IR 05000315/1999014

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Insp Repts 50-315/99-14 & 50-315/99-14 on 990517-0603.No Violations Noted.Major Areas Inspected:Licensee Radiological Effluent Control & Radiation Protection Programs
ML17326A018
Person / Time
Site: Cook  
Issue date: 06/18/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17326A017 List:
References
50-315-99-14, 50-316-99-14, NUDOCS 9906240247
Download: ML17326A018 (20)


Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos:

50-315; 50-316 License Nos:

DPR-58; DPR-74 Report No:

50-315/99014(DRS); 50-316/99014(DRS)

Licensee:

American Electric Power Company Facility:

Donald C. Cook Nuclear Generating Plant Location:

1 Cook Place Bridgman, Ml 49106 Dates:

May 17 - 21, 1999, with continued in office review through June 3, 1999 Inspector:

W. Slawinski, Senior Radiation Specialist Approved by:

Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety 9906240247 9'9'061,8 PDR ADQCK 05000SL5 PDR

EXECUTIVESUNIMARY D.C. Cook, Units 1 and 2 NRC Inspection Report 50-315/99014(DRS); 50-316/99014(DRS)

This routine inspection evaluated the effectiveness of aspects of the licensee's radiological effluent control and radiation protection programs.

Specifically, the inspection focused on the control of gaseous and liquid effluents and assessment of offsite dose, the radiological controls for access to high radiation areas and for portable equipment and tools used in the radiologically restricted area, the control of internal exposure, and the audit and self-assessment program.

The following conclusions were made in these areas:

Plant Su ort Gaseous and liquid effluents were adequately controlled, properly sampled, and quantified, and doses were determined consistent with the Offsite Dose Calculation Manual (ODCM). The total radioactivity released in liquid and gaseous effluents and associated doses remained well below regulatory limits. Annual Radioactive Effluent Release Reports for 1997 and 1998 included all required information, consistent with Regulatory Guide 1.21 (Section R1.1).

The 1998 Annual Radioactive Effluent Release Report was not submitted to the NRC within the timeframe required by technical specifications, resulting in a violation of minor safety significance not subject to formal enforcement action.

Inspector identified minor discrepancies in certain liquid effluent flow paths described in the Updated Final Safety Analysis Report (UFSAR) and ODCM and contractor audit recommendations for the development of a formal water management program were also being addressed by the licensee (Section R1.1).

The radiological respiratory protection program was effectively implemented.

Systems were in place to ensure workers were qualiTied to use respirators,'and respiratory protection equipment was in good physical condition, inspected regularly by the licensee and properly maintained and stored. A program for quality testing of station breathing air was established and was properly executed, and sources of supplied breathing air met industry quality standards (Section R1.2).

Problems were identified with the completeness of respirator issuance logs and with the timely removal of self contained breathing apparatus (SCBA) bottles from use for hydrostatic testing, both which the licensee acknowledged and planned to address.

Also, licensee derived alpha emitter conversion factors and derived air concentration and annual limitof intake values used to assess internal dose were not recalculated when new scaling factors were determined, (Section R1.2).

Radiological control of access to high, extreme high and very high radiation areas (HRAs) was effective. Station procedures governing HRA access control and posting were developed consistent with technical specifications and regulatory requirements, included administrative mechanisms to ensure proper HRA key and area access control, and were appropriately and consistently implemented (Section R1.3).

The program for the use and for the radiological control of portable high efficiency particulate air (HEPA) filtered ventilation systems and vacuum cleaners and of tools and associated equipment was effective. A verification process implemented by the radiation protection (RP) staff ensured that portable HEPA units were maintained operable and in good physical condition and that the equipment's radiological condition did not preclude its safe use (Section R2.1).

Radiological postings were well maintained and accurately refiected the area conditions.

Radiological housekeeping in the Unit 2 containment building and the auxiliary building was generally good and had improved over the last several months (Section R4.1).

inconsistencies were identified with the labeling and tagging of containers housing radioactive materials, and recent condition reports indicated that workers did not clearly understand the revised labeling program (Section R4.1).

Recent efforts to audit and self-assess the chemistry and RP programs were effective.

