IR 05000155/1975009
| ML20002D775 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/29/1975 |
| From: | Fisher W, Hueter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20002D774 | List: |
| References | |
| 50-155-75-09, NUDOCS 8101220454 | |
| Download: ML20002D775 (11) | |
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O U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCDENT
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REGION III
Report of Operational Radiological Protection Inspection IE Inspection Report No. 050-155-75-09
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. 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 Licensee:
BWR-240 Mwt Type of Inspection: Unannounced-Radiation Protection Dates of Inspection:
June 10-13, 1975 L. [A*h A/
W Hueter 7-b 7f
Principal Inspector:
(Date)
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Accompanying Inspector: None Other Accompanying Personnel: None Reviewed Fy:
W. L. Fisher 7 19-7 I Senior Health Physicist (Date)
Facilities Radiological Protection Section
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SUMMARY OF FINDINGS
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Inspection Summary
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Inspection on June 10-13, (75-09):. Reviewed radiation protection organi-zation, training, procedures, records, audits, reports, instrunentation and equipment, respiratory protection program, safety evaluations, and radioactive material inventory. The radiological safety aspects were re-viewed for two licensee reported abnornal occurrences. A cursory review was made of the continuing problem of canal monitor spurious alarms.
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Enforcement Action Non*e.
Licensee Action on Previously Identified Enforcenent Matters Thelicenseehascocpletedco{yectiveactionrelatedtoacitationnoted during a previous inspection.-
(Paragraph 7.c)
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Unusual Occurrences No problems were noted in reviewing the licensee's radiction safety considerations associated with two abnormal occurrences reported to the Commission.
(Paragraph 7.b)
Other Significant Findings i
A.
Systems and' Components
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None.
B.
Facility Items None.
C.
Managerial Items None.
D.
Noncompliance Identified and Corrected by Licensee None.
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E.
Deviations None.
1/ RO Inspection Rpt No. 050-155/74-05.
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Status of Previously Reported Unresolved Items
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No previously reported unresolved it6ns within the scope of this inspection.
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Management Interview The inspector conducted a nanagement interview at the conclusion of the inspection on June 13, with Messrs. Hartman (Plant Superintendent), DeMoor (Technical Engineer), Axtell' (Chemical and Radiation Protection Supervisor),
and Brun (Assistant Chemical and Radiation Protection Supervisor). The following matters were discussed:
A.
The inspector noted the recent development and expansion in the training program and continued plans for such in the near future.
(Paragraph 4)
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B.
The inspecto, noted the progress and continued plans in updating and expanding procedures which include the area of radiation protection.
The inspector also acknowledged his observance that some minor errors and/or inconsistencies between certain licensee procedures and requirements of 10 CFR Part 20 noted during a previous inspection had been corrected.
(Paragraph 5)
The inspector stated that he had observed the licensee's corrective C.
measures-with regard to a citation made during a previous inspectien /
against 10 CFR20.401(a) for failure to maintain individual occupaticaal exposure on the basis of calendar quarters on Form NRC-5 for several individuals. The inspector stated that we have no. further questions
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at this tine regarding the matter.
(Paragraph 7.c)
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2/ RO Inspection Rpt No. 050-155/74-05.
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REPORT DETAILS
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Persons Contacted
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C. J. Hartman, Plant Superintendent D. E. DeMoor, Technical Engineer C. E. Axtell, Chemical and Radiation Protection Supervisor T. M. Brun, Assistant Chemical and Radiation Protection Supervisor 1.
Organization (Chemical and Radiation Protection)
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There have been no terminations in the chemical and radiation protection group at the plant in the past year. One technician with five years tenure was promoted to a senior technician. The additional technician being sought at the time of the last radiation protection inspection was hired in August 1974. The individual had no previous radiation protection experience but has been trained by the licensee. The licensee also has a graduate from the University of Michigan, who is a su=mer student training as a technician. Charles Axtell is still the plant Chemical
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and Radiation Protection Supervisor and Roger Sinder=an is still the Senior Health Physicist at the corporate level.
2.
Licensee Audits The latest audit of the radiation protection program was conducted October 7-10, 1974, by the corporate Senior Health Physicist. The forcal audit report' covers the following areas:
Process area monitors
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Calculation of offgas rates and holdup Respiratory protection practices Internal dose measurements The report also showed satisfactory resolution of problem areas identified during the previous audit.
The only " audits" of contractors at the plant level involves the sending of " spiked" film badges two or three times yearly to the film badge vendor. The records have shown satisfactory results. Licensee personnel stated that any other audits of services and contractors that may be perfoecd would be at the corporate level. Although no records or details were readily available at the plant, licensee personnel stated that they were aware of an audit type trip made by the General Environe. ental Engineer (at the corporate level) to Interex at Natick, Massachusetts. This audit involved the analysis of cocposite liquid radwaste sanples for strontium, tritium, and alpha activity.for the licensee.
