IR 05000155/1975001
| ML19345F212 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/12/1975 |
| From: | Allan J, Greger L, Pagliaro J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19345F211 | List: |
| References | |
| 50-155-75-01, 50-155-75-1, NUDOCS 8102100058 | |
| Download: ML19345F212 (15) | |
Text
,
.g
.
-
-
-.
"
.
.
.
D U. S. NUCLEAR REGULATORY COMMISSION
[% J OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report of Environmental Program Inspection
-
Report of Emergency Planning Inspection
~
Report of Independent Measurements Inspection IE Inspection Report No. 050-155/75-01 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
-
Big Rock Point Nuclear Plant License No. DPR-6 Charlevoix, Michigan Category:
C
.
Type of Licensce:
Type of Inspection:
Routine, Announced e
a Dates of~ Inspection: January 28-30, 1975 Dates of Previous Inspection:
December 2-5, 9-13,1974 (Operations)
.
.
Principal Inspector:
A. Pagl
/ /[
'(Date)
Accompanying Inspector:
L. R.
c
,d]
'
(Date)
Other Accompany 4 g Personnel: None Artt'iy*)Y,
$Q
'
-
O'/O ~M Reviewed By-Jamis M. Allan, Chief Rac ological and Environmental Protection Branch (Date)
Sloc2/w 055
.
.
,
s
--
__
,.
-
_
..m_
_. ~
.
.
..
,
.
.
.
.
.
SUMMARY OF FINDINGS
,
Enforcement Action None Licensee Action on Previously identified Matters None Unusual Occurrences None within the scope of this inspection.
Other Significant Findings A.
Current Findings This inspection included examinations of the licensee's environmental monitoring, emergency planning, and independent measurements programs.
No unresolved items were identified during this inspection. A personnel shif t since the preceding environmental monitoring inspection has resulted in R. Sinderman assuming a newly created position of Senior Corporate llealth Physicist W. Strodic assuming Sinderman's former responsibilities as Environmental IIcalth Physicist, and 11. Pettengill
,
replacing E. Murri as Corporate 11calth Physicist.
A The approved Big Rock Point Plant Site Emergency Plan, revised i
January 20, 1975 (Revision 20), and the associated impicmenting
procedures were examined using Appendix E of 10 CFR 50 as a basis for evaluation. The licensee was informed by letter dated November 27,
1974 from the Directorate of Licensing, that the Big Rock Point Plant
-'
Emergency Plan dated March 30, 1972, with revisions dated October 16,
.,
1973, has been reviewed by the Directorate of Licensing and found to i
be acceptabic.
The items identified in a previous inspection report 1/ as requiring additional action in order to meet the requirements of Appendix E were reviewed. The status is given below:
1.
Completion of Letters of Agreement Letters of agreement have been received from all offsite support groups except the Michigan Department of Public llealth (MDPil).
liowever, the MDPil is responsive to the Michigan State Polfce from whom BRP has a letter of agreement. The licensee indicated these letters would be kept current.
1/
RO Inspection Rpt No. 050-155/74-02.
!
-2-i
.
.
t O
i
,r v
m w e
-
w
-
c
- -
.
.
2.
Provision for Specification of Involvement of Offsite Support Groups in Emergency Plan Drills Semiannual Site Emergency Plan drills vere conducted as required in 1974. The drills involve Little Traverse llospital, Charlevoix llospital, Fire Department Ambulance Service of Petoskey and the
.
Fire Department Ambulance Service of Charlevoix.
B.
Status of Previously Reported Unresolved Items No previously reported unresolved items within the scope of this inspection.
Management Interview A management interview was conducted with Messrs. llartman, Axtell, Strodic, and Zabritsky at the conclusion of the inspection on January 30, 1975. The following items were discussed.
1.
The licensee stated that work was in progress revising and expanding the existing environmental program proceduralization including administrative controls.
(Paragraph 3)
2.
The inspectors discussed the scope of this inspection and stated that the laboratory utilized by the licensee for performance of the radiological analysis would not be examined during this inspection.
The licensee
<
indicated that the laboratory had been examined by licensee personnel as part of their audit program.
(Paragraph 4.a)
3.
The inspectors noted that a technical specification change request (Including a revision of the environmental monitoring requirements) had been submitted by the licensee and was currently under review by the NRC Division of Reactor Licensing.
