IR 05000155/1976006
| ML20002D868 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/30/1976 |
| From: | Januska A, Pagliaro J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20002D864 | List: |
| References | |
| 50-155-76-06, 50-155-76-6, NUDOCS 8101230232 | |
| Download: ML20002D868 (14) | |
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-UNITED STATES NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT t
REGION III
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Report of Emergency Planning, Environmental Protection, Analytical Peasurement and Confirmatory Measurements
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IE Inspe' tion Report No. 050-155/76-06 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
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Big Rock Point Nuclear Plant License No. DPR-6 Charlevoix, Michigan Category:
C Type of Licensee:
GE 240 Mut-Type of Inspection:
Routine, Announced J
Dates of Inspection:
February 23 - 27, 1976
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.R 30/7(.
Principal Inspector:
A. G.
anuska (Date)
s Accompanying Inspectors: None Other Accompanying Personnel: 'None sk?. l
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Reviewed By:
Jesse A. Pagliaro, Chief 80 fd
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Environmental and Special (Date)
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Projects Section
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SUMMARY OF FINDINGS (-
Inspection Summary
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Emergency Planning, Environmental Protection and Analytical Measurement-Confirmatory Measurement Inspection on February 23 through 27 (76-06):
Examination of (1) Big Rock Point Site Emergency Plan and' Implementing Procedures, (2) Plant Environ-mental Monitoring Program and Implementation, (3) Plant Analytical Measurements-Program and Implementation and (4) a test of the licensce's measurements of radioactivity in actual samples of his effluents; visits or contacts with plant, corporate and of fsite support agencies; review of documantation.
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Enforcement Items None.
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' Licensee Action on Previously Identified Enforcement Items No previc tsly identified enforcement items within the scope of this insp.etion.
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i Other Significant Items A.
Systems and Components None.
B.
Facility Items (Plans and Procedures)
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None.
C.
Managerial Items None.
D.
Noncompliance Identified aa.'. Corrected by Licensee None.
E.
Deviations
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.Sectuafef Provi:ualy R:p3rtad Unracolvsd Itc=5 None.
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s Management Interview
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The f611owing items were discussed on February 27, 1976, with'Mr.
-Hartman, a member of his staff and members of corporate staff.
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A.
The scope of this inspection.
(Paragraph 2, Report Details).
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B.
Environmental matters discussed during a previous inspect
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(Paragraph 3.a, Report Details)
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Environmental monitoring program procedures, implementation and results.
(Paragraphs 3.a through 3.f, Report Details)
D.'
Emergency planning implementation, coordination with offeite agencies, drills and training. '(Paragrapns 4.a through 4.1, Report Details)
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E.
Analytical measurement program.
(Paragraph 5.a. Report Details)
F.
. Confirmatory measurement results.
(Paragraph 5.b, Report Details)
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1/ IE Inspection Rpt. No. 050-155/75-01.
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' REPORT DETAILS 1.
Persons' Contacted C. Hartman, Plant Superintendent (BRP)
T. Brun, Assistant Supervisor, Chemistry and Radiation Protection (BRP)
'R. Doan, Training Coordinatsr (BRP)'
G.'Szczotka, Quality Assurance Superintendent (BRP)
R. Schrader, Instrumentation and Control Supervisor (BRP)
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W. Strodl, General Engineer (CP)
C.sChang, Corporate Health Physicist (CP)
K. Boss, Director of Nure.s Training, Charlevoix' Hospital C. Smith, Emergene Room Supervisor, Little Traverse Hospital R. Zink, Sheriff, Emmet County J. - Curtis, Chief, Charlevoix Fire Department P. Lawrence, Sample Collector 2.
General The inspection included an examination of the licensee's environmental monitoring, emergency planning, and analytical measurement-confirmatory measurement programs.
Included in the environmental monitoring portion of the inspection was an examina-tion of the radiological environmental activities, monitoring results; management control aspects including organizational structure, responsibilities and authorities, and administrative controls. Although the licensee conducts certain non-radiological
..envircnmental monitoring activities, the technical specifications do not contain non-radiological requirements; such specifications will be issued in the future. All aspects of the licensee's environmental monitoring program inspected were found to conform to NRC Regulatory requirements.
s Included in the emergency plan inspection was an examination of Big Rock Point site Emergency Plan and available implementing procedures.