Programmatic and functional area restart readiness reviews included broad scope, self-critical assessments of the RP and chemistry programs'eadiness.

Other recent initiatives included thorough vendor and licensee audits of the radioactive eNuents management program and ODCM implementation, both which identified several findings. Assessment and audit findings were entered into the licensee's corrective action process to track resolution and were being evaluated by RP/chemistry management and staff (Section R7.1).

Re ort Details IV. Plant Su ort Radiological Protection and Chemistry (RP&C) Controls Control of Gaseous and Li uid ENuents Ins ection Sco e 84750 The inspector evaluated the licensee's program for controlling and quantifying gaseous and liquid radioactive effluents. The Updated Final Safety Analysis Report (UFSAR),

Offsite Dose Calculation Manual (ODCM), annual eNuent report data, and selected eNuent release records and associated procedures were reviewed; release pathways and liquid radioactive waste (radwaste) processing systems were walked-down; and chemistry and radiation protection (RP) staffs were interviewed and/or accompanied by the inspector;--

Observations and Findin s The inspector verified that eNuent treatment systems and normal release pathways for liquid and gaseous effluents remained as described in the UFSAR and ODCM, with some exceptions related to the liquid radwaste stream.

Specifically, a laundry facility described in the UFSAR has not existed for several years and does not contribute to liquid effluents. Also, two boric acid evaporators and a radwaste evaporator described in the UFSAR and partially depicted in the ODCM as liquid radwaste processing systems were either never used or not used since approximately 1995, depending on which evaporator.

Similarly, a recent station audit identified a discrepancy between and ODCM and UFSAR related to liquid effluent discharged via the turbine room sump. The RP staff acknowledged the discrepancies and planned to revise the UFSAR and ODCM accordingly.

Liquid eNuents were discharged primarily on a batch basis to the circulating water discharge system from the chemical and volume control system monitor tanks and from steam generator blowdowns, or to the absorption pond from the turbine building sump.

Gaseous releases were either continuous through the condenser air ejector, the gland seal condenser exhaust or through the auxiliary building unit vent, or batch released from the waste gas decay tanks or from containment purges or pressure reliefs.

In 1997, a total of about 0.066 curies and 17.3 curies (both excluding tritium) were released through liquid and gaseous effluent pathways, respectively, compared to 0.172 curies and about 1.0 curie in 1998. A relatively small quantity of noble gas was released in 1998 because both units were shutdown throughout the year. The doses associated with liquid and gaseous effluents for 1997 and 1998 remained below (maximum of 5% for liquid effluents) regulatory limits, and no abnormal releases were reported for 1997 and 1998. The inspector determined that dose from effluents was calculated consistent with the ODCM and the methodology in NRC Regulatory Guide 1.10 Approximately 1500 curies of tritium was released in liquid effluents in 1997, compared to between 1000 - 1300 curies in the preceding three years.

While the total quantity of tritium released was below UFSAR projections, the licensee acknowledged a recent contractor audit which concluded that the quantities exceeded industry averages for similar output plants. The licensee continued to evaluate the audit recommendations but recognized that a formal water management program did not exist for the station.

The licensee was also considering the development of a formal program to routinely track, trend and analyze liquid and gaseous eNuent system performance, as a mechanism to better assess and manage the effluent control program.

Inspector review of the data presented in the 1997 Annual Radioactive Effluent Release Report and a draft of the 1998 report disclosed no problems.

Both reports included all required information and followed the format of Regulatory Guide 1.21. The 1998 annual report, however, was not submitted timely to the NRC in accordance with technical specification requirements, which the licensee identified during an audit on May 6, 1999. The final report was subsequently completed and provided to the inspector during the exit.meeting on May 21, 1999. A condition report was generated and an apparent cause evaluation was planned.

According to the licensee, the report was drafted by the RP staff sufficiently in advance of the required technical specification due date, but work'assignment and work oversight deficiencies and other priorities within the Regulatory Affairs (Licensing) Department caused the problem. Technical Specification Section 6.9.1.7 requires that the Annual Radioactive Effluent Release Report covering the operation of the unit during the previous 12 months of operation be submitted within 90 days after January 1 of each year. The failure to submit the 1998 effluent report on or before April 1, 1999, is a violation of minor safety significance and is not subject to formal enforcement action.

