ML17329A531
| ML17329A531 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/28/1992 |
| From: | Paul R, Schumacher M, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A529 | List: |
| References | |
| 50-315-92-10, 50-316-92-10, NUDOCS 9206090112 | |
| Download: ML17329A531 (11) | |
See also: IR 05000315/1992010
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos.
50-315/92010(DRSS);
50-316/92010(DRSS)
Docket Nos.
50-315;
50-316
License Nos.
Licensee:
Company
1 Riverside Plaza
Columbus,
OH
43216
Facility Name:
D.
C.
Cook Nuclear Plant, Units
1 and
2
Inspection At:
D.
C.
Cook Site,
Bridgman, Michigan
Inspection
Conducted:, April 21-24 and May 13-20,
1992
Inspectors:
R. A.
aul
D t
Approved By:
N.
S ah
M. C.
Schumacher,
Chief
Radiological Controls and
Chemistry Section
Date
r/zr/r~
Date
Ins ection
Summar
Ins ection
on
A ril 21-24
and
Ma
13-20
1992
Re ort Nos.
50-
315 92010
DRSS
and 50-316
92010
DRSS
Areas Ins ected:
Routine unannounced
inspection of the radiation
protection program (Inspection Procedure (IP) 83750), the solid
radwaste
and transportation
programs
(IP 86750),
and the gaseous
and liquid waste programs
(IP 84750) including:
training and
qualifications;
management
controls; audits
and appraisals.
In
addition, the radioactive material building and the circumstances
surrounding
a contaminated
shipment of hazardous
waste were also
examined.
Results:
The licensee's
solid,
gaseous,,
liquid radwaste
and
transportation
programs are well conducted.
Operational
problems
with the main liquid discharge monitor have continued since the
previous radwaste
inspection
(Section 9); licensee
management
has
committed to resolve the problems this year.
Two violations were
identified; one for failure to follow the unconditional release
procedure
(Section
13) which led to the second violation
concerning transferring radioactive material to an unauthorized
recipient
(Section 13).
9206090ii2 920529
ADOCK 05000315
8
'
Persons
Contacted
DETAILS
K.
D.
+J.
+L.
+D.
+S.
+J.
+D.
J 0
- +D
+J.
Cunningham,
Radioactive
Waste Handling Supervisor
Foster,
Radioactive Material Specialist
Fryer, General Supervisor,
Radioactive Material Control
Gibson, Assistant Plant Manager
Holland, General Supervisor Radiation Support
Lehrer,
General Supervisor Radiation'ontrols
Long, Radioactive
Waste Specialist
Loope, Superintendent
Radiation Protection
Nadeu,
Senior
QA Auditor
Noble, General Supervisor Health Physics
E. Rutkowski, Assistant Plant Manager
+J.
Isom, Senior Resident Inspector
+Denotes those present at the April 24,
1992, Ekit Meeting
- Contacted by telecon
May 13-20,
1992
The inspectors
also interviewed other licensee
and
contractor personnel.
2 ~
General
This inspection
was conducted to review the licensee's
radwaste/transportation
program.
The inspection included
tours of the hazardous
waste building, observation of work
in progress,
review of records,
and discussions
with
licensee
personnel.
The radwaste facilities appeared well
maintained.
3 ~
Chan es
IPs 84750
and '86750
4 ~
The most significant change in the solid radwaste
and
transportation
program was the promotion of the plant
radiation protection supervisor to radiation protection
superintendent
who now has the general supervisor of
radwaste reporting to him.
With this change the radiation
protection superintendent
now has the responsibility for the
entire radwaste
program.
Licensee Action on Previous Ins ection Findin s
Closed
0 en Items
315 91015-01
and
316 91015-01
Incorrect receptor distance for the north sector in the
calculation of offsite doses using the computer program
MIDAS.
The MIDAS program was revised to correct the
discrepancy
and corrections
were submitted for affected
semiannual effluent reports.
In addition, both the
,Offsite Dose Calculation Manual
(ODCM) and MIDAS were
reviewed by the licensee
and found in agreement
(Section 11).
This item is considered
closed.
Audits and
A raisals
IPs 86750
and 84750
tt
A review of quality assurance
(QA) audits conducted
by
the licensee for 1991 and 1992 to date,
did .not
identify any problems.
Audits were of good quality and
management
review of findings were generally thorough,
timely and technically sound.
QA auditors assigned to
this area
have the necessary
expertise
and experience
prerequisites
and
a good working relationship exists
between
radwaste
and
QA management.
