IR 05000315/1992017
| ML17329A600 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/21/1992 |
| From: | Paul R, Schumacher M, Shan N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A599 | List: |
| References | |
| 50-315-92-17, 50-316-92-17, NUDOCS 9209020097 | |
| Download: ML17329A600 (9) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos.
50-315/92017(DRSS);
50-316/92017(DRSS)
Docket Nos.
50-315 50-316 Licensee:
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 License Nos.
D.
C.
Cook Nuclear Plant, Units
and
Inspection At:
D.
C.
Cook Site, Bridgeman, Michigan Inspection Conducted:
August 4-7, 1992 Inspectors:
~7g ~/'~c:8. '.
N. Shah g gy te zg-~As Date Accompanied By:
W. Radcliffe
+7)
. ills Approved By:
M. C.
Schumacher, Chief Radiological Controls Section
ate Ins ection Summar Ins ection on Au ust 4-7 1992 Re ort Nos.
50-315 92017 DRSS and 50-316 92017 DRSS Areas Ins ected:
Routine inspection of licensee's radiation protection program (IP 83750) during an outage, including training and qualifications, audits and appraisals, external exposure, ALARA, contamination control and licensee problem reports.
In addition, licensee corrective actions for two previously identified violations (50-315/92010-04; 50-316/92010-04 and 50-315/92010-05; 50-316/92010-05)
and the status of licensee evaluation of tritium migration from the onsite absorption pond were reviewed.
Results:
Overall, the licensee's program appears to be effectively run.
Good ALARA controls were evident, including the use of a contractor telemetry system, installation of reactor head shields and remote monitoring of outage activities.
A chemical decontamination of the unit 1 and
RTD bypass loops resulted in reduction of source term and area dose rates.
One non-cited violation (NCVs) was identified and reviewed during this inspection period and is discussed in section 8a.
9209020097 920821 PDR ADOCK 05000315
DETAILS Persons Contacted
- A. A. Blind, Plant Nanager D. Foster, Radioactive Material Speci'alist
- D. Holland, General Supervisor Radiation Support D. Noble, General Supervisor Health Physics
- S. Lehrer, General Supervisor Radiation Controls
- J. Fryer, General Supervisor Radioactive Haterial Control
- J.
E. Rutkowski, Assistant Plant Hanager
- L. Gibson, Assistant Plant Hanager D. Loope, Superintendent. Radiation Protection H. Springer, ALARA Supervisor The inspectors also interviewed other licensee personnel in various departments in the course of the inspection.
- Present at the Exit Meeting on August 7, 1992 Licensee Action on Previous Ins ection Findin s
IP 92701 Closed Violations 315 92010-04
6 92010-04 and 315 92010-05 ill-6:
f fh d
t t.
i td il hl'p d
t material to persons not licensed for its receipt and failure to conduct a required survey before unconditionally releasing a barrel of hazardous waste containing radioactive material from the radiological control area (RCA).
The inspectors reviewed revised radiological protection (RP)
and chemistry procedures associated with surveys of waste and waste containers.
Revised implementing procedures for radiation protection and administrative procedures for chemistry are in place.
The chemistry implementing procedures are being developed and should be in place before July 1993.
0 en 0 en Item 315 90012-02 316 90012-02:
Review ongoing licensee evaluation of tritium migration from the on-site absorption pond due to releases from the turbine room sump.
Starting in 1992 the licensee has set an investigational action level of 10,000 pCi/1 for tritium in the turbine room sump.
This level has been exceeded twice, indicating ongoing primary to secondary leakage.
In order to characterize possible off-site consequences, the licensee commissioned a study in 1991 to determine possible tritium intrusion into the groundwater.
As part of the study, groundwater samples were taken from on-site and offsite wells.
In a letter dated December 23, 1991, the licensee identified an apparent conflict with the hydrology portion of the study.
Water samples taken during the late summer/early fall of 1991 indicated possible tritium migration to wells assumed to be unaffected in the hydrology study.
In response to this conflict, a new hydrology study has been commissioned, and all onsite wells are now
monitored as part of the licensee's Radiological Environmental Honitoring Program.
The affected aquifer is apparently not used for human consumption, This item will remain open pending completion of the updated hydrology'study.
Audits'nd A
raisals IP 83750 The inspectors reviewed a sampling of problem reports and several quality assurance audits and surveillances performed since the last inspection.
guality Assurance reports and surveillences'ssued since the last inspection were reviewed, contained substantive findings, had corrective actions taken in a timely manner and were technically sound.
These audits were performed by personnel having the appropriate expertise in the functional area and interviews with licensee staff indicated a good working relationship existed between the Radiation Protection Department and the guality Assurance group.
As part of the gA process, auditors review industry issues identified at other plants for applicability to DC Cook.
