IR 05000315/1998019
| ML17335A255 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/25/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17335A254 | List: |
| References | |
| 50-315-98-19, 50-316-98-19, NUDOCS 9810050074 | |
| Download: ML17335A255 (13) | |
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U.S. NUCLEAR REGULATORYCOMMISSION
REGION III
Docket Nos:
License Nos:
50-315; 50-316 DPR-58; DPR-74 Report Nos:
50-315/98019(DRS); 50-316/98019(DRS)
Licensee:
Facility:
Indiana Michigan Power Company Donald C. Cook Nuclear Generating Plant Location:
1 Cook Place Bridgman, MI 49106 Dates:
August 31-September 3, 1998 Inspectors:
D. Nissen, Radiation Specialist N. Shah, Radiation Specialist Approved by:
Gary Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 9810050074 980925 PDR ADOCK 05000315
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EXECUTIVESUMMARY D. C.,Cook, Units 1 and 2 NRC Inspection Reports 50-315/98019; 50-316/98019 This inspection was conducted to review aspects of the radiation protection program, including the radiological environmental monitoring program, maintenance of effluent monitors, and self-assessment activities. Corrective actions for previously identified NRC violations were also reviewed. The following specific observations were made:
The radiological environmental monitoring program was well conducted, and associated results were documented as required.
An increase in the amount of tritium activity discharged to the lake had not resulted in doses exceeding regulatory limits and was adequately addressed by the licensee (Section R1,1).
Effluent radiation monitors were well maintained, and monitor alarm setpoints were conservatively set. Workers responsible for these monitors were aware of procedural requirements and of contingency actions for monitor inoperability (Section R2.2).
Self-assessments performed by the licensee were thorough but continued to identify problems with radiation worker practices.
These problems were confirmed by inspector
'bservations, and the licensee was planning additional corrective actions to address this issue (Section R7.1).
IV. Plant Support Radiological Protection & Chemistry (RP&C) Controls Radiolo ical Environrriental Monitorin Pro ram REMP Ins ection Sco e
IP 84750 The inspectors reviewed the licensee's implementation of the REMP. The inspection consisted of a walkdown of the REMP sampling equipment (including the meteorological tower), observations of REMP technician sampling activities, a review of documents and interviews with workers.
Observations and Findin s The REMP samples were collected by a licensee radiation protection technician (RPT)
who had several years experience with the program.
During the walkdown, the RPT demonstrated a good knowledge of the REMP procedures and familiaritywith the operability of the sampling. equipment.
This equipment was maintained in good condition based on direct observation and had a good operating history as documented in maintenance records.
The inspectors verified that the locations of onsite air sampling station nos.
1 through 9 were as described in the Offsite Dose Calculation Manual (ODCM) and that the installed equipment was appropriately calibrated.
The technician correctly changed the filter paper and charcoal cartridges and was familiarwith sample collection procedures and practices.
The inspectors also observed the collection of surface water samples at the Lake Township Water Treatment Facility; no problems were identified.
Meteorological data was collected by instrumentation located in an offsite tower which was maintained by the radiation protection (RP) group. The inspectors verified that the equipment was operable and that housekeeping inside the facilitywas good. This equipment was calibrated semi-annually by licensee mechanical maintenance staff in accordance with manufacturer specifications and had been upgraded within the last 3 to 4 years.
Some of the improvements included installation of sacrificial anodes, digital components and new wiring. The inspectors observed that tower indications were appropriately displayed in the licensee's main control room.
The inspectors reviewed the results of the annual 1997 land use survey and the 1997 REMP reports; no problems were identified. In particular, the inspectors noted that program exceptions (such as missing samples or non-participating dairy farms) were appropriately addressed and documented.
The inspectors also verified that the monitoring of tritium levels in groundwater (via onsite wells) was conducted as required and that no adverse trends had been identifie In March 1998, an industry audit identified an increasing trend in the amount of tritium released (in waste water) to the lake. Specifically, the audit noted that from 1992 through 1997, tritium activity discharged increased from about 500 to 1485 curies, which was significantly higher than the industry average.
