IR 05000155/1977009
| ML20031C358 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/16/1977 |
| From: | Fisher W, Hueter L, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20031C350 | List: |
| References | |
| 50-155-77-09, 50-155-77-9, NUDOCS 8110070082 | |
| Download: ML20031C358 (10) | |
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U.S. Nt' CLEAR REGULATORY COMMISSION OFFICE OF 11;SPFCfl0N AND ENFORCEME!;T RECION III
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Report lio. 50-155/77-09; 30-4E66/77-01; 70-660/77-01 Docket No. 50-155; 30-4866;70-660 License No. DPR-6; 21-08606-01; SNM-614.
Licensce: Consumers Fower Conany 212 West Michigan s,enue Jackson, MI 45 2'si Facility liace: Big Rock Point Nuclear Plant Inspection at: big Rock point Site, Charlevoix, MI Inspection conducted: July 20-29, 1977 Inspectors:
L. J. Hucter
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H. C. Schumacher
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Approved by:
W. L. Fisher, Chief
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Fuel Facility Projects ane'
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Radiation Support Section
.nspection Su varv Inspection on July 25-29 1977 (Report ':o. 50-155/77-09: 3C-W 6/77 r1; 7 0-f.( 0/ 7 /-01 )
Areas Inspected: Routine, unannounced inspection of radiation protection program for norral facility operation and the 1977 refue'.ing outape, includirg: qualifications; audits; training; radiation protection Pro-cedarcs; instrur.ents and equip :ent; exposure contr;l; posting, l a be li r e,,
and control; surveys; notifica. ions and acports; advanced planning and preparation; followup of previous insnection findings; and review of reportable occurrences. Activities under Materials Licenses 21-08606-01 and S!;".-614 were also inspect ed.
The inspection involved 92 inspecter-hour; ensite by two !!!:C inspectors.
Results: I;o itens of nonc wpliance were identified in the 13 areas inspected.
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DETAll.S 1.
Pc7 sons Contacted C. J. Hartman, Plant buperintendent
- C. E. Axtell, Plant Ilealtn Physicist
- T. M. Erun, Chenical & Radiation Protection Supervisor F. J. Valode, Shit: Engineer R. Doan, Training Supervisor
- D. DeMoor, Technical Engineer
- B. O' Donald, CA Engineer E. McNamara, Training Department The inspector also talkwJ with other licensee employees, including
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health physics and instrurnent and et,ncrol technicians.
- denotes tho?e present at exit interview.
2.
General This inspection, which began with vis;al observation of radio-logical warhing conditions in the turbine building and contain-ment at 6:15 a.m.
on July 25, 1977, was conducted to examine licensee rirdiation protection activities including those related to the refue!!ng o W ge that began on July 23. Additional visits were rade to varaour, locations in controlled areas during the course of the intpection. The inspectors note' satisfacto:y posting of radiological conditions and control of access to radiation and high radiation areas. However, it was noted that conditions in the access control area were very crowded with apparently inec* patible activitics taking place there. The area cont ains the !.calth physics ficId of fice, the laundry, a sink used for cleaning of respirators and occasional decontamination, and respirator supplies as well as the check out r.onitor.
Respirator training and fitting is also done in this small area.
Preparation of work arras was satisfactory. Adequate supplies of respirators, protective clothing and survey instruments were noted.
Supplies of self reading dosincters were somewhat short and the licensee had on ordcr an additional 25 units whic't were to be rented for use during the outanc.
No items of noncompliance were nott:d.
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3.
Licensee Action on Previoess inspection Findines (Closed) Infraction A.1 (155/76-22): High radiation area barricades preventing egress. Licensee correct 1<e actions stipulated in their letters dated March 3 and April 11, 1977; vere confirmed.
(Closed) Infraction A.2 (155/76-22): Inadequate measureme,t of
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released particulates owing to bypass of ieproperly sealed filter.
Licensee corrective action was confirmed..
(Closed) Deficiency (155/76-22): Solid waste shipment data omitted from January-June 1976 report. The data was submitted to NRR in a letter dated January 11, 1977.
4.
