ML17329A208
| ML17329A208 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/08/1991 |
| From: | Louden P, Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A206 | List: |
| References | |
| 50-315-91-24, 50-316-91-24, NUDOCS 9110170068 | |
| Download: ML17329A208 (7) | |
See also: IR 05000315/1991024
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos.
50-315/91024(DRSS);
50-316/91024(DRSS)
Docket Nos. 50-315;
50-316
Licensee:
Company
1 Riverside Plaza
Columbus,
OH
43216
License
Nos.
Facility Name:
D.
C.
Cook Nuclear Plant, Units
1 and
2
Inspection At:
D. C.
Cook Site,
Bridgman, Michigan
Inspection
Conducted:
Se tember 16-19,
1991 (On-site)
~
~
~
Inspectors:
R. A.
aul
yrl
P. L. Louden
Approved By:
M. C. Schumacher,
Chief
Radiological Controls
and
Chemistry Section
ic j'yy
/%/g/'
e
i~i/pr
ate
Ins ection
Summar
Ins ection
on Se tember 16-19
1991
(Re ort Nos.
(50-315/91024(DRSS);
~d:
d
.
dd
d
d
f
d
dd 'd
protection program,
including:
changes
( IP 83750); external
exposure
control
(IP 83750); internal exposure
control
( IP 83750); contamination control,
surveys,
and monitoring;
ALARA ( IP 83750); plant tours;
and licensee
actions
for previous inspection findings
( IP 92701).
Results:
During the course of the inspection,
one apparent violation was
identified for failure to follow procedures
while exiting the Radiation Control
Area (RCA).
The licensee's
Radiation
Work Permit
(RWP) program, plant
cleanliness,
and facility upgrades
were identified as strengths.
The radiation
protection group is well staffed,
however; Radiation Protection Technician
station experience
is limited.
Management
support for the radiological
control
and
ALARA programs is continuing to improve.
Weaknesses
were
identified in radiological access
controls
and in poor follow up of
identified contaminations
of modesty garments.
9fi0170068 9i2008
ADOCK 050003%5
G
Persons
Contacted
DETAILS
'.
- A. Blind, Plant Manager,
D.C.
Cook (DCC)
.
- S. Colvis, Radiation Support
NOD, American Electric Power Service
Corporation
(AEPSC)
- S. DeLong, Supervisor,
Production Engineering,
DCC
- E. Fitzpatrick, Vice President,
Nuclear Operations,
AEPSC
- J. Fryer,
TPS/RMC Supervisor,
DCC
- K. Haglund,
TPS/Chemistry Supervisor,
DCC
- D. Loope, TPS/Plant Radiation Protection Supervisor,
DCC
- D. Noble,.TPS/Health
Physicist,
DCC
- L. Umphrey, Administrative Compliance Coordinator,
DCC
- D. Williams, TPS/Health Physicist,
DCC
- J. Wojci k, TPS/Superintendent,
DCC
The inspectors
also interviewed other licensee
personnel
in various
departments
in the course of the inspection.
- Present at the Exit Meeting on September
19,
1991.
General
This inspection
was conducted
to review the licensee's
radiation
protection
program.
The inspectors
toured the licensee's facility to
observe posting,
labeling and access
control.
Independent
measurements
included direct radiation readings
and co~tamination
smear
measurements;
no smears
were in excess
of 100 dpm/100cm
and all direct measurements
were comparable
to posted radiation levels.
Licensee Action on Previous
Ins ection Findin
s (IP 92701)
(Open)
Open Item (315/91015-02;
316/91015-02):
Onsite disposal
of
low level radioactive sludge.
The licensee is continuing to prepare
information for submittal to the Office of Nuclear Reactor Regulation
to request
disposal
pursuant to
a
10 CFR 20.302 approval.
Completion
of the submittal is expected
in the near future.
(Closed)
Open Item (315/91008-01;
316/9100-01):
Installation of control
devices for EHRA gates.
Automatic closure devices
have
been installed
and tested
on all
EHRA gates,
several
of which were verified installed
and working by the inspectors.
In addition to these
devices,
automated
control access
devices
readers
(ACADs) with associated
strobe lights
are installed
on several of the
EHRA gates.
Installation of the strobe
lights and
ACADs on the remaining
EHRA gates is expected
to be completed
during the first refueling outage
in 1992.
(Closed)
Open Item (315/91015-01;
316/91015-01):
Error in airborne
release
calculations.
The licensee
has reviewed
and submitted corrections
for those
semi-annual
effluent reports written since the
1983 inception of
the
MIDAS code.
In addition, the licensee
has
implemented corrective
actions including,
a comparison
between
the
MIDAS code
and the
ODCM on
both
an annual basis,
and following any change to either
MIDAS or the
ODCM.
These actions
appear
adequate
to correct the discrepancy;
this
item is considered
closed.
Chan
es (IP 83750)
The inspectors
reviewed
changes
made since the last inspection
in the
organization,
equipment,
procedures, facilities, and implementation
of the licensee's
radiological protection
program.
