ML17326A915
| ML17326A915 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/07/1981 |
| From: | Greger L, Hueter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17326A913 | List: |
| References | |
| 50-315-81-12, 50-316-81-15, NUDOCS 8107210276 | |
| Download: ML17326A915 (17) | |
See also: IR 05000315/1981012
Text
U.S.
NUCLEAR REGULATORY COMMISSION
OFFICE
OF INSPECTION AND ENFORCEMENT
REGION III
Reports
No. 50-315/81-12;
50-316/81-15
Docket Nos. 50-315; 50-316
Licenses
No. DPR-58;
Licensee:
American Electric Power Service Corporation
and Michigan Power
Company
2 Broadway
New York, NY
10004
Facility Name:
D.
C.
Cook Nuclear Plant, Units
1 and
2
Inspection At:
Bridgman,
MI
Inspection
Conducted:
June 9-12,
1981
Inspector:
L. J. Hueter
Approved By:
L. R. Greger, Acting Chief
Facilities Radiation
Protection Section
v/v/zz
Ins ection Summar
Ins ection on June 9-12
1981
(Re orts No. 50-315/81-12
50-316/81-15)
protection program during refueling and maintenance,
including:
organization
and staffing, procedures,
advance planning
and preparation,
training, exposure
control, posting and control, material control,
and surveys.
It also included
review of inplant iodine instrumentation,
transportation activities,
IE Infor-
mation Notices,
IE Circulars,
and followup of selected
licensee
events
(LERs).
The inspection involved 41 inspector-hours
onsite by one
NRC inspector.
Results:
No items of noncompliance
were identified in 12 of the areas in-
spected.
Two violations in the area of posting (both Severity Ievel VI) were
identified; one concerns failure to post
a notice of violation involving
radiological working conditions,
and one concerns failure to post in a
sufficient number of places
the notice describing where copies of the regula-
tions, licenses,
and procedures
could be examined
(both units).
(Section 5)
810721027b
810708
ADQCK 05000315
J
6
DETAILS
Persons
Contacted
"N. Bolinger, IQi ISI Supervisor
J.
Hoss, Radiation 'Protection Supervisor
W. Jenkins,
Training Instructor
W. Ketchum, Health Physicist
T. Kriesel, Environmental Coordinator
D. Palmer, Plant Radiation Protection Supervisor
<'D. Shaller, Plant Manager
>E'. Smarrella,
Technical Superintendent
J. Stietzel,
gA Supervisor
<B. Svensson,
Assistant Plant Manager,
Operations
>E. Townley, Assistant Plant Manager,
Maintenance
J. Wojcik, Plant Chemical Supervisor
~"N. DuBry,
NRC Resident Inspector
E. Swanson,
NRC Senior Resident Inspector
The inspector also contacted
other licensee
employees,
including members
of the technical
and engineering staff.
+Denotes
those attending the exit interview.
General
This inspection,
which began about 8:00 a.m.
on June
9,
1981, near the
beginning of a refueling and maintenance
outage of Unit 1, included tours
of the upper
and lower levels of the containment building; the auxiliary
building; the turbine building; the radwaste
packaging,
handling,
and
shipping area;
and the control room.
During the tour of the auxiliary
building and upper and lower containment,
a licensee
survey instrume'nt
(Eberline
RO II, serial number 765, calibrated
on May 5,
1981)
was used
to monitor selected
areas.
Measurements
made were in agreement with
posted
survey data.
Radiation areas
were pro-
perly posted
and high radiat'ion areas
were locked.
The licensee's
efforts to improve housekeeping
were evident.
The Unit 2 refueling
outage
ended shortly before this outage
began.
Although a significant
amount of trash had accumulated in portions of the auxiliary building,
it was bagged
and placed behind roped barriers to maintain
a relatively
neat appearance.
Efforts are being
made to minimize trash accumulation
by increased
frequency of collecting and compacting the trash.
Or anization
and Staffin
In the past year, there
have been
no changes in the organization or
staffing of the radiation protection group -at the supervisory level and
no significant changes in the group
as
a whole.
The three radiation
protection supervisors
(who supervise
the technicians)
report. to the
- 2-
c
"I
Plant Radiation Protection Supervisor
(PRPS)
who is assisted
by a health
physicist.
The
PRPS reports to the Technical Superintendent
who in turn
reports to the Assistant Plant Manager,
Operations.
In the radiation protection group, the licensee
has four senior technicians
(two additional technicians
are taking a test for senior status),
four
technicians
(one is terminating),
and one junior technician.