The inspector accompanied a chemistry technician and witnessed the collection of the Unit 2 vent stack gas sample and the iodine and particulate filtercollection and replacement.

The technician demonstrated good analytical and sample handling techniques, displayed knowledge of the sampling system and sampling procedure requirements, and completed the sampling and subsequent analysis work proficiently.

In April 1999, the licensee's expanded system readiness reviews identified surveillance testing concerns with the process eNuent monitors related to injection of a simulated signal into the proper channels to satisfy the channel functional test. As a result of this concern, all process eNuent monitors were declared inoperable in April, a condition report was generated and the issues were being evaluated by the licensee.

The inspector discussed waste stream sampling activities with the RP staff and veriTied that mechanisms were established to ensure compensatory sampling was completed in accordance with the ODCM white the monitors were out of service.

c.

Conclusions Gaseous and liquid eNuents were adequately controlled, properly sampled and quantified, and doses were determined consistent with the ODCM. The total radioactivity released in liquid and gaseous effluents and associated doses remained below regulatory limits. Annual Radioactive Effluent Release Reports for 1997 and 1998

included all required information consistent with Regulatory Guide 1.21; however, the annual report for 1998 was not submitted to the NRC in accordance with technical specification timeliness requirements, resulting in a violation of minor safety significance.

Inspector identified discrepancies in certain liquid effluent flow paths described in the UFSAR and ODCM and contractor audit recommendations for the development of a'ormal water management program were being addressed by the licensee.

Control of Internal Ex osure Ins ection Sco e 83750 The inspector reviewed portions of the radiological respiratory control program focusing on the selection, issuance, maintenance and storage of respiratory protection equipment, the station breathing air quality control program and mechanisms for evaluating and tracking worker internal dose.

L Observations and Findin s Since the implementation of the revised 10 CFR'Part 20, the licensee experienced a

decline in the use of respiratory protection equipment.

Notwithstanding the reduced use of this equipment, the respiratory protection program was generally well implemented, consistent with station procedures and industry guidance.

Specifically, workers authorized to use respiratory protection equipment were medically certified annually by a physician or other licensed health care provider, completed the licensee's respirator user classroom training, and were fittested by the licensee at least annually. The inspector determined that adequate mechanisms were in place to ensure that respirator qualifications for individual workers were verified prior to equipment issuance and that the licensee's computerized data base contained appropriate up to date information.

The inspector verified that respirators were cleaned and sanitized after use, as required by station procedures, and that contamination limits for respirators destined for reuse were consistent with industry standards and specified in the contract with the vendor that performed the cleaning service.

The inspector also verified that selected respiratory protection devices available for both routine and emergency (control room) use were inspected, sealed and labeled by the RP staff within the previous 30-days as required by station procedure, that self-contained breathing apparatus (SCBA) regulators were calibrated annually by trained and authorized licensee staff, and that hydrostatic tests of SCBA bottles were completed by authorized vendors at manufacturer recommended intervals.

However, the inspector identified several incomplete entries in respirator issue and return logs for 1998 and 1999 to the date of the inspection, and that not all SCBA bottles were removed from service for hydrostatic testing sufficiently in advance of the next test due date to satisfy procedural recommendations.

Although these issues were not violations of procedure requirements, the licensee planned to issue condition reports to address these deficiencies and track resolution as part of its corrective action proces A program for quality testing the station breathing air supply and the system used for fillingSCBA bottles was established by the licensee to ensure industry air quality standards were met. The inspector verified that the station breathing air supply was tested monthly in accordance with station procedure and met established (Grade D) air quality standards.

However, the primary SCBA bottle fillingsystem was tested for air quality only once between January and April 1999, owing to problems that required the system be taken out of service.

The inspector learned that the air compressor system used to fillthe SCBA bottles was generally reliable until internal corrosion and sediment buildup problems were identified by an authorized equipment service vendor in the fall of 1998, when the unit failed to operate.

According to the RP supervisor responsible for the system, the problems developed because the compressor was infrequently used and because a formal preventative maintenance program was not established for the system.

