ML20010F272
| ML20010F272 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/30/1981 |
| From: | Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20010F268 | List: |
| References | |
| AEP:NRC:0579, AEP:NRC:579, NUDOCS 8109090551 | |
| Download: ML20010F272 (11) | |
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INDIANA & MICHIGAN ELECTRIC CONFANY P. o. box 18 BOWLING GREEN ST ATioN N EW YORK, N. Y.10004 July 30, 1981 AEP:NRC:0579 Donald C. Cook Nuclear Plant Unit Nos. I and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE Inspection Reports No. 50-315/80-23 and No. 50-316/80-19 l
Mr. James G. Keppler, Regional Director U.S. Navy Regulatory Commission Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
This letter responds to your letter of May 26, 1981, which transmitted IE Inspection Report Nos. 50-315/80-23 and 50-316/80-19.
Mr. Greger of your staff granted to us a fcur-week extension l
to respond to this report.
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' to this letter is our response to the "Significant Appraisal Findings". Attachment 2 is our response to the " Notice of Violation".
l Very truly yours, l
Ja
.S. Hunter Vice President Attachments cc: John E. Dolan - Columbus G. Charnoff R. C. Callen R. W. Jurgensen D. V. Shaller - Bridgman Joe Williams, Jr.
NRC Resident Inspector - Bridgman 010909561 3
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je (STATEOFNEWYORK )
(C0UNTY OF NEW YORK )
l R. S. Hunter, being duly sworn, deposes and says that he is the Vice President of Licensee Indiana & Michigan Electric Company, that he has read the foregoing response to IE Inspection Reports No. 50-315/80-23 l
and No. 50-316/80-19 entitled " Health Physics Appraisal" and knows the contents thereof; and that said contents are true to the best of-his l-knowledge and belief.
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llu -r) t Subscribed and sworn to before me this So# day of 6u 4 1921.
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l M-OH
' (Notary Public)
KAT11LIIIsN DA 1RY NOTAAV FU5i:C, f, tate cf New bak No. 414606792 Culiisd.a Gueens County Cert.fic.:e ided in New York County Ecs.un.u.vt. u a,a taarch SJ, h!#J v
' ATTACHMENT 1-to AEP:NRC:0579 This attachment refers to Appendix A of Region III I&E Report No. 50-315/80-23 'and No. 50-316/80-19 in which the NRC indicated that several significant weaknesses exist in our health physics program.
Following the NRC statement of the appraisal finding is our reponse which includes:
steps which have been taken steps which will be taken, if still needed schedule for completion of action where so indicated 1.
Organization and Management "Short staffing in the Radiation Protection (RP) Section and poor communications are pervasive weaknesses limiting the effectiveness of the Donald C. Cook health physics program.
Other related weaknesses involved in-plant supervisory presence, oversight of the contract health physics group, and corporate office responsiveness to plant health physics program needs.
(Section 2, 3.1, 3.4, 3.5, 7.4, and 11.2)
Short Staffing in the Radiation Protection Section t
Six new Junior Technicians have been hired within the past two months. All six hold A. ociate Degrees in Nuclear fewer or Reactor Plant Health Physics programs and are scheduled to start in June and July, 1981.
Individuals are also being sought through numerous place-ment agencies to further increase the number of technicians.
In an effort to ensure a future supply of trained technicians, a pilot program has been initiated with Terra Technical College of Fremont, Ohio.
Ten local high school graduates have been selected from recruited applicants to enter this program which will culminate in an Associate Degree in Nuclear Power.- Indiana & Michigan Electric Company (IMECo.)
is providing part of the tuition and fees for each of the two years, as well as providing cooperative student experience in the Radiation Protection Section for the two summers preceding each fall semester.
This program started on June 15, 1981.
IMECo. is also actively seeking to add two more degreed Health Physicists to the plant staff to increase the capabilities of the pro-fessional staff.
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In-Plant Supervisory Presence Augmenting the professional Health Physics Staff as described above should decrease the current work load of the Radiation' Protection Supervisors (foremen). This will allow more time for the Supervisors to be involved in the support and supervision of both plant Radiation
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Protection Technicians and contractor Health Physics personnel.