In addition to discussing the emergency plan, (Revision 28, December 15, 1975), and its implementation with licensee representatives, selected offsite facilities were visited or contacted, documentation pertaining to various aspects of the emergency preparedness program were reviewed cnd selected emergency equipment and materials were inspected.
The following offsite support agencies were visited or contacted by
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the inspector:
Little Traverse Hospital, Charlevoix Hospital,
Emmet County Sheriff, and the Charlevoix Fire Chief.
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Thi cn:lyticsl metzurament-confirmatory rea:urement inspection cin let;d of en cxaminction of the 'licensce's program to control quality of analytical measurements and of.a test of the licensee's U
measurements of~ radioactivity in~ actual sampics of his effluents.
Surveillance requirements, documentation and analytical results were examined to determine quality control of the program.
The confirmatory measurement test consists of-comparing the licensee's measurements with those of the NRC's reference laboratory. The two laboratories make measurements on the same samples, or on duplicates or. splits of the same samples.
The measurements made by the NRC referenc'e laboratory are referenced to the National Bureau of Standards radioactivity measurements system by laboratory intercomparisons.
3.
Environmental Monitoring
. a.
Procedural Controls-The licensce's administrative and procedural controls for
'impicmentation of the radiological environmental monitoring program were examined. This examination included a review of the assignment of responsibilities and authorities for program management.
The licensee utilized the services of Interex Corporation, Natick, Massachusetts to perform the radiologicci environmental laboratory analyses in 1975.
Effective December 1, 1975,.
Eberline Instrument Corporation (Midwest Facility) became the licensee's radiological environmental monitoring analytical contractor.
Radiation Detection Corporation of Sunnydale, California supplies the film badge service to satisfy the radiological environmental technical specification.
Itemsthathadnotg the time of the previous inspection yen completed at were discussed with a General Office representative.
- A written set of procedures entitled " Radiological Environmental Sample Collection Procedures" has been prepared for implenentation by the environmental contractor and the sample collector.
- Program administrat.ive procedures are in varied status, some complete, some partially complete, and
some under development.
- Internal audit programs are in the early stages of development.
2/ Ibid
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- C:ntract inboratory co:rdinction c:nd rcporting
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cctica icvals has been cctiefied by thi avaluation of the new analytical contractor and the development
of implementing procedures.
The procedures will be examined when they are completed
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during a subsequent inspection.
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Trend plots were observed to be current and a General Office
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representative indicated they wili continue to be maintained.
b.
Analytical Contractor Environmental analyses were performed by Interex Corporation until December 1, 1975, when the Eberline Instrument
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Corporation became the licensee's new analytical contractor.
Evaluation of the new contractor was made by Geacral Office personnel who examined the laboratory's quality assurance program, laboratory techniques and procedures, and laboratory facilities in September 1975.
c.
Technical Specification Implementation Film monitoring is the only environmental technical specification requirement. The licensee has continued to perform additional radiological monitoring for milk, various water parameters and airborne concentrations. A submitted technicert specification revision will include environmental monitoring requirements in addition to the one currently in effect.
d.
Film Monitoring The film data was examined and it was noted that the
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report periods of the individual monthly reports overlapped in some cases and were discontinuous in others. The licensee representative produced a schedule indicating that film is changed on the second Thursday of,each month.
An examination of the sample collectors log-book for 1975 confirmed that the film had been changed in accordance with the schedule. The General Office represent-ative stated that he will investigate the reporting discrepancy and document the correct information.
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e.
Air Samplers The inspector and a General Office representative visited three random air sampling sites.
Each site's sampler was operating, The licensee has recently changed sampling (
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herda cnd tha typ2 cf ptreiculets filtsr pIpsr u2:d. Ths
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Cen;rcl Offica rzprssentativs ctated that the reduced
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pressure drop of the new paper should rscult in lonstr pump life. A study is currently in process to determine
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the optimum position of the dry gas meter.
If the results warrant,-changes will be made as maintenance of the systems are required.- The dry gas meters are calibrated on an annual basis.
f.