However, the associated doses from these activities remained well below regulatory limits. A licensee investigation concluded that this increase resulted from inefficient management of waste water treatment and not from a adverse plant condition. A similar conclusion was also reached during an independent review by the inspectors.
This finding was documented in a station condition report (CR no. 98-2060), and corrective actions were being developed.
Conclusions The REMP was well conducted and associated results were documented as required.
An adverse trend regarding the amount of tritium activity discharged to the lake had not resulted in doses exceeding regulatory limits and was being adequately addressed by the licensee.
Status of RP&C Facilities and Equipment Effluent Release Radiation Monitors Ins ection Sco e IP 84750 The inspectors reviewed the operability of the effluent release monitors. The inspection consisted of a walkdown of the monitors, review of records and interviews with workers.
Observations and Findin s During the walkdown the inspectors observed that the monitors were in good condition and were operable.
However, a problem was noted with excessive dust loading on the air filterfor the unit 1 vent effluent monitor. This monitor was located adjacent to a construction area where work was ongoing for the ice condenser project. The inspectors noted that the excessive loading may caus@ the monitor to overheat and become inoperable.
Some minor debris (bolts, nuts, etc) was also noted near the sample pump for the "A"lower containment monitor, which could impact and potentially damage the pump components.
The licensee agreed with these observations and was planning corrective actions.
The inspectors observed the indications of the effluent monitors in the main control room (via the area and radiation monitor console) and verified, through interviews, that operators were familiar with the console operation and alarm responses.
Each monitor was currently calibrated and had undergone surveillances required by station procedures.
Allsurveillances involving radiation sources were performed by a separate group of instrument technicians assigned to the RP department.
These technicians were knowledgeable of as-low-as-is-reasonably-achievable (ALARA)
concerns and of monitor operability history. A selective review of maintenance records
and condition reports over the last six months did not identify any adverse trends with monitor operation.
However, the licensee had identified several examples of minor problems with the monitors'echnical data and use description contained in the Final Safety Analysis Report (FSAR). These examples were being addressed through the stations ongoing process to revalidate and update the FSAR.
The inspectors verified that monitor alarm setpoints were conservatively set, using a methodology consistent with industry practices.
Additionally, associated procedures were reviewed to ensure that contingency plans were developed for monitor in operability (i.e., confirmatory sampling). Through discussions, the inspectors verified that workers were aware of the stated actions.
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Conclusions ENuent radiation monitors were well maintained, and associated alarm setpoints were conservatively set. Those workers having responsibility for these monitors were aware of procedural requirements and of contingency actions for monitor inoperability.
'uality Assurance in RP&C Activities R7.1 Radiation Protection Self Assessments IP 83750 The RP department initiated a series of self-assessments to address a declining trend in radiation worker performance.
Specifically, RPTs were tasked to observe and question workers in the field regarding compliance with RP requirements and acceptable work practices.
Several of these assessments, conducted between June and July of 1998, were reviewed by the inspectors.
Overall, the assessments were thorough and had identified recurring problems with poor radiation worker practices, such as improper wearing of dosimetry or protective clothing. These findings were confirmed by the inspectors, who observed workers in the Unit 1 containment with their protective clothing improperly worn. As many of these workers appeared familiar with the RP expectations, the inspectors were concerned that the observed behaviors were inconsistent with the understood expectations.
Station management agreed with the inspectors'bservations and indicated that additional self-assessments were needed and that station expectations needed to be enforced.
Prior to the exit meeting, RP management implemented continuous RPT coverage in the Unit 1 containment to reinforce station requirements.
Subsequently, no additional examples of improper behavior were observed during the inspectors'ontainment walkdowns..