No violations or deviations
were identified.
Trainin
and
ualifications
and 83750
Training in current
NRC and
DOT requirements is
accomplished primarily through attendance
at contracted
'raining
courses
and supplemented
by maintenance
of
current shipping regulations.
Training records
were
reviewed by the inspectors;
no problems were
identified.
All plant personnel
are instructed in Nuclear General
Employee training
(NGET) to report to radiation
protection
(RP) whenever
an electronic dosimeter
(ED)
alarms;
however,
these
alarms are not demonstrated.
As
a result of several industry events involving EDs, the
licensee is revising their training to include
a video
presentation
explaining and demonstrating
proper
use.
This video is expected to be in use
by the end of
May 1992.
Contract
RP technician
(RPT) qualifications are
established
by the contractor
and reviewed by health
physics
management
in accordance
with procedure
PMI-
2260,
R4, "Selection of Contractual
Support Personnel".
Those hired are required to pass
a test
on RP
fundamentals
and attend both
NGET and plant specific
courses.
The inspectors
reviewed test results of the
contract
RPTs and the assessment
of their qualifica-
tions.
No violations or deviations
were identified.
7.
Solid Radioactive
Waste
and Trans ortation
XP 86750
a.
Waste Generation
and Processin
Solid radwaste consists primarily of spent resin
that has been dewatered
and packaged in high
integrity containers
(HICs), uncompacted
Dry
Active Waste
(DAW) packaged in 55 gallon drums and
authorized
LSA boxes,
and filters have been
dewatered
and stored in HICs.
While both spent
resin and filters are processed
and stored
on
site, the majority of DAW is sent offsite for
processing
and storage.
b.
=Total waste generation rates continue to decline
due to reduction initiatives documented in
inspection reports
50-315/91015(DRSS)
and 50-
316/91015(DRSS).
Wastewater
processed
by plant
systems
decreased
204'rom
1990 through
1991 due
apparently to increased
oversight of wastewater
processing
by management.
Further'initiatives
include increased
use of launderable.items
(mops,
bags, et+
and additional oversight of wastewater
processing.
r
Based
on a review of NRC topical reports,
procedures
and facility tours, it appears
and that
solid radwaste
processing activities were
performed in accordance
with the Process
Control
Program
(PCP).
Waste Classification
and Trans ortation
Waste classification
and manifest generation
continues to be performed
as descr'ibed in
'nspection
reports
50-315/91015(DRSS)
and 50-
316/91015(DRSS).
c ~
A review of radwaste
shipments for 1992 to date
did not identify any problems;
however,
a
violation was identified concerning
a hazardous
waste
shipment containing radioactive material
(Section 13).
A total of five shipments
comprising approximately
5846 ft of DAW was
made
to offsite contractors.
No transportation
incidents
have occurred since October
1986.
h
Onsite Stora
e of Radioactive
Waste
Construction of the radioactive material building
(RMB) for onsite,waste
storage
was completed
and
the licensee is currently finalizing procedures
and policies describing its use.
Approximately
104 of the RMB's 80,000 ft , will be utilized by
radioactive waste currently in storage.
Through a review of procedures,
tours of the
RMB, and discussions
with personnel,
construction
and planned operation
appeared
to be consistent with the licensee's
safety
analysis description for the facility.
No violations or deviations
were identified.
Li uid and Gaseous
Radioactive Naste
The insp'ectors
reviewed the.licensee's
liquid and
gaseous
radioactive effluent program including
information concerning:
semiannual
release
reports,
waste sampling,
process
and effluent monitor release
paths,
.batch releases
and procedures
for waste
and
effluent systems.
A general description of the
monitoring, gaseous
and liquid release
programs,
and
release
paths is discussed
in Inspection Reports
No.
50-315/90021
and No. 50-316/90021.
It appeared that
processing,
sampling and analysis,
and approval
and
performance of the radioactive effluent releases
were
conducted in accordance
with the procedures.
Contaminated oil collected in radiologically controlled
areas is incinerated in the plant heating boiler in
accordance
with technical specification 3.11.2.3.
The
oil is initially stored in the waste oil tank,
sampled
for activity and
a dose estimate is performed.
Based
on the results of the estimate,
a calculated
volume of
oil is transferred
from the waste oil tank to the
larger fuel oil tanks where another
sample is taken.
Following incineration,
the dose projection is
recalculated
and included in the total monthly
releases.