(Paragraph 5.a)
4.
The licensee confirmed that an evaluation of the airborne I-131 analytical methods would be initiated.
(Paragraph 5.b)
5.
The licensee stated that appropriate first aid training and certification would be provided for emergency response personnel.
(Paragraph 14.c)
6.
The inspectors noted that the critiques of the 1974 drills had been reviewed. The licensee stated that appropriate changes to procedures were being made to improve'the emergency plan effectiveness.
(Paragraph 8)
7.
The inspectors noted that monthly emergency kit inspections had been performed as prescribed with the exception of the fourth quarter of 1974.
The, licensee stated that appropriate action had been taken to assure such emergency kit inspection would be performed as required.
(Paragraph 11)
.
-3-i t'
o
-
.
..
.
.
. 8.
The licensee stated that the ventilation patterns in the access control area, decontamination area, and laundry room would be evaluated for-contamination control.
(Paragraph 12)
9.
The inspectors discussed the two instances of disagreement between the licensee's analyses.and those of the NRC Reference Laboratory on samples
_
,
.
The licensee agreed that further sampics pertinent to this inspection.
should be analyzed in order to better ascertain the reasons fer the disagreement.
(Paragraph 18)
-
W e
t-4-
?
,
t
-. -
.
.
.
.
...
.
.
--
-
_-
-..
- _,
-.
-.
.
__..
.
,
$
.
REPORT DETAILS
,
1.
Persons Contacted C. Hartman, Plant Superintendent (BRP)
-
C. Axtell,. Chemical and Radiation Protection Engineer (BRP)
W. Strodle, Environmental Health Physicist (CP)
T. Brun, Assistant Supervisor, Chemistry and Radiation Protection (BRP)
C. Smith, R,N., Emergency Room Supervisor, Little Traverse liospital Dr. Mengebier, Pathologist, Little Traverse Hospital R. Zink, Sheriff, Emmet County K. Boss, Director of Nursing, Charlevoix Hospital D. Leik, Lieutenant, State Police at Petoskey P. Sumner, Sheriff, Charlevoix County R. Dean, Training Coordinator (BRP)
2.
General The inspection included an examination of the licensce's environmental monitoring, emergency planning, and independent measurements programs.
Included in the environmental monitoring portion of the inspection was an examination of the radiological environmental activitics including
sampling techniques and procedures, co11cetion equipment and locations, and monitoring results; management control aspects including organizational structure, responsibilities and authorities, and administrative controls
'
were also examined. Although the licenceo conducts certain non-radiologien1 environmental monitoring activities, th,e technical specifications do not contain non-radiological requirements; such specifications will be issued in the future. The non-radfological portion of the licensce's environmental monitoring program will be examined in detail subsequent to issuance of the non-radiological environmental technical specifications. All
'
aspects of the licensee's environmental monitoring program inspected were found to conform to NRC Regulatory Requirements.
Included in the emergency plan inspection was an examination of the Big Rock Point Emergency Plan and availabic implementing procedures.
In addition to discussing the emergency plan, (revised January 20, 1975), and its implementation with licensee representatives, selected onsite facilitics were visited, documentatioa pertaining to various aspects of the emergency preparedness program was reviewed and selected emergency equipment and materials were inspected. The following offsite support agencies were visited by the inspectors:
Little Travarse Hospital, Charlevoix Hospital, Emmet County Sheriff, Charlevoix County Sheriff and the State Police at Pctoskey, Michigan.
'
The inspection included a test of the licensee's measurements of radioactivity in actual sampics of his effluents. The test consists of comparing the licensec's measurements with those of the NRC
,
-5-
l l
T l
[
-
-
. - -
-
-
.
l
i reference laboratory. The measurements made by the NRC laboratory are referenced to the. National Bureau of Standards radioactivity measurements system by laboratory intercomparisons.
Environmental Monitoring 3.*
Procedural Controls The licensee's administrative and procedural controls for implementation of the radiological environmental monitoring program were examined.
This examination included a review of the assignment of responsibilities and authorities for program management.