Because of recent industry concerns over ALARA, the gA department has incorporated a special ALARA assessment into the regular gA program.
The first of these assessments is scheduled for later this year and the results will be reviewed during a future inspection.
In general, problem reports appeared to be well investigated, addressed root causes and were well documented.
Several reports identified minor concerns with control of contaminated materials, however strong corrective actions were taken and these problems do not appear recurrent.
Two condition reports dealing with tritium vent stack calculations and steam generator blowdown are described in section 8.-
No violations or deviations were identified.
Trainin and ualifications IP 83750 All plant personnel are instructed in Nuclear General Employee Training (NGET) on how to read area radiation survey maps and how to recognize area postings.
However, in the plant many signs are posted
"as indicated," referring to the dose rates listed on posted surveys, This posting is not described in NGET and has proven to be a source of some confusion.
Although no problems have been noted to date, the inspector discussed this matter with the licensee who stated that it would be evaluated.
As described in a previous inspection report (315/92010; 316/92010),
the licensee has incorporated two new videos into their NGET.
One describes all plant alarms and the other shows correct use of their new electronic dosimeters.
Overall, the NGET seems comprehensive.
No violations or deviations were identified
External Ex osure Control IP 83750 The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in the program to meet routine and outage needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.
Selected RWPs were reviewed for appropriateness of the radiation protection requirements based on work scope, location, and conditions.
In general, radiological controls information was clearly presented and attached surveys were regularly updated.
During tours of the plant, the inspector o'bserved workers adhering to RWP requirements and discussed these requirements with plant workers at the job site.
The inspectors reviewed dose estimates and actual exposure received for sele'cted jobs during both the unit 1 and 2 outages.
In general, dose estimates were conservatively generated and exceeded actual exposure.
For those cases where actual exposure exceeded the estimate, an investigation was conducted and documented in the job history files.
For both the Unit 1 and 2 outages, the do'ses accrued were 115 (as of 8/5/92; goal
.= 289 person rem)
and 194 (goal
= 237 person-rem)
person-rem, respectively.
Personnel Contamination Events (PCEs)
recorded included 186 (goal
= 217) to date with 156 attributed to outage activities.
No violations or deviations were reported Control of Radioactive Naterials and Contamination Surve s
and Nonitorin IP 83750 The inspectors reviewed the licensee's p'rogram 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.
A tour of the plant and selected work areas did not identify any problems in the implementation of the licensee's contamination control program.
Overall, work areas were well maintained and workers appeared to use good contamination control practices.
A selective review of PCEs and Hot Particle Events to date, did not identify any violations of NRC or plant, administrative requirements.
Each PCE and Hot Particle Event is investigated in accordance with 12 THP 6010.RPP 763 "Personnel Contamination Incidents (PCI)"
and skin dose assessments are conducted as necessary.
The inspectors reviewed the investigation and dose calculations for selected PCEs and Hot Particle Events; no problems were note The inspectors reviewed routine surveys performed in the RCA, and found them to be properly documented and reviewed.
During plant tours, the inspectors noted surveys posted outside of all component rooms providing radiological information to anyone entering the area.
No loose surface contamination or inaccurate radiation level postings were detected during independent surveys performed by the inspectors.
No violations or deviations were noted.
Haintainin Occu ational Ex osures ALARA IP 83750 The inspectors examined the licensee's ALARA program for performance in the following areas:
radiation source and field control; worker awareness and involvement; ALARA goals and objectives; management involvement.
Procedure
PHP 6010 ALA.001 "ALARA Program Review of Plant Work Activities" defines the licensee's program for pre and post job ALARA reviews.
While reviewing selected outage activities, the inspectors noted good communication between work groups and radiation protection (RP) during both job planning and implementation.
Post job critiques were thorough and well documented, with identified concerns incorporated into subsequent activities.
Plant resources, including mockups and training, appeared to be effectively used.
During both outages, chemical decontaminations of the Unit 1 and
RTD bypass loops were performed using the CANDEREH process.
For the Unit 2 decon, a total of.925 curies were removed and a decontamination factor (DF) of 1.5 achieved in area dose rates.
This was the first time the licensee has performed a chemical decontamination and the lessons learned were incorporated in the subsequent unit
RTD decon, resulting in the removal of.5 curies and a
DF of 14.58.
The licensee estimates that as result of decontamination, general area dose rates in the lower plant area's were reduced approximately 35/o-40% from previous years.
Additional outage initiatives include the use of remote video monitoring of work activities, implementation of el'ectronic.dosimeters and the installation of reactor head shielding.
As part of the electronic dosimeter program, the licensee has incorporated a contractor radiation telemetry system for both the Units 1 and 2 outages.
The system allows RP technicians to monitor real time radiological data via electronic dosimeters and continuous air monitors that transmit data to local substations which feed into a personal computer system.