Due to the
difficulty in obtaining replacement
technicians,
the licensee is employing
contract technicians
from NUMANCO, Inc.
Four contract senior technicians
and one junior technician are onsite
on a semi-permanent
basis.
In
addition, for the outage,
two supervisors,
twelve senior technicians,
seven junior technicians
and one records clerk have been provided.
The
total complement is two technicians
more than utilized for the outage
,inspected in July 1980.
Contract technicians
continue to handle most
containment
work.
Efforts have been
made in the interest of uniformity
of practice in radiation protection matters by both plant and contract
technicians.
Plant technicians
have been assigned
selected
duties in
containment
and efforts have been
made to keep the radiation protection
supervisors
(foremen) current
on activities in containment.
Six junior technicians with associate
degrees
have been hired and will
start employment in June
and July.
In an attempt to find a long-term solution to the technician recruitment
problem, the licensee
has established
a subsidized
two-year training pro-
gram (leading to an associate
degree) with Terra Technical College at
Fremont,
Ohio.
Ten local high school graduates
are to start the program
in June.
The program also involves
summer training/employment at the
plant.
The graduates
are committed to work for the company for a period
of time upon completion of the degree.
Continuation of the program will
be based
upon its success
and
company needs.
No items of noncompliance
or deviations
were identified.
~Taainin
The inspector
reviewed the orientation training program and determind
that it meets
the requirements
of 10 CFR 19.12 regarding instruction to
workers.
No items of noncompliance
or deviations
were identified.
Postin
and Control
Posting
and controls were observed
during tours of the main gate area;
the access
control point used by plant personnel;
the separate
access
control point provided during the outage for contractors;
and the areas
toured
as listed in Section 2.
Doors to high radiation areas
required
to be locked were locked.
Selected radiation work permits reviewed had
proper approvals
and appeared
to require proper radiation protection
" 3-
precautions.
,Posting of radiation and high radiation areas
appeared
appropriate.
However,,problems
were identified with other required
posting.
A Notice of Violation involving radiological working conditions, specifi-
cally, failure to use
a frisker to check for contamination
on oneself
when
leaving a contaminated
area,
was contained in Appendix B enclosed with the
letter sent to the licensee
on May 26,
1981.
This document
had been re-
ceived by the licensee before this inspection began
on June 9,
1981.
The
Notice of Violation was not posted during the inspection
(June 9-12) nor
could the licensee provide evidence that it had been posted since receipt
from the Commission.
Actions correcting the violation had not been
com-
pleted in that
some workers were observed not using the friskers upon
leaving upper containment,
lower containment,
and the access
control point
for plant workers leaving the auxiliary building.
Further, it was found
that no frisker was provided (only a low sensitivity portal monitor) at
the access
control point for contract workers leaving the auxiliary build-
ing.
This constitutes
noncompliance with 10 CFR 19.11(e)
which requires
any Notice of Violation involving radiological working conditions
(pursuant
to
10 CFR 19.11(a)(4)) to be posted within two working days after receipt
from the Commission and requires
the 'document to remain posted for a mini-
mum of five working days or until action correcting the violation has been
completed,
whichever is later.
(b),
and (c) requires
(1) the posting of Form NRC-3,
"Notice to Employees,"
wherever individuals work in, or frequent,
any
portion of a restricted
area
and (2) the posting of the regulations in
10 CFR 19 and 20, the license with incorporated
documents,
and the operat-
ing procedures.
In lieu of (2) above,
a notice may be posted which des-
cribes the documents
and states
where the document
may be examined.
The
licensee,
in lieu of (2) above,
has
chosen to post
a document identified
as
PMSO 006 which states that the regulations,
licenses,
and procedures
are on file for examination in the plant library and/or plant master file.
It is noted that the most recent revision (Revision 2) of PHSO 006, issued
November 3,
1980,
does not specifically reference
the operating license
for Unit 2.
Posted
copies of Form NRC-3 observed
were outdated.
Host
bore dates of 1976, while one was dated
1973.
The current, form bears
the
date of January
1980.
During this inspection,
the following postings
were initially observed:
Location
NRC-3
PHSO 006
Hain Gate
(Guardhouse)
Yes
No
Auxiliary Building Access
For Regular Plant Workers
Yes~~
No
Auxiliary Building Access
For Contract Employees
,No
No
4>>
H
k
'
Upper and Lower Contain-
ment Access Points
No
No
Cafeteria
Control Room
Accounting Office
Yes
Yes
Yes
'es
Yes
Yes
- This posting was not in a location where it would be observed by most
'workers using this access point.
