ML17321B006
| ML17321B006 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/09/1985 |
| From: | Holtzman R, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17321B005 | List: |
| References | |
| 50-315-85-37, 50-316-85-37, NUDOCS 8512170115 | |
| Download: ML17321B006 (17) | |
See also: IR 05000315/1985037
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Report
Nos.
50-315/85037(DRSS);
50-316/85037(DRSS)
Docket Nos.
50-315;
50-316
Licensee:
American Electric Power
Service Corporation
and Michigan Power
Company
1 Riverside
Plaza
Columbus,
OH
43216
Licenses
No.
Facility Name:
Donald
C.
Cook Nuclear Plant, Units
1 and
2
Inspection At:
Donald
C.
Cook Site,
Bridgman,
MI
Inspection
Conducted:
November 18-21,
1985
P. 6.
Inspectors:
R.
B.
oltzm
n
g),Pg~cehd-
M. J.
Oestmann
Da
e
i~/efin
Date
(j30
Approved By: V. C.
chu
hAe
,
ef
Radiologica
Effluents and
Chemistry Section
Date
Ins ection
Summar
Ins ection
on November
18-21
1985
Re orts
No. 50-315/85037
DRSS
.
50-316/85037
DRSS
Areas Ins ected:
Routine,
announced
inspection of:
(1) confirmatory
measurements,
including sampling, quality control of analytical
measurements,
and comparison
of licensee
analyses
with those of the Region III Mobile
Laboratory
and the
NRC Reference
Laboratory; (2) chemistry
and radiochemistry,
including laboratory facilities and counting
room
- (3) radiological
environmental
monitoring program results;
and (4) review of corrective actions
taken
on previous inspection findings.
The Region III Mobile Laboratory was
onsite to analyze
samples split with the licensee for comparison.
The
inspection
involved 52 inspector-hours
onsite
by two NRC inspectors,
Results:
No violations or deviations
were identified during this inspection.
8512170115
851209
- DOCK OOOQOO15
8
PER
DETAILS
1.
Persons
Contacted
"W. G. Smith, Jr., Plant Manager
- B. A. Svensson,
Assistant Plant Manager,
Operations
"J.
F. Stietzel, guality Control Superintendent
G.
H. Caple,
Engineer, guality Control
"J. Wojcik, Plant Chemistry Superintendent
- J. 'Fryer,
Environmental
Coordinator
- L. G. Holmes, Administrative Compliance Coordinator
"N. A. Baker,
Department Assistant
W.
E. Hart, Radiation Protection Specialist
S.
W. McLea, Chemistry Laboratory Supervisor
K. Vogel, Senior Chemistry Technician
K. Haglund,
Chemistry Supervisor,
S.
Rose,
Chemistry Technician
"C. L. Wolfsen,
NRC Resident
Inspector
- R. L. Hague,
NRC Resident
Inspector (Acting)
The inspectors
also contacted
several
other licensee
employees
during the
course of the inspection,
including. chemistry
and radiation protection
personnel.
- Denotes those present at the exit interview on November 21,
1985.
Licensee Action on Previous
Ins ection Findin
s
a
~
(Cl osed)
Open
Item (50-315/82021-03;
50-316/82021-03):
Recal ibrate
gas geometry.
The licensee
did recalibrate
the gas Marinelli geometry
in early
1985
and obtained
agreement
of results with Analytics,
Incorporated for an
unknown
gas
sample
and also
had agreement
of
results with the
NRC on
a split gas
sample for this confirmatory
measurements
inspection.
This item is considered
closed.
b.
(Closed) Violation Severity
Level
V (50-315/84021-01;
50-316/84023-01);
The licensee failed to report the
1983 results'of
land use census,
gamma isotopic analyses
of monthly composite water samples
from three
locations (Ll, L2, L3) at the plant site
and gross
beta
and
gamma
isotopic analyses
of composite
samples
from three locations
from
public water intakes.
The licensee
provided the
1983 and the
1984
data for the land use census,
and the
gamma isotopic results
on
samples
from the three plant and three public water intake locations
and gross beta results
on samples
from the public water intake
locations in the
1984 Annual Environmental
Operating
Report.
The
licensee collects
broad leafy vegetation at the site boundary in the
direction sector with the highest
D/g in lieu of garden
census.
This closes this item.
C.
(Closed)
Open Item (50-315/84021-02;
50-316/84023-02):
Licensee to
determine whether water samples
from wells 4, 5,
and 6, which are
contaminated with fuel oil, had been distilled prior to tritium
analysis.