Airborne I-131 Results Interex analytical procedures for I-131 were to be examined with stack release and milk sampling data. ps not consistent no the result of high reported concentratig The General Office representative stated that the results in question were activities greater than background reported as I-131 without,the verification of a spectrographic analysis.
The final Interex reports listed < 9 and ( 6 picoeuries per cubic meter consistently for all samples.
The General Office representative stated that these were due to the fact that the contractor _had allowed too much decay time prior to counting. The new analytical contractor.results will be examined during a subsequent inspection.
g.
Completed Studier An aquatic entrainment study including fish, fish eggs, conducted by the licensee.49 ake bottom study have been larvae and zooplankton and l
The results of the entrain-ment study are due to be reported to the State of Michigan by June 30, 1976. The General Office representative
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stated that the lake bottom survey did not indicate any radioactive contribution from the plant operation.
The report of this study and the aquatic entrainment study will be examined during a subsequent inspection.
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4.
Emergency Planning a.
Administration The licensec's organization for implementation of the emergency' planning program has undergone one minogjchange since the previous emergency planning inspection.-
The title of the group to which the Senior Corporate llcalth Physicist reports has been changed to the Manager of Operating Services within the Bulk Power Operations
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Department.
C. Chang replaced 11. Pettengill as Corporate llealth Physicist.
3/ Ibid.
4/ Ibid.
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5/ Ibid.
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be R vptnsibility
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Emergency plan implementation instruction cards were
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reviewed.
Card No. I entitled " Plant Superintendent" and Card No. 2 entitled " Shift Supervisor" were revised effective Apri? 4,1975..The inspector noted that some of the instruction cards have no issuance-dates affixed to them.
c.
. Coordination The inspector visited or contacted offsite support agencies to determine if coordination between the licensee and the agencies is being maintained. The Charlevoix Hospital and Little Traverse Hospital were visited and their representa-tives indicated that coordination and training are adequate.
The Charlevoix Fire Department and Emmet County Sheriff's Office were contacted by phone and representatives indicated that they had a current copy of the emergency plan and were aware of their responsibility within the plan.
Letters of agreement from offsite support agencies were reviewed. The letters on file have been updated since September of 1975 with the exception of the Department of State Police which is dated January 20, 1974, and the Petoskey Fire Department dated February 5,1974.
The licensee representative indicated that the Petoskey Fire Department had declined to send a letter of agreement to the licensee because of jurisdictional problems.
The inspector stressed the importance of maintaining.up-to-date letters of agreement.
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d.
Emergency Equipment
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The contents of two site emergency kits were examined s
against a monthly inventory checkoff list.
The inspector noted the.c although the control room kit checkoff list indicated all items present, a dosimeter charger was miss-ing. A charger was placed in this kit prior to the termina-tion of the inspection.
A review of the emergency kit inventory sheets for 1975 revealed that the control room kit had not had an inven-tory performed for a three month period. A memo to the
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- Cheri:try cnd Radiatien Pr:tsetion tschnicians entitled
" Site Emergency Kit Inspection" dated January 31, 1976, f
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omission.
Emergency supplies were available at both the Charlevoix and Little Traverse Hospital.
It was noted at the Charlevoix Hospital that the facility had been modified and there is no longer-provision f ar the removal of waterborne contam-ination. A licensee representative has. stated that pro-visions would be made for the removal of waterborne con-tamination. 'In addition the modification also provided
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additional fan capability for better airborne contamination control. The provisions for airborne and waterborne contamination control at the Little Traverse Hospital could not be examined at this time..This item will be examined at a subsequent inspection.
The stack gas monitor and off-gas monitors were examined.
Records indicate that daily functional tests and required calibration tests are performed in accordance with a prescribed schedule. The off-gas monitors are alarmen and response versus activity levels are posted on the panel on the monitor, e.
Training The inspector reviewed the licensee's documentation regard-ing the training of offsite support groups in 1975.
The documentation satisfies the commitment in the site emergency plan.
The inspector reviewed training of the plant personnel with respect to the emargency plan and first aid.
Records are kept on an individual basis.
Emergency plan and first aid training was determined to be as specified in the site emergency plan.
First aid training which is required every three years was provided on March 11, 1975.
f.