RS R8.1 Miscellaneous RP&C Issues (IP 92904)
Closed Escalated Enforcement Item EEI 50-315/98006-01'50-316/98006-01:
A shipment of radioactive materials left the site without the proper shipping paperwork.
As a result of enforcement action number 98-113 this issue was determined to be an example of a Severity Level III problem (VIO 98-113-01013).
Immediate corrective
actions were to contact the driver and FAX him the appropriate shipping documents and to instruct him to placard the truck as required.
In addition, the licensee required that for all shipments that were leaving from outside the protected area or from any area other
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than the radioactive materials storage building, the carrier must be escorted at all times.
No new examples or problems with radioactive materials shipments had occurred.
This item is closed.
R8.2 'losed EEI 50-315/98006-02 50-31 6/98006-02:
A shipment of radioactive materials left the site without emergency response paperwork.
As a result of enforcement action number 98-113 this issue was determined to be an example of a Severity Level III problem (VIO 98-113-01023).
See Section R8.1 for corrective actions.
This item is closed.
R8.3 Closed Ins ection Follow-u Item IFI 50-315/98006-03 50-316/98006-03:
Response checks of the RM-14/20 detectors were at the low end of the acceptance criteria. The licensee's investigation identified that the source used for the response check was not properly decay corrected.
The licensee corrected this and had revised the procedure used to include a place for the worker performing the check to document the frisker reading. This revision ensured that future response checks would be easily trended to identify problems.
The inspectors reviewed the procedure revision and observed the source checks of several friskers. No problems were identified. This item is closed.
R8.4 0 en Violation IO 50-315/98006-04'0-316/98006-04:
Workers failed to ensure that their electronic dosimeters (EDs) were on prior to entering the radiologically controlled area (RCA). A contributing factor to this event was that an RPT manipulated the workers EDs to change the setpoints but was not trained on the use of the equipment.
The workers involved were counseled at the time of the event. An operator aid was developed to help the RPTs in the use of the equipment.
Additionally, all RPTs were required to attend training on the use of this equipment.
The inspectors reviewed the training records and the operator aid. Further training was planned for the middle of September.
However, the licensee identified two additional examples in August 1998 of workers entering the RCA with their EDs off. The licensee indicated that they were reviewing the incidents and continuing to implement corrective actions.
This item will remain open pending inspector review of these corrective actions.
R8.5 Closed VIO 50-315/98006-05'0-316/98006-05:
Aworker failed to notify RP after receiving two alarms of the security guard house gamma40 portal monitors. The licensee modified the monitors to initiate a recorded message describing the correct worker response folio'wing a radiation alarm.
New signs with the correct instructions were also placed in a high visibilityarea.
The licensee performed a review of the training provided to workers on the proper response to monitor alarms; several inconsistencies were identifie. The study guide used in the general employee training did not provide guidance that was consistent with station procedures.
The inspectors discussed this with training personnel who indicated that the study guide was being revised to accurately reflect the procedure requirements.
The proposed revisions to the study guide were reviewed by the inspectors and determined to be adequate.
This item is close R8.6 0 en VIO50-315/98006-06 50-316/98006-06:
Afailure to followthe radiation worker permit (RWP) dress requirements was identified. Immediate corrective actions included suspending the RWP, discussing the issue with the work group and the supervisors, and
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conducting tailgate sessions with the craft personnel.
The licensee also issued a radiation worker directive regarding the importance of following procedures and complying with RWPs.
RPTs were questioning workers in the field about radiation worker practices (see Section R7.1). The inspectors performed several inspections in containment and the auxiliary building to observe workers'ompliance with RWP dress requirements.
The inspectors identified several minor problems.
Following these observations, RP supervision stationed a RPT in the ice condenser at all times to
'onitor workers dress.
Subsequent inspections revealed that workers were dressed in accordance with their RWP requirements.
This item willbe reviewed in future inspections.
R8.7 Closed IFI50-315/98006-0 50-316/98006-07:
Poororincompleteresolutionand documentation of condition reports.