Poor Comunications in the Radiation Protection Section
.The additions to the plant staff and the changes indicated in our response concerning technical training, as described above, should
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improve communications within the Radiation Protection Section.
In-formation exchange during routine training classes will facilitate not only the transfer of technical information but also information of an
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administrative nature. Recent changes in the time of the daily meeting j
between the Radiation Protection Supervisorsand the Plant Radiation Protection Supervisor have been adjusted to #acilitate job assignments and briefings.
Recent changes in work scheules and meetings with representatives of the technician group have helped alleviate some of the comunication barriers that previously existed.
i Corporate Office Responsiveness
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The AEPSC Nuclear Engineering Division was reorganized effective June 1, 1981, to provide closer corporate involvement in plant operation.
4 The new position of Assistant Division Manager - Nuclear Operations was created and filled.
Reporting to the individual are the heads of two sections, the Nuclear Operations Section and the Rad N1ogical Support Section.-
The Nuclear Engineering Division is actively involved in recruiting an individual to be added to the staff with nuclear power p! =t (or other appropriate) experience to improve the capability to review and support the station's Radiation Protection Program.
Oversight of Contract Health Physics Group Closer supervision of the contract Health Physics Group will be provided upon augmentation of the plant's Health Physics Staff as indicated above.
2.
Technician Training
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" Training and development of radiation protection technicians and foremen 1
is inadequate.
It is limited by the small R? staff and lacks basic resources such as experienced instructors."
(Section 2.2 and 3) 4 m
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. Training and Development Program 1
To structure, coordinate and administer a technician training program, a new position of Chemical / Radiation Protection Technician l
Training Supervisor will be developed.
This supervisor will be involved in training RP technicians and will be aided by the addi-tional professional staff.
l' Two of the three Radiation Protection Supervisors have been sent to formal technical training cotrses in Radiation Protection at off-site locations. These have been one and two week courses of intensive' theoretical and practical considerations of Health Physics. The third supervisor was scheduled for attendance this spring, but this was post-poned due 'to personal conflicts and will be rescheduled. The Radiation Protection Department Performance Engineer (s) with a background in 4
Health Physics would also be called upon to help provide continuing education to these supervisors under the direction of the Plant Radiation Protection Supervisor and coordinated by the Trair.ing Supervisor, i
3.
Exposure Control "Significant weaknesses observed related to exposure control are weak documentation of contractor exposures, exposure investigations, and personal contamination occurrences; inadequately defined criteria for i
whole body counting decisions; and indifferently enforced facial hair j
standards."
(Section 4.2, 4.3, and 9.4) j Contractor and Visitor Exposure Record 2 A new system for recording and filing exposure records for non-plant persocnel was instituted on March 9,1981. The personal identification information and records of external and radiation doscs and whole body scan results are now recorded on a single 8" x 10" cardstock form.
This,.
i along with all other file records for that individual, is stored in a j
single file very similar to the file naintained for plant personnel, which was found to be an acceptable method of maintaining exposure i-i records.
(Section4.2) i Exposure Investigation and Documentation i
j A new procedure will be instituted by January 1,1982, which will identify the methods of investigation and documentation of exposure incidents including lost TLD badges, lost dosimetry, and off-scale dosimeters.
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' Internal Dosimetry Program On March M,1981, a revision was issued to 12 THP 6010. RAD.409,
" Assessment of Whole Body Count Results", which refined the methods of assessing doses from internal exposures, formalized the documentation of investigations into potentially significant airborne exposures (including guidance on when investigation is to be initiated) and also specified requirements for recounting individuals on a routine basis.
j Not all personal contamination incidents involve potential internal deposition of radioactive material.
In the past, only those individuals involved in personal contamination incidents were given whole body counts.
However, a new procedure will be instituted and approved by January 1, 1982, which will fonnalize the docune n.ing of personal contamination incidents and establish guidelines for required followup action, such as whole body counting.
