ML17331B373
| ML17331B373 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/29/1994 |
| From: | Cox C, Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17331B371 | List: |
| References | |
| 50-315-94-06, 50-315-94-6, 50-316-94-06, 50-316-94-6, NUDOCS 9405100035 | |
| Download: ML17331B373 (7) | |
See also: IR 05000315/1994006
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Repor t Nos.
50-315/94006(DRSS);
50-316/94006(DRSS)
Docket Nos. 50-315;
50-316
Licensee:
Company
1 Riverside
Plaza
Columbus,
OH
43216
.License
Nos. DPR-58;
Facility Name:
D.
C.
Cook Nuclear Plant, Units
1 and
2
Inspection At:
D.
C.
Cook Site,
Bridgman, Michigan
Inspection
Conducted:
March 28 through April 1,
1994
Inspector:
.R.
o
Approved By:
n
.
ro e,
cting
ie
eactor Support
Programs
Branch
'
e
I
Ins ection
Summar
Ins ection
on March 28 throu
h
A ril
1
1994
Re ort Nos.
50-315
94006
DRSS
and 50-316
94006
DRSS
Areas Ins ected:
Routine inspection of licensee's
radiation protection
program (IP 83750),
including audits
and appraisals,
internal
exposure,
outage
ALARA, and contamination control.
In addition, the inspector
reviewed
licensee follow up to a previous violation and to previously identified
inspection
items.
Results:
The licensee's
radiation protection program
was generally well',
conducted.
Low source
terms
were attributed to good shutdown chemistry
control
and decontamination
of hot spots.
Overall station cleanliness
was
excellent but problems in cleaning
up after jobs were noted in containment.
A strength
was noted in the quality of the radiation protection
and chemistry
guality Assurance
audit tea'm.
Some problems
were noted in ALARA planning
reflected
by exceeding
the
ALARA dose goals for the outage.
One violation of
NRC requirements
was identified as
a result of a resin spill and associated
personnel
contaminations.
9405l00035
940429
ADOCK 050003l5
'Q
DETAILS
Persons
Contacted
- B. Auer, Site guality Assurance
Auditor
- W. Burgess,
Superintendent
Scheduling
- J. Fryer,
General
Supervisor Radioactive Material Control
- L. Gibson, Assistant
Plant Manager
- J. Lyon, Secretary,
Radiation Protection
- D. Morey, Superintendent
Chemistry
- D. Noble, Superintendent
Radiation Protection
- H. Springer,
ALARA Supervisor
- R. West,
Licensing Coordinator
- J.
S. Wieble, Superintendent
guality Assurance
and Control
- J.
Isom, Senior Resident
Inspector
The inspector
also interviewed other licensee
personnel
in various
departments
in 'the course of the inspection.
- Present at the Exit Meeting on April 1,
1994
Licensee Action on Previous
Ins ection Findin
s
Closed
Ins ection
Fol 1owu
Item
IFI
315 92017-01
316 92017-01
Radiological liquid release
from condensed
airborne releases
via the
Unit
1 blowdown startup fl'ash tank which discharged
through the storm
sewer
system to Lake Michigan.
A plant modification .package
was
approved
and the modification has
been
scheduled for June
1994.
This
item is closed.
Closed
315 93010-01
316 93010-01
Exceeding
0.5 millirem per hour dose rate limits of Department of
Transportation
(DOT) requirements
during the shipment of an empty
package.
The vendor receiving the package
decontaminated
the package.
Procedure
Number
12
THP 6010
RPP.800
"Preparation of Radioactive
Shipments"
was revised to require
independent
surveys,
use of an optimal
instrument for the surveys,
and incorporated
a checklist to ensure
the
DOT limits for radiation
and contamination
would not be exceeded.
Training on the revised
procedure
was completed
in 1993.
The corrective
actions= appear
adequate.
This violation is closed.
Closed
315 93010-02
316 93010-02
Failure to ensure
surface
doses .rates limits of 0.5 millirem per hour
were not exceeded
on
an empty shipment to guadrex Recycling Center.
Procedure
Number
12
THP 6010
RPP.800
"Preparation of Radioactive
Shipments"
was revised to require
independent
surveys,
use of an optimal
instrument for the surveys,
and incorporated
a checklist to ensure
the
DOT limits for radiation
and contamination
would not be exceeded.
Training on the revised
procedure
was completed
in 1993.
The corrective
actions
appear
adequate.
This violation is closed.