The inspectors reviewed several condition reports and determined that the investigations had been performed by the due date assigned and no problems were identified regarding the thoroughness of the investigations or documentation.
The inspectors verified that one condition report (CR 97-3203), which had been open past it's due date, had been responded to and closed as appropriate.
This item is closed.
R8.8 Closed VIO 50-315/98013-01 50-316/98013-01:
Aworker entered containment with an open wound on his shoulder without notifying RP personnel, The inspectors reviewed a procedure revision which clariTied who had the responsibility to notify RP personnel of an open wound. The procedure indicated that all radiation workers have a responsibility to notify RP personnel of a wound, including the worker with the wound and anyone else with knowledge of the wound. This item is closed.
V. Management Meetings X1 Exit Meeting Summary.
On September 3, 1998, the inspectors presented the inspection results to licensee management.
The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identifie '
PARTIALLIST OF PERSONS CONTACTED D. Cooper, Plant Manager R. Fard, Health Physicist D. Foster, Radioactive Materials Specialist P. Holland, General Supervisor, Radiation Support D. Noble, Radiation Protection Superintendent M. Snyder, Health Physicist INSPECTION PROCEDURES USED IP 83750 Occupation Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92904 Follow-up-Plant Support Closed 50-315/316-98013-01 50-315/316-98006-01 50-315/316-98006-02 50-315/316-98006-03 50-315/316-98006-05 50-315/316-98006-07 Discussed 50-315/316-98006-04 50-315/316-98006-06 ITEMS OPENED, CLOSED, OR DISCUSSED VIO Failure to notify RP of open wound prior to entry to RCA.
EEI Shipment of radioactive material without shipping paper work.
EEI Shipment of radioactive material without emergency response paper work'.
IFI Response checks of detectors low end of acceptable range.
VIO Failure to notify RP after monitor alarm.
IFI Poor or incomplete resolution and documentation of condition reports.
VIO Failure to ensure EDs on prior to RCA entry.
VIO Failure to follow RWP dress requiremen CFR CR ED EEI FSAR IFI ODCM PDR RCA REMP RP RPT RP8C RWP VIO LIST OF ACRONYNIS USED As-Low-As-Is-Reasonably-Achievable Area Radiation/Process Radiation Code of Federal Regulations Condition Report Electronic Dosimetry Escalated Enforcement Item Final Safety Analysis'eport Inspection Follow-up ltem-Offsite Dose Calculation Manual Public Document Room Ra'diologicaily Controlled Area Radiological Environmental Monitoring Program Radiation Protection Radiation Protection Technician Radiation Protection and Chemistry Radiation Work Permit
'Violation
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"i Station Procedure Numbers.
LIST OF DOCUMENTS REVIEWED 12THP6010RPP.632 (rev. 4) Calibration of Environmental AirSamplers 12THP6010RPP.630 (rev. 2) Calibration of REMP Surface Water Samplers 12THP6010RPP.633 (rev. 4) Calibration of Environmental Radiation Dosimeters 12THP6010RPP.634 (rev. 2) Collection of Groundwater Samples 12THP6010RPP.622 (rev. 1) Collection of Drinking Water Samples 12THP6010RPP.643 (rev. 1) Quarterly Review of REMP Data 12THP6010RPP.637 (rev. 1) Collection of Lake Sediment Samples 12THP6010RPP.638 (rev. 1) Collection of Grape and Broadleaf Samples 12THP6010.RPC.810 (rev. 0)
