IR 05000155/1981011
| ML20032E593 | |
| Person / Time | |
|---|---|
| Site: | 03004866, Big Rock Point |
| Issue date: | 10/16/1981 |
| From: | Greger L, Lovendale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20032E581 | List: |
| References | |
| TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 30-04866-81-01, 30-4866-81-1, 50-155-81-11, IEC-80-18, IEC-81-07, IEC-81-7, NUDOCS 8111200722 | |
| Download: ML20032E593 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
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Reports No. 50-155/81-11; 30-4866/81-01 Docket Nos. 50-155; 30-4866 Licenses No. DPR-6; 21-08606-C1 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Big Rock Point Nuclear Plant Inspection At:
Big Rock Point Site, Charlevoix, MI Inspection Conduc e : September 21-25, 1981 Inspector:
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Approved By:
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. Greger, Chief Facilities Radiation Protection Section Inspection Summary Inspection on September 21-25, 1981 (Reports No.50-155/81-11; 30-4866/81-01)
Areas Inspected: Routine, unannounced inspection of licensee actions taken in response to Health Physics Appraisal findings.
It also included a review of transportation activities, IE Circulars, TMI Action Plan items, and previous items of noncompliance. The inspection involved 35 inspector-hours onsite by one hTC inspector.
Results: Of the four areas inspected, one apparent item of noncompliance was identified in one area (Severity Level V violation - failure to provide an individual qualified in radiation protection procedures on each shift -
Section 5).
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DETAILS 1.
Persons Contacted
- C. J. Hartman, Plant Superintendent
- C.
E. Axtell, Plant Health Physicist
- R. Abel, Operations and Maintenance Superintendent
- H. Dickson, Health Physicist
- G. Fox, Chemistry and Radiation Protection Supervisor
- R. Burdette, Assistant C&RP Supervisor R. May, Shift Supervisor T. Loudenslager, Training
- G. Wright, Senior Resident Inspector, NRC The inspector also contacted several other licensee employees, including members of the technical and engineering staffs.
- Denotes those attending the exit meeting.
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2.
General This inspection, which began at 2:00 p.m. on September 21, 1981, was conducted to examine licensee actiona taken in response to Health Physics Appraisal findings, past items of noncompliance, IE Circulars, i
and TMI Action Plan items. Also, the licensee's transportation ac-tivities were reviewed. The inspector performed independent surveys and reviewed radiation controls and postings during tours of the radiologically controlled areas.
Housekeeping and cleanliness appeared good.
3.
Licensee Action on Previous Inspection Findings (0 pen) Noncompliance (50-155/80-04): Failure to provide an individual qualified in radiation protection procedures on each shift. The licensee failed to take corrective action as outlined in a letter to
NRC Region III dated July 18, 1980. This matter is the subject of a Confirmatory Action Letter to the micensee dated September 30, 1981, and is discussed in Section 5 of this report.
(Closed) Noncompliance (50-155/80-04):
Failure to adequately control access to high radiation areas. Locked doors have been installed at the entrances to these areas.
(Closed) Commitment (50-155/79-02):
Install new area radiation monitor in the fuel pool area, and improve fuel pool rope control.
A new monitor has been insta14ed, and rope control has been improved.
In addition, training was conducted to present recurrence.
(Closed) Noncompliance (50-155/80-16): Failure to post radiation araas in accordance with 10 CFR 20.203(b). These areas have been properly posted and steps have been taken to prevent recurrence.
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4.
Chemistry and Radiation Protection Staffing During the Health Physics Appraisal, it was noted that staffing of the Chemistry and Radiation Protection Department was not sufficient.
Steps taken to improve staffing are:
3.
The number of chemistry and radiation protection (C&RP) tech-nician positions has been increased from seven to ten, and will probably be increased to thirteen by January 1, 1982. One technician vacancy existed at the time of this inspection. Three rental technicians are presently employed to allow training time for the recently hired technicians.
As noted in a previous inspectionN a new position for a pro-b.
fessional within the C&RP Department was created and filled.