Radiation Protectios. Orrar.itat ion The organizational structure and personnel staffing in the supervisory
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positions in the plant Health Physics Department are ynchanged from that described in a previous inspection report.j Seven (an increase of one in the past year) Chemical and Radiation Pro-tectian Technicians reoort to the Chemical and Radiation Protection Supervisor. In addition, during the sumner months, a college student training in *calth physics is assisting the licensee. Both new technicians hired within the past year,' onc in October 1976 and the other in April 1977, have had previous health physics training and expericcee. It was learned through observations during the
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inspection and through discussions with personnel that the health physics staf f is smaller than desirable particularly on occasion
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during outages. A licensee representative. stated plans to obtain
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another full-time technician next year which should alleviate this recurring problen.
No items of noncompliance were identified.
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5.
Licensee Audits The inspector eeviewed the reports of two onsite and two of fsite audits conduc'ed in late 1976 and early 1977 involving chenistry and radiatiot protection topics. Several itens of varying signifi-cance were identified, all of which had been either corrected or
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corrective reasures were in progress.
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No items of noncompliance were identified.
1_/ IE Inspection Rpt No. 50-155/76-15
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Training Radiation protection training and retraining was reviewed. New employees and visitors who will be unescorted receive general indoctrination which includes radiation protection. The course, attended by the inspector on the first day of inspection,vas of about three hours duration. It consisted of three video tapes with question and answer periods at the end of tape segr.ents.
The tapes, which were recently produced by a licensee contractor, appeared to satisfy the requirceents of 10 CFR 19.12.
Licensee representatives stated that this presentatien is essentially the same as that given to new plant employees as part of a Feneral indoctrination. The tapes were also shown to all plant eeployees as part of annual retraining prior to the current refueling outage.
Subsequent retraining for plant personnel will consist of a review each year of the Radiation Protection Manual (Volu=e 11 of the Big Rock Point Plant Manual) and particularly of changes thereto.
The presentations will be tailored for the various categories of employees, according to training departrent representatives.
The licent te recognizes a category of ecployees who are certified as R'n'P except by the plant health physicist. The exemption is granted af ter additional tsaining and pazsing of an exa-instion prior to certification. Exempt personnel include health physics, operation, the technical department and certain cembers of the maintenance departnent. Certification is reviewed by ex:nination given every two years. Except personnel are regarded as qualified to make surveys and therefore to work in posted areas witheut a
work permit or health physics coverage. They are, however. required to observe posting, to work with a second individual in entering certain high radiction areas and to consult with health physics before work in airborne areas. Records of KUP exempt personne!
are maintained by the health physicist.
The licensee has recently implceented a r. aster training plan described in V* lure 18 of the Eig Rock Point Plant Manual, it details training reouirements, including radiation protection for the various categories of plant ceployees. The Thspectors reviewed Volume 18 af ter the inspection and noted the following:
Training requirements for visitors not consistently addressed.
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b.
Requirecents for respirator training and retraining not addressed for all categories of workers.
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Requirements for RVP cxempt personnel not addressed.
d.
Absence of cross refs.'nces between volume 18 and the Radi-ation Protection Manut'. (Volumes 11 and 12) wherein other f
training requirements are addressed.
Titiesusedtorefertoradiationprotectiontrainingcourscs e.
inconsistent within Volume 18 and between Volumes 18 and 11.
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These items were discussed with the training coordinator by telephone on August 2 and with the plant superintendent on August 9, 1917.
No items of noncompliance were identified in this review of training.
Program improvements, particula.1: in the area of respirator training, will be reviewed during a forthcoming inspection.
7.
Radiation Protection Procedures The licensec's radiation protection procedures have been conpletely rewritten and incorporated into the " Big Rock Point Plant tunual,"
Volume ll, " Radiation Ps otection Manual-Cene:al," and Volume 12,
" Radiation Protection-Departcental."
The inspectors briefly reviewad Volume 11 and selected procedures from Voluna 12 including RP-29, " Radiological Surveys," and RP-37,
" Respiratory Protect ion Progran." Problems noted in review (Paragraphs 6 and 10) were discussed with licensee personnel at the exit interview.
No items of noncomp;:sace were identified.
8.
Instrueents and Ecuiprent The licensee has generally adequate nunbers of operable survey inst rument s and equipment. Survey instruments are calibrated quarterly. The area radiation monitors, two of which also serve
'as criticality monitors, are calibrated monthly.
A s,hortage of dosimeters was noted during the inspection. Rented dosimeters were on order.
No items of noncompliance were identified.
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9.
Exposure Contr
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External Expos _
the approxicate 100 rer,ular employees Film bauge data the non-regulor eu, _oyces (including visitors) at Big Rcek and Point were reviewed f or the last half of 1976 and the first half of 1977. Forms NRC-4 and NRC-5 for randomly selected individuals from both groups were reviewed with no problems or overexposure of personnel being noted.