Eberline RMS Channel Restoration 12THP6010RPC.804 (rev. 10)
Eberline RMS Iodine Channel Recalibration 12THP6010RPC.815 (rev. 0)
Eberline Radiation Monitoring System Particulate and Low Range Noble Gas Calibration 12THP6010RPC816 (rev. 0)
Eberline RMS DA1.1 and DA 1.6 Area Monitor Calibration 12THP6010RPC817 (rev. 0)
Eberline Radiation Monitoring System Mid and High Range Noble Gas Calibration 12THP6010RPC814 (rev. 10)
Eberline RMS Liquid Channel Calibration Calibration Records 12IHP6030.333 (5/30/98)
Meteorological Instrument Calibration AirSampler Calibration Records: AVS28-5512 (3/26/98); AVS 28-5508 (3/31/98); AVS 28-5505 (4/13/98); AVS 28-5501 (2/23/98)
Eberline RMS Iodine Calibration Records for Detector Nos: 2217 (4/28/98); 2126 (5/12/98); 221 (7/1 7/98); 2570 (2/26/98)
Eberline Particulate and Low Range Noble Gas Monitor Calibrations for Detector Nos: P2497 (3/4/98); LNG2493 (5/12/98); P2405 (5/21/98); LNG2261 (5/21/98); P2548 (6/2/98); LNG2523 (7/14/98); P1803 (2/13/98); LNG2260 (2/24/98)
Eberline RMS Mid and High Range Noble Gas Calibrations for Detector Nos: 52872 (6/15/98);
62688 (8/1 0/98); 74417 (1/30/98); 23900 (1/9/98); 74314 (3/11/98)
Eberline Liquid RMS Channel Calibrations for Detector Nos: 2558 (10/16/97); 1902 (10/29/97);
2560 (10/28/97)
Radiation Protection Technical Evaluation Numbers 97-06 (rev. 0)
97-07 (rev. 0)
97-08 (rev. 0)
97-13 (rev. 0)
97-16 (rev. 0)
97-19 (rev. 1)
Determination of Reference Response to Beta Reference Disc Source Set for Eberline RDA-31 Detectors Determination of Low Range Noble Gas Detector Calibration Constant Determination of the Particulate Channel Calibration Constant for the Eberline SPING Determination of Area Monitor Calibration Constants Determination of Reference Responses for DAI-1 and DAI-6 (Area Monitors)
Detectors Voltage/Gain Setpoint and Reference Response Determination for Eberline RMS
Liquid Detectors (RDA-5A)
97-17 (rev. 0) Determination of Reference Responses for High Range Noble Gas Detectors 97-14 (rev. 1) Eberline RMS Calibration Constants 97-19 (rev. 0) Voltage/Gain Setpoint and Reference Response Determination for Eberline Monitors 97-20 (rev. 0) Multiple Release Point Factor Determination Condition Re ort Numbers.
98-2060 98-1860 98-2749 98-0368 98-4368 984370 98-0544 98-2845 98-2715 98-1930 98-2736 98-3157 98-2309 Miscellaneous.
Offsite Dose Calculation Manual (ODCM) section 4.5, "Radiological Environmental Monitoring Program (REMP)"
1998 Land Use Survey Report (6/23/98)
Annual Environmental Operating Report for 1/1/97 to 12/31/97 Environmental AirSample Log for 1" and 2~ Quarter of 1998 (4/1/98-5/27/98)
Surface Water Sample Log for 4/98-7/98 Environmental Thermolumiscent Dosimeter Sample Log for 4/1/98 and 7/1/98 Groundwater Sample Log for4/23/98 and 1/22-23/98 Drinking Water Sample Log for 4/98 - 6/98 Unavailable REMP Sample Log for 1" and 2~ Quarter of 1998 Sediment Sample Log for 4/98 Broadleaf Sample Log for 6/98 Plant Performance Audit no. PA-98-14/NSDRC¹255 (5/29/98)
Operability History Records for ENuent Monitor Nos: CRS-3301, CRS 3400, CRS-3401, DRS-3101, DRS-4101, ERA-7703, ERA-7504, ERA-7600, ERS-1301, ERS-1400, and ERS-1401 Rps-98-020 Tour/Inspection of ice condenser maintenance Rps-98-021 Work control-Aux/Containment radworker Compliance with RWP's and ED's b
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