The licensee hopes to relate the real time dose data to the video taped work activities for future radiological planning.
No violations or deviations were identifie Onsite Follow-u of Events a o Problem Re ort 91-1108 "Incorrect Flow Rate Used to Calculate Tritium Vent Stack Concentrations."
The licensee identified in a'roblem Report, dated October 4, 1991, that on numerous occasions between July 6, 1990 and September 20, 1991, vent stack calculations for tritium had been calculated using an incorrect flow rate and that 21 of the 32 samples taken during this period were not within procedural limits.
No problems'ere noted by the inspector with those calculations performed before and after this time period.
The cause of the error appears to be confusion in chemistry technician interpretation 'of the scale for new tritium collectors installed in June 1990.
The new collectors req'uired use of a correction factor to determine the flow rate, whereas the old ones were direct reading.
Consequently, a flow correction table was placed in the chemistry lab and a
memo was circulated.
During the following year, it became apparent to the licensee that chemistry technicians were reading flow rates directly off the new collectors and not using the correction factors.
This resulted in underreporting of tritium effluent concentrations'and doses by at least a factor of three.
Technical specification 4. 11;2. 1.2 states in part, that dose rate due to radioactive materials shall be determined in accordance with the sampling and analysis program specified in Table 4. 11-2.
Footnote (d) to Table 4. 11-2 requires that the ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation.
Failure to calculate doses using known sample flow rates is a
violation of technical specification 4, 11.2. 1.2
"Gaseous Effluents, Surveillance Requirements."
However, the licensee identified this violation and it is not being cited because the criteria specified in Section VII.B.1 of the "General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy,
CFR Part 2, Appendix C (1992)
were satisfied.
Licensee corrective actions included revising the July-December 1991 Semi-Annual Effluent Report and modifying chemistry laboratory procedures to require use of the flow'correction tables.
b.
Unex ected Radiolo ical Li uid Effluent Dischar e via Unit
Startu Flash Tank Vent 0 erations Problem report 92-0929, liquid effluent pathway operation of the Unit
June, 1992.
Condensate system which could have dated 6/19/92, described a radiological that existed during extended periods of Startup Flash Tank (SFT)
between Hay and from SFT venting entered the yard drainage discharged to the beach outside the owner
~
~
'
'
controlled area.
Isotopic analysis of sand samples from the yard drains and SFT condensate indicate low levels (lE-8 lE-6 uCi/gm sand; 1E-8 1E-7 uCi/cc condensate)
of fission and activation products.
In addition, a radiological survey near the beach discharge area did not identify any radiation levels above background, however, further sampling and analysis of beach sand is planned.
The SFT is primarily used to clean up contaminants present in the steam generator secondary side during plant start up and shutdown.
Normal operation consists of routing blowdown from the steam generators through a
common line into the SFT where approximately
,
30% flashes to steam and is vented to two moisture separators and eventual atmospheric release.
To maintain proper secondary side chemistry, blowdown must be maintained at 250 gpm or greater.
Because of a design deficiency in the piping, unequal flow distribution among the moisture separators occurs when the blowdown rate exceeds 250 gpm.
Consequently, entrained moisture in the'ented steam could enter the yard drains as condensate.
During normal operation only the blowdown between the steam generator and the SFT is monitored for radioactivity.
However, releases via this pathway are accounted for in the Semi-Annual Effluent Reports based on samples of blowdown in which 30% of the activity is assumed released as steam.
The licensee estimates that for May-June 1991, when the SFT was in extended operation, that if all the steam condensed, entered the yard drains and was discharged into the lake (approximately 1.5E6 gallons; total activity = 4.57E-3 Ci), the estimated total body dose would be 1.61E-3 millirem.
To date, an engineering evaluation of the necessa'ry design changes to correct the piping deficiency has been completed and submitted to plant management.
This item will continue to be reviewed by the inspectors during future inspections (IFI 50-315/92017-01; 50-316/92017-01).
One non-cited violation was identified.
9.
Ins ector Followu Items IFI Inspector follow up items are matters which have been discussed with the licensee, will be reviewed further by the inspector, and which involve some action on the part of the NRC, licensee or both.
Inspection follow up items disclosed during the inspection are discussed in section 8b.
10.
Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on August 7, 1992.
The licensee did not identify any documents as proprietary.
One non-cited violation was identified during this
inspection period and is discussed in section 8a.
The-following matters were specifically discussed by the inspectors:
a ~
b.
C.
d.
e.
f.
Use of "as indicated" postings (section 4)
Chemical decon of RTD bypass loops (section 7)
Outage ALARA controls (section 7)
Unexpected release pathway via Unit 1 Startup Flash Tank vents (section 8b)
Response to notice of violation (section 2)
Tritium migration from onsite absorption pond'section 2).