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Licensee personnel, including the Chemical and Radiation Protection Supervisor, attended a training session on audits during this inspection.
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3.
' Initial Discussien with Management During the initial discussion, licensee management stated that to their knowledge there have been no unreported exposures or releases since the last radiation protection inspection. The inspector stated that, in addition to the routine radiation protection inspection, if time was available,-the inspector would review the radiation safety aspects of 1975 abnormal occurrence report nunbers 2, 4 and 6, as well as the noted continuing problem with spurious canal monitor alarms as re-
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ported-in the past two semiannual-operating reports, aAbnormal necurrence report nutbar 4 was not reviewed and only a cursonr review was made of the canal monitor alarm problem.
4.
Training For initial indoctrination, specialized training, and periodic retraining of regular plant personnel, contractor personnel, and visitorsinradiationsafetyaspects,thelicenseeugyspraining
materials referenced in previous inspection reports.-
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The licensee has obtained a new radiation protection training program for radiation protection technicians. The comprehensive 3-week video taped course prepared by NUS Corporation has been augmented by the licensee to emphasize given areas and to relate.
it to the licensee's specific needs. All licensee radiation
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protection personnel are being given the course for retraining-purposes. All but two have completed the course.
The licensee plans to update in the near future the basic radiation protection indoctrination given to plant workers. Also, a new test is being prepared for re-evaluation of Radiation Work Permit (RWP)
exempt empJoyees. Records of individual tests for RWP exemption were observed by the inspector. The licensee now has a check-in sheet for new employees to show thtir status regarding indoctrinations, training, testing, etc.
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3/ RO Isnpection Rpt No. 050-155/73-03.
4/ RO Inspection Rpt No. 050-155/74-05.
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Radiological Protection Procedures
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At the time of a previous inspectionE/, revievof radiation protection procedures revealed several minor errors or inconsistencies between procedures E2.0 and.E3.2.1 and 10 CFR Part 20. During this inspection it was noted that appropriate management-approved changes,_such that-the procedures now conform _ to 10 CFR Part 20 requirecents, had been
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The licensee is preparing new procedure manuals. The new 20-chapter Adninistrative Procedures Manual includes consideration of As Low As Practicable (ALAP) philosophy. Chapter 7 is titled Radiation Protection Adninistration.' Other administrative chapters. cover areas
such as:
Organization.and Respon'sibility
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Review and Audit Personnel Training Surveillance Testing and Inspection Program The licensee is beginning work on preparation of both a general and a departnental radiation protection procedures manua.*; and a chenistry procedures manual to meet criteria defined in the new Administrative Procedures Manual. This will involve updating as well as expansion of implementing type procedures.
6.
Instrumentation' and Equipment Selected radiation protection' survey equipnent used in radiation,
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contamination, and airborne surveys was examined by the inspector and found operable and properly calibrated. No problems were found in_ adequacy of instruments nor in the interpretation of survey results. This included a review of the reflash capability of area monitors thatannunciate in the reactor control room.
7.
Records-Radiation Safety Evaluation a.
In-Plant Air Sampling Program
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Monitoring of airborne activity within the facility is
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accomplished by continuous air monitors (CAM's) utilizing moving particulate filters and by grab sa=ple surveys for airborne particulate and halogen activities. The CAM's are used primarily for trend indicators. Numerous spec'ial and routine grab samples are taken.
Ga==a isotopic analysis is 5/ RO Inspection Rpt No. 050-155/74-05.
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. performed when airborne concentrations'are such that.MPC-hours
f of exposure may be of concern. The licensee maintains a log of-
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MPC-hours of exposure for personnel entering airborne areas.
No-overexposures were.noted in reviewing the logged data for the past year.
b.
Unusual Occurrences (1) The radiation safety aspects of abnormal ~ occurrence report
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A0-2-75 were reviewed..No discrepancies yere found in the-
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-information as reported. About 50 gallons of low 1evel
activity feedwater was inadvertently poured down a " diked"
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turbine building floor. drain which discharges directly'to:
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the discharge canal upstream of ~ the canal monitor. 1Rua
~ release, attributed to failure'of administrative controls,.
involved less than one microcurie of scrivity. lThe proposed'
ccrrective action has been implemented, including locating-and marking floor' drains that discharge directly to the.
canal and reviewing with maintenance supervision the
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responsibility for administrative control. Ten such drains
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verified to discharge directly to the canal have been posted with signs stating " Direct-Drain to Lake, Do Not Dump.
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Contaminated Liquids Here."