This person was assigned responsibility for upgrading plant staff's radiation protection training and for implementing and maintaining an AI. ARA program. Since that inspection, this individual has spent most of his time on the development of an ALARA program. Another person has been hired into the Training Department to upgrade plant staff radiation protection training.
c.
The licensee plans to hire a degreed health physicist by January 1, 1982.
Based on the above, it appears that staffing of the C&RP department has improved. However, additional C&RP technicians are needed to provide coverage on each shift by November 1, 1982, as stated in the licensee's response to NUREG-0737 dated July 9, 1981.
5.
Off-Shift Radiation Protection Coverage During the Health Physics Appraisal, it was noted that off-shift radia-tion protection coverage nee $ 1 upgrading to assure that necessary measurements can be made and actions taken during accident or other anomalous situations. A more comprehensive appraisal of this matter is te be performed during the Emergency Planning Appraisal scheduled for lat'e November 1981. Therefore, the inspector did not review this area, but noted that the licensee has committed to provide a C&RP technician on each shift by November 1, 1982.
In a related matter, Technical Specification 10.6.2.2(d) requires that an individual qualified in radiation protection procedures be onsite when fuel is in the reactor. The criteria required to be satisfied were forwarded in a letter fror Ziemann (NRC) to Bixel (CPCo)
dated March 15, 1977. During the Health Physics Appraisal conducted March 3-14, 1980, the licensee was found in noncompliance with this
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requirement. Specifically, offshift radiation protection coverage is routinely provided by the shift supervisors who typically are not 1)
IE Inspection Report No. 50-155/80-16.
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qualified to conduct special and routine contamination and airborne radioactivity surveys and evaluate the results of such surveys.
The licensee's response to this item of noncompliance, dated June 13, 1980, stated that a training program would be fully imple-mented by January 1, 1981, and would include, for RWP-exempt personnel (includes operators and shift supervisors), training in all six criteria-for individuals qualified in radiation protection procedures. Region III NRC accepted this proposed corrective action in a letter dated September 24, 1980.
During this inspection, it was found that the licensee's proposed corrective action had not been taken and that shift supervisors were still not capable of conducting special and routine contamination and airborne radioactivity surveys and evaluating the results of those surveys. This is an apparent item of noncompliance with Technical Specification 10.6.2.2(d). and is repetitive.
A Confirmatory Action Letter was sent to the licensee on September 30, 1981, detailing the corrective action that will be taken to correct this apparent noncompliance. The results of this corrective action will be reviewed during a future inspection.
(155/81-11-01)
6.
AI. ARA During the Health Physics Appraisal, it was noted that the licensee's
"as low as reasonably achievable" (ALARA) program required significant improvement, especially in the areas of program formalization and chemistry and radiation protection staff authority.
As noted in a previous inspection,2_/ Radiation protection staff authority is addressed in Nuclear Operations Department Policy No. N0D-014 titled
" Health Physics Policy." This policy also addresses Consumers Power Company's commitment to maintain worker exposures ALARA. Also, a person was hired to develop and implement an ALARA program at the plant based on
corporate guidance. Since that inspection, a corporate ALARA coordinator has been appointed and a corporate ALARA plan has been finalized.
Plant implementing procedures are being developed, with the assistance of a contractor, and the final formalized ALARA program should be fully implemented by July 1982.
In the interim, a somewhat informal, but apparently effective, ALARA program is in use on certain jobs.
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Although somewhat slowly, it appears that improvements have been made in the licensee's overall ALARA program.
Progress in this area will j
be reviewed during future inspecticas.
(155/81-11-02)
7.
Training l
During the Health Physics Appraisal, it was noted that the licensee's
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C&RP technician and RWP-exempt training program needed significant i
improvement.
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Ibid.
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I RWP-exempt training has not changed significantly since the llealth Physics Appraisal. One improvement made is the requirement that RWP-exempt candidates spend at least one week in on-the-job training
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with the C&RP department. This requirement was often waived in the past, but apparently will not be waived in the future.
Presently, the licensee is revising other portions of this training program. A few weeks ago an individual was assigned to the plant Training Department from the corporate office. This person is reviewing the entire RWP-exempt training program including the RWP-exempt re-qualification requirements which were criticized during the llealth i
Physics Appraisal.