The unit was subsequently overhauled and a routine maintenance and service agreement was established with the vendor. The unavailability of the primary filling system did not significantly impact the respiratory protection program, because a

sufficient number of previously filled SCBA bottles were maintained for routine and emergency-uses, and a backup compressor was available in-the training building.

Responsibility for the alternate compressor was recently transferred to the RP department to ensure air quality tests were regularly conducted for the backup unit.

The inspector evaluated the licensee's methodology for determining derived air concentration (DAC) values and tracking DAC-hours for work in areas where a potential for intake of radioactive material exists. The DAC-hour tracking procedure and station practices were reviewed by the inspector and determined to be appropriate and in compliance with regulatory requirements for monitoring internal occupational dose specified in 10 CFR 20.1502.

The inspector also concluded that licensee calculations to support the use of DAC and annual limitof intake (ALI)values based on reactor coolant system chemistry, for converting contamination from alpha emitting radionuclides to DAC fractions and for establishing a DAC value for unidentified alpha emitters based on 10 CFR Part 61 scaling factors, were technically sound.

However, the inspector identified that calculations performed by the RP staff to justify use of calculated DAC and ALIvalues and for alpha conversion factors were not reevaluated for several years to validate their continued applicability, despite potential changes in coolant chemistry and plant scaling factors.

Radiation protection management expected the derived values to be recalculated and validated annually when plant scaling factors were determined, and as otherwise dictated by changes in coolant chemistry. The licensee planned to initiate a CR to address resolution of this matter.

c.

Conclusions The radiological respiratory protection program was effectively implemented.

Systems were in place to ensure workers were qualified to use respirators, and respiratory protection equipment was in good physical condition, inspected regularly by the licensee and properly maintained and stored. A program for quality testing station breathing air was established and was properly executed, and sources of supplied breathing air met industry air quality standards.

Some problems, however, were identified with the completeness of respirator issuance logs and with the timely removal of SCBA bottles from use for hydrostatic testing, both which the licensee acknowledged and planned to

address.

Also, licensee derived alpha emitter conversion factors and DAC and ALI values used to assess internal dose were not recalculated at expected frequencies, coincident with plant scaling factor determinations and changes to reactor coolant chemistry.

R1.3 Control of Hi h Radiation Areas a.

Ins ection Sco e 83750 The inspector evaluated the licensee's radiological control of access to high radiation areas (HRAs), including extreme high radiation areas (defined by the licensee as accessible areas in which radiation levels exist in excess of one rem per hour at 30 centimeters) and very high radiation areas (as defined in 10 CFR Part 20). High radiation area access control procedures were reviewed; RP staff were interviewed; and HRA security, control, posting and procedure implementation were selectively verified.

b.-

Observations arid Findin s The inspector reviewed the station procedure for control of access to HRAs and determined that it was consistent with Section 6.12 of the technical specifications and the regulatory requirements specified in 10 CFR Part 20 for control and posting of HRAs. Several good administrative controls for HRA access were incorporated into the station procedure.

However, the inspector noted that the procedure did not require a physical search or include a similar worker accountability process to ensure all personnel had vacated an extreme or very HRA prior to securing the area.

The licensee acknowledged the inspector's comment and planned to consider whether such a process was warranted.

Inspector interviews of RP staff, review of HRA key logs and CRs, inspection of the HRA key storage, area maintained in the RP department and a walkdown of selected HRAs determined that the control of access to HRAs was effective. Specifically, the inspector verified that:

positive custody was maintained by RP supervision over key issuance; combined HRA and security vital areas were equipped with separate locks; physical inventories of HRA keys and security checks of HRA doors located outside containment were completed once per shift by the RP staff; each entrance to a very HRAwas controlled by a lock and key unique to that area; only RP staff or other staff authorized by RP supervision in writing provided entry into extreme or very HRAs; HRA key logs were properly maintained; and selected extreme HRA doors were locked or barricaded as required and that other HRAs were properly posted and controlle Conclusions Radiological control of access to high, extreme high and very high radiation areas was effective. Station procedures governing HRA access controls and posting were developed consistent with technical specifications and regulatory requirements, included several administrative mechanisms to ensure proper HRA key and area access control, and were appropriately and consistently implemented.