Facial Hair Standards A letter for internal di".ribution has been written outlining the policy of the plant regarding che state of facial hair on persons using respirators indicating that:
- 1) persons using tight-fitting respirators shall not have any facial hair that interferes with the sealing surface of the respirator; 2) any worker who has facial hair that intrudes into the area where the respirator seals against the face shall not be fitted with a respirator; and 3) any worker who is not clean shaven shall not be allowed to wear a respirator, even though he has previously obtained a satisfactory fit with a particular device.
The procedures for the use of face-piece type masks have' been I
changed to re-emphasize the above policy and to prohibit the issuance of a face-piece type respirator to any individual who does not meet the above criteria.
4.
Access and Contamination Control
" Lack of frisker availability within the plant, poor personal contamina-l tion surveillance at access control, uncertain key inventory, and awkward radiation work permit (RWP) controls combined to produce significant control weaknesses."
(Sections 5 and 7.6)
Frisker Availability At present there are friskers located in twelve pecified locations within the Controlled Area. Additional locations will be identified closer to contaminated areas with frequent entries.
All friskers in service are now checked on a daily basis with a radioactive source to assure satisfactory operation.
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The importance of using friskers to monitor for contamination is presently stressed in the training of all personnel receiving radiation training.
To supplement this, the topic will be included in future updates for all plant personnel and"others receiving the semiannual Radiation Protection update training.
Contamination Surveillance at Access Control a
The major portion of the traffic through the Access Control Facility is by individuals,who have not entered contaminated areas in their work in the Auxiliary Building.
Closer contamination sur-veillance by those who do enter contaminated areas will be improved through training, changes to plant procedures, and increasing the availability of friskers near contamination area exits.
Contamination surveillance will be increased at Access Control by (1) the installation of a prototype hand / foot frisker to aid in frisking individuals exiting from the Access Control. Facility, and (2) by maximizing the sensitivity of the existing portal monitors by changes in the methods of calibration and operation.
Key Inventory
. Although not proceduralized, in actual practice the use of High Radiation Area keys by individuals is well controlled by signing in and out for those keys not specifically assigned to a single individual.
However, a Plant Manager's rocedure will be written and approved by o
January 1,1982, which formalizes and documents that control.
RWP Controls On April 1,1981, a new tour RWP was initiated for use by personnel in the Operations Department.
The RWP permits entry to a list of specific rooms and locations, and is written to permit Operations Department personnel assigned to tour duty to enter for inspection and tour of any (or all) of the rooms routinely entered on a tour 'on that single RWP.
During the past two refueling outages (and in use during the current refueling outage), a new system of handling RWP's has been employed to decrease the number of-RWP's posted but not actively being used. -The system involves posting the permit for only those activities scheduled to be performed or those specifically requested by personnel doing the work.
By January 1,1982, a change will be made in the use of the RWP system such that no RWP's requiring notification of Radiation Protection prior to entry or start of work will be posted until work is actually to begin.
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.Instruwentation "Significant weaknesses identified in in'strumentation were unsuitable i
monitor locations, inadequate portable instrument check sources, absence of quality control of counter calibration standards, and un-satisfactory performance of contamination control monitors."
(Section7)
Sources for Field Checking of Survey Meters In addition to check sources in the Radiation Protection Counting Room there are two check sources mounted in the Auxiliary Building.
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One is located adjacent to the storage facility for the Operations Departmentsurvey. meters on the 609' level close to t'ie Acc.ess Control Facility, the other located at the Maintenance Hot Tc91 Crib where the attendent checks each survey meter before it is issued.
2 Additional sources have been ordered and will be installed on each
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level of the Auxiliary Building and near the Containment entrances.
1 Quality Control of' Calibration' Sources i
The report indicates that with "the daily use of these standards" there can be no guarantee that they are not deteriorating.
The calibration standards used to calibrate the automatic planchette counters (APC's) will be reconfirmed within 60 days.
However, it should
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be noted that the standards used to calibrate the analytical instruments j
are used only for calibration.
Separate sources are used for daily checks j
of efficiency by comparing the counts generated by these daily check sources to the counts generated by that source at the time of a full calibration. Thus, the calibration sources (each stored in separate containers in separate locations from the check sources and having a i
different physical appearance) are handled only during the actual cali-(
l bration of the instruments.