A review of both projected
and final dose
assessments
did not identify any problems.
Because
of
the possibility of contamination,
access to the plant
heating boiler is controlled and
RP notification is
required before entry.
No violations or deviations were identified.
Li uid Dischar
e Monitor Problems Identified in LERs
The inspectors
reviewed Licensee
Event Reports
91010
and 92003 describing failure of the liquid radwaste
monitor
(RRS-1001) to automatically terminate radwaste
releases
on October
16,
1991,
and March 7,
1992,
when
the monitor became
The releases
were
terminated manually by the control room operator
when
the monitor malfunctions were recognized at six and
twenty-five minutes, respectively, after the monitor
failure.
Subsequent
samples
taken in duplicate
confirmed that activity in the discharge
had been
reliably determined
by the samples
taken before -the
release.
The releases
were properly reinitiated and
completed without incident.
A similar event,
documented in Inspection Reports
50-
315/91010
and 50-316/91010
(LER 91003)
was experienced
on this monitor on March 8,
1991, shortly after it
became operational in early 1991 as
a replacement for
the plant s original liquid discharge monitor.
The
licensee's
investigation of these
events
have
identified a number of root causes
including failure of
the monitors trip/isolation relay system, failure of
the
DC backup power supply source,
operator error,
and
problems associated
with the radiation monitoring
systems
(RMS) monitor alarm logic.
Corrective actions
for these
events
included
some design
changes,
replacement
of parts/equipment,
operator procedural
revision,
system modification,
and
a requirement for a
radiation protection technician to monitor each release
to ensure the release is terminated in the case of
system failure.
The RPT monitoring is a temporary
action taken pending final correction of the
system.
This matter
was discussed
at the exit meeting,
where
the inspectors
expressed their concern about these
failures.
The licensee
also shared the concern
and
recognized
the importance of the issue.
In addition a
task force to address
problems identified with the
has
been developed.
The task force recommended
the
implementation design of changes to the system, to
improve signal communication reliability and overall
system performance.
These
measures
are expected to be
accomplished
by February
15,
1993.
LERs 91003,
91010,
and 92003 are considered
closed
and the actions taken
to address, the reliability problems with the system
will be reviewed during a future inspection
and is
considered
an Inspection Follow-up item (IFI).
(IFI
315/92010-01;
316/92010-01)
No violations or deviations
were identified.
One
Inspection Follow-up Item was identified.
10.
Effluent Control Instrumentation
The inspectors selectively reviewed secondary calibration
and channel functional test records
and selected
setpoint
records for effluent radiation monitors on the liquid and
gaseous
radwaste
systems
and observed calibrations of
process
monitors and in the calibration facility.
No
problems were identified.
The primary and secondary calibrations of the
SPING gaseous
effluent monitors ~are discussed. in Inspection Reports
No.
50-315/91015
and 50-316/91015;
there have been
no
significant changes to the calibration program since then.
Review of the calibration and test records for the most
recent calibrations indicated they were accomplished in
accordance
with procedural requirements
and no significant
problems were identified.
The primary cal'ibration of the Eberline liquid release
monitor used concentrations
of radioactive liquid to
establish efficiencies
and to demonstrate linearity.
At the
same time, solid cap sources
were counted
and efficiencies
determined for use in subsequent
calibrations.
During the
most recent calibration the licensee identified the "as
found" monitor response
correction values
and threshold
voltage were outside the licensee's
procedural
acceptance
criteria.
The licensee
issued
a condition report on this
finding and is determining if liquid effluents met release
criteria.
The evaluation results will be reviewed by the,
inspectors; this is considered
an Inspection Follow-up Item.
(IFI 50-315/92010-02;
50-315/92010-02)-
During a previous inspection
(Reports
No. 50-315/91015;
50-
316/91015) it was noted there were performance
problems with
the Westinghouse liquid monitors.
Since then the problems
have decreased
considerably
as
a result of upgrading
instrument
and maintenance testing
and surveillance
procedures.
A review of the most recent. calibrations of
some of these monitors verified better performance.
No violations or deviations
were identified.
One Inspection
Follow-up Item was identified.
Dose Assessment
Offsite doses
from effluent releases
are calculated
using the computer
code
MIDAS as described in
inspection reports
50-315/91015(DRSS)
and 50-
316/91015(DRSS).
The inspectors
performed confirmatory
calculations using the
ODCM for typical gas
and liquid
releases.