Although some progress has been made, it appears that additional improvements are needed. Progress in this area will be reviewed during future inspections.
(155/81-11-03)
By the end of December 1981, all junior C&RP technicians will have completed a 12-week basic chemistry and health physics course being presented at the Midland plant. Also, all technicians will attend an advanced chemistry and health physics course at the Midland plant by about November 1982. Both courses were developed and are admin-intered by a contractor training organization. Also, increased staffing should result in more time available to the staff for retraining. This appears to be a significant improvement over the conditions existing during the Health Physics Appraisal. Progress in this area will be reviewed during future inspections.
(155/81-11-04)
8.
RWP-exempt Program
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Significant weaknesses in the RWP-exempt program were identified during the Health Physics Appraisal.
A new position within the Training Department was recently created and filled. The individual is to revise the RWP-exempt program and provide radiation protection training to the plant staff. The person filling this position was a C&RP technician at the plant for about
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ten years and worked in the corporate training group for about three
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years. Since this person was only recently hired, no significant progress has been made.
A review of RWP-exempt persons was conducted by'the licensee, and several were removed from the list. Progress in this area vill be reviewed during future inspections.
(155/81-11-05)
9.
Personal Contamination Monitoring
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During the llealth Physics Appraisal, it was noted that significant improvements were needed in personal contamination monitoring practices.
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To improve personal contamination monitoring practices, the licensee has installed two new friskers, which utilize pancake type GM detectors, at access control. The waist high portal monitor has been removed. All personnel exiting the controlled area are required to frisk themselves before leaving the area. Also, a new gatehouse portal monitor, which will be more sensitive than the present monitor has been ordered.
Problems remaining to be resolved include needed relocation or shielding of friskers that are located in high background areas, and needed improvement in the sensitivity of friskers located at alternate access points. These matters will be reviewed during future inspections.
(155/81-11-06)
10.
Airborne Effluent Controls During the Health Physics Appraisal, it was noted that improvements in airborne effluent controls were needed in the areas of noble gas quantification methods, laboratory ventilation release deterr~ ations, and HEPA filter changeout and testing criteria.
A high range monitor, which can be used to monitor and quantify noble gas releases, has been installed on the stack. A Ge(Li) detector and
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multichannel analyzer system will be installed on the stack early in
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1982.
A manthly contamination survey on the laboratory exhaust fan duct is being conducted to detect any releases via this pathway.
Changeout and sampling of HEPA filters has been added to the Maintenance Department's preventive maintenance schedule.
No further problems were identified.
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11.
High Radiation Area Access Controls Several problems concerning high radiation area controle were iden-
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tified during the Health Physics Appraisal. Three examples of
noncompliance with high radiation area control requirements listed in 10 CFR 20.203(c)(2) were noted.
The three cited areas are now adequately controlled. No other problems were noted.
12.
Extendible Probe Survey Instruments The Health Physics Appraisal identified a need for additional extendible
probe survey instruments. The licensee has since purchased one additional instrument, t-6-a
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Of the two now available, however, one was out of calibration at the time of this inspection. The licensee stated that it was to be sent offsite for calibration. No other problems were noted.
13.
Procedure Coverage and Adherence Several problems concerning procedure coverage and adherence were identified during the Health Physics Appraisal.
The identified problems are being corrected by procedure revisions, writing of new procedures, and placing emphasis on the need for procedure adherence during plant staff training.
Progress in this area will be reviewed during future inspections.
(155/81-11-C7)
14.
Temporary Storage of Low-Level Radioactive Wastes All problems identified in this area during the Health Physics Appraisal will be corrected when the licensee's new radwaste facility is complete (cbout November 1981). No additional problems were identified.
15.
Byproduct License No. 21-08606-01 This license covers the licensee's instrument calibration sources. The inspector reviewed the licensee's compliance with 11eense requirements.
No problems were noted.
16.