Drills Semiannual emergency plan site practice drills and annual
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offsite support agency drills involving both the primary and backup hospitals have been conducted as per the licensee's l
emergency plan commitments. A deficiency noted during the
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e Deccab:r 1975 drill and dstsiled in thm critique has been corrected..The SARB reviewed a' scenario that had j'
been developed and determined it to be adequate for a practice. drill.
g.
Accident Analysis and Emergency Action Preplanned decisional aids, to be used in the evaluation of offsite protective measures, vergflisted as under study at the time of the last inspection.-- The only decisional aids developed to date are 10% core meltdown curves showing the elapsed time in hours to reach a one rem whole body
.)se-and 10 rem thyroid dose at various distances from release point. These are listed in Appendix J.
A General Office representative stated that additional decisional aids will be prepared. An overlay of the vicinity of Big Rock Point
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has been prepared but is not in its final form.
The inspector noted that Section 9.6.12 which contains d,ses listed in the Appendix J plots, differs from Section 9 0.14, both of which are listed in the site emergency plan as con--
forming to the EPA guideline consideration of action levels.
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These will be corrected in a. subsequent emergency plan change.
The licensee representative stated during the last inspection 7/-
that the EPA interim guidelines were presently under study in the general office for-incorporation into the site emergency plan. A General Office representative stated that futuro proposed emergency plan changes will result in the incorporation of TPA Protective Action Guides into the emergency plan imple-menting procedures. This matter will remain open.
h.
Facility Ventilation Patterns
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Ventilation patterns in the access control area, decontam-
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ination area and laundry room have been evaluated.
An enginect is working on a facility change.
This item will be examined during a subsequent inspection, i.
Emergency Plan Review Quarterly reviews were performed by the Chemistry and Radiation Protection Supervisor as-prescribed in Section 9.13.2 of the plan.
The emergency plan has been reviewed by both the Plant Review Committee and the Safety
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Audit and Review Board in early 1975.
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Analytical Measurement - Confirmatory Measurement Program
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Administration
'The licensee's program to control quality of analytical measurements was examined. Although the program is not completely proceduralized; approved procedures for count-ing, liquid release, operation of a GeLi system and stack analyses are currently in use.
Sampling, analyzing and
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off-gas analysis are among the procedures currently in draft.
Although the program is not audited formally in plant, the Assistant Supervisor or Supervisor of the Chemistry and Radiation Protection Group review all release data calculations as they are generated.
All release data.s then reviewed on a monthly basis by General Office personnel.
The Operating
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Services group within the Bulk Power Operation Department in the General Office audit the Chemistr and Radiation Pro-tection group on an annual basis.
The licensee representative stated that NBS ccrtified liquid radionuclides have been purchased as a method of independent testing of their program capability for various media. Tritium capability has been tested against an EPA standard, b.
Confirmatory Measurements g
The licensee's analytical results for effluent samples pertinent to this inspection when compared to the results of the NRC reference laboratory yielded 27% agreements or possible agreements and 73% disagreements (see Attachment 1 for acceptance criteria). The types of samples tested
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and the results of the measurements were:
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(1) Type of Sample:
Liquid Waste (October 17, 1975)
(Results in unit of pCi/ml)
ACC'iPTABLE Radionuclide NRC Reference Measurement Licensce's Measurement Gross Beta 3.11 1 0.06 E-03 3.14 -1 0.017 E-03 Mn-54 1.41 1 0.04 E-04 1.466 1 0.03369 E-04
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Zn-65 8.8 0.3 E-05 7.916 1 0.84 E-05
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NOT ACCEPTABLE'
C Radionuclide NRC Reference Measurement f/censee's Measurement
- H-3 1.09 1 0.01 E-02 6.9 E-03 Sr-89 8.8.t 0.3 E-05 3.05 E-05
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Sr-90 4.3 1 0.2 E-06 9.80 E-04
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Cs-134 8.4 1 0.2 E-04 1.894 g 0.03202 E-04 Cs-137 2.71 1 0.08 E-03 5.282'r 0.04055 E-04
Co-60 5.0 t 0.1 E-04 1.115 1 0.01218 E-03 Ba-140
4 1 E-05 Not identified Co-58 1.9 1 0.1 E-05 Not identified (2) Type of Sample:
Gaseous Waste (October 17, 1975)
(Results in units of pCi/ml)
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ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurement Xe-133 6.5 1 0.2 E-02 8.96 1 0.24 E-02 NOT ACCEPTABLE
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Radionuclide NRC Reference Measurement Licensee'sMeasurement
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Xe-123m 5.4 + 0.2 E-03 Not identified
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12 E-04 Not identified (3). Type of Sample: Particulate Filter (October 17, 1975)
(Results in units of,pCi/ sample)
ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurement Cs-134 1.6 i 0.1 E-04 1.23 1 0.38 E-04 Cs-137 5.0 1 0.2 E-04 4.2 1 0.59 E-04 NOT ACCEPTABLE
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Radionuclide NRC Reference Measurement Licensee's Measurement
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Ba-140 1.6 0.2 E-04 Not identified Co-60 2.3 1 0.6 E-05 4.7 i 0.67 E-04
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((4) L ' Typn.cf - Ssaplo:
Charcoel-Adsorbsr;. (October-s17.- 1975).
