IR 05000315/1990014
| ML17328A422 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/17/1990 |
| From: | House J, Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17328A421 | List: |
| References | |
| 50-315-90-14, 50-316-90-14, NUDOCS 9008310160 | |
| Download: ML17328A422 (15) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos.
50-315/90014(DRSS);
50-316/90014(DRSS)
Docket Nos.
50-315; 50-316 License Nos.
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
D.
C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.
C.
Cook Site, Bridgman, Michigan Inspection Conducted:
June 25 - July 3, and August 8, 1990 (On-site)
Inspectors:
R. A.
u Da o
J.
.
Hou Approved By:
M. C.
chum che
, Chief Radiological Controls and Chemistry Section Da Dat Ins ection Summar Ins ection on June 25-Jul 3,
and Au ust 8, 1990 Re ort Nos.
50-315/90014 DRSS
50-316/90014 DRSS di<<i
<<t 1i 'i protection program including organization and management controls (IP 83750),
external exposure controls and personal dosimetry ( IP 83750), internal exposure controls and assessment ( IP 83750), training and qualifications ( IP 83750),
radiological controls (IP 83750),
and followup on previous inspection items ( IP 92701, and review of a hot particle event ( IP 83724).
Results:
Of the five areas inspected, no violations or deviations were identified.
The licensee's radiation protection program is improved and
.
adequately protects the health and safety of workers.
Strengths:
Aggressive program for hot particle and contamination control.
Management support and staff stability.
Weaknesses:
Poor communications between operation and radiation protection regarding operating status of containment ventilation system.
Uncertain knowledge of drinking water use of groundwater aquifer.
90083iOi60 9008i7 PDR ADQCK 050003i5 G
PNU
Fragmented responsibility regarding environmental releases.
No violations or deviations were identifie DETAILS 1.
Persons Contacted 1,3 A. A. Blind, Plant Manager, D.
C.
Cook (DCC)
1,2,3 D. Fitzgerald, TPS/Environmental Coordinator, DCC 2 D. Foster, Radioactive Material Specialist, DCC 2,3 J. Fryer, Radioactive Material Control Supervisor, DCC J. Jackson, Radiation Protection Training Specialist, DCC 1 B. A. Jepkema, Site gA, AEPSC 1 J.
M. Kauffman, IMP Site Construction, AEPSC 2,3 S.
Klementowicz, AEPSC 2 B. Lauzau, Nuclear Safety and Licensing, AEPSC 1 S. Lehrer, TPS/Radiation Protection Section, DCC 2 R. Looker, Chemical Supervisor, DCC 1,2,3 D. Loope, TPS/Plant Radiation Protection Supervisor, DCC S.
McLea, Chemical Supervisor, DCC 1,2 D. Noble, TPS/Health Physicist, DCC 1 J.
Nodeau, Site equality Assurance, AEPSC 1 M. Norton, TPS/Performance Engineer, DCC 3 J. Oetken, TPS/Environmental, DCC F. Rosser, Supervisor, Dosimetry, DCC 1,3 J.
Rutkowski, Assistant Plant Manager, DCC 1 D. Schroeder, Senior Instructor, Training, DCC 3 L. Umphrey, Administrative Compliance Coordinator, DCC 3 K. Toth, Licensing, AEPSC 1,2 D. Williams, TPS/Health Physicist, DCC 1 B. L. Jorgensen, Senior Resident Inspector, NRC 1 J.
A. Isom, Nuclear Reactor Regulation, NRC 1 Present at the Exit Meeting on July 3, 1990.
2 Contacted by telephone between July 13 and August 6, 1990.
3 Present at exit meeting of August 8, 1990 The inspectors also interviewed other licensee and contract employees.
2.
'icensee Action on Previous Ins ection Findin s
( IP 92701 a
~
(Cl osed)
Unresolved Item (50-315/89016-01; 50-316/89017-01):
Region III to track NRR resolution of licensee's variance requests regarding TMI Action Plan (NUREG 0737)
item II.F. 1 (Attachments 1,
2 and 3).
Licensee variance requests have now been approved by NRR.
Thus, the unresolved item and SIMS items II.F. 1.2.A, II.F. 1.2.B, and II.F. 1.2. C are cl osed.
b.
(Cl osed)
Open Item (50-315/88011-01; 50-316/88013-01):
Assistance to the plant RPM from the corporate health physics staff.