IE Circular No. 80-18 The inspector reviewed the licensee's actions in response to IE Circular No. 80-18, "10 CFR 50.59 Safety Evaluations for Changes to Radioactive Waste Treatment Systems." The licensee had reviewed the contents of this circular with appropriate Technical Department personnel. No problems were noted.
17.
IE Circular No. 81-07 The inspector reviewed the licensee's actions in response to IE Circular No. 81-07, " Control of Radioactively Contaminated Material." The licensee had reviewed the contents of this circular and determined that present material release procedures comply with the stated requirements. No problems were noted.
18.
Transportation Activities The inspector reviewed the licensee's program for receipt, packaging, and transport of radioactive materials.
Procedure RM-53, Revision 6,
" Radioactive Materials Shipments," was found to be consistent with the requirements of 49 CFR 170-189 and 10 CFR 71; no problems were noted.
Records of shipments from January 1981 to date were reviewed. No problems were noted.
No items of noncompliance were identified.
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TMI Action Plan Items Licensee actions in response to NUREG-0737, Items III.D.3.3, II.B.2, II.B.3, and II.F.1, were reviewed. The licensee's response to NUREG-0737 ic contained in letters dated December 19, 1980 and July 9, 1981, to NRR.
a.
Improved Inplant Iodine Instrumentation (III.B.3.3)
The licensee's response to this item states that portable air samplers equipped with silver zeolite. cartridges will be employed to obtain samples and that these samples will be counted with a multichannel analyzer equipped with a Ge(Li) detector (or its equivalent).
The inspector. verified that the above equipment is available for use. The portable air samplers and silver zeolite cartriJges are stored in the Shift Supervisor's office. A multichannel analyzer equipped with a Na(I) detector is located in the air compressor room. Procedure 5c in Volume 9A of the Big Rock Point Manual covers the operation of this equipment. Training of plant staff in the use of this equipment has been completed. No problems.were noted.
b.
Design Review of Plant Shielding (II.B.2)
The licensee has completed the design review of plant shielding.
The need for shielding is being evaluated by means of a Pro-babilistic Risk Assessment (PRA). The PRA was submitted to NRR on March 31, 1981 for their review. At the time of this inspec-tion, the licensee and NRR had not reached agreement concerning what additional shielding will be required. This item will be reviewed during future inspections.
(155/81-11-08).
c.
Post-Accident Sampling Capability (II.B.3)
Based on the results of the PRA and plant features, the licensee has requested deferral of this requirement. The justification for this request is contained in the PRA submittal letter, dated March 31, 1981. This submittal is under review by NRR. This item will be reviewed during future inspections.
(155/81-11-09)
d.
Noble Gas Effluent Monitor (II.F.1 Attachment I)
The licensee has committed to install a noble gas effluent monitor on the plant stack by the end of the 1982 refueling outage, scheduled to begin January 1982. This installation will be reviewed during a future inspect *on.
(155/81-11-10)
e.
Sampling and Analysis of Plant Effluents (II.F.1 Attachment 2)
The licensee has committed to install the required on-line sampling and analysis system by the end of the 198 refueling outage, scheduled to begin January 1982. This installation will be reviewed during a future inspection.
(155/81-11-11)
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Containment Hijh Range Monitor (II.F.1 Attachment 3)
The licensee has committed to install exterior containment high range radiatica monitors by the end of the 1982 refueling outage, scheduled to segin January 1982. The installation of this monitor will be reviewed during a future inspection.
(155/81-11-12)
20.
Exit Meeting The inspector met with licensee representatives (denoted in Section 1)
on September 24, 1981. The inspector summarized the scope and find-ings of the inspection. Further dissussions, conducted by telephone on September 30, 1981, between NRC Region III management and licensee corporate management, resulted in the issuance of a Confirmatory Action Letter, dated September 30, 1981.
In response to certain items discussed, the licensee:
a.
Stated that by October 15, 1981, a designated individual qualified in radiation protection procedures would be assigned to each shift.
This individual will be free to leave the control room to perform radiation protection duties as may be required.
b.
Stated that by October 15, 1981, training will be completed for these designated individuals as outlined in the Confirmatory Action Letter, dated September 30, 1981.
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