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-(Resulta in units-ofjaCi-
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'NOT ACCEPTABLE Radionuclide NRC' Reference Measurgment_ -Licensco's Measurement
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1-131'
3.95 + 0.09 E-03 1.91- + 0.09 E-03 Ba-140
- 5. 8 1 0.1 E-03 Not identified
Cs-134 1.7-1 O.2 E-04 Not identified
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S.6 1 0.4 E-04 Not identified-The licensco was contacted when it-was obvious there were
many disagreements in'tho October sampic split.:in order-to have him verify his results. At that-time,;n licensco representative stated that he had become aware of problems in the CcL1 system in November of 1975.
In reviewing the
.iteensco's disagreemente with the reference laboratory and noting:
(1) the wide range of ratio discrepancies and-(2) the random spread of disagreements, the licensee representative and inspectors concur that it is possible that the problem-of the Celi system was present prior to:
Novembu.. 1975, but not recognized until that time.
This is demonstrated by the fact _that certain nuclides
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are identified in_ agreement in.one media, in disagrec' ment in another media and not identified in a third media.
The inspector also pointed out that particulate matter was identified on the charcoal adnorber and eme nuclide-constituted a significant' percent of the total radioactivity quantified. The licensee representative referred to a
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moisture problem that might have act,od as a carrier of
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these nuclidos through the particulato filter and agreed to' investigate thn cause further.
Eccause of some-nuclides not.having been identified, tho'licennee represcr.cative agreed to adjust his counting time to be in agreement with the reference laboratory's counting-time for the next sample split in order to demonstrate his analytical capabilitics. The inspector further noted,that there is
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a generic problem with the method in which off-gas sampics are collected. Non-homogeneous splitting of these sampica could result in further di-'greemento.
Because of the
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fact that the licensee's of. gas samples and the reference are not collected simultaneously, laboratory off-gan samp1
a different method of co11ceting off-gas samples will be investigated.
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-Attachment:
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ATTACUMENT 1
--h CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS
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This attachment'provides criteria for comparing results of capability tests and verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the accuracy
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needs of this program.
In these criteria, the judgement limits are variable in relation to the comparison of thc.NRC Reference Laboratory's value to its associated
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As that ratio, referreo to in this program as " Resolution",
increases the acceptability of a licensec's measurement should be more selective.
Conversely, poorer agreement must be considered acceptable as the resolution decreases.
RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Possible Pot:sible Agreement Agreement A Agreement B 3.0 No Comparison
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2.0 0.4
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2.5 0.3
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1.66 0.5 -
2.0 0.4
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1.33 0.6 -
1.66 C.5 -
2.0 51 - 200 0.8G -
1.25 0.75 -
1.33 0.6 ~-
1.66 200 0.85 -
1.18 0.80 -
1.25 0.75 -
1.33
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"A" criteria are applied to the following analyses:
Camma Spectrometry.where principal gcmma energy used for identifi-
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cation is greater than 250 Kev.
Tritium analyses of liquid samples.
"B" criteria are applied to the following analyscs:
Camma spectrometry where principal gamma energy used for identification is less than 250 Kev.
89Sr and 90Sr Determinations.
Cross Beta where samples are counted on f.he same date using the same ceference nuclide.
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