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Operation, Calibration, and Sensitivity of Contamination Control Monitors Contrary to the statement made in the report, there are not six, but twenty-seven friskers available in the plant.
Of these, sixteen are placed in specific locations in the plant for personnel and equipment i
monitoring in routine or emergency situations. Alarm points are not set I
with a pulse generator. A pulse generator is used to calibrate the scaler j
to assure that meter response is accurate and that the alarm setting indication is accurate.
As part of the determination of additional locations for friskers, consideration will-be given o shielding frisking stations where
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background levels are too high. A study is currently underway to determine ways to increase portal monitor sensitivity by changing the calibration method to establish setpoints in response to a known radioactive source (rather than count rate).
Both the portal monitors and friskers have been placed on daily checks including operability and alarm function.
Area and Effluent Monitors As part of the Radiation Monitoring System (RMS) upgrade for the D. C. Cook Plant, a digital Radiation Monitoring System will be in-stalled which includes high-range in-containment monitors, extended range noble gas monitors, normal range particulate and Iodine - 131 measurement channels, area monitors and duct monitors.
l The RMS upgrade consists of two phases.
Phase I consists of equipment required to meet our commitments in response to NUREG-0737.
Work for Phase I is scheduled for implementation by January 1,1982, as required by NUREG-0737.
4 Phase II will consist of the additional equipment required for the_ general upgrade of the RMS.
This phase consists of the addition of equipment to improve and automate the plant's RMS and includes airborne nonitors, duct monitors, liquid monitors and additional area moni tors.
Phase II of the RMS upgrade is tentatively scheduled for completion by December 31, 1983.
Regarding the present liquid waste discharge monitor (R-18), under Phase 'II a new and upgraded liquid waste disposal monitor, will be installed.
Purchase and delivery of a new monitor is being u.<pedited with the vendor.
It is expected that installation of the new monitor will commence upon delivery of new equipment.
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ATTACHMENT.2 to AEP:NRC:0579 This attachment refers to the Notice of Violation attached to I&E Report No. 50-315/80-23 and No. 50-316/80-19 in which the NRC indicated that certain of our activities appeared to be in noncompliance with NRC requirements. One item was identified as a Violation.
Our response includes:
(1) corrective action taken and the results achieved (2) corrective action taken to avoid further noncompliance, and (3) the date when full compliance will be achieved
Response
Most areas of the Auxiliary Building are clear areas without con-tamination hazards due to the strict contamination control measures taken within the building.
Consequently, many of the individuals have not been in contaminated areas. However, to minimize the remote possibility that small amounts of contamination may be inadvertantly carried past the Access Control Facility, the requirement for all personnel to frisk them-selves prior to passing through Access Control is being enforced.
The additional following steps will also be taken to improve our operation with regard to the use of friskers in checking for contamination:
a.
Hand / Foot friskers have been developed to aid in frisking individuals exiting from the Access Control Facility. A prototype model has been built at the plant and is installed.
b.
A requirement that all personnel exiting any area posted as a " Contamination Area" are to frisk themselves at the nearest frisker station will be added to the appropriate procedures.
Reminders of this requirement will be posted at the exit to the " Contamination Areas" and the topic will be included in-regularly scheduled Radiation Protection classes (semi-annually) for all plant personnel.
Non-plant personnel attend the training lectures which already emphasize the need for such frisking.
To facilitate these requirements, new frisker stations will be established at various points in the Auxiliary Building at or near exits to " Contamination Areas" where significant traffic may occur.
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The sensitivity of the present portal monitors will be maximized by changes in the methods of calibration and operation.
We have placed an order for additional friskers.
New permanent frisker locations will be in operation within 45 days contingent upon the receipt of the additional friskers.except where additional shield-ing will be required.
Changes in the procedures governing frisker use will be completed prior to placing these friskers in service. The in-stallation requiring shielding will take an additional 45 days.
The changes to portal monitor calibration and use will be completed within 60 days.
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