ML17317B447
| ML17317B447 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/20/1979 |
| From: | Fisher W, Schmacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17317B441 | List: |
| References | |
| 50-315-79-14, 50-316-7911, NUDOCS 7908150346 | |
| Download: ML17317B447 (13) | |
See also: IR 05000315/1979014
Text
U. S.
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 315/79-14;
316/79-11
Docket No. 50-315;
50-316
License No.
DPR 58;
DPR 74
Licensee:
American Electric Power
Co.
ATTN:
Mr. John Dolan
Senior Executive Vice President
Engineering
2 Broadway
New York, NY
10004
Facility Name:
D. C. Cook Nuclear Plant Units
1 and
2
Inspection At:
Site
Inspection
Conducted:
May 29 June
1,
1979
Inspector:
.
C. Schumacher
Approved By:
W. L. Fishe
, Chief
Fuel Facility Pro5ects
and
Radiation Support Section
Ins ection
Summar
Ins ection on Ma
29-June
1
1979
Re ort No. 315/79-14'16/79-11
Areas Ins ected:
Routine,
unannounced
inspection of radiation
protection program, including:
qualifications; training; radiation
protection procedures;
instruments
and equipment;
exposure control;
posting, labeling,
and control; surveys; notifications and reports;
followup on IE Bulletins and Circulars; previous noncompliance
review; and Unit
1 refueling outage
advance planning and preparation.
The inspection involved 43 inspector-hours
on site by one
NRC
inspector.
Results:
No items of noncompliance
were identified in 10 of the ll
areas
inspected.
Two infractions in the area of internal exposure
control were identified; one concerned
inadequate air sampling,
and
one concerned
inadequate
followup on whole body counting results
(both units).
(Paragraphs
10b and
10c)
DETAILS
1.
Persons
Contacted
- D. Shaller, Plant Manager
+E. Smarella,
Technical Supervisor
- D. Palmer, Plant Radiation Protection Supervisor
- J. Stietzel, Quality Assurance
Supervisor
J. Fryer, Radiation Protection Supervisor
W. Ketchum, Engineer
(Radiation Protection)
J. Hoss, Radiation Protection Supervisor
- R. Masse,
U.S.
NRC, Resident
Inspector
- Denotes those present at the exit interview.
2.
General
This abbreviated
inspection began at about noon on May 29,
1979.
After security processing
and initial discussions
with the
NRC
resident inspector,
the plant manager,
and the plant radiation
protection supervisor,
a rather extensive tour was made of Unit
1
containment
and the auxiliary building to observe radiological
working conditions.
Both units were shut
down with work in progress
on repair of feedwater nozzles.
The Unit
1 refueling was essentially
complete.
Housekeeping
was generally poor, owing, according to
licensee representatives,
to the intensity of work during the outages.
Radiological controls observed
appeared
adequate.
No items of noncompliance
or deviations were identified.
3.
Licensee Action on Previous Ins ection Findin s
(Closed)
Deficiency (315/78-11):
Failure to retain daily survey
records in accordance with Technical Specification 6.10.2.C.
The
licensee is currently retaining these records.
4.
Facilities
Access control facilities for radiaion protection had been
significantly improved1/ with the acquisition of space
formerly used
as
a hot machine
shop
and the construction of additional space
on the
adjacent
turbine floor.
The total area allocated to the technicians
1/RIII Inspection Report No. 50-315/78-11.
and their immediate supervisors
was more than doubled.
The final
configuration had not yet been achieved
and the modification will be
resumed after the outage.
Contractors
continue to be processed
through
a separate facility outside the auxiliary building.
5.
Radiation Protection
Or anization
Changes in the radiation protect
on department
since the previous
radiation protection inspection-
include promotion of a senior
technician to supervisor
and the addition of four technicians.
Radiation protection coverage is provided around-the-clock.
During the outage
the staff was augmented
by one supervisor,
eight
senior technicians,
and four junior technicians
from NUMANCO, Inc.
In discussion,
licensee
supervisors
indicated satisfaction with their
work.
They stated that many have worked at the station before
and
that the licensee
can and has excercised right of refusal.
No items of noncompliance
or deviations were identified.
6.
~Trainin
No formal audit of licensee radiation protection training program was
made during this inspection.
The inspector did examine records at
access
control for selected
contractors indicating that basic
radiation protection orientation and respirator training had been
received.
No items of noncompliance
or deviations were identified.
7.
Procedures
The inspector
made
a limited review of radiation protection related
procedures
during this inspection.
The following procedures
were
reviewed with no significant problems identified.
RAD 401, 12/19/78,
"Access Control and Controlled Area Entry and Exit."
RAD 408, 5/ll/78, "Control of Airborne Radioactivity Exposure."
RAD 410,
12/19/78, "Visitor Dosimetry."
RAD 429, 9/12/78, "Operation and Use of the
3M Brand Airline Apparatus."
RAD 445, 5/ll/78, "Respiratory Test Booth Operation."