The total nan-ren received in 1976 was about 270 based on film badge data; this was the highest for any year except 1973,when about 300 man-ren dose was received. About 80 percent of this can-rem dose was received during a lengthy refuelieg and main-tenance outage.
No items of noncompliance were identified.
10.
Internal Exposure Control Respiratory Protection a.
The licensce's respiratory protection precra, consisting of training, face piece fitting, testing, cleaning, inspection.
repair, and storage was reviewed. All devices observed 1.ad been approved by NIOSH, Supplies of respirators Records of respirator fitting are appeared adequate.
maintained for individuals and a naster list is kept for plant personnel. The licensee also raintains a record,
" Internal Dose Estinates from Inhalation of Airbarne Radioact ive Material," on which respirator use tines, locations, and airborne concentrations are logged.
Respirator issuance is controlled by the health rhysicist.
Selection, training and fitting are donc by the health physics technicians at the access control point. Fitting The inspectors is by qualitative test with isoanyl acetate.
observed a training and fitting sessica for three contractor individual had difficulty obtaining a fit employees. One The difficulty and several masks were tried before success.
may have been caused by failure to adequately ti hren the t
headstraps to achieve a good scal. The test canisters on the first nask tried were double stacked and being heavier than the normal canister, tended to pull the nask It was also noted that training away from the f ace.
conditions were poor owing to the crowded and distracting-6-
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conditions which occur in the access control area. It was also noted that the licensee imposes.no requirements for medical examination of users. The program will probably require upgrading to meet the requirements that will become ef fective December 1977.
No items of noncompliance were identified.
b.
Air Sampling Records of air samples for the period July 1976 through July 1977 vere reviewed. High volume air samples are taken routinely during normal operatian at selected loca-
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tions, for entry into areas rarely frequented, and for l
special maintenance jobs. The records shew much rore i
frequent air sampling, including iodine, during the
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refueling outage.
Continuous air monitors, used for trending devices, are located in the turbine building, :he containe.ent sphere
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entrance, and the sphere exhaust du ring normal operations.
i For the outage, the exhaust CAM, which has both iodine and
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particulate capability, was moved to the reactor deck to monitor conditions over tSe fuel pool.
Celi spectrometer analysis of air samples is used if gross counts exceed a specified threshold. An associated computer program is used to determine an HPC for the aggregate of identified and unidentified nuclides (obtained by subtraction from. the gross count). No significant
problems were noted in the review of this program.
If the Celi spectrometer is unavailable, a sodium iodide analyser is used for isotopic identification and an ef fective HPC is computed by hand. The algorithm for this computation, given in Procedure RP-29, " Radiological Surveys," appeared to be incorrect. The licensee agreed to review this procedure.
The licensee also agreed to review the formula for calculating air concentrations based on gross counting. A collection ef ficiency factor of 0.9 which is in the numerator of the equation properly belongs in the denominator.
No items of noncompliance were identified.
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Bionssay Procran Whole body -countin,1 records were reviewed for the period August 1976 through July 1977. Counting is done on a' rental
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whole body counter with data processing and reporting by the vendor. The program appears to have been conducted in accor-dance with section 11.5 of the Radiation Protectien Manual and Procedure RP-37, " Respiratory Protection Program." The frequently observed isotopes are cesium-137 and cobalt-60.
most No indications of body burdens in excess of 10% were noted.
The inspectors reviewed the licensee's evaluation of airborne exposure (MPC-hours) for a previously examined series of counts
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of an individual made in May 1976.' The licensee's and RIII
' inspector'sevaluationsjndicatedtheexposurehadbeen less than 40 HPC-hours.2-he items of noncompliar e were identified.
11.
Advaneca Planninc and ALARA The inspectors reviewed outage planning with regard to ALARA. The
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Chemistry and Radiation Protection Supervisor reviews the daily
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l outare schedule of maintenance jobs and assigns specific tecanicians
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l to follow each job. The man-rem dose commite.ent for broad categories cf jobs is based upon experience fron previous entages. The inspec-
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tors reviewed internal correspondence wherein the licensee analyzed the sources of dose (240 man-ren) incurred during the six-conth 1976 The documentation listed ceasures to consider ~for dose outape.
reductico in subsequent outages. For trial during the current cutage, the licensee has initiated an ALARA cvaluation forn which the health physics technicians use to evaluate, for dose reduction, those jobs with anticipated dose cor=itments greater than 10 man-rems.