Corporate health physics personnel provided assistance to the station RPM for about two years.
During this period the RPM has gained the experience required to meet ANSI N18. 1975, criteria, and has been involved in upgrading the station health physics progra.l
(Closed)
Open Item (50-315/88011-05; 50-316/88013-05):
Correct MPC-hour conversions in Health Physics Procedure THP 6010.
RAD.409
"Assessment of Whole Body Count (WBC) Results."
The inspector verified the procedure has been revised and adequate for use to convert WBC data to MPC-hours in accordance with ICRP-2 methodology.
The licensee intends to convert to ICRP-30 methodology in the near future and procedural changes will be made.
(Closed)
Open Item (50-315/89017-01; 50-316/89016-01):
Review use of large number of contractor workers to compress outage duration.
The inspectors verified that as part of the licensee's current refueling outage steps have been taken to improve overall planning/scheduling activities including limiting assigned workers to those necessary for a specific job,function.
(Closed)
Open Item (50-315/89017-02; 50-316/89016-02):
Failure to perform an adequate evaluation of the radiation hazards associated with the reactor cavity pit.
The corrective actions described in Section 11 of Inspection Report Nos.
315/89017 and 315/89016 have been taken and appear sufficient to prevent recurrence.
(Cl osed)
Unresolved Item (315/89012-01; 316/89012-01):
Resolve regulatory concerns regarding radioactivity released from the turbine room sump (TRS) to an onsite absorption pond.
The licensee attributed the presence of radioactivity to primary-secondary leakage in the Unit 2 steam generators.
The licensee's 1986-1990 TRS release data indicated compliance with the unrestricted area, limits of 10 CFR 20 and with technical specification monitoring requirements.
This matter is considered resolved.
However, the licensee's knowledge of human use of the aquifer and of dose projections via this pathway will be followed under Open Items (315/90012-02;316/90012-02).
(Open)
Open Item (315/90012-02; 316/90012-02):
Review ground water dose pathway affected by the TRS discharges.
The inspectors reviewed
'icensee well monitoring TRS release data for the period 1986-1990.
The Radiological Environmental Monitoring Program (RENP) identified tritium below the required reporting levels (20,000 pCi/liter) in wells down gradient (west toward L. Michigan) from the absorption pond, which the licensee believed to be the source; no other isotopes were identified.
There is still some uncertainty in this attribution owing to the location of the most affected wells near the main plant buildings where other sources such as leaks from a nearby tank or pipe could exist.
Most recent ( 1989-1990)
data indicate that concentrations in wells and in TRS releases much reduced, but licensee analyzed samples from three non REMP wells nearer the
'ond during this inspection saw tritium at about 5000 pCi/liter.
Additional examination of this matter is needed.
Technical Specification 4. 11. 1.2 requires the licensee to determine dose from liquid effluents in accordance with its Offsite Dose Calculation Manual (ODCM) which assumes that no drinking water wells draw from the affected aquifer.
The updated FSAR notes the presence of three offsite drinking water wells within 1500 feet of the southern site boundary but does not identify the aquifer they use.
The
presence of tritium in one of the non REMP wells which was in that general direction indicates a need for the licensee to review its assumption regarding use of the aquifer and thereby the ODCM basis for projecting waterborne dose.
Licensee representatives also discussed the results of seven sediment samples taken from the bottom of the absorption pond during this inspection and analyzed by a contractor.
The results positively identified cesium-137 in concentrations up to 250 pCi/gram and lesser amounts of cesium-134 and cobalt-60.
These matters were discussed with licensee representatives in the exit interview on July 3, in subsequent telephone calls and in the exit meeting of August 8, 1990.
The licensee agreed to perform a
further evaluation of the source of tritium in onsite wells and of human use of the groundwater aquifer.
This topic will be reviewed in subsequent inspections.
(Open)
Open Item (316/89034-01):
Review licensee investigation of a January 1990 event involving unanticipated iodine intakes by approximately 30 workers in the Unit 2 containment.
A regional Radiation Specialist who visited the site shortly after the event, confirmed that intakes were generally less than 5 MPC-hours as estimated by the licensee but noted that the event may have resulted
'rom
"unexpected and uncoordinated operation of containment ventilation systems."
During the current inspection, the inspectors reviewed the licensee's investigation conclusions and corrective actions, examined pertinent records and interviewed involved personnel.