RAD 447, 5/ll/78, "Whole Body Counting Procedures."
No items of noncompliance
or deviations were identified.
2/Ibid.
8.
Instruments
and
E ui ment
Records of calibration of portable survey instruments
and area monitors
for the period
May 1978 through May 1979 were reviewed.
The records-
indicated calibrations at the appropriate
frequencies;
up-to-date
calibration stickers were observed
on portable instruments
examined at
access
control.
After reviewing calibrations of release
monitors,
particularly the Unit
1 stack iodine monitor, R32, in view of the
large efficiency changes
noted in the monitor during a previous
inspection, licensee representatives
stated that no equipment
3
problems were found and that the reason for the apparent
change
could
not definitely be identified.
However, they found poor and possibly
inaccurate
source descriptions
and suspect
that successive
calibrations
may have used different sources.
They stated that new sources
have
been obtained,
that those
used for calibration have been uniquely
identified, and that controls for their use have been established.
Licensee representatives
stated that there are no radiation monitors
on the containment fan coolers
and, therefore,
there is no potential
for isolation because
of high radiation levels.
No items of noncompliance or deviations were identified.
9.
External
Ex osure Control
Exposure records,
including computer generated
quarterly summaries,
selected
weekly and daily summaries,
and individual dose files, were
reviewed for 1978 and
1979 through May 28.
No exposures
above
NRC
limits were identified.
The principal dosimeter is a vendor
supplied
TLD augmented
occasionally
by licensee
supplied
and analyzed
chips.
Persons
entering the controlled area also wear self-reading
dosimeters,
which are read
and logged on individual entry time cards
upon exit.
Discussion with licensee representatives
and review of records
indicated that:
a.
Personal
neutron dosimetry records
appeared
to be consistent
with recommendations
b.
Neutron dose to individuals is based
on stay time in a dose
rate measured with an Eberline
PNR-4 rem-meter;
c.
NTA film is not used;
d.
Areas of potential neutron exposure
are identified in surveys
made after each refueling outage;
3/Ibid.
e.
f.
Responsibility for specifying neutron monitoring rests with
the radiation protection supervisor
who receives
the
applicable
RWP;
In 1977 neturon doses
up to 40 millirems were recorded for
ll persons
involved chiefly with loading of Unit 2 startup
sources;
and
go
No neutron doses
were recorded in 1978.
No items of noncompliance
or deviations were identified.
10.
Internal Ex osure Control
a 0
Res irator
Protection
During a previous inspection-~ it was hoted that several
procedures
required by Regulatory Guide 8.15 had not been completed.
These
procedures
were completed
and approved
two weeks after that
inspection
and the licensee's
program appears
to be consistent
with the guide.
b.
~Bioassa
In the period March 30,
1978,
through April 20,
1979, approximately
1140 individuals were whole body counted for internally deposited
radionuclides.
No results suggesting
exposures
greater
than 520
MPC-hours were noted.
Adequate followup counts to confirm that
exposures
were below 40 MPC-hours were taken in all cases
except
one.
On May 13,
1978, the termination bioassay of a Westinghouse
employee indicated
a possible
combined exposure of approximately
300 MPC-hours to cobalt
58 and cobalt 60.
The individual left the
site before
a followup count could be made
and no evaluation of
the exposure
was performed.
There appears
to be noncompliance
with 20.103.b.2.,
which requires evaluations
and actions to prevent
recurrence
of exposures
greater
than 40 MPC-hours.
Ce
Air Sam lin
Selected air sampling records for the period May 1978 to May 1979
were reviewed with particular emphasis
on records for the ongoing
Unit
1 refueling outage.
Approximately 2500 air samples
were
taken in 1979 through
May 4.
Examination of these records
together with Radiation Work Permits
(RWP's)
and 'theMPC-hour'og
revealed generally careful monitoring for specific gobs
and use
of respirators.
However, three examples of inadequate
evaluation
owing at least partly to loss of information between
two departments
are described
below.
4/Ibid.
The licensee's air samples
are comprised of a particulate filter
and, if deemed
necessary,
an air iodine cartridge.
They are counted
for gross radioactivity by radiation protection;
the chemistry
department
does
gamma isotopic (GeLi) analyses if requested
and
returns the results.
Iodine identified on particulate filters is
not included in the results returned.
The inspector noted that on
three occasions
in 1979,
when only a filter sample
was taken,
possibly significant iodine activity was identified on the
particulate filter but not identified in the results returned
from
chemistry.
Sample
No.
1488 on April 12, taken for work on reactor
coolant
pump seals
showed iodine-131 at 1.3 E-9 yCi/cc;
sample
No.
1568 on April 14 for work on check valve No.
4 showed
iodine-131 at 1.3 E-8 pCi; and sample
No.
2397
on May 3 for entry
into steam generator
No.
3 showed iodine-131 at 2.5 E-8 pCi/cc.