The health physics staff has lost six technicians
in the past year, three
of which were promotion transfers
to other departments.
Although this is
about
a ten percent
turnover, it does not appear
to have
had
a significant
impact on staff stabi lity.
Forty-three of the fifty-three house
technicians
and all twenty-six contractor technicians
are
qualified.
The junior technicians,
technicians,
and senior technicians
average
three years,
six years,
and nine years
industry experience
respectively
and
one year,
one
and
a half years,
and six years station
experience
respectively.
The technician
supervisors
average
about
fourteen years
industry experience
and about nine years station
experience.
Station experience f'r the junior and regular techs
appeared
to be limited.
The licensee
has recently encouraged
the technicians
to participate
in an
in house training program for National Registry of Radiation Protection
Technology
(NRRPT) certification.
Currently there are twenty four in
house technicians
and nine contractor technicians participating.
In
addition, the licensee
has also purchased
contractor
health physics
and
mathematics
cour se material for interested
technicians
and staff.
Overall,
the staff is comprised of a sufficient number of professionals
and
technicians with good support
from upper management.
The licensee is currently constructing
a
new hot tool crib storage
and
distribution facility.
The new facility, which includes
space for
tool/equipment
surveys
and storage,
appears
to be
a considerable
improvement over. the old facility in which several
radiological control
problems
had been identified.
The licensee is also modifying all of the frisker booth monitoring
stations
in the auxiliary building.
The new booths will house
hand
and foot monitors
and be seismically qualified.
External
Ex osure Control (IP 83750)
I
The inspectors
reviewed selected
standing
and special
Radiation
Work
Permits
(RWPs) for appropriateness
of the radiation protection
requirements
based
on work scope,
location,
and conditions
and found
the
RWPs to be thorough
and complete.
The inspectors
found- the manner
in which information was presented
to be easy to follow and special
requirements
wer e clearly understandable.
The inspectors
ident ified
the methods of conveying dress
requirements for specific jobs and the
itemization of jobs covered
by
RWPs to be
a program good practice.
'nternal
Ex osure Control
( IP 83750)
Through reviews of whole body count
and dosimetry records,
the inspectors
determined that
no licensee
personnel
received greater
than the 40
NPC-hour regulatory limit since the last inspection.
The inspectors
reviewed recent calibration
and daily energy
gC checks for the
FASTSCAN
whole body counter.
All checks
were well documented
and performed
according to procedures.
The inspectors
reviewed the licensee's
program for respiratory protection.
A selective
review of wearer qualification records
indicated
no
discrepancies.
Respirator fit testing,
usage,
issuance,
accountability,
storage,
deconning,
and maintenance
progr'ams
were reviewed
and appeared
to be performing adequately.
An internal surveillance of the respiratory protection
program performed
in August 1991 identified the licensee
does not use unique fittings for
respiratory protection equipment.
The "Chicago" fitting
is used
for service air, breathing air, plant water,
and nitrogen spargers.
This practice is inconsistent with NUREG-0041 which specifies that all
fittings and
components
shall
be standardized
so that the introduct'ion
of nonrespirable
gases
and materials into the respirator
system is
impossible.
The licensee
indicated that corrective actions
were underway
to standardize
the fittings for respiratory
equipment.
This matter
was
identified as
an open
item until the corrective actions
were completed
and was discussed
at the exit interview.
(Open Item 315/91024-01;
316/91024-01)
7.
A review of analyses
and tests for breathing air quality indicated all
supplies
met the Compressed
Gas Association
Grade
"D" requirements.
Control of Radioactive Materials
and Contamination,
Surve
s
an
on> orsn
The inspectors
reviewed routine surveys
performed in the
RCA, and found
them to be properly documented
and reviewed.
Additionally, the inspectors
reviewed calibration records for selected
portable
survey instruments
and
found all records to be current
and complete.
The licensee
maintains
a sufficient inventory of survey instruments
and those
in need of
repair/calibration
are clearly labeled.
A review of Condition Reports
indicated
an incident involving contaminated
material discovered
outside the
RCA.
In a letter to the
NRC dated July
16, 1991, the licensee detailed events
and investigations
surrounding
the
discovery of contaminated
material in the licensee
s scrapyard.
The
material
was traced to the 1970's
and to the Steam Generator
Repair
Project of 1988.
All the material discovered
was fixed, with levels at
2,000
dpm or below.
The inspectors
noted the thorough investigation,
notification to the
NRC, and plans to perform surveys of the entire
scrapyard for additional
contaminated
material.
The inspectors
reviewed records for required
sealed
source
leak tests,
and found all tests to be current
and complete.
All calibration sources
reviewed were traceable
to National Institute of Standards
and Technology
specifications.
The licensee
had recorded
56 personnel. contaminations
(PERCONs) for the
year.
The inspectors
noted that approximately
80 percent of the
PERCONs
were attributed to "clean areas"
of the plant.
The licensee
provides
modesty
garments
(MGs) for workers entering the
RCA which are
recommended
for use under Anti-contamination clothing (Anti-C's).
