to determine compliance with the Technical Specification requirements for the I-131 dose equivalent (DEI-131) concentration.
The selective review and discussion with licensee personnel indicated that the DEI-131 concentration for the primary system remained less than the applicable Technical Specification limit throughout the review period for both units.
No violations or deviations were identified.
Air Cleanin S stems IP 84750 Technical Specifications (T/S) require filter testing of the Control Room Emergency Ventilation Systems (one filter train for each unit) as specified by T/S 3/4. 7. 5; the ESF Ventilation Systems (two independent filter trains for each units)
as specifically T/S 3/4.7.6. 1; and the Spent Fuel Storage Pool Exhaust Ventilation System as specified by T/S 3.9. 12.
The inplace leakage test criterion specified both the DOP testing of HEPA filters and for freon testing of charcoal adsorbers is equal to or less than one percent penetration.
The laboratory test criterion for carbon sample removal efficiency for methyl iodide is equal to or greater than 90 percent.
A selective review of surveillance tests date for 1986-1988 showed that the survei llances for the above ventilation systems had met test acceptance criteri Although the licensee has passed the surveillance test requirements for all appropriate ventilation systems, the inspector noted that the test conditions did not appear to meet current NRC regulatory positions in that:
~
The testing methodology specified by the licensee for the methyl iodide test is RDT M16-1T (per ANSI/ASME N510-1975).
This methodology (testing protocol)
has been shown to be inappropriate; the test protocol recommended to replace RDT H16-1T is specified by NRC Information Notice No. 87-32.
The licensee acceptance criterion of 90K efficiency for carbon adsorbers tested with methyl iodide may not adequately reflect iodine removal credit assumed in the associated HVAC system design basis safety evaluations.
The NRC regulatory position is that carbon adsorbers should be tested with methyl iodide at acceptance criteria which requires a higher efficiency than that assumed in the HVAC system design basis safety evaluation to allow a margin of safety to account for potential degradation of the carbon adsorber between surveillance tests.
The methyl iodide test specified by the licensee's Technical Specifications is at 130'C and 95K relative humidity (RH).
The test at 130 C has been shown to be inappropriate; the NRC recommends a
testing temperature of 30 C.
References:
NUREG/CR-4960 (ANL-87-22)
and EGG-CS-7653 (prepared for the NRC under contract).
Mhen the inspector discussed the above concerns at the onsite exit meeting, the licensee informed the inspector that the licensee's technical staff will evaluate their current testing program and revise the Technical Specifications and plant procedures, as appropriate.
The licensee plans to complete the evaluation, request all appropriate T/S amendments, and revise appropriate procedures by the end of June 1989.
The licensee expects to work closely with their testing vendors in resolving these regulatory concerns.
Pending completion of the licensee's evaluation, this matter is considered an unresolved item which will be reviewed further during a future inspection.
(Unresolved Item 315/89016-05; 316/89017-05)
No violations or deviations were identified; however, one unresolved item was identified.
15.
NRC Information Notices IP 92701)
The inspector reviewed licensee actions in response to selected Information Notices (INs).
For the following INs, the inspector noted the licensee reviewed the IN for applicability; the IN was distributed to appropriate personnel; and if applicable, corrective actions were scheduled/performed.
Chemical Reactions with Radioactive Waste Solidification Agents.
Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations.
IN No. 88-101:
Shipment of Contaminated Equipment Between Nuclear Power Stations.
16.
Exit Meetin IP 30703)
The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection on April 28, 1989, and by telephone through May 22, 1989.
The inspector summarized the scope and findings of the inspection, including the apparent violation, the open items and the unresolved items.
The apparent violation, which involved a failure to report required information regarding radioactive gaseous batch releases in the 1985-1988 Semiannual Radioactive Effluent Reports as specified by Tech Specs, would probably not be issued per Section V.A of Appendix C to 10 CFR Part 2.
The unresolved items discussed involved:
NRR Resolution of the licensee's variance requests regarding TMI Action Plan (NUREG-0737) Item II.F. 1, and; the licensee's need to evaluate the adequacy of the current HVAC charcoal adsorber testing program, and revise Tech Specs and procedures, as appropriate.
The open items discussed involved:
development of a formal batch release program for containment vents, and; the licensee's need to expedite the resolution of recurrent problems with the Westinghouse liquid radwaste effluent monitors.
The inspector also discussed the likely informational content of the inspection report with regard to documents and processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents or processes as proprietary.