Among the licensee identified contributing causes to this event were failure to keep radiation protection (RP)
informed of containment purge status, allowing work in containment to continue with the purge system not operating, relevant information missing from the RWP, insufficient RP personnel and counting equipment to allow prompt analyses of air samples, and absence of alarming continuous air monitors (CAMs).
Corrective actions to preclude recurrence included steps to assure adequacy of RP support to meet the demands of job coverage, acquisition and use of portable CAMs, and improvement of communications between radiation worker supervisors and RP.
A significant weakness in licensee corrective action was failure to address the need for operations to keep RP informed of containment ventilation changes.
A similar weakness contributed significantly to a similar event described in Open Item 315/88011-11; 316/88013-11, which led to personal contamination occurrences in the auxiliary building.
Expected licensee corrective action for that problem, which was to include a written procedure, had not been completed when the January 1990 event occurred.
This weakness was discussed with licensee representatives including the plant manager during the exit interview.
The licensee has since established appropriate written instructions for operations to make the needed notifications.
This item will remain open pending review of licensee implementation of these corrective actions.
Open items 315/88011-11 and 316/88011-11, which cover essentially the same subject are considered close 'r anization and Mana ement Control (IP 83750 The inspectors reviewed the licensee's organization and management controls for the radiation protection program including changes in the organizational structure and staffing, and experience concerning self-identification and correction of program implementation weaknesses.
Health Physics (HP) group staffing was quite stable with the complement of permanent house radiation protection technicians (RPTs)
increased somewhat and the supervisory and professional staff staying about the same.
Although three senior RPTs were transferred (promoted)
to other departments, there are still thi rteen seniors and three more RPTs near senior status.
About 100 contractor RPTs were hired for the current outage.
The RPM has direct access to the Plant Manager who recently issued a
memo to all plant supervisors clarifying the areas of RPM responsibility and emphasizing his support for the Radiation Protection program.
The station professional HP staff, which appears qualified to manage the radiation protection program, also receives substantial support from the corporate HP staff.
The inspectors noted an apparent weakness regarding licensee oversight of matters pertaining to control and evaluation of liquid releases to the environment via the turbine room sump.
Several groups reporting to the Technical Physical Sciences (TPS) Superintendent and the operations group have responsibilities for various aspects of the program which they appear to carry out independently without good communications between the groups.
No one individual appears to have comprehensive knowledge of program implementation or responsibility for overall functional oversight.
The inspectors were shown a
new (6-21-90)
TPS standing order (TPS0.024)
which represents a first step to address this weakness by listing the relevant procedural responsibilities of the various groups.
No violations or deviations were identified.
4, Trainin and ualifications ( IP 83750 The inspector reviewed the licensee's general employee radiation protection and respiratory programs, including:
policies, goals, and methods; course content and applicability; and instructor qualifications.
Previously trained or experienced personnel, are given the INPO challenge exam as a first step; satisfactory completion of this exam (score of. 80K or greater)
results in a condensed version of general employee training with emphasis on site specific issues.
If an employee fails the INPO test or has never been trained, then they must attend the full day general employee training (NGET).
An inspector attended the respiratory and nuclear general employee training program.
The inspector found the NGET program adequately covered the topics in 10 CFR 19. 1 Students who pass the NGET exam are provided a practical session to demonstrate their radiation protection skills.
The instructor audits the class on their use of plant procedures, survey meters, and good work practice, in a simulated contamination area.
The respiratory training consists of a series of video tapes, lectures, and practical demonstrations, followed by the students donning and removing full face respirator masks.
All students are required to have a medical certification on file prior to attendance.
The NGET instructors have received special in house training, and are qualified radiation protection personnel.
On occasion, a similarly qualified contractor will be called in to teach.
A review of past outage NGET and respiratory records, indicated an average class size of 35-50 students and a failure rate between 5-10%.
The inspector discussed with the instructors his concern over large class size.
Both trainers indicated that classroom size has not affected the quality or effectiveness of the training.
The inspector reviewed selected training records of long term (more than six months) contractor RPTs after noting an audit finding that fewer than most of them were not attending scheduled training.
Licensee representatives and contractor supervisors acknowledged that scheduled training had not been well attended.
However, licensee representatives stated that there was now strong support from plant management for this training program.
A review of a recent training session conducted from May 17 - June 6, 1990, showed improved attendance with approximately 87%
of those eligible in attendance.
No violations or deviations were identified.