I
Recent
S ent Resin
S ill Event
On Saturday,
March 19,
1994,
contaminated
spent resin
was spilled in the
587 Drumming room during the transfer of spent resin from the Chemical
and Volume Control
System
(CVCS) mixed bed demineralizer to the Spent
Resin Storage
Tank.
The spill was the result of some spent resin being
inadvertently diverted to and overfilling a High Integrity Container
(HIC) in the
Drumming room.
As the resin dried out on the floor of the
Drumming room, the ventilation in the
room spread
the contaminated
resin
into several
areas of the Auxiliary Building causing
20 personnel
to
receive foot contaminations.
Radiation Protection
(RP) personnel
were
alerted to the problem when the contaminated
personnel
alarmed the
personnel
contamination.,monitors
(PCHs)
upon trying to exit the
Radiologically Controlled Area
(RCA).
RP p'ersonnel
quickly responded
by
securing
access
to the Auxiliary Building, locating the source
and
extent of the contamination,
and decontaminating
the affected personnel
'nd affected
areas of the Auxiliary Building.
Full decontamination
of
the Drumming room was completed
several
days later.
Whole body counts
conducted
on the affected
personnel
on March
21 through March 22,
1994,"
indicated there
may have
been four uptakes of the contamination.
Those
four uptakes
indicated approximately 0.1 per cent of the annual limit
for intake (ALI) with the maximum committed effective dose equivalent
(CEDE) of 3 millirem.
While the radiological significance of the contaminations
appears
minor,
the events that lead to the inadvertent diversion of the spent resin to
the
HIC raised
some concerns.
On Friday,
March 18,
1994, the Radio-
active Waste Handling Supervisor
(RWHS) tried to conduct
a sluicing of a
new liquid radwaste
processing
system using
a procedure
(12
THP 6010
RPP.606
"Operation of the Radioactive
Waste Water Demineralization
System
(RWDS)") recently revised to conduct the evolution.
The valve
lineup in the procedure
proved to be inadequate
to conduct the evolution
and in the process
of troubleshooting
the valve lineup,
two valves were
left open which led to the diversion of the resin
on the following day.
An Auxiliary Operator
(AO) used
Procedure
02
OHP 4021.007.002
"Reactor
Coolant Demineralizer
Resin Sluicing and Replacement" for the resin
transfer
on March 19,
1994.
That procedure failed to direct the
AO to
verify the position of the two valves that were left open from the
previous
day which provided the alternative flow path.
Also during the
resin transfer evolution, the
AO did note flow noises
from a valve that
should
have
been closed
so
he shut that valve.
Both the
RWHS and the
had indications that their procedures
were inadequate
due to no flow on
the first day
and flow through the valve on the next.
However, the
sluicing operation
attempt continued
as did the resin transfer.
Both
procedure
inadequacies
are considered
a violation of 10 Code of Federal
Regulations
(CFR) Part
50 Appendix
B Criterion
V (315-94006-01/316-
94006-01).
Audits and
A
raisals
The guality Assurance
(gA) department
was recently reorganized
to
strengthen
the licensee's
overall self-assessment
capabilities.
The
,3
reorganization
resulted
in a new Superintendent
of guality Assurance
and
Control.
No major effect from the reorganization
was noted
on
an
already strong chemistry
and radiation protection
gA audit team which
consisted of four auditors.
Team members
had health physics or
chemistry experience.
Several
chemistry
and radiation protection surveillances
were completed
during the outage.
One major finding in chemistry identified
a
continuing negative trend in the Chemistry Department
performance.
A
condition report
was written acknowledging that corrective actions to
previous
problems in procedural
compliance
and document control were
ineffective which resulted
in the negative trend.
A new chemistry
manager
was brought in to address
the negative trend.
Issues identified
in radiation protection during an ongoing work in progress
audit
included not meeting the
ALARA goals,
reviewing the personnel
contamination
incidents
(PCIs) to determine the effect of reduced
respirator
use,
and reviewing the effectiveness
of early boration during
the shutdown
and chemistry decontamination
of the regenerative
heat
exchanger
and the resistance
temperature
detector
(RTD) loops for source
term reduction.
The conclusions
from the work in progress
surveillance
report will be reviewed during the next inspection.
No violations or deviations
were identified.
Control of Radioactive Naterials
and Contamination
Surve
s
and
Honitorin
Tours of the plant
and selected
work areas
did not identify any problems
,in the implementation of the licensee's
contamination control program.
Overall, work areas
were well maintained
and the cleanliness
of the
station
was noteworthy.
An exception to the overall high standard of
cleanliness
at the facility was in containment..
Tie wraps
and other
debris left over from completed jobs were noted accumulating in
containment.