The licensee
determined that all water samples
from the
~
~
wells were distilled prior to tritium analysis.
This item is
considered
closed.
d.
e.
(Closed)
Open
Item (50-315/84021-03;
50-316/84023-03):
Review of
the licensee's
Nuclear Safety
and Design
Review Committee
(NSDRC)
Audit Report
No.
111
on the'REMP
gA Program.
The inspector
reviewed
the results of Audit No.
111 conducted
October
29 through
November
1,
1984.
No deficiencies
were found.
This item is considered
closed.
1
(Closed) Violation Severity Level
V (50-315/84021-04;
50-316/84023-04):
Licensee failed to prepare
a procedure for PC-55 gas flow counter
and implement procedure
12
THP 6020.
LAB.088, "guality Control of
Counting Equipment".
The licensee
revised procedure
12
THP 6020
LAB.073 "Calibration of Gas Proportional
Counter PC-5/PC-55,"
dated
August 17,
1985 to include operation of the PC-55.
Procedure
12
THP
6020
LAB.088 was also revised
on June 20,'985 to include
a
description of response
actions for unacceptable
calibrations
and
requirements
for calibration checks of counting equipment.
Observation
of control char ts for each detect'or involving daily source
checks
and background
revealed
no problems.
This item is considered
closed.
f.
(Closed) Violation Severity Level IV (50-315/84021-06;
50-316/84023-06):
The licensee failed to accurately quantify radioactive releases.
The
licensee
prepared
Procedure
12 THP 6020
LAB.135 "Collection of
Samples
from Continuous
Stack Monitor," dated
March 12,
1985, which
addresses
the correct orientation of charcoal
adsorbers
in the
SPING holder and the adsorber relative to the Ge(Li) detector.
No
problems were noted during counting of a spiked charcoal
adsorber
used in the
NRC confirmatory measurements
program.
This item is
considered
closed.
\\
g.
(Closed)
Open
Item (50-315/84021-07;
50-316/84023-07):
The licensee
committed to reanalyze silver zeolite cartridges
or correct derived
radioactive concentrations
for release
to environment.
A licensee
representative
stated that
no cartridges
had been available for
reanalysis
after the previous iqspection.
However, appropriate
corrections
were
made
when reporting radioactive
releases
in the
semi-annual
effluent report for July
1 through
December
31,
1984.
This item is considered
closed.
Mana ement Controls
Or anization
Trainin
and
ualifications
The Plant Chemistry Supervisor
has the responsibility for the sampling
and analyses
of plant chemical
and radiochemical
samples.
Four chemistry
supervisors,
a chemist (currently vacant),
a performance
engineer,
seven
senior technicians,
ten technicians
and two junior technicians
report to
the Plant Chemistry Supervisor.
The inspectors dealt primarily with the
counting
room supervisor
and
one senior technician
in performing the
confirmatory measurements
program.
The licensee
also
has about six
contract technicians
available
so as to permit the licensee's
chemistry
personnel
to undergo training on specific topics,
such
as the operation
of the Canberra
gamma-ray
spectrometry
system.
The licensee's
senior
technicians
are in the process
of taking requalification training which
extends
over
a two-year period.
Instrumentation,
plant system topics,
and laboratory test performance
are being presented
to the technicians
in
0
greater
depth than
was done originally.
The technicians
and junior
'echnicians
are completing
a formal 28-week three-phase
program designed
to upgrade
the knowledge of the chemistry technicians
in chemistry
laboratory practices
and chemistry fundamentals.
The formal training
program
and hands-on
experience
gained
by the chemistry staff since the
previous inspection'ere
very effective,
as evidenced
by the good
performance of the licensee
in the confirmatory measurements
program.
The licensee's
chemistry staffing and training program appeared
to be
satisfactory.
With regard to the radiological environmental
monitoring program
(REMP),
the licensee
changed contractors
as of October
1,
1985,
from Teledyne
Isotopes,
Inc. to Controls for Environmental Pollution, to perform the
sampling
and analyses
of environmental
media in accordance
with Technical
Specifications
3/4 12. 1.
No problems
were noted in this change.
No violations or deviations
were identified.
ualit
Control of Anal tical Measurements
in the Chemistr
and
Radiochemistr
Pro
ram
The inspectors
reviewed Procedure
12 THP 6020
LAB.044 "Laboratory Quality
Assurance,"
dated
September
12,
1985,
and Procedure
12
THP 6020
LAB.088
"Quality Control of Counting Equipment," dated June
20,
1985
and their
implementation.