R2 Status of RP&C Facilities and Equipment R2.1 Control of Portable Hi h Efficienc Particulate Air HEPA Filtration Units and Tools Ins ection Sco e 83750 b.

The inspector reviewed the licensee's program for testing, issuance, use and storage of portable HEPA filtration systems and HEPA equipped vacuum cleaners and for the radiological control of tools and other equipment usedin the radiologically restricted area (RRA). Relevant procedures were reviewed by the inspector; station staff were interviewed; and areas of tool and equipment use and storage were inspected.

Observations and Findin s Station procedures for the use and control of portable HEPA ventilation units and

'vacuum cleaners were reviewed and determined to clearly outline the necessary radiological and industrial hazard controls for the safe use of the equipment.

Procedures included a routine verification process to ensure that units were in good physical condition, that differential pressure across the filter housing met specified standards and that radiological conditions did not preclude continued equipment use.

The inspector interviewed RP supervisory and technician staff, inspected the storage area (cage) where portable HEPA units were maintained when not in use and conducted walkdowns of equipment use and temporary storage in the auxiliary building and Unit 2 containment.

The inspector verified that the routine (monthly) equipment verification process was implemented as required by station procedure, that units were maintained operable and were in good physical condition, that filterunits were locked within the cannister and equipment was properly labeled with appropriate cautions signs, and that issuance and return logs were properly completed.

However, contamination control deficiencies were identified with some of the HEPA vacuums maintained in the storage cage.

Specifically, the inspector found that suction ports and hose ends on some vacuums were not properly sealed to prevent the potential spread of contamination.

These deficiencies were quickly rectified by the RP staff, and alternative methods of sealing tlie ports and hoses were being considered.

Tools and related equipment reserved for use in the RRA was maintained in the hot tool crib (HTC) located in the auxiliary building. A tool and equipment decontamination area (TEDA)was located adjacent to the HTC and used to decontaminate tools and equipment prior to return and storage in the crib. Potentially contaminated tools used in the RRA were surveyed by RP staff and transferred to the TEDA, ifnecessar Appropriate radiological criteria were established for the return of tools to the HTC for reuse in the.RRA. A contamination free anteroom located between the TEDA and HTC was used to transfer tools decontaminated in the TEDAto the crib. Routine, weekly contamination surveys were performed in the anteroom and HTC to evaluate the effectiveness of the tool contamination control program.

Inspector review of survey records, discussions with the RP staff and a tool crib attendant, and inspector independent contamination smear surveys of tools and other selected equipment stored in the HTC revealed no problems.

Conclusions The program for the use and the radiological control of portable HEPA filtered ventilation systems and vacuum cleaners and of tools and associated equipment used in the RRA was effective. A verification process implemented by the RP staff ensured that portable HEPA units were maintained in appropriate physical, operational and radiological condition, consistent with industry standards and practices and manufacturer recommendations.

Staff Knowledge and Performance in RP&C Plant Walkdowns and Other Observations Ins ection Sco e 83750 Walkdowns of the Unit 2 containment building and auxiliary building were conducted during the inspection to evaluate radiological posting, labeling, housekeeping and radworker practices.

Condition reports related to the RP program were also selectively reviewed.

Observations and Findin s Radiological postings were adequately maintained, and the inspector determined through independent measurement that selected radiation areas and HRAs were appropriately posted.

During walkdowns, the inspector verified that high and extreme HRAs were controlled in accordance with station procedures, technical specifications and other regulatory requirements.

The inspector reviewed a recently revised station procedure and evaluated station practices for labeling containers housing radioactive materials.

The evaluation identified inconsistencies with the use of radioactive material (RAM)tags affixed to some of the containers.

The RAM tags were to be fastened to the containers only ifthe contents caused radiation and contamination levels to exceed specified thresholds.

The tags were intended to fulfillthe informational requirements for labels specified in 10 CFR 20.1904 and to permit individuals handling the containers or working in the vicinityto take the necessary actions to reduce exposure.

The inspector identified that RAM tags were fastened to some containers (mostly bagged material) that did not require tagging by the licensee's procedure, while other containers that created similar radiological hazards were not tagged.