The posting
as observqd
above appears
to be in noncompliance with 10 CFR 19.11(d) which requires
the notices
and forms to be conspicuous
and to
appear in a sufficient number -of places
to permit individuals to observe
them on the way to or from the location of any particular licensed acti-
vity.
In particular, contract personnel
could routinely perform assigned
work without observing the
PMSO 006 postings.
Two items of noncompliance
(both Severity Ievel VI violations) were
identified regarding posting of notices to workers required in 10 CFR 19.11.
No deviations
were identified.
One licensee identified instance of improper controls involving failure
to follow radiation work permit requirements
is noted in Section S.b.
6.
Procedures
No significant problems were identified by a limited review of the
following radiation protection and radwaste
related procedures:
12 THP 6010
RAD 204
Revision
3
Low Volume Air Sampling
and Containment Air
Sampling
12 THP 6010 RAD 303
Revision
1
Solid Waste Handling and
Drumming
12 THP 6010
RAD 304
12 THP 6010
RAD 406
12 THP 6010
RAD 711
Revision
4
Revision 3
Revision
0
Shipment of Radioactive
Material
r
Radiation Work Permit
Special Monitoring for
S/G Work
12 THP 6040 PER
.067
Revision
1
Radwaste
Shipping Cask
Handling
12 THP 6040
PER
.070
Revision
0
Resin Transfer From Spent
Resin Storage
Tank to a
Cask
"5-
r
0
01
THP SP
.021
Revision
0
Resin Transfer from Unit 1 S/G
Blowdown Dgmin System to
a
Liner
PMI 3150
Revision
0
Receipt,
Packaging,
and Ship-
ment, of Radioactive
and
Fissile Material
No items of noncompliance
or deviations
were identified.
Plannin
Pre aration
and
The licensee is now using Hydro Nuclear Services
(HNS) employees
on a
full time basis for area
decontamination
work using hydrolaze equipment.
About three workers are used during non-outage periods with the number
increased
during outages.
At the beginning of this outage, for the first
time,
HNS deconned
the floor of the annulus
and portions of the containment
to minimize contamination
spread
and use of protective clothing and respira-
tory equipment.
Other routine cleaning using the hydrolaze
equipment
planned for the outage include steam generators
and walls of the cavity
after flood-up water has been drained.
Floors of one of the trash
com-
pacting areas
were being cleaned
during the inspection.
Contamination levels
on the f/oor of containment
were being maintained in
the 3,000 to 5,000 dpm/100
cm
range
The maximum levels in the cavity
ranged
up to about 40,000
dpm/100
cm
,
Flood-up, reactor head"removal,
and steam generator
work had not begun during the inspection.
Work on
pump seals
was nearing completion and had apparently
progressed
without significant problems.
No significant exposure to
iodine activity is anticipated
based
on reactor water and air sample
analyses.
A special procedure
had been developed for head,
chest, waist,
and
extremity monitoring of steam generator
workers.
It includes evaluation
of beta exposure.
To minimize handling of compacted
waste
and thereby minimizing exposure
to radiation,
the licensee
has established
a practice of keeping
a trailer
backed
up to the loading dock.
When compacted trash barrels
are ready
for shipment,
they are transferred directly to the trailer rather than
'o
the temporary in-house
storage facility, thereby eliminating one
handling step.
This practice
has apparently resulted in another problem.
The trailer is located in the vicinity of the controlled area
access for
contract workers -and results in a high and variable background radiation
level which interferes with portal and frisker monitoring of workers exit-
ing the controlled area.
The problem apparently resulted in discontinu-
ance of the use of the frisker at that location (see Section 5).
The
licensee is constructing
a new controlled area
access for contract workers
at another location which should eventually solve the problem.
I
Supplies of protective clothing, respiratory equipment dosimetry devices,
and survey and monitoring instruments
appear
adequate for the routine
outage activities with the possible exception of operable friskers
some
of which are being ordered.
No items of noncompliance
or deviations
were identified.
8.
E
osure Control
a
~
External
E
osure
The licensee'as
no simplified way of quickly determining the dose
received for various jobs during the outage or the total man-rems to
date associated
with thy outage.
The
REM system described in a pre-
vious inspection report-
should provide this capability when oper-
ational.
Preliminary tests of the system are
now being conducted.
The current system for tracking and limiting both short-term
and
quarterly individual dose
appears
to function satisfactorily.
The
licensee
has
a record of relatively low annual
man-rems.
No items of noncompliance
or deviations
were identified.
b.