Procedure
LAB.044 was revised in response
to a deficiency
identified in the Quality Assurance
Department Audit QA 84-20.
The
procedure
now includes
a description of personnel
responsibilities
for
the program
and of a program outlining the traceabi lity of standards
and
instruments,
and calibration of laboratory instrumentation.
Procedure
LAB.088 was revised to encompass
individual responsibilities for
implementation of the
QA program,
a description of response
actions for
unacceptable
calibrations
and calibration checks,
and
an update
on split
sample analysis.
The revised procedures
provide improvements
over their
earlier versions.
During
a tour of the cold and hot laboratories, all reagents
were found
to have current labels of preparation
and all instruments
were found with
current calibrations stickers.
The licensee
improved the housekeeping
of
the laboratory in response
to an inspector's
comments.
No problems were noted during the collection of gas
samples
from the gas
decay tanks
and the dirty waste
holdup tank liquid sample.
The technicians
appeared
to be knowledgeable
in laboratory practices
and adequately
followed
the appropriate
procedures.
No problems
were noted during the filtering of
the dirty waste tank sample to prepare
a sample for counting.
Implementation of Procedure
LAB.088 on quality control of counting
room
equipment
has
improved since the previous inspection.~
No problems were
noted with documentation
of the daily check source
and background
counts
'Inspection
Report
Nos.
50-315/84021;
50-316/84023.
~Ibid
0
on control'harts for the appropriate
dates.
All equipment
was found
operational
and properly calibrated.
Procedures
for each counter were
available.
A licensee
representative
reported that recently
a program for split and
unknown spiked
samples for quality control of analytical
measurements
was
initiated with Science Applications, Incorporated
(SAI).
Results to date
have
been in agreement with those
from SAI.
No violations or deviations
were identified.
Confirmator
Measurements
Three
samples
from a waste-holdup
tank,
a. gas-decay
tank and reactor
coolant,
were split and counted
by the licensee
and in the Region III
Mobile Laboratory.
Because
the radioactive content of the plant air
particulate filters and charcoal
adsorber cartridges
were too low to
obtain effective intercomparisons,
the licensee
was asked to count
a
spiked filter and
a spiked charcoal
cartridge supplied
by the inspectors.
A liquid r adwaste
sample
was filtered through paper
and membrane filters,
split and sent to the
NRC Reference
Laboratory,
the Radiological
and
Environmental
Sciences
Laboratory (RESL), in Idaho Falls,
Idaho, for
analyses
and gross beta.
The licensee
agreed to analyze
the
sample
and report the results 'to Region III
(Open Item 50-315/85037-01;
50-316/85037-01)
.
The results of comparisons
made during this inspection
are presented
in
Table
1 and the comparison criteria in Attachment
1.
All of the
31
comparisons
were agreements.
The "L WASTE" sample
was
a split sample
from a "dirty" source (floor drains, etc.) that
had been filtered prior
to the split.
The data for "L WASTE2" were those of the licensee's
results for the above
sample
taken prior to filtration and compared with
those of the
NRC on the filtered sample.
The good agreements
show that
the solids contained little or no activity.
While one result, that for
Cd-109 in the spiked filter, was
20% low,
a large majority of the licensee's
results
were essentially identical to those of the
NRC.
The inspectors
noted that for a sample with a complex gamma-ray
spectrum
the licensee
report
showed the presence
of lines, which
on further analysis
were found to be absent.
This indicates
the need for
the licensee
to perform
a more careful
review of the gamma-ray data.
No basic
problems
were observed
in the gamma-ray
measurements.
The good
results with the
SAI (Section
5) and
NRC intercomparisons
indicate that
the quality control/quality assurance
program
has
improved since the last
inspection.'.
Overall, the radiological
measurements
were very good and
the license's
system
appears
to be operating well.
No violations or deviations
were identified.
6.
Radiolo ical Environmental Monitorin
Pro
ram
The inspectors
reviewed the
REMP section of the
1984 Annual Environmental
Operating
Report to ensure
compliance with the T/S Section 3/4. 12 and
6.9. 1.7
(Amendment 69, effective date Apri 1
13,
1983).
The inspectors
noted that the licensee is having difficulty in obtaining regularly the
required daily collections of water
samples
from the public water supply
intakes
from Lake Michigan at St. Joseph,
Lake Township and
New Buffalo
for the preparation
of monthly composite
samples.
While daily telephone
calls are
made to the personnel
at these
stations
to remind them to
collect the daily grab samples,
nevertheless,
according to the licensee's
condition reports in the
1984 Annual Report, this problem continues,
especially at
New Buffalo.