The licensce's organization for implementation of the environmental monitoringprogramhasungprgoneminorchangessincetheprevious environmental inspection.-
A corporate organizational change resulted in the creation of a Senior Corporate Health Physicist pusition under the Manager of Technical Services within the Bulk Power Operations Department. The Corporate Health Physicist and the Environmental Health Physicist report to the Senior Corporate Health Physicist.
R. Sinderman has assumed the position of Senior Corporate Health Physicist, W. Strodle has assumed Sinderman's former responsibilitics as Environmental Health Physicist, and H. Pettengill replaced E. Murri as Corporate Health Physicist. The division of responsibilities between corporate and plant personr.21 remains unchanged. The licensee continues to utilize the services of Interex Corporation, Natick, Massachusetts (moved from Waltham, Massachusetts) to perform the radiological environmental
,
laboratory analyses except for the film badge service which is provided by Radiation Detection Corporation, Sunnydale, California.
The plant trend plots were observed to be current; a corporate representative indicated that the corporate trend plots continued to be maintained. The corporaterepresentativefurtgprindicatedthatthefollowingitemsdiscussed during a previous inspection,- although not finalized, were in various stages of implementation; sample co11cetion procedurcs, program administrati'
procedurcs, internal audit programs, and contract laboratory coordination including the establishment of reporting action Icvels.
These items will be examined further during a subsequent inspection.
4.
Analytical Capabilities The licensce's methodology and control of the sample collection, preparation, and analysis functions were examined. This examination included a review of sample co11cetions, instrument calibrations, and physical plant facilities.
t a.
Analytical Laboratory All environmental analyses continue to be performed by the contract laboratory. A licensee representative visited the contract laboratory 2/
R0 Inspection Rpt No. 050-155/74-02.
3/
lbid.
-6-
-
i
.
,-
-
, -,
-. ---
- -,
--
.
ri
'
- .
_.
in December'~1974 and examined'the laboratory's analytical
-#
~-
'
techniquec;and procedures, quality control program, and general-administrative methods. The only item identified by the licensee as requiring further attention was the method of assuring that action
' levels for specific analyses were observed.
'
'
.
b.
Air Sampler Operation The only major equipment possessed by the licensee for use-in conjunction with the environmental monitoring program are the air samplers.
The licensee replaced all samplers during 1974 due to equipment age and increasing maintenance prob 1 cms.
. (Gast pumps are presently utilized. ) The dry gas meters were calibrated in accordance with an annual schedule during 1974.
Additionally, all vacuum gauges were replaced and calibrated during 1974. The licensee indicated that at least one complete spare sampler would be maintained for replacement of malfunctioning equipment and that a corrective maintenance philosophy-would_be followed.
5.
Implementation of Monitoring Program The results of the licensee's radiological environmental monitoring progran for the period from July 1973 through June 1974 were selectively examined for compliance with monitoring and reporting requirements and for corrective actions for identified deficiencies.
Except as noted belca, no unusual results or trends were identified in this review.
<-
a.
Environmental Monitoring Requirements The licensee's technical specification requirements with respect to environmental monitoring have not changed during 1974. Although environmental film monitoring remains the sole environmental requirement, the licensee has continued to-perform additional radiological monitoring of the following parameters: milk, Charlevoix municipal water, inlet and outlet condenser circulating water, onsite well water, aquatic biota, and airborne particulate and radioiodine. A lake bottom gamma survey was conducted in 1974 to determine if any changes have occurred since the 1971 survey.
The results of the lake bottom survey were not available during this inspection; these results will be examined during a subsequent inspection.
The licensee has submitted a proposed revision to the Technical Specifications to include among other items, a more detailed specification of the environmental monitoring requirements, b.
Airborne I-131 Monitoring
- Review of the contract laboratory's analytical results for the
..
period under examination revealed reported airborne I-131 concentrations up to 0.1 picocurie per cubic meter.
Airborne-7-T-
'
-
_,
.
.. - -
.-
I-131 concentrations of this magnitude are not predicted by-stack release monitoring nor are they supported by the milk a
.
sampling conducted in areas surrounding the plant..The licensee indicated that~the contract laboratory's airborneiradioiodine analytical procedures would be examined in an attempt.to resolve this issue.
This item will be examined further during a subsequent inspection.
c.
Non-Radiological Monitoring Although not required by regulatory requirements, the licensee commenced an aquatic entrainment study during 1974.
