IR 05000155/1985009

Insp Rept 50-155/85-09 on 850520-23.No Violation or Deviation Noted.Major Areas Inspected:Gaseous & Liquid Radioactive Program,Including Effluent Releases,Records & Repts of Effluent & Effluent Control Instrumentation

ML20127A718
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/14/1985
From:	Hueter L, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20127A648	List: IR 05000155/1985009 ML20127A645
References
50-155-85-09, 50-155-85-9, NUDOCS 8506210236
Download: ML20127A718 (7)

Text

• .

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/85009(DRSS)

Docket No. 50-155 License No. DPR-6 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 Conducted: May 20-23, 1985 Y/,b&4& /lO, Inspector: L. J. Hueter F Date Approved By:

Q}$

M. C. Schumacher, Chief 6///

/9/O ,-

Independent Measurements and Date Environmental Protection Section Inspection Summary:

Inspection on May 20-23, 1985 (Report No. 50-155/85009(DRSS))

Areas Inspected: Routine, announced inspection of gaseous and liquid radioactive program including: effluent releases; records and reports of effluent; effluent control instrumentation; procedures for controlling releases; reactor coolant chemistry and activity; gaseous effluent filtration; and audits. The inspection involved 35 inspector-hours on site by one NRC inspecto Results: No violations or deficiencies were identified.

.

PDR

. _ . _ , _ . _ . - ~ ,

. .

DETAILS Persons Contacted

• R. Alexander, Technical Engineer R. . Bearss, Chemistry and Radiation Protection Senior Technician

• J. ' Beer, Superintendent, Chemistry and Health Physics

• R. Burdette, Chemistry and Radiation Protection Supervisor D. Hoffman, Plant Manager J.-Lovell, QC Supervisor

• L. Monshor, QA Superintendent

• G. Petitjean, Technical Superintendent

• R. DeFayette, NRC Reactor Inspector

• S. Guthrie, NRC Resident Inspector

• Denotes those present at the exi . General

This inspection, which began at 12:15 p.m. on May 20, 1985, was conducted

.to examine the licensee's gaseous and liquid radwaste management program and related activities for compliance with regulatory requirement . Liquids and Liquid Radioactive Wastes The inspector reviewed the licensee's reactor liquids and liquid radwaste

. management programs, including: determination whether reactor liquids meet chemical and radiochemical requirements; determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse The licensee's reactors liquid and-liquid radwaste management programs were reviewed for calendar year 1984 and the first quarter of 198 During this period, the reactor was operating except for a refueling outage from June 1-July 28, 1984, and four short outages lasting four to twelve days in September 1984, January, April and May of 1985. The next scheduled refueling outage is currently planned to begin September 1, 198 As noted in Inspection Report 50-155/84-04 for the inspection conducted May 7-10, 1984, the licensee's noble gas release rate had been increasing significantly, doubling about every 30 days,'since mid' December 1983 due to leaking fuel rods. From mid December 1983 to early May 1984 the noble gas release rate had increased from approximate 1y'400 pCi/sec to 30,000 pCi/sec, a factor of 75. During the same period the particulate and iodine release rates in gaseous effluents had increased by a factor of'four and the concentrations of iodines and gross activity of the reactor coolant increased by approximately a factor of six. However, this increase in

-

_

_ _ - _ .. - _ __ . - .

.

reactor coolant activity was not reflected in an increase in activity in liquid effluents. In 1984, the licensee continued the long standing downward trend in liquid effluent activity releasing 148 millicuries

,

(excluding tritium) in 1984 compared to 390 mil 11 curies (excluding tritium)

in 1983. The release concentrations from the liquid radwaste system have been limited to less than one percent of MPC (quarterly average).

l During'the refueling outage which began June 1, 1984, one third of the fuel was replaced including all leaking fuel rods as evidenced when the reactor returned to power in late July 1984. However, in late November 1984, the noble gas release rate again increased from about

>

-400 pCi/sec to 3000-4000 pCf/sec, a factor of about 10, due to new leaking fuel rods. Since the initial peak in release rate, the release' rate has 1 dropped back to about 2500 pCi/sec, except slightly higher following the short outages, indicating a low level relatively stable leak thus far in this fuel cycle. This has resulted in no significant increases in particulate and iodine release rates in gaseous effluents and no

-

significant increases in concentrations of iodines and gaseous activity

.in the reactor coolan There were 18 liquid batch releases in 1984 and five releases in 1985 as of May 20, most being from the chemical waste tank. From review of records and discussions with licensee personnel, it appears that