The results of the calculations
were in
agreement
with the MIDAS assessment.
No violations or deviations
were identified.
Air Cleanin
S stems
Technical Specifications
(T/S) requires filter testing of
the Control Room Ventilation Systems,
Engineered
Safety
Features Ventilation Systems,
and the Spent Fuel Storage
Pool Exhaust Ventilation System.
A selective review of
the surveillances test data for 1991 showed that the
surveillance
on the ventilation systems
met test
acceptance criteria. It was also noted that charcoal
filters in the control room ventilation system are
changed
every
18 months but no "as found" tests of the
charcoal
were performed.
Without these the licensee
would not be aware of possible degradation of the
charcoal during the previous
18 month period.
This
matter
was discussed
with the licensee
and it is the
inspectors'nderstanding
that the licensee
plans to
perform future "as found" tests
when charcoal is
replaced in the control room ventilation systems.
This
matter will be reviewed during a future inspection
and
is considered
an Inspection Follow-up Item. (IFI 50-
315/92010-03(
50-316/92010-03)
No violations or deviations
were identified.
One
Inspection Follow-up Item was identified.
Onsite Followu
of Events
On April 3,
1992, the licensee
informed the
NRC of the
March 30,
1992, notification from a vendor in Arkansas
that
a barrel labeled
as hazardous
waste (liquid
solvent)
they received for incineration contained
radioactive material.
The vendor did not have
a
license to receive or possess
radioactive material.
The barrel was returned to the licensee the next day.
Direct radiation measurements
confirmed the barrel
(30
gallons)
contained radioactive material; later analysis
showed the barrel contained
about
40 microcuries of
mixed isotopes
and 134,
and cobalt-60).
Surveys of the outside of the barrel and truck bed
indicated
no contamination.
No violations of
Department of Transportation
(DOT) requirements
occurred
because
the radioactivity levels did not meet
the
DOT definition of radioactive material.
The licensee
issued
a condition report and
a subsequent
investigation discovered that samples of the barrel were
sent to several unlicensed laboratories prior to shipment.
These laboratories
were also not authorized to receive
radioactive material.
The transfer of the radioactive
solvent to the incinerator
and laboratory vendors is a
violation of 10 CFR 30.41(a)
requirements
(50-315/92010-04;
50-316/92010-04)
~
Plant personnel
surveyed
each of the laboratories
on
April 8 and 9,
1992,
and no contamination
was found.
The licensee's
investigation also revealed that on
September
14,
1991,
a spill involving the solvent had
occurred in the hazardous
waste storage building, but
that no surveys
were done because
the solvent's
radioactivity was not known.
Followup surveys
(April 4,
1992) indicated fixed contamination levels on
sections of the floor ranging up to 40,000
dpm/100
cm2,
and low levels of contaminated soil at locations
immediately outside the building.
No other equipment
or barrels
were found contaminated
during these
surveys.
The soil apparently
became
contaminated
from
periodic floor sweepings
which had been
swept outside
a
door of the building during the time the spill occurred
and its subsequent
discovery.
The contaminated soil
was recovered for disposal
and the inspectors verified
the building has
been appropriately posted
and
controlled.
The investigation did not determine
where the
contaminated
solvent
came from, but the licensee
concluded that it must have been brought out of the
radiological controlled area
(RCA) without an
unconditional release
survey.
The failure to perform
an unconditional release
survey is a violation of
Procedure
12
PMP 6010-RPP.301
"Control of Equipment
and
Material in a Restricted
Area" (50-315/92010-05;
50-
316/92010-05).
Immediate corrective actions taken to prevent recurrence
of
this event included strengthening
of the
RCA release
survey
and chemical control programs,
and performing radioactivity
surveys of all hazardous
wastes
leaving the protected
area
or the plant site.
These matters
were discussed
during the
exit interview and will be reviewed during a future
inspection.
Two violations and no deviations
were identified.
Exit Interview
The scope
and f'indings of the inspection were reviewed with
licensee representatives
(Section
1) at the conclusion of
the inspection
on April 24,
1992.
The licensee did not
identify any documents
as proprietary.
The following
matters
were specifically discussed
by the inspectors:
a.
Contaminated
hazardous
waste shipment
(Section 13),
b.
Onsite storage of radioactive waste
(Section 7c).
Incineration of contaminated oil (Section 8),
Calculation of effluent doses
(Sections
4 and 10),
and
Charcoal filter testing of T/S ventilation
, systems
(Section 12).
10