- (2) The radiation safety; aspects of AO-6-75 were reviewed. In particular,' the inspector reviewed'the licensee's evaluation and handling of the minor airborne contamination in the is turbine building that occurred during an offgas isolation
. test run at 20 MWE on January 16, 1975. The air activity
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was-believed.to have possibly.resulted from the test, as,
indicated in:the report.1 Review of the licensee's related
. procedures, tests, and evaluation showed that the licensee
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had anticipated possible leakage with resultant turbine
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building air activity. -The procedure required notification
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of radiation. protection personnel prior ~ to beginning the test; ascertaining that the turbine building CAM was in good working order;-and marking the CAM' chart with applicable test information. The test lasted about 45' minutes. The-CAM went' from a background level count rate of about 500 cpm to-about 1700 cpm during the' test and quickly returned to near bakground following the test.
Sample analysis
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I showed the' activity.to be primarily nitrogen.13 having a
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10-minute half-life; hence, radiological considerations
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Surveys and monitors showed no indications'of radiation levels signif-I icantly above background. Based'on the CAM calibration with mock iodine, a restricted area MPC of1 soluble strontium 90 would result'in a CAM count rate of 2000 cpm above the
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background count rate. The inspector found no problems with the licensee's evaluation and handling of the occurrence.
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(3) The inspector made acurccry inquiry into tha centinuing problem of reported spurious canal monitor alarms re-ported in the-two semiannual operating rep 6rts for 1974, t
The instrument and control supervisor who has been the
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primary individual working on this problem was not at the plant during this inspection. It was stated by
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licensee personnel that the spurious alarms occur rather routinely (an estimated 5. daily), even when no radwaste is being released..Special grab sample and composite sample analyses have shown the alarms to be apparently false in -
dications. The licensee believes thatthis problem is complicated by the requirement of making measurements with the alarm set point near the minimum detection limits of the systen and feeding the resultant weak signal through a long cable to the control room. Further, operaticn of certain electrical.
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equipment items have been identified as causing spurious alarms. The licensee is continuing efforts to solve this problem. The matter will be examined in greater depth at a later inspection.
c.
Personal Dosimetry
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The licensee utilizes the services of Radia*. ion Detection Company to provide beta and garna sensitive film badges for personal monitoring. Additionally, direct reading gamma dosimeters are required to be worn along with the badges. Neutron film badges supplied by the same vendor are assigned to selected individuals entering potential neutron exposure areas. Ring badges are also assigned for selected jobs having potential for extremity exposure
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significantly greater than whole body exposure. Exposure data and records were reviewed for the lest half of 1974 and the first-
four months of 1975. No indication of overexposure was found. No discrepancies were found in records or reports.
Forms NRC-4 and NRC-5 or equivalents are maintained. Dosimeter and film badge exposure results showsatisfactory agreement. Neutron films consistently indicate no exposure to neutron radiation..The highest individual exposure in calendar year 1974 was 6,600 millirems. There are still about 60 routinely badged individuals at the plant in addition to contractor typ personnel and visitors.
e At the time of a previous inspection /, the licensee was cited
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against 10 CFR 20.401(a), in that for a few individuals working
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at both Big Rock Point and Palisades and being badged separately at both facilities the occupational exposure was not being main-tained on the basis of calendar quarters on Form NRC-5 as required.
It was observed during this inspection that the licensee has corrected the matter by now using a single badge for a badge period whether assigned to one or both facilities during the period.
Further, it was observed that past Form NRC-5 exposure records were corrected for the individuals involved.
6/ RO Inspection Rpt No. 050-155/74-05.
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Bioassays and In Vivo Counting The licensee continues to contract the perforEance of whole body counts by Helgeson Nuclear Service about semiannually. The licensee is in the process of installing a rental unit.from Helgeson.
Whole body counts were performed for 62 people on June 20 and 21, 1974, during an outage and for 56 people again on December 18 and 19. No significant body depositions were indicated. Trace levels of cobalt 58 and 60 and cesium-134 and 137 were detected in a number of people during both' counts. Trace levels of iodine
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131 were detected in two individuals-in the June count.
Some evidence of low level external body contamination was
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observed during the June count on a few operations men who had been working on'the reactor level and a few maintenance men who had been working in the rod drive access area. The-licensee conducted a detailed study to evaluate the cause.and initiated corrective action. Certain items in the area were found to be contaminated. Decontamination of tools and equiptent was carried out and a procedure was established to wash down.
tools associated with refueling twice per_ shift during refueling operations. Review of CCI charts showed no evidence of significant airborne activity being associated with the co.ntaminated items on the reactor level.
Urine sa=ples are routinely counted for both new and tereinating employees.
It was stated that a urine count would also be taken li if data indicated'an exposure to airborne concentrations in excess of 10 MPC-hours during a seven day period.