External Ex osure Control and Personal Dosimetr ( IP 83750)
The inspectors reviewed the adequacy of the licensee's external exposure control and personal dosimetry programs.
No significant changes were noted in the licensee's external exposure measurement and control program.
The licensee's total person-rem for 1989 was 493 person-rem.
For 1990 through April it was about 60 person-rem compared 'with the station goal of about 475 person-rem.
For the current refueling outage, the licensee has established sufficient radiation protection entrance/exit and dosimetry control stations.
RPTs continually man the control stations where related RWPs, associated survey maps, and secondary dosimetry are maintained and issued.
The flow of materials, equipment, and personnel to and from the containment building entrance is monitored by the technicians manning the stations.
The licensee continues to qualify in the National Voluntary Laboratory Accreditation Program (NVLAP) for categories one through seven with a contractor meeting the requirements of category eight (neutron dosimetry).
An on-site assessment by NVLAP on June 25-26, 1990, noted the need for a structured training program for new RP technicians in addition to yearly retraining.
License representatives stated that a program for
L
basic dosimetry instruction being developed by the Training Department would soon be available.
A new technical director for the dosimetry program has been hired and the licensee has arranged for a contractor to provide a training program for dosimetry management personnel.
This area will be reviewed in future inspections.
The inspectors reviewed calibration of Area Radiation monitors (ARMs) as described in Procedure
THP 6010 RPC 804.
Additionally, calibration of the J.
L. Shepherd model 89 calibrator, Procedure 12 THP RPC 566, was reviewed.
Selected data for the previous year indicated that the ARMs and Calibrator were maintained within operational parameters and calibrated as required.
All gC checks are performed with a radioactive source; no light emitting diodes (LEOs) are used.
No violations or deviations were identified.
Internal Ex osure Control and Assessment IP 83750 The inspectors reviewed selected aspects of 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 maintenance tasks including ALARA considerations.
The inspectors selective review of whole-body count results for 1989 and 1990 indicated no results exceeding the 40 MPC-hour control measure.
The licensee uses the "Fastscan" whole body counter for routine counting and the "Accuscan" whole body counter for backup.
The inspectors selectively reviewed relevant whole body count and calibration procedures, the WBC facility and equipment, recent calibration results, and discussed the WBC program with cognizant health physics personnel.
No significant problems were identified.
Selected aspects of the licensee's respiratory program were reviewed.
Workers'uthorization information, proof of required training, and expiration date are required.
Provisions are made during the issuance and return cycle for MPC accountability.
Inspector observations in the field indicated sufficient attention is given to respirator inspection, storage, and maintenance; no unreturned respirators were observed.
The general scope of the licensee's respiratory program was discussed with licensee personnel and it appears to be satisfactory.
Air sample data were selectively reviewed.
Air samples are taken, counted, and evaluated in accordance with procedural requirements.
The procedures appear adequate for use in determining air sample results, placement, and type.
Although there were some problems concerning the counting and assessment of air sample data associated with a recent iodine airborne problem (Section 2.g), it appears the licensee normally makes adequate use of air sample results to establish requirements for use of respirators and protective clothing.
No violations or deviations were identifie 'ontrol of Radioactive Materials and Contamination (IP 83750 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; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials'he licensee recently implemented a valve recovery program in the auxiliary building.
The program is part of a joint HP/Maintenance effort to reduce contamination through improved maintenance of valves, orfices and packing.
From April 1990, to the latter part of June, 1990, the number of leaking components has been reduced from about 730 to about 490'he licensee has also implemented an aggressive program to reduce contaminated areas in the auxiliary building.
Since January 1,
1990 through July 1, 1990 the number of square feet controlled as contaminated has been reduced from about 27,000 to about 16,000.
The inspectors took about 50 floor and horizontal smears during plant tours, with only one found in excess of the contamination control limit of 1000 dpm/100 cm2.
The inspectors reviewed selected data of personal contamination events (PCEs) including those involving hot particles.
A licensee representative stated that there were 308 PCEs in 1988, 374 in 1989 and a projected goal of 300 has been established for 1990; all PCEs are investigated.
The inspector's review of selected individual and monthly reports noted that the licensee had attributed some of them to workers exceeding the boundries of the uncontrolled area, to poor work and clothing removal habits, and to hot particles on scaffolding that may be assembled or disassembled in various areas of the plant.
The licensee's investigations of these events and its program for hot particle dose assessment appeared satisfactory.