Evaluations indicating cost benefit factors of $600 per man-rem or
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less are to be submitted to the plant superintendent for consideration.
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i 12.
Posting, Labelinn and Control
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The inspectors observed labeling of containers, posting of areas
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containing radioactive materials, posting of radiation' areas including,
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high radiation areas, and posting of airborne radioactivity areas.
Bullatin boards were observed for the postings required by 10 CFR.
19.11. No labeling or posting probicos were noted.
l 2/ IE. Inspection Rpt No. 50-155/76-19.
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The licensee has administrative procedures for controlling access to and work in controlled areas. These procedures, which are contained in the Radiation Protection Manual, specify that work in controlled areas by non-RWP exempt personnel be reviewed by health physics in advance. Work in posted areas by such individuals must be under a Radiation Work Permit (SWP) or with the surveil-lance of'a health physics technician. Few RWP's are used at the plant. RWP exempt personnel may work alone in posted areas but
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must adhere to specific requirements posted on applicable status boards. They must notify the health physics department of the need to enter posted airborne areas so that respirators may be assigned and air sampic may be taken.
The radiation protection log for March 15, 1977, contains a racord regarding th. entry into a controlled area by contractor personnel for the purpose of doing minor maintenance on the stack. The visitors were escorted by RWP exempt personnel but health physics i
l had not been consulted beforehani nor had a "Cuest Record" been l
filled out, as required by Sectian 11.6 of the Radioactive Protection l
Manual and procedure RP-4.
Corrective action for this violation of procedures, docume ted under Deviation Report No. 77-35, included a review of control.ed area access requiraments with involved personnel by the Chenistry and Health Phy.ics Supervisor.
l No items of noncompliance were identified in the inspectors' review.
13.
Surveys Selected records of routine (daily, weekly, monthly) and special surveys of direct radiation and surface contamination were reviewed for the period July 1976 through July 197 7.
The surveys, pe r forced under procedure RP-29 " Radiological Surveys," appeared adequate tc satisfy regulatory requirements.
The inspectors examined licensee records to confirm the perfo:mance of leak tests on scaled sources as required by !bterial Licenses 21-08606-01 and S::M-614. No items of noncompliance were identified.
14.
Notification and Reports Based on statements made by licer.sec representatives and substantiated to the extent of records reviewed by the inspectors, it was concluded that the licensee has had no thef t or loss of licensed material.
The inspectors examined and discussed, with licensee personnel, i
records and reports of personal exposure to radiation and radio-active material.
No items of noncompliance or deviations were identified.
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15. Licensee Event Report No. PO-77-13 On May 16, 1977, the licensee reported the inaperability of air ejector offgas ocnitors during steady state-ver oge ation,,
on April 21, 1977. The cause was attributed to excess noisture co8 4ction in the n:onitoring systen. The inspectors reviewed licenst? records of of fgas and stack samples and the stack mon * tor to conf.ru that release rates were essentially constant dering the'
six hour period of inoperability, Release rate quantification was not affected by this failure. Further licensce enrrective action being pursued during is outage is being reviewed by the RIII operations inspector 16. Materials Licenses The licenree possesses an.8n-gram plutoniun-beryllium neutron s'ource 'mder NRC License SFrt-614 and various byproduct n:aterial sources under Licenre No. 21-08606-01. The inspectors reviewco the licensee's ure of these sources, including leak test and inventory records. The sources are used by or under the super-vision of the plant health physicist, who is named on the license.
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No items of nodcompliance were identified.
17. Exit In:erview
'Ihc inspect met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on July'24, 1977.
Further discussions of the inepection findings were conducted by telephone with Mr. R. Doan, Training Coordinator, on August 2, 1977, Mr. C. Axtell, Plant :lealth Physicist,. on August 8,1977, and Mr. C. Hartmsn, Plant Superintendent, on August 9, 1977.
The inspectors sunnar! zed the findings of the inspection. The
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licensee agreed to review and revise as necessary, the procedures relating to air sample analysis, to review and strengthen respirator training as necessary, and to amend the caster training plan to
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better address radiation protection training and retraining require-ments. A licea ca representative stated that budget funds were being requested to provide additional space for activitics conoucted at the access control area.
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3/ IE Inspection Rpt No. 50-155/77-11.
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