PERCONs are not
recorded for contamination
detected
on the
MGs.
However, all particle
detections
are recorded
and skin doses
assigned.
The licensee
does
not
track modesty
garment contaminations,
and when queried
by inspectors for
numbers
associated
with MG contaminations
a number could not be provided.
The licensee
indicated that
some of the
MG contaminations
are investigated
by technicians.
This item was discussed
at the exit interview with the
inspectors
noting that an aggressive
contamination control program
typically follows up on all contaminations
to accurately
assess
potential
undetected
contamination.
The licensee
commented that
an evaluation
would have to be conducted
to determine
the extent of changes
necessary
to implement tracking and investigating of MG contaminations.
Maintainin
Ex osure Control
During a previous inspection
(IR91008), the licensee
indicated they were
considering installing permanent
scaffolding structures
in the containment
and possible
removal of the Resistance
Temperature
Detector
(RTD) Bypass
Loop Line during the next refueling outage
scheduled for 1992.
Both
initiatives would save considerable
dose during future outages.
The
licensee
indicated that although these initiatives are still being
considered, it appears
more likely that during the next refueling outage
installation of the permanent
scaffolding will occur and less likely
that the
RTD line will be removed
because
of cost/benefit considerations.
However, the licensee
plans
on
a contractor performing
an
RTD line
decontamination
as
an experiment during the next Unit 2 refueling
outage with the hopes of achieving
a significant decontamination factor.
Significant initiatives to reduce radia'tion fields during the next
refueling outage
include; experimental
RTD line chemical
decontamination
(vendor provided);
and controlling
RCS temperature
and
pH during shutdown
to solubilize
crud from the system
and recover it on the demineralizers.
The later initiative was used during
a forced outage
in early
1991
and the
licensee
c'1aims that approximately
400 curies of cobalt was
removed from
the system.
The scheduling of work outside the initial scope during previous
outages
resulted
in poorly planned work and work without adequate
ALARA review.
This was
a weakness
identified during
a maintenance
team inspection.
To
correct that weakness
the licensee
plans
on performing the scope of the
next refueling outages
without making other than necessary
changes
during
the course of the outage.
The station goal for 1991 is about
85 person-rem.
Through August 1991,
the licensee
was at about
75% of the goal.
Although there were
no
refueling outages
in 1991 there were
4 weeks of outage activities from
the 1989 refueling outage
and
6 weeks of forced outage activities.
The
licensee's
projected three year average
dose
per reactor is about
200
person-rem;
the national
average for the
same perjod was about 300.
The
inspectors
noted the licensee
is continuing to strengthen
the
program.
Tours
The inspectors
made several facility tours throughout
the inspection
period to observe
posting
and labeling, radiological controls
and to
observe
personnel
performing various jobs.
During the tours it was
noted that plant cleanliness
was good.
During one tour, the inspectors
noted
a contaminated
area
improperly
posted.
The area
had
a step off pad in place but did not have tape or
a sign to clearly designate
the boundary of the contaminated
area.
Production supervisors
were informed of the inadequate
posting,
agreed
with the inspectors
observations,
and corrected
the problem in a timely
manner.
On another tour, the inspectors
observed
three individuals alarm the
personnel
contamination monitors
(PCMs) at the turbine building exit;
no
RP technicians
were in the immediate
area at the time and
no acknow-
ledgment of the alarms
was
made
by the
RP staff.
The workers proceeded
to attempt decontamination efforts
on the areas
indicated
by the monitors
(head
and hand).
These efforts involved the cleaning of their respective
hard hats
and either wiping or washing their hands.
After deconning,
the
individuals cleared
the
PCMs and exited the area.
No attempt
was
made
to notify RP of the alarms to request
assistance
as required
by procedures
and posted instructions.
During
a previous inspection,
(IR-91008) similar
weaknesses
were noted in the access-egress
controls at the
same control
point, and were discussed
with the licensee.
To strengthen
the controls
the licensee
posted written instructions for workers to follow after
alarming the
PCM, and installed
a telephone for use to inform RP.
However,
no significant measures
were taken to provide sufficient
coverage/observance
of this control point.
These events
were continuing
examples of failure to follow procedures for exiting the
RCA. (Violation:
315/91024-01;
316/91024-01).
Overall, the general
housekeeping
of the
RCA appeared
very good.
~0en Items
Open items are matters
which have
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.
Open
items disclosed
during
the inspection
are discussed
in Section 5.
Exit Interview
The scope
and findings of the inspection
were reviewed with licensee
representatives
(Section
1) at the conclusion of the inspection
on
September
19, 1991.
The licensee
did not identify any documents
as
proprietary.
The following matters
were specifically discussed
by the
inspectors:
a.
The violation of procedural
requirements
(section 9).
b.
Followup of modesty
garment
contaminations
(section 7).
c.
Plant cleanliness,
upgrade of facilities, improvement in the
program,
and initiatives to certify technicians
in NRRPT (Sections
9, 4,
and 8).
d.
The Open Item concerning
the installation of unique fittings for
respiratory protection equipment
(Section 6).