An event involving hot particles that occurred on following this inspection on July 11, 1990 is discussed in Section 8.
The inspectors reviewed monitor alarm setpoint methodology, functional tests and calibration procedures for the RCA exit friskers (PCM-1Bs)
and the gatehouse Gamma-10 portal monitors.
The required tests and calibrations appeared to have been performed in accordance with the applicable procedures.
The PCM-1Bs are set to alarm at a nominal 5000 dpm/100 cm2 (about 2.5 nanocuries);
operational source checks are made dai ly.
No violations or deviations were identified.
8.
Hot Particle Event of Jul 11, 1990 ( IP 83724)
In a July 18 telephone discussion, licensee representatives described an increase in incidence of personal contamination events (PCE's) involving hot particles that ensued from pressure testing of a let-down safety valve (SY-51) using a
new test rig.
A blast of air from the lifted valve dislodged a baffle set up to direct air to a special ventilation system exhaust; the baffle penetrated the plastic tent surrounding the test rig and struck an attending radiation protection technician (RPT).
No one was in the enclosure at the time.
When the RPT checked out of the area about an hour later, several discrete hot particles were found on his
clothing.
Hot particles were also found on the the clothing of four other individuals who were in the area but none were found on skin.
In all, 46 particles were documented between July 1 and July 16, compared with 30 between January 1 and June 1,
1990.
There was also a shift from mainly activation to mainly fission particles, possibly owing to known leaking fuel elements during the last operating cycle.
A whole body count on the most affected individual (the RPT)
was negative and the maximum dose (to his thigh) was 1.7 rem from direct measurement and about 1 rem as calculated by VARSKIN.
The licensee described response to this occurrence included personnel evacuation, decontamination of individuals and taking steps to control further spread of contamination.
Other measures were a temporary ban on further use of the test rig and on opening of any closed systems, and increasing the "sticky roller" surveys to hourly.
The licensee also requested assistance of an INPO expert, obtained assistance from its corporate office and designated a committee of engineers to consider further corrective actions.
Information on the event was also widely disseminated to the plant staff via a "Plant Flash".
This matter was again discussed by telephone with a licensee representative on August 1, 1990.
The licensee representative indicated that normal operations were resumed on the weekend of July 27, 1990, under additional guidance suggested by its committee.
Safety valve testing is being done in a permacon building instead of the plastic enclosure.
This matter will be reviewed further in an inspection scheduled for later in August 1990.
Open Item (315/90014-01; 316/90014-01).
Deviation Event Re orts DERs IP 83750 The inspectors selectively reviewed DERs and Problem Reports generated between July 1989 to May 1990 to determine if programmatic problems exist and if deficiencies were promptly and adequately corrected.
During this period, the licensee identified several repeat incidents involving contamination levels in excess of control limits, TLD/SRD discrepancies, administrative exposure limits exceeded as the result of inadequate review of TLD data, and failure to minimize material entering the RCA.
Several of the DERs were the result of not following radiation procedures and poor work practices.
The reports were generally well investigated and timely, appropriate disciplinary actions were taken, and adequate corrective actions were taken.
Most of the repeat occurrences were adequately addressed.
However, worker carelessness, which appears responsible for most of the TLD/SRD discrepancies that arise under low dose conditions warrant additional management attention.
This matter was discussed at the exit interview.
No violations or deviations were identified.
Audits and A
raisals (IP 84750 The inspectors reviewed the most recent Corporate assessment of the Radiological Control Program, gA-90-03, conducted from January 2-March 15, 1990 and the stations subsequent response.
The auditors
appeared to address in adequate detail the radiological protection quality assurance program and plant condition reports.
Items identified in the audit appeared to have been addressed and resolved in a timely manner.
No violations or deviations were identified.
11.
~0en 1teme 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 8.
12.
Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on July 3, 1990.
The inspectors discussed the iodine uptake event described in Section 2 along with observations on the quality control program, and the DER system.
Open items related to liquid releases via the turbine room sump and tritium identified in onsite monitoring wells were discussed in a second exit interview held on August 8, 1990.
Licensee representatives agreed to evaluate possible use of the groundwater aquifer beneath the site as a
source of drinking water and to further evaluate the source of tritium in onsite monitoring wells.
The inspectors noted that functional responsibility for turbine room sump releases to the environment was somewhat fragmented.
During the exit interview, 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 processes as proprietary.
11