'

appropriate use is being made of strainers, filters, demineralizers and

'

holdup in tanks (for purposes of radioactive decay) in order to minimize activity in liquid effluent atch releases from any of the tanks (chemical waste receiver tank, dirty waste receiver tanks, clean waste receiver tanks or waste hold tanks) would be monitored by RE 8275 which

also provides alarm and release isolation function 'The licensee is not yet subject to the Radiological Effluent Technica:

Specifications (RETS) and the related offsite Dose Calculation Manual (ODCM). This matter was discussed at the exit. Although not required by

, current technical specifications, the licensee calculated potential doses to individual in 1984 from water-related exposure pathways using the NRCs LADTAP computer code, inputting annual values of curies released for each isotope. The calculated maximum total body dose and maximum organ dose any individual beyond the site boundary could receive from liquid

-

releases during the year were 8.38E-02 mrem and 1.29E-01 mrem respectively.

In review of liquid release procedures, records and semiannual effluent reports an error was identified in the semiannual effluent report covering the second half of 1984. The report identifies an abnormal

- release from an underground pipe leak from the demineralized water supply

,

to the condensate storage tank on May 30. 1984, which was calculated to contain 2.38E-04 Ci Cobalt-60, 1.32E-O' 'nganese-54, 1.74E-03 Cf cesium-137 and 1.22E-03 Ci cesium-13 ele 3b of the semiannual

effluent report for July-December 1984, . Isks are placed in front of i the nuclides cobalt-60, manganese-54, cesium-137 and cesium-134 (which j are presented in terms of curies released of each nuclide) with a foot

!

4

---> - - ,, . ,__,,,-w.,-c, c, ,,-- - n,,,,-n.,,w ,,-n ,n,---. .n-~~,---.n.-nn-,+ - - , , - , , , - - , - - , , , , - , , , , , , . - - . .

. .

note stating " Totals include quantities of nuclides estimated to have been released onsite from condensate storage tank leak." The note is erroneous in that the total curies released given in Table 3b for these four nuclides does not include the activity estimated to have been released onsite from the condensate storage tank leak. If if had been included it would have increased the reported releases for the third quarter for cesium-137 and cesium-134 by about 18 percent and about 60 percent respectively but would not have significantly increased the reported releases for manganese-54 or cobalt-60. This error in the semiannual effluent report was discussed in the exi It should be noted that since the above leak was "onsite" and since none of the activity may have at this time migrated offsite, it may be inappropriate at this time to quantify all or any part of the leak with offsite liquid effluent The licensee's actions regarding disposition of the contaminated water / soil from this leak has been documented in other inspection reports (most recent is Inspection Report No. 50-155/85008)

and is being tracked under Open Item No. 155/84-08-0 Reactor coolant sampling and analysis records were reviewed for compliance with chemical and radiochemical criteria contained in Technical Specification 4.1.2. Test results reviewed for the period July 1, 1984, through May 20, 1985, included pH, conductivity, chloride and boron. The dose equivalent iodine-131 test results were reviewed for the period December 3, 1984, through May 19, 198 No problems were identified during the review in either frequency of testing or compliance with concentration No violations were identifie . Gaseous Radioactive Waste The inspector reviewed the licensee's gaseous radwaste management program, including: determination whether gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notification; and experience concerning identification and correction of programatic weaknese The program was reviewed for calendar year 1984 and the first quarter of 1985. The inspector reviewed semiannual effluent reports for 1984 and selectively reviewed effluent records for the period July 1, 1984 through May 15, 1985. Refer to Section 3 for information regarding period of reactor operation versus outages and elevated off gas release rates due to leaking fuel rod During reactor operation noble gas releases are quantified from the off gas monitor response and off gas flow rate. Compensation is made for a small percentage of nuclides (not identifiable by the off gas monitoring system) by using the long established specified ratios of certain identified nuclide concentrations to specified unidentified nuclide

. .

concentrations, depending upon the off gas mixture. Frequent checks by the licensee has shown good agreement between the noble gas release rate as indicated by the off gas monitor and the stack normal range noble gas monitor. During outages, noble gas releases from such operations as fuel sipping are quantified and included in the semi-annual report. Iodine and particulate effluent releases are quantified on the basis of analysis of stack sample iodine adsorbers and particulate filters. No errors or problems were identified in the review of procedures, work sheets, records and reports of gaseous effluent .