These
samples
were not suitable for determining compliance with
the limits of 10 CFR 20.103
as required by 10 CFR 20.103(a)(3).
The inspector's
review of MPC-hour logs associated
with these
three occurrences
indicated it was unlikely that any exposure
limits had been exceeded,
even though the iodine results
had not
been evaluated
by the licensee.
Apparently no entries were made
in conjunction with Sample
No.
1488; entries were made in
conjunction with other samples
taken earlier which showed
no gross
radioactivity above the limits for unidentified isotopes.
The
entry associated
with Sample
No.
1568 was of 1.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> duration
and therefore unlikely to have
exceeded
exposure limits even for
concentrations
a factor of 100 greater
than that seen in the
filter.
Entries
made in conjunction with Sample No.
2397 were
made in supplied air masks with a protection factor of 2000.
A somewhat similar situation occurred
on March 24,
1979,
(Sample
No.
1129) when both a particulate filter and iodine
cartridge were taken.
However, the information forwarded from
the laboratory erroneously listed the iodine-131 result from
the filter of 2.6 x 10
pCi/cc rather than the cartridge result
of 2.4 x 10
~ pCi/cc.
ll.
Postin
Labelin
and Control
a 0
Postin
and Labelin
No discrepancies
in licensee posting or labeling pursuant to
10 CFR 19.11 or
10 CFR 20.203 were identified.
b.
Control
The inspector's
observation
and discussions
with licensee
employees
indicated that no significant changes
have been
made in access
control practices.
Many outage
RWP's posted in access
control
cover gobs in progress,
)obs anticipated,
and in some cases
gobs
already completed.
Without detailed
knowledge, it is impossible
to know which, because
actual beginning and ending times are not
listed on the
RWP form.
Licensee representatives
stated that
effectiveness
of RWP control had been reviewed
and found adequate.
Licensee representatives
also stated that a new computer based
system involving electronic control of access
to associate
entry
location, person,
time of entry,
RWP number,
and previous
exposure
was due by fall.
No items of noncompliance
or deviations were identified.
12.
Notification and
Re orts
The inspector
reviewed
and discussed with licensee
personnel
notifications
and reports required pursuant to 10 CFR 19.13,
20.402,
20.403,
20.405,
and 20.408.
No items of noncompliance
or deviations were identified.
~Surve
s
Selected
records of radiation and contamination surveys
made during
the period February through May 1979 were reviewed.
These records
suggested
a general increase in contamination levels
and an increase
in the number of areas
posted for contamination control during the
outage.
Licensee personnel
indicated the unusual
amount of work and
number of people associated
with this outage were the cause.
This
was discussed
at the exit interview.
Records of source inventory and sealed
source leak tests
reviewed
for the past year;
no problems were noted.
No items of noncompliance
or deviations were identified.
14.
Outa
e Plannin
and Pre aration
Licensee representatives
stated that radiation protection problems
experienced
during the last outage were documented
and used in
planning meetings for the outage.
Radiation protection participated
in rehersals
of steam generator entries
by licensee
QC personnel
who
would be doing eddy current testing for the first time.
A steam
generator
mockup was used.
(~%
The inspector
was told that higher 'than usual exposures
were being
incurred during this outage because
of a more extensive inservice
inspection,
program on both units.
The licensee
indicated that
feedwater nozzle work did not involve high exposures.
No items of noncompliance or deviations were identified.
15.
IE Bulletins
Circulars
and Information Notice
a.
"Protection Afforded b
Air-Line Res irators and
Su
lied Air Hoods"
The inspector reviewed this matter with licensee representatives
and found no discrepancies
with the licensee's
response letter
of August ll, 1978.
b.
"Radiation Levels from Fuel Element Transfer Tubes"
The inspector
reviewed the licensee's
survey data for Unit
1 and
control measures
and found them as described in the licensee's
letter of August ll, 1978.
Measurements will be made
on the
Unit 2 transfer
tube during its next refueling outage.
c.
"Interconnection of Contaminated
S stems
with Service Air S stems
Used
as
a Source of Breathin
Air"
Discussion with licensee
personnel
revealed that service air is
used for breathing in low containment.
The compressor
used has
water seals,
is tested,
and meets specifications for breathing
air.
Tests
performed
on four breathing air stations in April 1975
were shown to the inspector.
When used for breathing the air is
passed
through a manifold incorporating charcoal
and
HEPA filters.
16.
Exit Interview
An exit interview was held with Mr. Shaller
and others
(denoted in
Paragraph
1) of his staff on June
1,
1979.
The inspection findings
were discussed,
including the noncompliance
items related to iodine
air sampling and whole body counter result evaluation.
The inspector also remarked
on the messy conditions
seen in the
plant, the apparent
increase in contamination levels in the plant,
and
the number of rooms posted
as contaminated
areas.
The licensee stated
that these
problems result largely from the amount of work in progress
and the number of extra people
on site and that these conditions will
be markedly improved after the outage.