The biota involved in the study include fish, fish eggs, larvae and zooplankton. The study is expected to be completed during 1975. The results of this and'a previous fish entrapment study will be examined during a subsequent inspection. The licensee further performs non-radiological effluent monitoring to comply with an NPDES discharge permit issued by the State of. Michigan. The parameters monitored include:
condenser circulating water flow and temperatures, total suspended solides, biological oxygen demand, phosphates, fecal coliform, and chlorine.
.
Emergency Planning 6.
Authority and Responsibility
'
The authority and responsibility aspects of the emergency organization were examined. Changes to emergency plan implementation instruction cards-9 and 14 were reviewed. Assignments of responsibility for theimplementationofthesecardshavebeenspeciped. The action is responsive to item 9 in the report referenced.
7.
Coordination The inspectors visited the following of f-site support agencies to assess the existing coordination between the licensee and the agency: Charlevoix Hospital, Little Traverse Hospital, Charlevoix County Sheriff's Office, the Emmet County Sheriff's Office, and the State Police Headquarters at Petoskey. The degree of coordination between the licensee and the support agencies appears to be adequate, a.
Letters of agreement have been received from all offsite support agencies except the Michigan Department of Public Health (MDpil). The MDPil would be called by the Michigan State Police for assistance. The licensee has a letter of agreement
, from the Michigan State Police.
.
4/
RO Inspection Rpt No. 050-155/74-02.
,
-8-
,
-
.
.
.
'
b.
The emergency supplies for decontamination which are maintafued-and availabic at both Little Traverse Hospital and Charlevoix Hospital, the. primary and backup hospitals, respectively, were examined. The supplies were in good order. The inspectors discussed with the licensee representative the necessity of providing contamination control for airborne and waterborne
-
' radioactive contaminated waste.
The licensee stated that the
^
matter had been brought to the attention of the Jackson, Michigan office and that such decisions were made by that office.
It was further noted that the. Jackson, Michigan office had decided not to provide for airborne and waterborne contamination control collection devites in the hospitals.
The.inspec; ors indicated that they would follow up on this matter with the Jackson, Michigan office.
This matter will Jbe examined in a subsequent inspection.
,.
. The inspectors -reviewed licensee documentation regarding the c.
training of offsite support groups in 1974.
Offsite support
_
groups have been visited and provided training agjper the licensee's statement during the 1973 inspection.-
d.
Discussions with the Michigan Department of Public Health on July 1, 1974, indicates that there has been good communication and coordination between the licensee and the State of Michigan.
8.
Accident Analysis and Emergency Action a
The provisions for identification of emergencies, collection and i
evaluation of emergency information and selection of appropriate actions were examined. Discussions were held on the following -
topics:
(
a.
The licensee has standardized the various types of emergency
'
!~
alarms. The licensee stated that this standardization has I
solved the problem of distinguishing between the different types of emergency alarms.
b.
Provisions for preplanned decisional aids such as nomographs
<
or-isopleths for estimating offsite doses from an accidental
'
release of radioactivity to be used in the evaluation of offsite protective measures are presently under study at the Jackson, Michigan office. This item remains open.
c.
Action levels specified for implementing offsite protective measures do not conform with existing EPA interim guidelines.
The licensee representative stated that the matter of incorporating the EPA interim guidelines into the Site Emergency Plan is presently under study in the Jackson, Michigan office. This matter remains open.
5/
RO Inspection Rpt No. 050-155/74-02.
.
_9-j
.
,
e
.
.
.
.
.
..
9.
Communications s-Provisions for onsite'and offsite communications'were examined.
The items die ussed in the January 29-February 1, 1974 inspection /
'
as requiring additional action were examined. The licensee has taken adequate action on determining the range, specific uses, and
,
effectivenese of his' communications equipment.
'
10.
Site Evacuation
,
The site evacuation provisions appear'to meet the needs of the Big
~
-
Rock Point Plant operating staff.
11.. Emergency _ Equipment-The provisions for placement, use, and maintenance of emergency
.cquipment were examined. With the exception of the fourth quarter
-
-of 1974, the emergency kits have been checked on a monthly schedule.
The licensee representative took action to assure that the monthly schedule is maintained.