Internal Ex osure
Air sample records,
radiation work permits
(RWPs),
and MPC-hour data
were reviewed for selected
outage jobs.
As noted previously,
the
licensee
has delayed reactor
head
removal
and anticipates
no signifi-
cant airborne iodine-131 problems.
An outage related problem identi-
fied in this area involved a contract worker who entered
the reactor
cavity on the night shift (June 11-12) to work on the upper internals
lifting device while not following RWP requirements
including the
use of respiratory equipment.
This entry resulted in contamination
ranging
up to 500-1000
cpm on portions of the person's
upper body
and arms
as measured with an RM-14 probe with an efficiency of about
ten percent.
The contamination
was successfully
removed after two
showers.
Nasal smears, initially up to 5000
dpm, were reduced after
several
nose blowings to 190
dpm in one nostril and less than 50
dpm
in the other nostril.
The preliminary data,
from whole body counting
of the individual on June
16, indicated that the
40 MPC-hour control
measure
was not exceeded.
The licensee is continuing to evaluate
the
matter.
The inspector will review the licensee's
evaluation during
a future inspection.
Another contamination incident occurred
on June
2 when an engineer
was sprayed with RHR water when a small hose disconnected
during
a
valve testing operation.
Th'e worker contamination (primarily on the
face and hair) was successfully
decontaminated
by showering.
A whole
body count verified that no significant internal exposure
resulted.
1/
IE Inspection Report No. 50-315/80-23
- 7-
No items of noncompliance
or deviations
were identified.
9.
Material Control
No problems
were identified during review of the licensee's
procedures
and practices for movement of materials both within and from the con-
trolled area.
10.
~Serve
e
The review of airborne activity surveys is described in Section 8.b.
Direct radiation and surface
contamination survey data for areas of upper
and lower containment,
the auxiliary building, and the radwaste
area were
reviewed.
No problems
were identified.
Independent
surveys
were conducted
during the inspection
as noted in Section 2.
Radiat'ion levels measured
agreed with data in the licensee's
survey records.
Iocal area posting of
survey data
was current.
No items of noncompliance
or deviations
were identified.
11.
-IE Circulars
and IE Information Notices
The following IE Circulars
and IE Information Notices were reviewed with
the licensee.
No problems
were identified.
IE Circular No. 80-18:
10
CFR 50:59 Safety Evaluations for Changes
to Radioactive
Waste Treatment
Systems
IE Information Notice No. 80-22:
Breakdown in Contamination Control
Procedures
IE Information Notice No. 80-32:
Clarification of certain requirements
for Exculusive-Use
Shipments of
Radioactive Materials
The inspector explained the NRC's current position regarding
compliance
with 49
CFR 173.393(i)
and 393(j) of the DOT regulations.
No problems
were noted.
12.
In-Plant Airborne Radioiodine
Sam lin
and Anal sis
S stem
The licensee's
response
to Section III'D.3.3 of NUREG-0737 concerning
improved inplant airborne radioiodine sampling y~d analysis is detailed
in Section
11.2 of a previous inspection report-
.
The licensee still
does not have available at the plant the maps associated
with the shield-
ing study (required by NUREG-0578, Item 2.1.6.b)
performed by the corporate
2/
IE Inspection Report No. 50-315/80-23
- 8-
office. It was verified that the licensee
has battery operated air sam-
plers which use
12 volt car batteries
as
a source of power.
The air
samplers
are compatible with both silver zeolite and charcoal cartridges.
No significant problems
were identified in the licensee's
improved inplant
airborne radioiodine sampling
and analysis
program.
Trans ortation Activities
The following areas of the licensee's
transportation
program were reviewed:
management
controls; selection of packaging; preparation of packages
for
shipment; delivery of completed packages
to carriers; receipt of packages;
incident reporting; indoctrination -and training; audit program;
examination
of packages;
and record keeping.
No significant discrepancies
were noted
between the licensee's
current program and
NRC requirements in 10 CFR Part 71 and
DOT requirements
in 49
CFR 170-189.
By procedure
(PMI 3150), the Technical Superintendent
is delegated
overall
responsibility for receipt,
packaging,
and shipment of radioactive material.
Specific responsibilities
are delegated
to other individuals.
Other pro-
cedures
(Section 6) govern waste handling, packaging,
and shipping activi-
ties.
Radwastes
consist of dewatered
resins, solidified evaporator bottoms,
and compressible
and noncompressible
dry waste.
t
Iow-activity resins
(about 250 cubic feet generated in 1980) originate
from the S/G blowdown treatment
system.