Inserting into the NRCs GASPAR computer code, the annual values of curries of each nuclide released in gaseous effluents in 1984, the calculated average thryroid dose (most restrictive organ dose) and average total body dose beyond the site boundary from gaseous effluents were 1.4E-03 mrem and 1.1E-02 mrem respectivel In March 1985, during the semiannual verification of hold-up time, which is based in part upon the off gas flow meter response, the test indicated that the response of the off gas flow meter was marginally outside of the prescribed error band in a nonconservative direction (Iow flow reading). A check of the flow meter, including orifice size, identified no problem with the meter. Other calculations of the hold-up time based on radioactive decay and expected off gas flow, based on megawatt thermal production, appear to confirm that the off gas flow meter is responding somewhat nonconservatively. The licensee issued a deviation report concerning this matter and the problem is currently under engineering review. In the interim, to preclude nonconservative quantification of noble gas releases, the off gas flow meter is not being used for off gas flow in quantification calculation Flow rates used are based on megawatt thermal power and air in leakage. The latter is determined based on density at the air ejecto No violations were identifie . Calibrations and Surveillances of Gaseous and Liquid Process and Effluent Monitors The inspector reviewed records for five monitors on the liquid system (including radwaste, service water discharge, and canal discharge) and

'

three monitors on the gaseous system including the two off gas monitors and the vent stack normal range noble gas monitor. Technical Specification 6.4.3 requires monthly calibrations and functional tests of gaseous system monitors and quarterly calibrations of the liquid system monitors with the exception of the liquid radwaste monitor which requires

'

monthly calibration. The ifcensee performs monthly calibrations for all of the above monitors. The inspector reviewed monthly calibration records and functional tests for the monitors described above for the period May 1, 1984 through April 30, 1985. The review showed that the calibrations and functional tests were conducted on a timely basis. No problems were identified in the methodology of the calibrations. The set point of selected monitors were also reviewed with no problems being noted.

i No violations were identifie _ . _ _ - .-

_ - . __ _ __ , _ . _ _

. ..

6. Procedures for Controlling Releases The inspector selectively reviewed revisions to the licensee's liquid and gaseous radwaste procedures. No significant problems were identified during the procedures revie RCP-1, Revision 6 Sampling RCP-2 Revision 15 Analysis of Off Gas RCP-5 Revision 9 Changing Stack Gas Sampling Filters -

RCP-6 Revision 15 Analysis of Stack Gas Filters RCP-7 Revision 18 Analysis of Liquid Radioactive Batch RCP-9 Revision 17 Radiochemistry Procedure CIP-17 Revision 1 Calibration of Liquid Process Monitors CIP-19A Revision 3 Stack Gas Monitor Calibration Checks No violations were identifie . Audits The inspector reviewed one audit conducted in the past year involving the gaseous and liquid radwaste processing and effluent programs. Audit Report No. QT 85-4, conducted April 1-4, 1985, covered Health Physics, emergency plan, and packaging and shipping of greater than Type A material. A small part of this audit covered some areas of the gaseous and liquid radwaste programs including instrument calibration schedule, batch cards and off gas activity records. The two audit findings and four observations did not involve the gaseous and liquid radwaste program No violations were identifie . Changes to Equipment and Procedures No changes have been made in the gaseous or liquid waste systems or related procedures which would require a 10 CFR 50.59 review / evaluation, according to statements made by a licensee representative and substantiated to the extent of records reviewed by the inspecto No violations were identifie . HEPA Filter and Charcoal Adsorber Systems The licensee has no ventilation / gaseous effluent systems having HEPA filters and charcoal adsorbers subject to technical specification surveillance requirement The chemistry laboratory, which involves limited handling of radioactive materials, has its own separate vent with ,

HEPA filtration. An in place filter efficiency test using DOP and using an administrative 1y established acceptance criterion of 98 percent is performed annually for the chemistry laboratory vent filter. No monitor is located on this vent. In addition to the annual efficiency test, smears are taken in the ducting down stream of the filter on a monthly basis. Analysis of these smears has never shown any detectable activity 1 above backgroun l

i

l l

._ .. -- . . . . .. .

. - -

.. . , . .

f A moisture separator and HEPA filter is also located in the off gas line i at the base of the vent stack downstream of the 30 minute hold up lin This filter is replaced with a new HEPA filter every refueling outag ,

Following installation, a pressure type integrity test is performed from the isolation valve at the base of the-stack back upstream through the length of the holdup line, however, no DOP type of in place filter test is performed. The vent stack effluent sampler filters /adsorbers and noble gas monitors are located down stream of this filte No violations were identifie . Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on May 23, 1985. The inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify such documents / processes as proprietary. The inspector summarized the scope and findings of the inspection. In response to certain items discussed by the inspector, the licensee: Stated that their current goal is to implement the RETS Technical Specifications and 00CM, by January 1, 1986. The inspector discussed the need for adequate advance preparation for the many procedure changes and related training that will be' involved in the implementation. (Section 3) Acknowledged the error in Table 3b of the semiannual effluent report for the last half of 1984 and stated that proper corrections would be officially submitted to correct the error regarding inclusion of the quantities of nuclides estimated to have been released onsite from the condensate storage tank leak. (Section 3).

7