IR 05000155/1982007

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IE Insp Rept 50-155/82-07 on 820427-29 & 0505-11.No Noncompliance Noted.Major Areas Inspected:Radiological Environ Monitoring & Confirmatory Measurements Program
ML20053E208
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/18/1982
From: Nicholson N, Rozak S, Schumacher M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20053E194 List:
References
50-155-82-07, 50-155-82-7, NUDOCS 8206070696
Download: ML20053E208 (7)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/82-07(DEPOS)

Docket M1,. 50-155 License No. DPR-6

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Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201

Facility Name: Big Rock Point Nuclear Plant

Inspection At: Big Rock Point Nuclear Plant

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Inspection Conducted: April 27-29 and May 5-11, 1982 Y~

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inspectors:

S. Rozak b 5/s///z.

blYA N. A. Nicholson

  1. # [# 6

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n.4/wA Approved By:

M. C. Schumacher, Chief

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Independent Measurements and Environmental Protection Section

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Inspection Summarv l

Inspection on April 27-29. May 5. and May 11. 1982 (Report No. 50-155/82-07)

Areas Inspected: Routine, unannounced inspection of the radiological environmental monitoring and the confirmatory measurements program. Radio-logical air sampling and TLD monitoring stations weta observed. Effluent

sampics were collected and analyzed onsite with the Region III Mobile Laboratory for comparison with the licensee. The inspection involved 48 inspector-hours onsite by two NRC inspectors.

Results: No items of noncompliance or deviations were identified, i

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8206070696 820520 PDR ADOCK 05000155 G

PDR

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DETAILS 1.

Persons Contacted D. L. Hoffman, Plant Superintendent

  • R. L. Kirchman, Quality Assurance
  • C R. Abel, Operations and Maintenance Supervisor C. Axtell, Plant Health Physicist
  • J. Eppesson, Associate Health Physicist
  • G.

Fox, Chemistry and Radiation Protection Supervisor

  • R.

L. Burdette, Senior Chemistry and Radiation Protection Technician M. Scalley, Document Control Clerk C. Vaun, Senior Office Clerk

  • M. Parker, NRC Resident Inspector
  • Denotes those present at the exit interview on Apill 29, 1982.

In addition Mr. Fox was interviewed by telephone on May 5, 1982.

2.

Licensee Action on Previous Inspection Findings (Closed) Open Item (50-155/78-11-01): Concern about the use of a NaI detector to quantify effluent releases. The NaI detector was being used because the licensee's Ge(Li) system was down for repair. The licensee has since purchased another Ge(Li) system which is to be the primary system for quantifying effluent releases. This system was not operational during this inspection. Durirg a subsequent telephone conversation on May 5, the Chemistry and Radiation Protection Super-visor stated that the new system has been repaired and will be operational and in use by June 30, 1982. The older Ge(Li) system will then serve as a backup and the NaI detector will be moved to the EOF for use during accident situations.

This item will be considered closed with the understanding that if it becomsa necessary to use the NaI detector to quantify effluent releases the committment made

December 1, 1978 to routinely hold gas samples for a recount at a later date will be honored. The inspectors have no further questions regarding this matter.

3.

Results of Comparative Analyses Results of comparative gamma analyses for ef fluent samples collected and analyzed onsite with the Mobile Laboratory are in Table I; com-parison criteria are in Attachment 1.

Analyses for gross beta, H-3, Sr-89 and Sr-90 will be reported in an addendum to this report.

Nineteen of twenty-two comparisons met criteria for agreement or possible agreement. Samples in four media-liquid, air particulate, charcoal adsorber, and gas were collected and analyzed.

IE Inspection Report No. 50-155/78-11.

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The licensee had two disagreements for the particulate filter, Np-239 and Cr-51.

The licensee also failed to detect Mo-99, Tc-99m, Co-58, and Cs-137 on the air particulate; however, the concentrations of these nuclides in the air flow stream were below 10% of 10 CFR 20, Appendix B concentrations and are not included as comparisons in Tablo I.

For the air particulate comparisons, licensee results are greater than NRC values by an average of '+0%.

This overgt_ntification may be a function of calibration standard preparation. A mixed gamma isotopic liquid standard solution is pipetted onto a filter and allowed to dry.

It is postulated that the 11guld migrates to the cater edge of the filter as it is drying, resulting in an inhomogeneous concentration of radioactivity on the filter; the efficiencies subsequently calculated with this standard are too low, yloiding higher isotopic quantifications for homogeneous sampics.