The licensee
planned to clean
up any debris left over from
completed
work towards the end of the outage.
While no foreign material
exclusion
problems
were noted,
the accumulation of the debris
increased
the potential for such
problems to arise.
Also, potentially higher
doses
could
be received
from cleaning
up at the end of the outage rather
than having workers clean
up their work site
on
an ongoing basis.
Through March 29,
1994, there were
205 PCIs,
most of which were
identified during the refueling outage.
While that number
was high,
higher numbers
were expected
due to the reduced respirator
use.
Of the
205 PCIs,
60 were attributed to the
new
10 CFR Part 20 evaluated
conditions,
75 due to personnel
error,
and
107 to facial contaminations.
The high number of facial contaminations
is similar to what other
facilities have
been experiencing with r educed respirator
use.
The
licensee
was re-evaluating
the method
used to determine reportable
contaminations.
Using
a threshold value of total effective dose
equivalent
(TEDE) appeared
to be the approach
they were planning to use.
Any PCI not resulting in a dose
exceeding
the threshold
TEDE would still
be evaluated
and recorded to trend the data,
but would it would not be
considered
reportable.
The methodology
and procedures
implementing the
new system will be reviewed in a future inspection.
No violations or deviations
were identified.
I
aintainin
Occu ational
Ex osures
There
have
been
no major changes
in the overall station
ALARA management
program since the previous inspection.
The inspector
reviewed
program performance
and initiatives implemented during the on-going
refueling outage.
Six weeks into the outage
had resulted
in 195 person-
rem verses
an
ALARA goal of 135 person-rem,
approximately
140 per cent
off the goal for the sixth'eek of the outage.
A major contributor to
the high dose
appeared
to be the hydro-lazing work causing all four
to be drained at the
same time and for a longer period
than the
ALARA planners
expected.
Having all four steam generators
drained at the
same time caused
higher than planned
doses for all the
other activities in the general vicinity of the steam generators.
The'LARA
group estimated that the final outage total exposure
would be 210,
person-rem.
That would place the total outage
exposure
approximately
116 percent
over the total goal of 180 person-rem.
Overall station
dose
rates indicate that the license
has low source
terms.
Therefore,
the
planning problems
encountered
during the outage did not cause
the
g'oal to be exceeded
by
a significant margin.
However, the licensee
acknowledged that significant lessons
could
be learned
from the outage
and
be used to better plan the
1994 Unit 2 outage.
Source
term reduction at the facility appears effective as evident
by
the low dose rates
encountered
during the outage.
Efforts included
chemical
cleanup of the reactor coolant
system
performed at shutdown
using acidification of. the coolant
by lithium removal
and boration
followed by addition of hydrogen peroxide
and control of reactor coolant
temperature
to increase
solubilization of crud
and removal
by
demineralizers.
The chemical
cleanup
accounted for the removal of 1279
curies of cobalt-58
and
17 curies of cobalt-60 from the primary system.
A chemical
decontamination
was also performed
on the Regenerative
Heat
Exchanger
and the Resistance
Temperature
Detector
(RTD) loops.
The
decontamination
appeared
very effective for the heat
exchanger
but had
mixed results with the
RTD loops.
The licensee initiated *a more
rigorous dose rate measurement
of the effectiveness
of the
decontamination
by bringing in a vendor to conduct the measurements.
The new data was'eing
analyzed to provide
a baseline for future
decontaminations.
No violations or deviations
were identified.
Trainin
and
uglification of Personnel
Contractor Radiation Protection'Technician
qualifications were reviewed
by the inspector.
The screening
process for the technicians
involved
the contractorsite representative
reviewing resumes
and sending the
licensee
a list of potential
candidates
with their qualifications.
Likely candidates
would have their references
checked.
As an additional
screening tool,
an examination
developed
by another utility would be
administered
by the facility., Test scores
would be tracked
by the
utility who developed
the examination
and technicians
would be required
to retake the
exam every two years.
The contractor,
the licensee,
and
other licensees
were participating in the program.
No violations or deviations
were identified.
8.
Exit Interview
The scope
and findings of the inspection
were reviewed with licensee
representatives
(Section
1) at the conclusion of the inspection
on
April 1,
1994.
The licensee
did not identify any documents
as
proprietary.
The following specific items were discussed
with the
licensee
during the exit meeting:
o
The resin spill and the resulting violation.
The exceeded
ALARA goal
and the lessons
learned.
The overall station cleanliness
compared to the problems
noted in
containment.
The quality of the guality Assurance
surveillances for Radiation
Protection
and Chemistry.