The licensee attributed the inconsistency to the recently

revised procedure, which differed from previous revisions because it established radiation and contamination level thresholds at which RAM tags were required.

The inspector reviewed the revised labeling procedure and determined that it met the intent of the regulations in 10 CFR 20.1904, provided all station workers were properly instructed and understood the new procedure and the tagging process was consistently implemented.

Tlie inspector also noted that CRs were generated for improperly tagged containers since the procedure was revised late in 1998.

Radiation protection management recognized the problem, was addressing it through RP staff tailgate meetings and instructions, and planned to reevaluate the procedure and the need for station wide training.

Radiological housekeeping in the auxiliary building was generally good and appropriate contamination control practices were observed such as securing hoses and other items that crossed contamination area boundaries.

Auxiliarybuilding housekeeping had improved since the inspectors previous walkdowns three months earlier, and the number of bags and other containers housing contaminated tools was significantly reduced.

During the inspection, considerable effort was being taken by the licensee to improve the overall station housekeeping and included efforts to reduce auxiliary building contamination accumulated on horizontal surfaces above head level.

The inspector selectively reviewed CRs generated between January 1998 and May 1999, to determine the scope and depth of RP problems identified by the licensee and the actions taken.

The review revealed a significant increase in the number of CRs generated since March 1999, when expanded system readiness reviews and other audit and self-assessment initiatives were initiated. However, no significant radworker performance problems or other significant RP program issues that warranted immediate licensee action were disclosed through the CR reviews.

Identified problems were placed into the licensee's corrective action process, and the RP department was focusing its efforts to correct program deficiencies.

Conclusions Radiological postings were well maintained and accurately reflected the area radiological conditions.

Radiological housekeeping in the Unit 2 containment building and the auxiliary building was generally good and had improved over the last several months.

However, inconsistencies were identified with the labeling and tagging of containers housing radioactive materials, and recent CRs indicated that workers did not clearly understand the revised labeling program.

R7 Quality Assurance in RP&C Activities R7.1 Audits and Self-Assessments Ins ection Sco e 83750 84750 The inspector reviewed the results of recent vendor and licensee audits of the radiological effluent management program and ODCM implementation and discussed

.

ongoing efforts to self-assess the chemistry and RP programs with the RP/Chemistry management and staff.

Observations and Findin s The inspector reviewed the preliminary results of a licensee performance audit of the radioactive effluent control program and ODCM implementation completed in May 1999, satisfying technical specification requirements for the 24 month cycle audit. The audit was conducted over the course of a two week period by a two person team knowledgeable in the subject matter. The inspector reviewed the draft audit report, discussed the audit findings with one of the auditors and determined that the audit was thorough, properly focused and self-critical. The audit concluded that ODCM implementation and eNuent controls were effective; however, several problems were identified including the violation of minor safety significance discussed in Section R1.1 for the untimely submittal of the annual eNuent report. The audit also identified procedural problems, unclear management expectations for certain chemistry sampling activities, and questioned the adequacy of the liquid eNuent monitor background radiation default set point. The RP/Chemistry staffs were evaluating the assessment findings at the time of the inspection.

Condition reports were written to track resolution of the findings.

The inspector also reviewed the results of a two week vendor audit of the effluent management program conducted in February 1999. The audit identified organizational and management weaknesses associated with the program including the lack of a formal waste water and waste gas management program and the need to establish mechanisms to track, trend and analyze the performance of eNuent systems.

Several recommendations for improvement were made by the audit team, were entered into the licensee's corrective action process and were being evaluated by the RP and chemistry staffs.

The licensee recently devoted considerable effort to self-assess its chemistry and RP programs, as part of station wide functional area and programmatic restart readiness reviews. Self-assessments of these programs were nearing completion and results were due to plant management in late June 1999. The inspector discussed the self-assessment activities and preliminary results with RP management and staff and determined that broad scope, self critical assessments were completed of functional areas important to station restart readiness.

Assessments were conducted by cross functional teams involving staff from various levels within the RP organization and included contributions from the technician staff, who independently developed reform issues to improve program management and ownership.

Several findings and recommendations resulted from the assessments and were being evaluated and tracked by the licensee's corrective action process.