,
12.- Facility Ventilation Patterns The ventilation patterns in the access cont rol area,; decontamination area, and laundry room were examined. The licensee representative
,
stated that due to failure of testing materials, the evaluation of the ventilation patterns had not been completed but that the evaluation would be conducted when new testing materials arrived onsite. This item remains open.
,
13.
Ilealth physics
,
Discussions were held with the licensee representative regarding
'
provisions for exposure control guidelines. The licensee stated that the provision for exposure control guidelines is presently being worked on and that they are considering referencing the NCRp
,
Report No. 39 " Basic Radiation Protection Criteria" as guidelines.
'
This item remains open.
.14.
Training t
Emergency Plan practice drills have been conducted and training a.
has been provided to the offsite support agencies as per.the licensee's emergency plan and commitments.
b.
Consideration has been given to providing scenarios as a basis for emergency plan drills, as a training tool, by the Jackson, Michigan office.
The licensee representative stated that the
l scenarios are presently under development. This item remains open.
6/
RO Inspection Rpt No. 050-155/74-02.
- 10 -
l
!
?
,
.
, - - -
n s
,--,.
,m-
-
,m-
.
.
.
First aid training and certification'was discussed with the c.
licensee. The licensee-representative stated at the management l interview -that arrangements were being made to provide updating
.
of first aid training to emergency response' personnel prior to June,of-1975. The inspectors discussed the necessity of-providing documentation to support completion of'the first aid training.
15. Administrative' Control
.,
The administrative control' aspects of the the Site Emergency Plan were examined during this inspection. The documentation reviewed was complete and orderly and revealed that an effective audit of the emergency preparedness program is being conducted on a timely basis.
~16.
Documentation Review The documentation examined during this inspection relative to emergency preparedness was complete and in good order. A listing of the files examined is provided below:
a.
Instruction Cards b.
11ealth Physicist's quarterly review of emergency plan a
c.
Training files d.
Audit files c.
Letters of Agreement f.
Emergency Plan drill critiques l
g.
Calibration log Independent Measurements
-
17.
Analytical Results The licensee is required to raeasure the quantities and concentrations of radioactive material in effluents from his facility to assure that they are within the l'imits specified in his license and AEC regulations. During this inspection a comparisen was made of the licensee's measurements and those of the NRC reference laboratory on actual sampics of the licensee's radiological effluents. The two laboratories made measurements on the same samples, or on duplicates or splits'of the same sampics. The licensee's analytical
.
.
- 11 -
I
..
-
-
.
,
o-
.
+
.
,,
'4 results for effluent samples pertinent to this inspection, when
~
compared to the results of the NRC reference. laboratory, yielded 75% agreements or possible agreements and 25% disagreements.
(See f Attachn.ent 1 for acceptance criteria). The types of samples tested and the results of the measurements were:
a.
. Liquid Waste Sample (10/74) (Results in Units of uCi/ml)
ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurement
'
Gross beta 1.32 1 0.07 E-02 2.6 i 0.1 E-02 Sr-89 1.09 1 0.04 E-03 1.20 E-03-Sr-90 2.6 1 0.2 E-05 3.96 1 0.07 E-05 Co-60.
5.8 1 0.2 E-04 7.0 1 0.3 E-04 Mn-54 1.71 1 0.09.E-04 2.12 1 0.04 E-04 NOT ACCEPTABLE
.Radionuclide NRC Reference Measurement Licensee's Measurement Cs-137 8.4 1 0.2 E-03 3.39 1 0.05 E-03 b.
Off Gas Sample (10/74) (Results in units of uCi/ml)
<
NOT ACCEPTABLE
,
Radionuclide NRC Reference Measurement Licensee's Measurement Xe-133 2.4 1 0.1 E-02 8.6 11.2 E-03 c.
Charcoal Adsorber Sampler (10/74) (Results in units of uC1)
ACCEPTABLE Radionuclide NRC Reference Measurement Licensce's Measurement 1-131 2.1 1 0.1 E-03 2.92 E-03
'
18.
Samples Not Meeting Acceptance Criteria The majority of the licensee's measurements on the effluent samples
'
pertinent to this i spection were within the limits of acceptability when compared with the NRC reference laboratory's results, llowever, two 2'
of the licensee's measurements did not fall within the limits of acceptability.
(The two measurements -will be re-examined during a followup inspection.)
'
- 12'-
l
'
i
.