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Radiation Surveys and Exposure Control The licensee conducts routine daily, weekly, and monthly radiation, contamination, and airborne radioactivity surveys.
Survey results were observed for February 1975 and in addition all grab.sa ple airborne surveys were reviewed for January 1975. No problems were noted'in co=pletion of surveys, evaluations, or follow-up.
Licensee personnel interviewed stated that to their knowledge no nitrogn 16 exposure evaluation had been made for the site -
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boundary and environs. The reactor is located in'a rather remote
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area'on the shore of Lake Michigan.
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Radiation Work Permits (RFP)
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A review was made of the eleven RWP's in current use as well as several which had been terminated..No proble=s were observed.
Work appeared to be properly preplanned and the RWF's were properly completed and utilized for maintenance and special activities.
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Respiratory Protection'
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- The licensee's respiratory protection program, which consists of.
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training, face piece fitting, testing, cleaning, inspection, repair, and storage, was reviewed.-
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The licensee had Model 60 A2MS Scott Air-Pak self-contained breathing apparatus; regulated'and filtered plant air for use with Acme and MSA full-face masks and polyethylene hoods under the name of-Maxi-Vision
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The licensee currently has a log titled " Personnel Airborne Activity Accumulation Record-7 Day" showing the' individual's name, date of exposure, exposure time, the measured air concentration, and type of'
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protective equipment worn. A review of the log for the past. year showed no evidence of overexposure. The type of exposure devices worn were half or full-face masks with filter cartridges. A revised form I'or this log, which will provide more detailed data, is being prepared.
The licensee is not using protection factors for equipment for which the licensee cannot provide evidence of approval by either Bureau of Mines or National Institute for Occupational Safety and Health. Records show general face fit tests were conducted for employees in October through Decenber 1974 with a few face fit tests finished in January 1975.
9.
. Materials Inventory During this inspection the inspector toured the instrument calibration facility. The storage of the nominal 5-curie plutonium-beryllium neutron source was observed-in the locked and posted facility. A
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number of other calibration sources are possessed and used under a separate byproduct license which was not inspected at this time.
10.
Receipt and Transfer of Materials The licensee has given oral training covering procedures for receiving and opening packages and package inspection for radioactive materials.
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Licensee personnel stated that these procedures would be in written l
form by September of this year. A review of the file on incoming
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shipments showed there have been no receipts since the last radiation protection' inspection conducted in August 1974.
There has been one irradiated fuel shipment in the past year. This j
shipment was on November 26, 1974. The licensee had available the
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written procedure used showing sign offs as well as documentation of approved changes. The licensee had available a copy of the cask authorization and other appropriate records pertaining to the shipnent.
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Shiping Accidents r
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LAccording to. licensee personnel there'have'been no accidents involving shipeents of radioactive material. ' Review ofirecords'of the spent
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fuel shipment referred to in the preceding paragraph and; review of jad-
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vaste and other radioactive' material transfer records during the last radwaste inspection did not reveal anycEscrepancies in this area.
12.
Facilities and Ecuipment-For facility. changes, the Plant L Review Co==ittee ' determines byf a safety evaluation or review whether a core detailed safety _analysisi is required for a change. If it is concluded _that-a safety analysis-
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is needed,- then various aspects of the analysis are assigned to persons having. appropriate expertise. The records:of safety. reviews _-
cf facility changes having radiation protection significcuee revealed no-problems.
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A tour upon arrival' at the plant was made of !the containment' building, turbine building, counting room, change roo=s, radioactive caterial storage area, and the personal and laundry decontamination areas. The operation of transfering spent resins to a cask and liner and. dewatering the resin was observed a ccuple days later. 'ihe plant was found to-
- be very clean, and sigus and posting were _ observed to be current, mo s t'
all_having been updated the day prior to the inspection when~the licensee was going up in power following an extended outage. High radiation areas were observed to be appropriately pested and locked.
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The spent resin tcansfer operation was well =onitored, posted..and prepared for conta=ination control.
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13. Notifications and Reports A licensee representative stated that the licensee has experienced no theft or loss of licensed material, incidents, overexposures, excessive levels, or concentrations which would require reporting under applicable sections of 10 CFR Part 20.
A review of the licensee's personal exposure records and the annual report of such submitted to the Cc=missien indicates that the reporting require =ents of 10 CFR 20.407 have been met.
N.o problems were noted during the review of records of personal exposure reports submitted to botL the.ndividual and the Cc=nission upon termination of employ =ent.
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14.
Posting of Notices to Workers The applicable documents specified in 10 CFR 19.11 were observed to
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be either posted or~ instructions posted as to the location where the documents could-be inspected.
Bulletin boards in the lunch roen and in the hallway leading to access control were observed to have the required posting.
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