Conclusions Recent efforts to audit and self-assess the chemistry and RP programs were effective.

Programmatic and functional area restart readiness reviews included broad scope, self-critical assessments of the RP and chemistry program readiness.

Other recent

initiatives included thorough vendor and licensee audits of the radioactive eNuents management program and ODCM implementation, both which identified several findings. Assessment and audit findings were entered into the licensee's corrective action process to track resolution and were being evaluated by RP/chemistry management and staff.

V. Mana ementMeetin s

X1 Exit Meeting Summary The inspector presented the preliminary inspection results to Mr. Bakken and other members of licensee management and staff at the conclusion of the site inspection on May 21, 1999. On May 27 and 28, 1999, additional information was received from the licensee, was reviewed by the inspector in the Region III office and discussed with the RP program manager on June 3, 1999. The licensee acknowledged the findings presented and did not identify any of the information reviewed as proprietary.

PARTIALLIST OF PERSONS CONTACTED J. Arias, Compliance Manager C. Bakken, Site Vice President P. Barrett, Director, Performance Assurance J. Cassidy, Acting General Supervisor, Radiation Protection B. Chambers, Senior Radiation Protection Technician R. Fard, Health Physicist D. Foster, Auditor, Performance Assurance F. Kick, Health Physicist A. Kivela, Radiation Protection Technician T. Lechenet, Supervisor, Radiation Protection D. Noble, Radiation Protection Program Manager M. Norton, Health Physicist T. O'eary, Manager, Radiation Protection & Chemistry J. Piazza, Chemistry Superintendent F. Poppell, Compliance Engineer, Regulatory Affairs C. Vandemiet, Quality Assurance K. Van Dyne, Compliance Engineer, Regulatory Affairs S. Watkins, Acting General Supervisor, Radiation Protection INSPECTION PROCEDURES USED IP 83750:

IP 84750:

I Occupational Radiation Exposure Radioactive Waste Treatment, and ENuent and Environmental Monitoring ITEMS OPENED, CLOSED AND CLOSED None

ALI CR DAC HEPA'RA HTC ODCM QC Radwaste RP RRA SCBA TEDA UFSAR LIST OF ACRONYMS USED Annual Limitof Intake Condition Report Derived AirConcentration High Efficiency Particulate Air High Radiation Area Hot Tool Crib Offsite Dose Calculation Manual Quality Assurance Radioactive Waste Radiation Protection Radiologically Restricted Area Self Contained Breathing Apparatus Tool and Equipment Decontamination Area Updated Final Safety Analysis Report

PARTIALLIST OF DOCUNIENTS REVIEWED Station Procedures 12 THP 6010 RPP.406 (Rev 6), DAC-Hour Tracking 12 THP 6010 RPP.203 (Rev 8), Breathing AirSystems 12 THP 6010 RPP.201 (Rev 3), Maintenance and Repair of Respiratory Protection Devices 12 PMP 6010 RPP.201 (Rev 8), Control and Use of Respiratory Protection Devices 12 PMP 6010 RPP.003 (Rev 9), High, Extreme High and Very high Radiation Area Access 12 PMP 6010 RPP.304 (Rev 7), Use of HEPA Vacuum Cleaners 12 THP 6010 RPP.302 (Rev 10), Use of HEPA Ventilation Units 12 PMP 6010 RPP.301 (Rev 12), Control of Material in a Restricted Area 12 THP 6020 CHM.322 (Rev 0), Vent Stack Gaseous Sampling Audits and Self-Assessments Draft Audit Report ¹ PA-99-06/NSDRC ¹ 266, May 19, 1999, Radiological Environmental Monitoring Program and Offsite Dose Calculation Manual PMP 7200.RST.010 (Rev 1), Radiation Protection Functional Area Assessment Plans Other I

Electronic Corrective Action Program Condition Report Summary Data for Radiation Protection, January 1, 1998 - May 14, 1999.

RP-95-11, Determination of Lung Clearance Classification for Radionuclides at the Cook Nuclear Plant.

RP Calculation 97-15, TEDE Evaluation Alpha Conversion Factors.

1997 Annual Radioactive Effluent Release Report 1998 Draft Annual Radioactive Effluent Release Report 16