This item was discussed
at the exit meeting
and the licensee
agreed to take positive steps to resolve the problem
within the next month.
This item will be examined
in a subsequent
inspection
(Open Item 50-315/85037-02;
50-316/85037-02).
All other samples
have
been
accounted for.
No unusual
trends or anomalies
were identified, except for tritium results.
Water samples
taken
from the
seven wells onsite, (including wells 4, 5,
and 6)
showed elevated tritium
levels (up to 7890 pCi/L).
The licensee
agreed to investigate
the cause
of the elevated levels in the wells and provide results of the investiga-
tion within six months of this inspection
(Open Item 50-315/85037-03;
50-316/85037-03).
The licensee's
NSDRC reviewed the
REMP, Audit No.
120,
conducted
on
September
9-12,
1985, in which three findings were identified.
These
findings noted the lack of written, approved,
and implemented
procedures
regarding
sampling
and analyses
of surface water (at locations
L1, L2,
and L3) and drinking water at the above public water supply intakes.
This sampling
and analysis
are performed
by the Chemistry Department.
The licensee
has prepared
or revised the appropriate
procedures
(12
THP 6020 LAB.037, dated
September
26,
1985 and
12
THP 6020
LAB.157,
dated October 25,
1985) in response
to the findings.
The
NSDRC plans to
perform a*followup audit in the next six months to assure
that all findings
have
been resolved.
No violations or deviations
were identified.
7.
~oee
Items
Open items are matters
thatshave
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.
Three
open items disclosed
during the inspection
are discussed
in Sections
5 and 6.
8.
The inspectors
reviewed the
scope
and conclusions of the inspection with
the licensee
representatives
denoted
in Section
1 at the conclusion of
the inspection
on November 21,
1985.
The inspectors
presented
the
results of the confirmatory measurements
and discussed
their probable
findings.
On environmental
matters
the licensee
acknowledged
the
inspectors
concerns with problems of sample collection
and tritium in
the well waters,
noted in Section
5 and 6,
and agreed to resolve the
problems in a timely manner.
During the inspection the inspector's
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 procedures
as proprietary.
Attachments:
1.
Table 1, Confirmatory Measurements
Program
2.
Criteria for Comparing Analytical Measurements
TABLE
1
U S
NUCLEAR REGULATORY COMMISSION
OFFICE
OF
INSPECTION
AND ENFORCEMENT
CONFIRMATORY MEASURFMENTS PROGRAM
FACILITY: D.
C.
COOK
FOR
THE 4 QUARTER
OF
1985
NRC
--LICENSEE
LICENSEE: NRC
SAMPLE
ISOTOPE
RESULT
ERROR
RESULT
ERROR
RATIO
T
F SPIKED CO-57
CD-}0/
C SPIKED CO-57
4.5E-04
1.6E-02
6.6E-02
2'E-02
2. 2E-04
6'E-03
2.9E-02
7.9E-03
3'E-05
2'E-04
1 'E-03
3.0E-04
3.6E-05
2.4E-04
1.4E-03
2. 1E-04
4. 5E-04
1.5E-02
5.3E-02
1.8E-02
2. 2E-04
6.6E-03
2.7E-02
7.6E-03
3. BE-05
4. 3E-04
i. BE-03
3. 6E-04
3. 1E-05
3. 2E-05
1.4E-03
2.6E-04
9. BE-Oi
9. 7E-01
8. OE-Oi
9. OE-01
/. 9E-Oi
1.0E
On
9. 5E-Oi
9. 7E-01
1.4E
01
A
5 ~ 9E 01
A
5.5E Oi
A
6.6E
01
A
6.1E 00
A
2.8E Oi
A
2.1E Ol
A
3.7E Oi
A
4.1E-03
9. 4E-04