This standard is also used to determine efficiencies for face-loaded charcoal adsorbers. When the calibration is performed the standard is placed somewhat closer to the detector than is representative of activity on the adsorbor. This tends to overestimate the efficiency for the charcoal cartridge. The above two effects tend to cancel each other which explains why the licensen had agreements for comparisons with the charcoal adsorber. The licensee agreed to evaluate the standard pre-paration technique and calibration method by July 29, 1982.

All comparisons for the liquid collected from a holdup tank and the charcoal adsorber vere categorized as agreements. The licensee failed to detect Co-58 and Zn-65 in the liquid sample; howver, these were present in concentration below 10% of CFR 20 Appendix B concentrations and are not included as comparisons in Table I.

The licensee did not detect Xc-133 in the off gas sample collected from the Steam Jet Air Ejectors (SJAE).

In the past the licensee has identified this nuclido at a level of approximately 1.5 E-3 uCi/cc.

Regulatory Guide 1.21 states that the sensitivity of analysis for each of the principal radioactive gases in representative samples of gaseous effluents should be such that concencontrations of E-4 uCi/cc are measureable. The reason for the licensee's failure to detect this nuclide and nuclides in other media is most probably a combination of short counting Imes, a relatively poor officiency for the Go(Li)

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detector used and a rejection criteria in the analyzer software that is too strict. These problems have been seen during past inspections *

and during the inspection of May 1981 the licensee agreed to review i

l the matter. The licensee's proposed solution is to use a new Ge(Li)

l system with a detector of higher efficiency. This should adequately address the above concerns if the counting times the licennee

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i routinely uses are not reduced; however, at the time of this inspection this new system was not operational. The licensco stated that the new system was nearly ready to be used routinely but that it had been l

exhibiting a problem of noise pickup and was being repaired. During a telephone conversation on May 11, 1982, the Chemisty and Radiation IE Inspection Reports No. 50-155/81-06; 50-155/80-08; 50-155/78-11; 50-155/78-03.

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IE Inspection Report No. 50-155/81-06.

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Protection Supervisor stated that the problem had been corrected and that the system would be operational and in routine use by June 30, 1982. This will be examined during the next inspection.

No items of noncompliance or deviations were identified.

4.

Environmental Monitoring The inspectors reviewed the licensee's environmental monitoring program results for CYs 1980 and 1981. The licensee's environmental monitoring program remains essentially the same as described in a previous inspection report" except that TLD monitoring chips, rather than film, have been used since the 4th quarter of 1981. This is in compliance with Section 6.4.2(c) of the Technical Specifications.

This part of the environmental monitoring program is now handled by a contractor, Eberline Instrument Company, which also handles the licensee's voluntary environmental monitoring program not required by the Technical Specifications.

No unusual trends or anomalies were reported by the licensee except for fallout effect observed in CY 1981 from weapons testing by the People's Republic of China.

Also, aquatic biota near discharge showed higher levels of certain radionuclides than did samples at remote locations. The levels were consistent with levels observed over past years and have been observed and reported by the Great Lakes Radioecology Group at Argonne National Laboratory.

The inspectors toured selected air sampling stations, TLD stations and a composite water sampler. They also reviewed the licensee's Procedure RP-32, Revision 3 " Environmental Dosimetry" which describes the environmental saro ing program.

No items of noncompliance or deviations were identified.

5.

Exit Interview The inspectors met with licensee representatives denoted in Paragraph 1 on April 29, 1982, to discuss inspection findings. At that time the licensee agreed to the following:

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a.

Analyze the liquid waste sample collected April 28, 1982, for gross beta, H-3, Sr-89 and Sr-90 (gross beta to be counted on May 12, 1982, 10:00 EDT) and to report the results to Region III (Open Item 50-155/82-07-01);

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Evaluate the calibration method for the air particulate geometry

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by July 29, 1982 (0 pen Item 50-155/82-07-02).

j The inspectors discussed the Xe-133 disagreement with the Chemistry and Radiation Protection Supervisor during a telephone conversation l

IE Inspection Report No. 50-155/79-07.

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May 11, 1982. He stated the new analytical system would be opera-tional and in use by June 20, 1982, and that the licensee will insure that sensivity levels are sufficient to see principal radioactive gases in effluent samples at concentrations of E-4 uCi/cc (0 pen Item 50-155/82-07-03).

Attachments:

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Table I, Confirmatory Measurements Program, 2nd Quarter of 1982 2.

Attachment 1, Criteria for Comparing Analytical Measurements.