Higher activity resins,
which
still meet
LSA criteria (about 600 cubic feet generated
in 1980),
originate -from the
CVCS Letdown Charging System,
and the waste evaporator
and boric acid evaporator
feed ion exchangers.
The licensee
generates
about .30,000 cubic feet per year of solidified
radwaste
evaporator
bottoms using the Hittman cement process.
The
licensee
discontinued
urea formaldehyde solidification in September
1980.
The Hittman contract personnel
operate
the solidification equip-
ment in the radwaste
area
under D.
C.
Cook plant procedures
and
coverage.
The 30
gpm radwaste
evaporator is being augmented with in-
stallation of a new
15
gpm waste evaporator
expected
to be operational
in about
a year.
About 18,700 cubic feet of solid waste
was generated in 1980 by the
licensee
consisting of noncompressible
materials placed in banded
boxes
'nd
compressible
wastes
placed in 55-gallon drums'or the latter,
one
of two compactors
located in the auxiliary building are used.
One of
the units is generally reserved for compacting waste with higher activity.
A standing order,
PMSO .050, titled "Solid Waste Control," instructs
workers not to take packing materials unnecessarily
into the controlled
area.
Various Hittman Nuclear casks
and/or liners are used
as appropriate
with waste shipments.
Any periodic maintenance
on casks is performed
by the cask vendor.
Records of recent.
shipments of each type were
reviewed, with no problems being identified.
One waste package,
a
55-gallon barrel ready for shipment,
was selected
at random to open
and observe contents.,
The barrel,
tape sealed,
marked
LSA, and numbered
for identification, was first placed
on its side for about three minutes
before being placed upright and opened.
The gasket
was found in place,
contents
consisted of items listed on records,
and no evidence of liquid
was observed.
The licensee
had committed to annual training of personnel
involved in
radwaste
shipping and packaging of radioactive waste.
Training is cur-
rently being conducted
about semiannually.
In December
1980 - January
1981,
34 workers including; maintenance,
radiation protection
and environ-
mental technicians,
Hydro Nuclear Service,
and Hittman Nuclear Development
Corporation personnel
attended
the training.
The training included appli-
cable material in 10 CFR 71,
49
CFR 170-179, burial site criteria and
licenses,
and plant shipping and handling procedures.
For each type of shipment,
the licensee is developing
a comprehensive
audit plan showing major steps
and detailed plant procedures
for each
major step.
The inspector reviewed
an audit record
(gA Surveillance
Report No. 12-81-149),
including the package of all procedures
used
in the audit, of a dewatered
resin shipment
made
on April 20,
1981.
No significant problems
were identified by the licensee audit.
A full
audit of a spent resin transfer is planned for the period June
17"19,
1981.
No items of noncompliance
or deviations
were identified.
Licensee Event Followu
The inspector identified a problem in reviewing the licensee's
data
prepared for LER 'jj81-001/04L-0 regarding
two unplanned airborne releases.
In one release,
involving a gradual loss of pressure
of an "isolated"
waste
gas decay tank over the period from February 3,
1981, to March 13,
1981, the total curies released
and the percent of technical specification
limit were significantly underestimated.
This was because
the calculations
did not account for radioactive
decay during the lengthy period of the
release.
Rough calculations indicate that the release
rate
was
a very
small percentage
of the technical specification release
rate limit.
This
matter
was discussed
at the exit meeting.
The inspector also reviewed IER No. 81-001/04X-1 concerning
an unmonitored
release
from a steam generator
(small primary to secondary leak) while the
startup
blowdown flash tank was in service.
Loss of flow to radiation
minitor R-19 due to crud blockage of the side stream line apparently
caused
the problem.
A change
request,
RFC No. DC-12-1825,
was initiated and is
being processed
to modify flow meters
on S/G blowdown sample lines to a
type that will incorporate
a loss of flow alarm in the control room.
In
10 "
I
5
the interim, surveillance of the flow meters is conducted
every eight
hours.
The inspector
has
no further questions
regarding this matter.
"'
"K
The inspector
met with licensee
representatives
(denoted in Section
1)
on June
12,
1981.
The following items were discussed:
a.
The purpose
and scope of the inspection.
b.
The inspection findings including the noncomp'liance
items
listed in Appendix A.
c.
The need to obtain the dose rate
maps associated
with the improved
inplant iodine monitoring study.
(Section
12)
d.
The inspector's
finding that radioactive
decay had not been accounted
for in quantifying an unplanned
gaseous
release.
The licensee
stated
that he would requantify the release
and issue
a correction to the
LER.
(Section
14)
0