XE-133M 2. 3E-05
XE-135
4.2E-05
1. 2E-04
3. 5E-06
2.6E-06
7.4E-07
4. OE-03
9.2E-04
1.9E-05
3.7E-05
6.4E-05
1.3E-05
8.3E-07
3 ~ 1E-07
/. 9E-01
9. BE-Oi
8. 4E-Oi
8. 9E-Oi
3.3E Oi
A
2.7E 02
A
B.BE 00
A
5.7E
01
A
PRIMARY
CO-58
AG-110M
CS-134
CO-58
I-132
I-133
I-135
NA-24
1. 3E-05
1.7E-05
2.6E-03
1.2E-04
3.5E-04
6.4E-05
7.4E-05
7.4E-04
1.1E-03
1.6E-02
1.2E-02
2.4E-02
5.1E-03
1.3E-06
1.2E-06
6.9E-06
2.3E-06
3.2E-06
3.6E-06
2.8E-O6
7. 4E-05
7 ~ 7E-05
5. 1E-04
1.4E-O4
7.4E-04
1.6E-04
1
~ 3E-05
1.8E-05
2.6E-03
1.2E-04
3.2E-04
6 'E-05
7'E-05
6.SE-04
1.1E-03
1.5E-02
1.3E-02
2.4E-02
5.4E-03
S. OE-07
8. OE-07
3.0E-05
2.OE-06
4.0E-06
4.0E-06
1
~ 6E-06
8'E-05
7.6E-05
3. 1E-04
2. OE-04
7.2E-04
1.8E-04
1
~ OE 00
1. OE 00
1. OE 00
1.0E
00
/. 2E-Oi
1. OE 00
9. /E-Oi
9. 1E-01
9. 6E-01
9. 3E-01
1. OE 00
9. 9E-Ol
1. OE 00
9. BE
1. 4E
3. SE
5. 3E
1. 1E
1. SE
2. 7E
1
~ OE
1. 4E
3 ~ 1E
8 ~ 9E
3. 3E
3. 3E
00
A
01
A
02
A
01
A
02
A
01
A
Oi
A
01
A
01
A
01
A
Oi
A
Oi
A
Oi
A
L NASTE2 MN-54
1.3E-05
1 'E-05
1.3E-06
1 'E-06
1. 3E-05
1 ~ BE-05
1.2E-06
1.0E-06
1.0E 00
1. OE 00
9.8E 00
A
1.4E Oi
A
T TEST RESULTS:
AGREEMENT
SAGREEMENT
ITERIA RELAXED
N=NO COMPARISON
~
S
TABLE
1
U
S
NUCLEAR REGULATORY COMMISSION
OFFICE
OF
INSPECTION
AND ENFORCEMENT
CONFIRMATORY MEASUREMENTS PROGRAM
FACILITY: D.
C.
COOK
FOR
THE 4 QUARTER
OF
1985
--NRC
LICENSEE
---LICENSEE: NRC
SAMPLE
ISOTOPE
RESULT
ERROR
RESULT
ERROR
RATIO
T
L NASTE2 CO-58
AG-110M
CS-134
2. 6E-03
1.2E-04
3.5E-04
6.4E-05
7.4E-O5
6. 7E-06
2.3E-06
Z.2E-06
3.6E-06
2.8E-06
2 ~ 6E-03
1. 2E-04
3. 4E-04
6. 1E-05
7. ~E-05
6. 9E-06
2.0E-06
5.0E-06
2.4E-06
2.1E-06
1.0E
00
1
~ OE 00
VISE-Oi
9 ~ 5E-Oi
I. '9E-Oi
3.8E 02
5.3E Oi
1. 1E 02
l.SE'1
2. 7E Oi
A
AA'
A
T TEST
RESULTS'-
A=AGREEMENT
D
ISAGREEMENT
ITERIA RELAXED
COMPARISON
v
~
~
e
'V
r
ATTACHMENT
1
CRITERIA FOR
COMPARING ANALYTICALMEASUREMENTS
This attachment
provides criteria for comparing results of capability tests
and verification measurements.
The criteria are based
on an empirical
relationship which combines prior experience
and the accuracy
needs of,<his
program.
In these criteria, the judgment limits are var'iable in relation to the
com-
parison 'of the NRC's value to its associated"one
sigma uncertainty.
As that
ratio, referred to in this program
as "Resolution", increases,
the acceptability
of a licensee's
measurement
should
be more selective.
Conversely,
poorer
agreement
should
be considered
acceptable
as the resolution decreases.
The
values in the ratio criteria may be rounded to fewer significant figures to
maintain statistical
consistency with the number of significant figures reported
by the
NRC Reference
Laboratory, unless
such rounding will result in a narrowed
category of acceptance.
PcSO
UTIO"t
RATIO = LICENSEE VALUE/NRC REFERENCE
VALUE
~Areement
<3
>3
and
<4
>4
and
<8
>8
and
<16
>16 and
<51
>51
and
<200
>200
No Comparison
0.4
-
2.5
0.5
-
2.0
0.6
-
1.67
0.75 -
1.33
0;80 -
1.25
0.85
1.18
Some discrepancies
may result from the use of different equipment,
techniques,
and for some specific nuclides.
These
may be factored into the acceptance
criteria and identified on the data sheet.
h