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TABLE I U S HUCLEAR REGULATORY COMMISSION

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DFFICE OF IriSPECTION AfiD ENFORCEMENT CDriFIRMATORY MEASUREMEi.iTS PROGRAM FACILITY: BIG ROCK PT FOR THE 2 QUARTER OF 1982


NRC-------

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---LICEtiSEE:NRC----

SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T

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C FILTER I-131 1.2E-03 2.4E-05 1.0E-03,4.3E-05 8.5E-01 4.8E 01 A

XE-133 2.7E-04 2.1E-05 2.6E-04 3.4E-05 9.6E-01 1.3E 01 A

L WASTE CD-60 6.8E-05 9.8E-07 7.8E-05 1.9E-06 1.2E 00 6.9E 01 A

MH-54 3.9E-05 6.3E-07 4.0E-05 1.2E-06 1.0E 00 6.2E 01 A

CS-134 1.3E-05 4.4E-07 1.3E-05 9.6E-07 1.0E 00 2.9E 01 A

CS-137 3.9E-04 1.8E-06 3.8E-04 3.2E-06 9.8E-01 2.2E 02 A

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P FILTER fiP-239 6.5E-04 1.8E-05 1.5E-03 1.0E-04 2.3E 00 3.7E 01 D

CR-51 8.4E-03 1.4E-04 1.1E-02 4.4E-04 1.4E 00 6.0E 01 D

I-131 7.2E-04 1.6E-05 1.0E-03 5.4E-05 1.4E 00 4.5E 01 P

BA-140 1.3E-03 6.8E-05 1.6E-03 1.8E-04 1.3E 00 1.8E 01 A

AG-110M 8.9E-04 2.0E-05 1.0E-03 7.3E-05 1.2E 00 4.4E 01 A

MH-54 5.3E-04 2.2E-05 4.8E-04 5.6E-05 9.0E-01 2.5E 01 R

2N-65 1.4E-03 5.0E-05 1.5E-03 1.5E-04 1.1E 00 2.7E 01 A

CD-60 1.3E-03 3.8E-05 1.8E-03 0.0E-01 1.4E 00 3.3E 01 P

LA-140 1.4E-03 3.7E-05 1.8E-03 1.1E-04 1.3E 00 3.7E 01 A

DFF GAS XE-133 1.1E-04 2.8E-05 0.0E-01 0.0E-01 0.0E-01 4.1E 00 D

XE-135 3.8E-03 3.9E-05 3.7E-03 1.5E-04 9.7E-01 9.7E 01 A

XE-135M 2.2E-02 9.6E-04 2.5E-02 2.8E-03 1.1E 00 2.3E 01 A

XE-138 1.4E-01 3.1E-03 1.4E-01 7.8E-03 9.6E-01 4.7E 01 A

KR 85M 1.3E-03 2.1E-05 2.2E-03 1.4E-04 1.7E 00 6.52 01 P

KR-87 8.9E-03 1.4E-04 9.7E-03 5.4E-04 1.1E 00 6.6E 01 A

KR-88 5.5E-03 8.7E-05 5.9E-03 4.4E-04 1.1E 00 6.3E 01 A

T TEST RESULTS:

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A= AGREEMENT D= DISAGREEMENT P=POSSIBLE AGREEMENT fi=ND COMPARISDri

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ATT AC)D.LU 1 CRITERI A FOR N&r11NG ANALYTICAL MFASURIMENTS This attachment provides criteria for comparing results of capability tests and verification measurements.

The criteria are based on an

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empirical relationship which cumbines prior experience and the accuim y needs of this program.

In these criteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated one si'ma uncertainty. As that ratio, referred to in this progren as

" Resolution", increases, the acceptability of a licensee's measurement should be more selective.

Conversely, poorer agreement should be con-sidered acceptable as the resolution decreases.

The values in the ratio criteria may be rounded to fewer significant figures to maintain statistical consistency with the number of significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a

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narrowed category of acceptance.

The acceptance category reported will be the narrowest into which the ratio fits for the resolution being used.

RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Possible Possible Agreement Agreement "A" Agreeable "B"

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No Comparison No Comparison No Comparison

>3 and <4 0.4 2.5 0.3 3.0 No Comparison

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2.0 0.4 2.5 0.3 3.0

>4 and <8 0.5

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T8 and <16 0.6 1.67 0.5

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2.0 0.4 2.5

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T16 and <51 0.75 - 1.33 0.6 1.67 0.5

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ISI and <200 0.80 - 1.25 0.75 1.33 0.6 1.67

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1200 0.85 - 1.18 0.80 1.33 1.25 0.75

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"A" criteria are applied to the following analyses:

Camma spectrometry, where principal gamma energy used for identifi-cation is greater than 250 kev.

Tritium analyses of liquid samples.

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"B" criteria are applied to the following analyses:

Camma spectrometry, where principal gamma energy used for identifi-cation is less than 250 kev.

Sr,-89 and Sr-90 determinations.

Cross beta, where samples are counted on the same date using the same reference nuclide.

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